Disclaimers and Disclosures

Asset Servicing

Global Disclosure

bny.com

BNY is the corporate brand of The Bank of New York Mellon Corporation and may be used to reference the corporation as a whole and/or its various subsidiaries generally. This material does not constitute a recommendation by BNY of any kind. The information herein is not intended to provide tax, legal, investment, accounting, financial or other professional advice on any matter, and should not be used or relied upon as such. The views expressed within this material are those of the contributors and not necessarily those of BNY. BNY has not independently verified the information contained in this material and makes no representation as to the accuracy, completeness, timeliness, merchantability or fitness for a specific purpose of the information provided in this material. BNY assumes no direct or consequential liability for any errors in or reliance upon this material.

The Bank of New York Mellon operates in the U.K. through its London branch (U.K. companies house numbers FC005522 and BR025038) at BNY Mellon Centre, 160 Queen Victoria Street, London, EC4V 4LA and is subject to regulation by the Financial Conduct Authority (FCA) at 12 Endeavour Square, London, E20 1JN, U.K. and limited regulation by the PRA at The Bank of England, Threadneedle St, London, EC2R 8AH, U.K. Details about the extent of our regulation by the PRA are available from us on request.

BNY Mellon Fund Services (Ireland) Designated Activity Company is registered with Company No 218007, having its registered office at One Dockland Central, Guild Street, IFSC, Dublin 1, Ireland. It is regulated by the Central Bank of Ireland.

The Bank of New York Mellon operates in Germany through its Frankfurt am Main branch (registered in Germany with Registration No. HRB 12731) at Friedrich-Ebert-Anlage 49, 60327 Frankfurt am Main, Germany. It is under the supervision of the German Central Bank and the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, Marie-Curie-Str. 24-28, 60439 Frankfurt, Germany) under registration number 10100253.

The Bank of New York Mellon SA/NV, a Belgian public limited liability company, with company number 0806.743.159, whose registered office is at Boulevard Anspachlaan 1, B-1000 Brussels, Belgium, authorised and regulated as a significant credit institution by the European Central Bank (ECB), under the prudential supervision of the National Bank of Belgium (NBB) and under the supervision of the Belgian Financial Services and Markets Authority (FSMA) for conduct of business rules, a subsidiary of The Bank of New York Mellon.

The Bank of New York Mellon SA/NV operates in Ireland through its Dublin branch at Riverside II, Sir John Rogerson's Quay Grand Canal Dock, Dublin 2, D02KV60, Ireland and is registered with the Companies Registration Office in Ireland No. 907126 & with VAT No. IE 9578054E. The Bank of New York Mellon SA/NV, Dublin Branch is subject to additional regulation by the Central Bank of Ireland for Depository Services and for conduct of business rules.

The Bank of New York Mellon SA/NV is trading in Germany as The Bank of New York Mellon SA/NV, Asset Servicing, Niederlassung Frankfurt am Main, and has its registered office at MesseTurm, Friedrich-Ebert-Anlage 49, 60327 Frankfurt am Main, Germany. It is subject to limited additional regulation by the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, Marie-Curie-Str. 24-28, 60439 Frankfurt, Germany) under registration number 122721.

The Bank of New York Mellon SA/NV operates in Poland as The Bank of New York Mellon SA/NV (Joint-stock Company) Branch in Poland with Statistical Number 524311310, whose registered office is at Sucha 2, 50-086 Wroclaw, Poland. The Bank of New York Mellon SA/NV (Joint-stock Company) Branch in Poland is a non-contracting branch.

The Bank of New York Mellon SA/NV operates in the Netherlands through its Amsterdam branch at Tribes SOM2 Building, Claude Debussylaan 7, 1082 MC Amsterdam, the Netherlands. The Bank of New York Mellon SA/NV, Amsterdam Branch is subject to limited additional supervision by the Dutch Central Bank (“De Nederlandsche Bank” or “DNB”) on integrity issues only (registration number 34363596). DNB holds office at Frederiksplein 61, 1017 XL Amsterdam, the Netherlands.

The Bank of New York Mellon SA/NV operates in Luxembourg through its Luxembourg branch at 2-4 rue Eugene Ruppert, Vertigo Building – Polaris, L- 2453, Luxembourg. The Bank of New York Mellon SA/NV, Luxembourg Branch is subject to limited additional regulation by the Commission de Surveillance du Secteur Financier at 283, route d’Arlon, L-1150 Luxembourg for conduct of business rules, and in its role as UCITS/AIF depositary and central administration agent.

