William Blair & Company L.L.C.

Allegations: BETWEEN APPROXIMATELY JULY 1999 AND SEPTEMBER 2000, WILLIAM BLAIR & COMPANY,L.L.C. FAILED TO ESTABLISH WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE NASD'S FREE-RIDING AND WITHHOLDING INTERPRETATION IN THAT ITS EXISTING WRITTEN PROCEDURES FAILED TO REQUIRE A PERIODIC REVIEW OF ACCOUNTS THAT PURCHASED HOT ISSUES TO CONFIRM THAT REGISTERED REPRESENTATIVES HAD PERFORMED REASONABLE DUE DILIGENCE TO DETERMINE THAT THE ACCOUNT WAS NOT RESTRICTED. DURING THE SAME PERIOD, STEPHEN ELKINS, A PRINCIPAL OF WILLIAM BLAIR & COMPANY, L.L.C., SOLD HOT ISSUE SECURITIES TO AN INDIVIDUAL WHO WAS REGISTERED WITH ANOTHER MEMBER OF THE NASD, IN HIS PERSONAL ACCOUNT AND IN AN ACCOUNT IN WHICH THE INDIVIDUAL HAD A BENEFICIAL INTEREST. Status: Final Sanction Detail: AS TO WILLIAM BLAIR & COMPANY, L.L.C. - A FINE OF $2,500; AS TO STEPHEN ELKINS - A FINE OF $4,233.46, WHICH INCLUDES DISGORGEMENT OF COMMISSIONS OF $1,733.46

Allegations: THE FIRM ALLEGEDLY ENTERED 11 ORDERS INTO THE NASDAQ MARKET CENTER THAT FAILED TO CORRECTLY INDICATE WHETHER THE ORDERS WERE A BUY, SHORT SALE OR LONG SALE. Status: Final Sanction Detail: FINE OF $5000.00

Allegations: DURING THE PERIOD JANUARY 1, 2002 THROUGH MARCH 31, 2002, WILLIAM BLAIR & COMPANY ("THE FIRM") ALLEGEDLY VIOLATED SEC RULE 11AC1-4 BY FAILING TO IMMEDIATELY DISPLAY THIRTY SEVEN CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION. DURING THE SAME TIME PERIOD, THE FIRM ALLEGEDLY VIOLATED NASD MARKETPLACE RULE 6955(A) AND NASD CONDUCT RULE 2110 BY TRANSMITTING TO OATS FIFTY EIGHT REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. DURING THE TIME PERIOD JUNE 30, 2003 THROUGH JULY 3, 2003, THE FIRM ALLEGEDLY VIOLATED NASD MEMBERSHIP AND REGISTRATION RULE 1032(F) BY FAILING TO REGISTER ONE PERSON WITH THE NASD AS A LIMITED REPRESENTATIVE - EQUITY TRADER. Status: Final Sanction Detail: THE FIRM WAS NOTIFIED ON MAY 2, 2005 THAT THE NASD'S OFFICE OF DISCIPLINARY AFFAIRS AND THE NATIONAL ABJUDICATORY COUNCIL HAD ACCEPTED THE ACCEPTANCE, WAIVER AND CONSENT (AWC) TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO PAY THE FINE OF $15,000 TO SETTLE THE MATTER. Summary: THE FINE OF $15,000.00 WAS PAID ON JUNE 3, 2005.

