Wellington Alternative Investments Llc

Allegations: THE FDF ALLEGED THAT WELLINGTON HAD NOT FILED, WITHIN THE SPECIFIED TIME PERIOD, REPORTS THAT ITS COLLECTIVE OWNERSHIP OF A SWISS SECURITY CROSSED AN OWNERSHIP THRESHOLD. Status: Final Sanction Detail: THE AMOUNT OF THE SETTLEMENT WAS CHF7,000 (APPROXIMATELY USD7,000.) Summary: WE CONSENTED TO THE FINE IN FULL SETTLEMENT OF THE MATTER. THERE WERE NO ADDITIONAL CONDITIONS IMPOSED.

Allegations: THE GERMAN FEDERAL FINANCIAL SUPERVISORY AUTHORITY ("BAFIN") SANCTIONED WELLINGTON MANAGEMENT IN RELATION TO THREE INDIVIDUAL ADMINISTRATIVE BREACHES OF LARGE SHAREHOLDER DISCLOSURE REQUIREMENTS. THE BREACHES RELATE TO EVENTS WHICH OCCURRED IN 2016, 2018 AND 2019 RESPECTIVELY. Status: Final Sanction Detail: THE AMOUNT OF THE ADMINISTRATIVE CHARGE WAS EUR 165,000 Summary: WE CONSENTED TO THE FINE IN FULL SETTLEMENT OF THE MATTER. THERE WERE NO ADDITIONAL CONDITIONS IMPOSED.

Allegations: THE FDF ALLEGED THAT WELLINGTON HAD NOT PROVIDED AN ADDITIONAL TABLE THAT PROVIDES A BREAKDOWN OF SHARES AMONG OUR CLIENT ACCOUNTS WITH SIX LARGE SHAREHOLDER DISCLOSURE FILINGS MADE IN 2016 AND 2017 IN ACCORDANCE WITH ART. 151 IN RELATION WITH ART. 120 OF THE FEDERAL ACT ON FINANCIAL MARKET INFRASTRUCTURES AND MARKET CONDUCT IN SECURITIES AND DERIVATIVES TRADING (FINMIA; SR 958.1). THE OMISSION WAS UNCOVERED BY WELLINGTON AND SELF-DISCLOSED TO THE REGULATOR IN 2017. WHILE THE SHARES HELD BY WELLINGTON MANAGEMENT GROUP LLP WERE PROPERLY DISCLOSED, WELLINGTON DID NOT INCLUDE A BREAKDOWN OF SHARES HELD AMONG OUR ACCOUNTS AS REQUIRED UNDER THE REGULATION. Status: Final Sanction Detail: THE AMOUNT OF THE SETTLEMENT WAS CHF 31,550 (APPROXIMATELY USD 35,500) Summary: WELLINGTON CONSENTED TO THE FINE IN FULL SETTLEMENT OF THE MATTER. THERE WERE NO ADDITIONAL CONDITIONS IMPOSED.