The Bank of New York Mellon SA/NV operates in France through its Paris branch at 7 Rue Scribe, Paris, Paris 75009, France. The Bank of New York Mellon SA/NV, Paris Branch is subject to limited additional regulation by Secrétariat Général de l’Autorité de Contrôle Prudentiel at Première Direction du Contrôle de Banques (DCB 1), Service 2, 61, Rue Taitbout, 75436 Paris Cedex 09, France (registration number (SIREN) Nr. 538 228 420 RCS Paris - CIB 13733).

The Bank of New York Mellon SA/NV operates in Italy through its Milan branch at Via Mike Bongiorno no. 13, Diamantino building, 5th floor, Milan, 20124, Italy. The Bank of New York Mellon SA/NV, Milan Branch is subject to limited additional regulation by Banca d’Italia - Sede di Milano at Divisione Supervisione Banche, Via Cordusio no. 5, 20123 Milano, Italy (registration number 03351).

The Bank of New York Mellon SA/NV operates in Denmark as The Bank of New York Mellon SA/NV, Copenhagen Branch, filial af The Bank of New York Mellon SA/NV, Belgien, and has its registered office at Strandvejen 125 DK-2900 Hellerup, Denmark. It is subject to limited additional regulation by the Danish Financial Supervisory Authority (Finanstilsynet, Strandgade 29, DK-1401 Copenhagen K, Denmark).

The Bank of New York Mellon SA/NV operates in Spain through its Madrid branch with registered office at Calle José Abascal 45, Planta 4ª, 28003, Madrid, and enrolled on the Reg. Mercantil de Madrid, Tomo 41019, folio 185 (M-727448). The Bank of New York Mellon, Sucursal en España is registered with Banco de España (registration number 1573).

The Bank of New York Mellon (International) Limited is registered in England & Wales with Company No. 03236121 with its Registered Office at BNY Mellon Centre, 160 Queen Victoria Street, London EC4V 4LA. The Bank of New York Mellon (International) Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority.

Regulatory information in relation to the above BNY entities operating out of Europe can be accessed at the following website: https://www.bny.com/corporate/emea/en/regulatory-information.html.

For clients located in Switzerland: The information provided herein does not constitute an offer of financial instrument or an offer to provide financial service in Switzerland pursuant to or within the meaning of the Swiss Financial Services Act ("FinSA") and its implementing ordinance. This is solely an advertisement pursuant to or within the meaning of FinSA and its implementing ordinance. Please be informed that The Bank of New York Mellon and The Bank of New York Mellon SA/NV are entering into the OTC derivative transactions as a counterparty, i.e. acting for its own account or for the account of one of its affiliates. As a result, where you enter into any OTC derivative transactions with us, you will not be considered a "client" (within the meaning of the FinSA) and you will not benefit from the protections otherwise afforded to clients under FinSA.

BNY Mellon Saudi Financial Company is licensed and regulated by the Capital Market Authority, License number 20211-04, located in Alfaisaliah Tower, 18th Floor, King Fahad Road, P.O. Box 99936 Riyadh 11625, Kingdom of Saudi Arabia.

The Bank of New York Mellon, Hong Kong Branch (a branch of a banking corporation organized and existing under the laws of the State of New York with limited liability), is subject to regulation by the Hong Kong Monetary Authority and the Securities & Futures Commission of Hong Kong.

The Bank of New York Mellon, Seoul Branch, is a licensed foreign bank branch in Korea and regulated by the Financial Services Commission and the Financial Supervisory Service. The Bank of New York Mellon, Seoul Branch, is subject to local regulation (e.g. the Banking Act, the Financial Investment Services and Capital Market Act, and the Foreign Exchange Transactions Act etc).

The Bank of New York Mellon is regulated by the Australian Prudential Regulation Authority and also holds an Australian Financial Services Licence No. 527917 issued by the Australian Securities and Investments Commission to provide financial services to wholesale clients in Australia.

The Bank of New York Mellon has various other subsidiaries, affiliates, branches and representative offices in the Asia-Pacific Region which are subject to regulation by the relevant local regulator in that jurisdiction.