Allegations: THE FINDINGS OF THREE EXAMINATIONS FROM 2006 (2006006387), 2007 (20070089900), AND 2008 (20080133281) WERE COMBINED AND THE ALLEGATIONS WERE THAT THE FIRM FAILED TO: DISPLAY IMMEDIATELY 27 CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES AND TRANSMITTED TO OATS 60 REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA; SUBMIT THE CORRECT BUY, SELL, SELL SHORT OR CROSS SYMBOL FOR 56 TRANSACTIONS; ON 69 OCCASIONS DISCLOSE THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE; PROVIDE FOR ONE OR MORE MINIMUM REQUIREMENTS FOR ADEQUATE SUPERVISORY PROCEDURES; ON FOUR OCCASIONS DISCLOSE ITS CORRECT CAPACITY, ON SIX OCCASIONS DISCLOSE THE CORRECT COMPENSATION TYPE, AND ON ONE OCCASION DISCLOSE THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE AND DATA USED FOR RULE 605 REPORTING INCLUDED INCORRECT INFORMATION. THE TRANSACTIONS INVOLVED REPRESENTED LESS THAN .01% OF TRANSACTIONS CONDUCTED DURING THE TIME PERIODS. Status: Final Sanction Detail: THE FIRM PAID THE FINE OF $38,000 ON 2/26/2010. Summary: THE FINDINGS OF THREE EXAMINATIONS FROM 2006 (2006006387), 2007 (20070089900), AND 2008 (20080133281) WERE COMBINED AND THE ALLEGATIONS WERE THAT THE FIRM FAILED TO: DISPLAY IMMEDIATELY 27 CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES AND TRANSMITTED TO OATS 60 REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA; SUBMIT THE CORRECT BUY, SELL, SELL SHORT OR CROSS SYMBOL FOR 56 TRANSACTIONS; ON 69 OCCASIONS DISCLOSE THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE; PROVIDE FOR ONE OR MORE MINIMUM REQUIREMENTS FOR ADEQUATE SUPERVISORY PROCEDURES; ON FOUR OCCASIONS DISCLOSE ITS CORRECT CAPACITY, ON SIX OCCASIONS DISCLOSE THE CORRECT COMPENSATION TYPE, AND ON ONE OCCASION DISCLOSE THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE AND DATA USED FOR RULE 605 REPORTING INCLUDED INCORRECT INFORMATION. THE TRANSACTIONS INVOLVED REPRESENTED LESS THAN .01% OF TRANSACTIONS CONDUCTED DURING THE TIME PERIODS.

Allegations: NASDR ALLEDGED THAT WILLIAM BLAIR & COMPANY FAILED TO FILE COPIES OF FINAL OFFICIAL STATEMENTS AND COMPLETED FORMS G-36(OS) WITH THE MSRB ON A TIMELY BASIS; FAILED TO ACCURATELY RECORD CERTAIN DATES OF FINAL AGREEMENTS TO PURCHASE, OFFER OR SELL SECURITIES AS AN UNDERWRITER; FAILED TO MAINTAIN RECORDS OF THE DATES FORMS WERE MAILED. Status: Final Sanction Detail: THE FIRM WAS NOTIFIED ON MAY 29, 1998 THAT THE NASDR HAD ACCEPTED THE ACCEPTANCE, WAIVER AND CONSENT (AWC) TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO PAY THE FINE OF $3000 TO SETTLE THE MATTER.

Allegations: DURING THE PERIOD FROM SEPTEMBER 6, 1983 THROUGH JUNE 28, 1984, WILLIAM BLAIR & COMPANY ALLEGEDLY PERMITTED TEN PUBLIC CUSTOMERS TO ENGAGE IN LISTED OPTION TRANSACTIONS PRIOR TO THEIR ACCOUNTS BEING APPROVED BY A REGISTERED OPTIONS PRINCIPAL Status: Final Sanction Detail: FINE WAS PAID ON MAY 29, 1985 IN THE AMOUNT OF $1000.00.