The Bank of New York Mellon, Tokyo Branch, is a licensed foreign bank branch in Japan and regulated by the Financial Services Agency of Japan. The Bank of New York Mellon Trust (Japan), Ltd., is a licensed trust bank in Japan and regulated by the Financial Services Agency of Japan. The Bank of New York Mellon Securities Company Japan Ltd., is a registered type 1 financial instruments business operator in Japan and regulated by the Financial Services Agency of Japan.

The Bank of New York Mellon, DIFC Branch, regulated by the Dubai Financial Services Authority (DFSA) and located at DIFC, The Exchange Building 5 North, Level 6, Room 601, P.O. Box 506723, Dubai, UAE, on behalf of The Bank of New York Mellon, which is a wholly-owned subsidiary of The Bank of New York Mellon Corporation.

Past performance is not a guide to future performance of any instrument, transaction or financial structure and a loss of original capital may occur. Calls and communications with BNY may be recorded, for regulatory and other reasons.

Disclosures in relation to certain other BNY group entities can be accessed at the following website: https://www.bny.com/corporate/emea/en/disclaimers/eu-disclosures.html.

This document and the statements contained herein, are not an offer or solicitation to buy or sell any products (including financial products) or services or to participate in any particular strategy mentioned and should not be construed as such. This material is intended for wholesale/professional clients (or the equivalent only), is not intended for use by retail clients and no other person should act upon it. Persons who do not have professional experience in matters relating to investments should not rely on this material. BNY will only provide the relevant investment services to investment professionals.

Not all products and services are offered in all countries.

If distributed in the U.K., this material is a financial promotion. If distributed in the EU, this material is a marketing communication.

This material, which may be considered advertising, is for general information purposes only and is not intended to provide legal, tax, accounting, investment, financial or other professional advice on any matter. This material does not constitute a recommendation or advice by BNY of any kind. Use of our products and services is subject to various regulations and regulatory oversight. You should discuss this material with appropriate advisors in the context of your circumstances before acting in any manner on this material or agreeing to use any of the referenced products or services and make your own independent assessment (based on such advice) as to whether the referenced products or services are appropriate or suitable for you. This material may not be comprehensive or up to date and there is no undertaking as to the accuracy, timeliness, completeness or fitness for a particular purpose of information given. BNY will not be responsible for updating any information contained within this material and opinions and information contained herein are subject to change without notice. BNY assumes no direct or consequential liability for any errors in or reliance upon this material.

This material may not be distributed or used for the purpose of providing any referenced products or services or making any offers or solicitations in any jurisdiction or in any circumstances in which such products, services, offers or solicitations are unlawful or not authorized, or where there would be, by virtue of such distribution, new or additional registration requirements.

Any references to dollars are to U.S. dollars unless specified otherwise.

This material may not be reproduced or disseminated in any form without the prior written permission of BNY.

Trademarks, logos and other intellectual property marks belong to their respective owners.

The Bank of New York Mellon, member of the Federal Deposit Insurance Corporation (FDIC).

Asset Servicing

Compensation Disclosure (PDF)

A password is required to open the disclosure document. The password can be found on your fee schedule, or by contacting your BNY Asset Servicing relationship team.

These disclosures apply only to Asset Servicing compensation related to services provided under a trust or custody agreement.

For ERISA accounts, these disclosures (i) are intended to comply with ERISA §408(b)(2) and applicable regulations thereunder and to satisfy the alternative reporting option for eligible indirect compensation of a service provider for Form 5500, Schedule C; and (ii) are meant for the “responsible plan fiduciary” as defined in ERISA § 408(b)(2), or any other fiduciary with authority to enter into, extend or renew the contract with respect to which these disclosures are being provided to you. If you know of a change in the identity of or contact information for the “responsible plan fiduciary” or other appropriate fiduciary, please provide that information to your BNY relationship team contact for that contract or arrangement.

For non-ERISA accounts, these disclosures are provided for informational purposes only. Additional forms of compensation may apply. Please contact your BNY relationship team for more information.

Direct Compensation Not Included on Fee Schedule

BNY, acting through any of its branches or affiliates, Credit and Debit Interest Rate Policy

Each interest-bearing cash account held with BNY shall accrue credit or debit interest daily based on the end of day balance for that account and the interest period shall be a period of a month (unless otherwise agreed with BNY) based on the day count convention for the currency of the account. Unless otherwise agreed with BNY, interest is credited (or debited) on the last business day of the month. The last business day of the month is included in the following month’s calculation.