Allegations: THE COMPLAINT ALLEGED THAT THE FIRM SOLD SHARES OF HOT ISSUE SECURITIES TO PERSONS ASSOCIATED WITH A BROKER DEALER IN CONTRAVENTION OF THE NASD INTERPRETATION ON FREE-RIDING AND WITHHOLDING. THE SALES ALLEGEDLY VIOLATED ARTICLE III, SECTION 1 OF THE NASD RULES OF FAIR PRACTICE. THE COMPLAINT DID NOT IDENTIFY ANY ACTUAL OR ALLEGED DAMAGES. Status: Final Sanction Detail: AN OFFER OF SETTLEMENT WAS SUBMITTED TO THE DISTRICT BUSINESS CONDUCT COMMITTEE. THE OFFER WAS ACCEPTED AND THE FIRM WAS CENSURED AND FINED $7,000. THE FINE WAS PAID ON JUNE 8, 1993 Summary: THE DBCC NOTED THAT THE VIOLATIONS WERE NOT INTENTIONAL AND THAT THE FIRM DID NOT REALIZE THAT THE CUSTOMERS INVOLVED WOULD BE CONSIDERED RESTRICTED UNDER THE INTERPRETATION.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED, IN 157 INSTANCES, TO MAINTAIN A CONTINUOUS TWO-SIDED TRADING INTEREST DURING REGULAR MARKET HOURS AT PRICES WITHIN CERTAIN PERCENTAGES AWAY FROM THE NBBO AND FAILED TO MAINTAIN A CONTINUING TWO-SIDED TRADING INTEREST DURING THE ENTIRE TRADING DAY REQUIRED BY NASDAQ RULE 4613(A), FOR THE REVIEW PERIOD OCTOBER 1, 2018 THROUGH MARCH 31, 2019. THE VIOLATIONS OCCURRED BECAUSE OF A SYSTEM ISSUE WITH THE FIRM'S ORDER MANAGEMENT SYSTEM. THE CONDUCT ALSO CONSTITUTES A VIOLATION OF NASDAQ RULES 2010A AND 3010. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $25,000 (COMPRISED OF $12,500 FOR THE VIOLATIONS OF NASDAQ RULE 4613(A) AND $12,500 FOR THE VIOLATIONS OF NASDAQ RULES 2010A AND 3010)

Allegations: THE DIVISION ALLEGED THAT WILLIAM BLAIR & COMPANY'S AFFILIATE, WILLIAM BLAIR MUTUAL FUNDS, INC. SOLD UNREGISTERED MUTUAL FUND SHARES IN TENNESSEE BETWEEN JULY 1991 AND OCTOBER 1992. THE VALUE OF THE SECURITIES ALLEGEDLY TOTALLED $30,500 IN 20 TRANSACTIONS. Status: Final Sanction Detail: AFTER DISPUTING THE DIVISION'S ALLEGATIONS FOR A PERIOD OF 18 MONTHS, WILLIAM BLAIR & COMPANY AGREED TO SETTLE THE MATTER AND PAID A FINE OF $20,000. Summary: WILLIAM BLAIR & COMPANY VIGOROUSLY OPPOSED THE DIVISIONS ALLEGATIONS THAT UNREGISTERED SHARES HAD BEEN SOLD IN TENNESSEE. AN APPLICATION WAS FILED DURING THE ROUTINE RENEWAL PROCESS IN ADVANCE OF THE FUNDS EXPIRATION. EIGHT MONTHS AFTER THE RENEWAL WAS SUBMITTED, THE DIVISION DEEMED IT INCOMPLETE FOR INSUFFICIENT FILING FEES.

Allegations: THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ("FINMA") FOUND WILLIAM BLAIR TO HAVE NEGLIGENTLY FAILED TO COMPLY WITH SWISS SECURITIES REGULATIONS DUE TO WILLIAM BLAIR'S LATE FILING OF SHAREHOLDING REPORTS IN TWO INSTANCES. Status: Final Sanction Detail: WILLIAM BLAIR WAS ASSESSED A FINE IN THE AMOUNT OF CHF 9,000, WHICH WAS APPROXIMATELY $9,315 (USD) AT EXCHANGE RATES CURRENT AT THE TIME THE FINE WAS ASSESSED. THIS AMOUNT CORRESPONDS TO 0.9% OF THE MAXIMUM FINE OF CHF 1,000,000. WILLIAM BLAIR WAS ALSO ASSESSED PROCEDURAL COSTS OF CHF 1,570, WHICH WAS APPROXIMATELY $1,625 (USD) AT EXCHANGE RATES CURRENT AT THE TIME THE COSTS WERE ASSESSED. Summary: A PENAL DECREE DATED MAY 14, 2013 ("DECREE") BY THE FEDERAL DEPARTMENT OF FINANCE ("FDF") OF THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ("FINMA") FOUND WILLIAM BLAIR TO HAVE NEGLIGENTLY FAILED TO COMPLY WITH SWISS SECURITIES REGULATIONS DUE TO WILLIAM BLAIR'S LATE FILING OF SHAREHOLDING REPORTS IN TWO INSTANCES. SWISS REGULATIONS REQUIRE THAT A PERSON WHO ACQUIRES OR SELLS SHARES OF A COMPANY INCORPORATED IN SWITZERLAND WHOSE EQUITY SECURITIES ARE LISTED IN WHOLE OR IN PART IN SWITZERLAND AND THEREBY ATTAINS, FALLS BELOW OR EXCEEDS THE THRESHOLD PERCENTAGES OF VOTING RIGHTS SEND NOTIFICATIONS TO FINMA AND THE COMPANY. SUCH NOTIFICATIONS MUST BE RECEIVED BY FINMA AND THE COMPANY WITHIN FOUR TRADING DAYS. IN THIS CASE, WILLIAM BLAIR EXCEEDED THE 3% THRESHOLD (THE LOWEST THRESHOLD FOR REPORTING PURPOSES) IN TWO SEPARATE INSTANCES AND REPORTED SUCH TRANSACTIONS THREE CALENDAR DAYS AFTER THE DEADLINE. FINMA DEEMED THESE MATTERS TO BE SIMPLE NEGLIGENCE. HOWEVER, WILLIAM BLAIR WAS ASSESSED A FINE IN THE AMOUNT OF CHF 9,000, WHICH WAS APPROXIMATELY $9,315 (USD) AT EXCHANGE RATES CURRENT AT THE TIME THE FINE WAS ASSESSED. THIS AMOUNT CORRESPONDS TO 0.9% OF THE MAXIMUM FINE OF CHF 1,000,000. WILLIAM BLAIR WAS ALSO ASSESSED PROCEDURAL COSTS OF CHF 1,570, WHICH WAS APPROXIMATELY $1,625 (USD) AT EXCHANGE RATES CURRENT AT THE TIME THE COSTS WERE ASSESSED.

Allegations: FIRM ALLEGEDLY FAILED TO SUBMIT AUDITED FINANCIAL STATEMENTS WITHIN TEN DAYS OF PUBLICATION AS REQUIRED BY SECTION 13.1-518.1 OF THE VIRGINIA SECURITIES ACT. Status: Final Sanction Detail: FIRM CONSENTED TO A COMPROMISE AND SETTLEMENT ORDER PROPOSED BY THE DIVISION AND WAS FINED $1000.00. Summary: WILLIAM BLAIR SENT FINANCIALS TO THE DIVISION ON MARCH 14, 1990 AND AGAIN ON JULY 24, 1990. ON AUGUST 27, 1990 BLAIR SENT A THRID COPY TO THE DIVISION AT ITS REQUEST. ON SEPTEMBER 14, 1990, THE DIVISION NOTIFIED BLAIR OF THE RECEIPT AND ALLEGED THAT BLAIR HAD VIOLATED SECTION 13.1-518.1 OF THE VIRGINIA SECURITIES ACT. BLAIR CONSENTED AFTER THE ESTIMATED EXPENSE EXCEEDED THE AMOUNT OF THE PROPSED FINE. REGULATORY ACTION IS OVER 10 YEARS OLD.