Interest rates can change from time to time without notice at the discretion of BNY. Further detail of standard daily interest rates will appear in the daily rate reference file we publish on our Online Portal, NEXEN (“Online Portal”). In calculating standard interest, BNY will take the end of day balance of account, multiply this by the applicable standard/managed rate and divide by the applicable day count convention/market divisor.

Should you not have access to the Online Portal or be in receipt of the above statements and interest rate information, please contact your BNY relationship manager.

BNY will provide notice to you 30 days in advance of any change (excluding rate changes) of the basis of computation of its standard interest rate(s) by means of written notice issued through a client publication (which may include NetInfo or other electronic communication or posting). BNY may need to recoup additional costs and charges in the event of a change in law, regulation, market conditions, or government or Central Bank measures, and in such circumstance may change the basis of its charge or computation upon less than 30 days’ advance notice.

Terms and Conditions in respect of discretionary advances and overdrafts are detailed in your client agreement and/or relevant fee schedule.

Negative Interest Rates: BNY may (except where it has otherwise agreed with you) apply a charge to any cash account or balance when, for any currency:

(i) any recognized overnight benchmark rate or any official overnight interest rate set by any applicable central bank or other monetary authority is negative or zero; or

(ii) any market counterpart or other institution applies a negative interest rate or any related charge to any account or balance of BNY or to any account or balance opened for you by BNY; or

(iii) the combination of the applicable recognized overnight benchmark rate or any official overnight interest rate set by a central bank or other monetary authority (where positive) and any charge applied by BNY over relevant balances results in a negative rate.

For negative interest rates for certain major currencies, any spread may be determined by reference to factors including client type and operational nature of deposits. We will provide notice to you 30 days in advance of any application of a negative interest rate by means of written notice issued through a client publication (usually a NetInfo). BNY will provide notice to you 30 days in advance but only the first time that BNY applies negative interest charges in a currency. Notice will not be provided if BNY is changing rates on a currency that already carries a negative interest rate.

Excess Balance Charge - If the end of day cash balance on any of your cash accounts on the last business day of a calendar quarter exceeds the average cash balance of the prior calendar quarter then BNY may apply an excess balance charge in the following month.

The charge will be 1% per annum of the excess cash balance (subject to market conditions for the currency to which the charge is applied which we will discuss with you where applicable).
The charge applies to excess long cash balances held by you with BNY on the “Relevant Dates.” For the purposes of our policy, a “Relevant Date” is defined as the last business day of a calendar quarter and each subsequent non-business day until the relevant BNY deposit entity reopens for business.
This will apply to any excess long cash balances held by you with BNY.
When determining excess cash balances BNY will not:

a) apply a cross currency approach, or

b) allow overdraft or debit balance set offs unless specifically agreed.

Sale Failed Trades

Asset Servicing endeavors to settle all trades in an accurate and timely manner but occasionally trades fail to settle. In those markets where the proceeds of a pending sale are credited to the client’s account on settlement date (“contractual markets”) and the transaction fails, Asset Servicing charges the client’s account for the number of days that BNY advanced the funds at the overdraft rate as outlined above.

Charges related to failed trades in contractual markets will be calculated at the beginning of each month, reflecting fail events that were resolved during the prior month or 60 days and will post on the second business day of the following month. There will be no charge for amounts less than 500 USD equivalent per failed trade or failed turn-around trades. For example, charges for a failed trade occurring in February will be calculated the beginning of March and post on the 2nd business day in April.

It is the responsibility of the client or the client’s investment manager to claim against a third party, where applicable. Asset Servicing will investigate third party claims of 500 USD equivalent and above received from clients, investment managers or their agents within 60 days of actual settlement to determine the reason for the fail and associated charge. If Asset Servicing determines that it or its agent caused the failed transaction, it will pay the claim or back value the transaction in accordance with local market practice. Where Asset Servicing paid client interest on a balance that relates to a claim, and the claim results in a payment or in the transaction being back valued, Asset Servicing will charge the client’s account for the amount of interest related to that claim. If the fail and charge are determined not to be caused by Asset Servicing or its agent, the claim will be rejected back to the originating party.