Allegations: ON SEPTEMBER 29, 2023, WILLIAM BLAIR & COMPANY, L.L.C. AND WILLIAM BLAIR INVESTMENT MANAGEMENT, LLC (COLLECTIVELY, WILLIAM BLAIR) ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES & EXCHANGE COMMISSION (SEC) IN CONNECTION WITH THE AGENCY'S INDUSTRY-WIDE INVESTIGATION INTO THE PRESERVATION OF ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. THE SETTLEMENT REQUIRES WILLIAM BLAIR TO PAY A CIVIL MONETARY PENALTY OF $10,000,000 AND RETAIN A COMPLIANCE CONSULTANT, FOLLOWING THE FORMAT FOR ALL OTHER RECENT ELECTRONIC COMMUNICATIONS SETTLEMENTS. WILLIAM BLAIR COOPERATED WITH THE GOVERNMENT'S INQUIRY AND HAS ALREADY TAKEN SIGNIFICANT STEPS TO FURTHER STRENGTHEN THE FIRM'S COMPLIANCE ENVIRONMENT AS IT RELATES TO ELECTRONIC COMMUNICATIONS. Status: Final Sanction Detail: THE FIRM IS ORDERED TO CEASE AND DESIST, IS CENSURED, SHALL PAY A CIVIL MONEY FINE OF $10,000,000 JOINTLY AND SEVERALLY, AND SHALL COMPLY WITHCERTAIN UNDERTAKINGS. Summary: ON SEPTEMBER 29, 2023, WILLIAM BLAIR & COMPANY, L.L.C. AND WILLIAM BLAIR INVESTMENT MANAGEMENT, LLC (COLLECTIVELY, WILLIAM BLAIR) ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES & EXCHANGE COMMISSION (SEC) IN CONNECTION WITH THE AGENCY'S INDUSTRY-WIDE INVESTIGATION INTO THE PRESERVATION OF ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. THE SETTLEMENT REQUIRES WILLIAM BLAIR TO PAY A CIVIL MONETARY PENALTY OF $10,000,000 AND RETAIN A COMPLIANCE CONSULTANT, FOLLOWING THE FORMAT FOR ALL OTHER RECENT ELECTRONIC COMMUNICATIONS SETTLEMENTS. WILLIAM BLAIR COOPERATED WITH THE GOVERNMENT'S INQUIRY AND HAS ALREADY TAKEN SIGNIFICANT STEPS TO FURTHER STRENGTHEN THE FIRM'S COMPLIANCE ENVIRONMENT AS IT RELATES TO ELECTRONIC COMMUNICATIONS.

Allegations: THE SEC ALLEGED THAT FROM 2010 UNTIL 2014, AS A RESULT OF ERRONEOUS PAYMENTS, WILLIAM BLAIR NEGLIGENTLY USED MUTUAL FUND ASSETS TO PAY FOR (I) DISTRIBUTION AND MARKETING OF FUND SHARES OUTSIDE OF A WRITTEN, BOARD-APPROVED RULE 12B-1 PLAN AND (II) SUB-TRANSFER AGENT ("SUB-TA") SERVICES IN EXCESS OF BOARD-APPROVED LIMITS. THE SEC ALLEGED THAT WILLIAM BLAIR ALSO FAILED TO FULLY DISCLOSE TO THE FUNDS' BOARD OF TRUSTEES THAT WILLIAM BLAIR (AND NOT A THIRD-PARTY SERVICE PROVIDER) WOULD RETAIN A FEE FOR PROVIDING SHAREHOLDER ADMINISTRATION SERVICES TO THE FUNDS UNDER A SHAREHOLDER ADMINISTRATION SERVICES AGREEMENT BETWEEN CERTAIN OF THE FUNDS AND WILLIAM BLAIR. Status: Final Sanction Detail: WILLIAM BLAIR WAS ASSESSED A CIVIL MONEY PENALTY IN THE AMOUNT OF $4,500,000 THAT IT PAID ON MAY 8, 2017. CEASE AND DESIST PROCEEDINGS WERE INSTITUTED PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 AND SECTION 9(F) OF THE INVESTMENT COMPANY ACT OF 1940. Summary: AN ORDER BY THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DATED MAY 1, 2017 FOUND THAT FROM 2010 UNTIL 2014, AS A RESULT OF ERRONEOUS PAYMENTS, WILLIAM BLAIR NEGLIGENTLY USED MUTUAL FUND ASSETS TO PAY FOR (I) DISTRIBUTION AND MARKETING OF FUND SHARES OUTSIDE OF A WRITTEN, BOARD-APPROVED RULE 12B-1 PLAN AND (II) SUB-TRANSFER AGENT ("SUB-TA") SERVICES IN EXCESS OF BOARD-APPROVED LIMITS. THESE PAYMENTS TOTALED APPROXIMATELY $1.25 MILLION AND RENDERED CERTAIN OF WILLIAM BLAIR FUNDS' ("FUNDS") DISCLOSURES CONCERNING PAYMENTS FOR DISTRIBUTION AND SUB-TA SERVICES INACCURATE. AS A RESULT OF THIS CONDUCT, WILLIAM BLAIR VIOLATED SECTION 206(2) OF THE ADVISERS ACT AND SECTION 34(B) OF THE INVESTMENT COMPANY ACT, AND CAUSED THE FUNDS TO VIOLATE SECTION 12(B) OF THE INVESTMENT COMPANY ACT AND RULE 12B-1 THEREUNDER. THE SEC ALLEGED THAT WILLIAM BLAIR ALSO FAILED TO FULLY DISCLOSE TO THE FUNDS' BOARD OF TRUSTEES ("BOARD") THAT WILLIAM BLAIR (AND NOT A THIRD-PARTY SERVICE PROVIDER) WOULD RETAIN A FEE FOR PROVIDING SHAREHOLDER ADMINISTRATION SERVICES TO THE FUNDS UNDER A SHAREHOLDER ADMINISTRATION SERVICES AGREEMENT BETWEEN CERTAIN OF THE FUNDS AND WILLIAM BLAIR. AS A RESULT OF THIS CONDUCT, WILLIAM BLAIR VIOLATED SECTION 206(2) OF THE ADVISERS ACT. WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, WILLIAM BLAIR CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 AND SECTION 9(F) OF THE INVESTMENT COMPANY ACT OF 1940, MAKING FINDINGS, AND IMPOSING A CEASE-AND-DESIST ORDER. WILLIAM BLAIR ALSO WAS ASSESSED BY THE COMMISSION A CIVIL MONEY PENALTY IN THE AMOUNT OF $4,500,000.

Allegations: FROM OCTOBER 2, 2001 TO DECEMBER 31, 2001, WILLIAM BLAIR & COMPANY, L.L.C., A MARKET MAKER, WAS A PARTY TO A LOCKED OR CROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING DURING THE PERIOD BETWEEN 9:20 AND 9:29:59 A.M. EASTERN TIME AND RECEIVED, IN 105 INSTANCES, A TRADE-OR-MOVE MESSAGE THROUGH SELECTNET. WILLIAM BLAIR, WITHIN 30 SECONDS OF RECEIVING SUCH MESSAGES, FAILED TO FILL THE INCOMING TRADE-OR-MOVE MESSAGE FOR THE FULL SIZE OF THE MESSAGE OR MOVE ITS BID DOWN (OR OFFER UP) BY A QUOTATION INCREMENT THAT WOULD HAVE UNLOCKED/UNCROSSED THE MARKET, IN VIOLATION OF NASD MARKETPLACE RULE 4613(E)(1)(C). Status: Final Sanction Detail: THE FINE OF $15,000 WAS PAID ON MARCH 26, 2003.

Allegations: DURING THE FIRST AND FOURTH QUARTERS OF 2004, WILLIAM BLAIR & COMPANY ("THE FIRM") ALLEGEDLY TRANSMITTED TO OATS REPORTS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA AND FAILED TO SUBMIT REQUIRED INFORMATION TO OATS REGARDING ONE ORDER. ON 18 OCCASIONS DURING THE FOURTH QUARTER OF 2004 THE FIRM ALLEGEDLY FAILED TO COMPLY WITH THE LIMIT ORDER DISPLAY RULE. FURTHER, IN THE FIRST QUARTER OF 2004 THE FIRM ALLEGEDLY FAILED TO CONDUCT INDEPENDENT REVIEWS OF LIMIT ORDERS TO ENSURE THAT THE AUTOMATED COMPLIANCE SYSTEM WAS WORKING AS INTENDED. Status: Final Sanction Detail: THE FIRM WAS NOTIFIED ON FEBRUARY 15, 2007 THAT THE NASD'S OFFICE OF DISCIPLINARY AFFAIRS AND THE NATIONAL ADJUDICATORY COUNCIL HAD ACCEPTED THE ACCEPTANCE, WAIVER AND CONSENT (AWC) TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO PAY THE FINE OF $25,000 TO SETTLE THE MATTER. THE FINE WAS PAID ON MARCH 9, 2007.

Allegations: DURING THE THIRD QUARTER OF 2005 WILLIAM BLAIR & COMPANY ("THE FIRM") ALLEGEDLY VIOLATED SEC RULE 11AC1-4 BY FAILING TO IMMEDIATELY DISPLAY TWENTY-TWO (22)CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES, IN ITS PUBLIC QUOTATION. DURING THE SAME TIME PERIOD, THE FIRM ALLEGEDLY VIOLATED NASD MARKETPLACE RULE 6955(A) BY TRANSMITTING TO OATS, REPORTS CONCERNING SEVENTY (70) ORDERS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. Status: Final Sanction Detail: THE FIRM WAS NOTIFIED ON DECEMBER 12, 2007 THAT THE NASD'S OFFICE OF DISCIPLINARY AFFAIRS AND THE NATIONAL ADJUDICATORY COUNCIL HAD ACCEPTED THE ACCEPTANCE,WAIVER AND CONSENT (AWC) TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO PAY THE FINE OF $20,000 TO SETTLE THE MATTER (CONSISTING OF $10,000 FOR THE LIMIT ORDER DISPLAY VIOLATIONS AND $10,000 FOR THE OATS VIOLATIONS).

Allegations: THE COMPLAINT ALLEGED THAT WILLIAM BLAIR & COMPANY VIOLATED SECTION C3C OF THE RULES OF FAIR PRACTICE AND PROCEDURE FOR SOES AND ARTICLE III, SECTION 1 OF THE NASD RULES OF FAIR PRACTICE BY EFFECTING 11 TRANSACTIONS VIA SOES BETWEEN FEBRUARY AND JUNE 1994, WHEN TRADES WERE NOT ELIGIBLE FOR SUCH EXECUTION. Status: Final Sanction Detail: THE FIRM WAS NOTIFIED ON MARCH 15, 1996 THAT THE NASD HAD ACCEPTED THE ACCEPTANCE, WAIVER AND CONSENT TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO SETTLE THE MATTER. THE FINE WAS PAID APRIL 25, 1996 Summary: DURING A ROUTINE EXAMINATION CONDUCTED IN SEPTEMBER 1994, DISTRICT STAFF REVIEWED THE SOES TRADING. THE NASD ALLEGED THAT FOUR SERIES OF TRANSACTIONS EXECUTED DURING THAT PERIOD WERE BASED ON A SINGLE INVESTMENT DECISION. THE FIRM EXECUTED APPROXIMATELY 2000 SOES TRANSACTIONS DURING THE PERIOD IN QUESTION.

Allegations: IN THREE INSTANCES WILLIAM BLAIR & COMPANY FAILED TO CONTEMPORANEOUSLY EXECUTE OR PARTIALLY EXECUTE A CUSTOMER LIMIT ORDER AFTER TRADING IN THE SAME SECURITY FOR ITS OWN ACCOUNT AT PRICES THAT WOULD HAVE SATISFIED A CUSTOMER LIMIT ORDER. OVER 150 TRANSACTIONS WERE INCLUDED IN THE REVIEW. Status: Final Sanction Detail: THE FINE OF $1000.00 WAS PAID ON MAY 6, 1999.