Clients and investment managers can track their failed transactions on NEXEN via the following reports

Unsettled Trades; Unsettled Trades with Detail Status; Cash and Security Transactions

Euroclear Surcharges

Asset fees for International Debt Instruments (as defined by Euroclear Bank) held at Euroclear will be assessed at our standard Euroclear rate reflected on our fee schedule. All other types of securities (including but not limited to International Equities, International Depository Receipts, International Warrants and Domestic Market Securities) held at Euroclear will be subject to a surcharge. The amount of the surcharge varies considering features of the particular security held. Purchases or sales Transactions involving the delivery of securities as referenced above within Euroclear or from a Euroclear account to a third party depository or settlement system will also be subject to a surcharge that varies based upon the details of the transaction. Please refer to the Surcharge Fee Schedule provided with your fee schedule for further information. Please note the Surcharge Fee Schedules are subject to change and can be requested at any time.

Indirect Compensation

Shareholder Servicing Fees Related to Sweep to Mutual Fund

Where a client elects to sweep excess cash to a non BNY affiliated mutual fund, the mutual fund, its investment adviser(s), distributor(s) and/or administrator(s) may make payments to BNY in connection with certain shareholder support services that BNY Asset Servicing provides to the fund in an amount that is a percentage of the average daily net assets of the holdings of the fund. The specific percentage depends upon the fund selected and is set forth in the form for Direction of Cash Balances, which is completed by the client or investment manager prior to use of any fund for a particular account and which is available upon request from your BNY client representative. As of December 31, 2024 the maximum shareholder servicing fee received by BNY for any fund did not exceed 35 basis points. Such shareholder support services may include, but not be limited to, answering client inquiries, processing dividend payments, providing assistance to clients in changing dividend options, account designations and addresses, aggregating and processing purchase and redemption transactions, providing periodic statements showing fund balances and purchases, sales and positions in the fund, providing sub-accounting services to the fund for shares held by BNY Asset Servicing’s clients and forwarding to the client communications from the fund or its distributor as requested by the fund, its distributor or the client. Depending on market conditions, a fund may reduce the shareholder servicing fee paid. For clients using Liquidity Direct, BNY’s services may also include processing purchases of securities transactions through affiliates and placing funds on deposit in accounts with third parties. Funds that pay BNY a shareholder servicing fee with respect to cash sweep do not use the Matrix service described below.

Shareholder Servicing Fees Related to Matrix Settlement & Clearance Services

To enhance and improve mutual fund processing, BNY has entered into a reciprocal processing agreement with Matrix Settlement & Clearance Services, LLC (Matrix), a company which provides standardized, consolidated, automated clearing and settlement services for certain mutual funds that use Matrix’s service. Reporting, income and dividend processing, and reconcilement services are improved significantly through these arrangements. In connection with transactions for these mutual funds, BNY provides certain administrative services, including, but not limited to, maintaining participant accounts and records, processing purchase and redemption transactions, and furnishing periodic statements. For its clearance and settlement functions, Matrix receives administrative services fees directly from the funds (“Fees”). Matrix pays BNY, as compensation for its administrative services, 95% of the Fees and retains the remaining 5%. Matrix also pays BNY, as compensation for its administrative services, an amount equal to 100% of the Fees collected and Matrix pays a fixed fund revenue collection fee of $50,000 per quarter. The Fees are described in each fund’s prospectus and those funds using Matrix are identified with the applicable Fees at the following link (copy and paste to your web browser).

https://rtk.broadridge.com/MatrixServices/GetReport.aspx?token=C3648F78-65FC-467D-81E1 2E36BD423961&rpt=FD

The Fees are in addition to any fees paid directly to BNY by the client, the plan or the plan sponsor in connection with a contract or arrangement for services between the client and BNY. In addition, a fund may (a) purchase securities from or through BNY or its affiliates; (b) engage in repurchase transactions in which BNY or its affiliates act as clearing bank or custodian; (c) place assets on deposit in accounts with BNY Mellon or its affiliates and receive interest income; or (d) obtain other services from BNY or its affiliates that result in compensation to BNY or its affiliates.

Note: BNY does not receive these Fees for ERISA accounts where BNY or one of its affiliates has investment discretion.

Amounts Received in Connection with Shareholder Communications

As one of its custodial functions BNY is responsible for distributing to investors’ proxy statements, annual reports and other shareholder communications from issuers and for collecting proxy vote instructions, tallying a cumulative vote and reporting it to each issuer. To assist in this process BNY has engaged the services of Broadridge Financial Solutions, Inc. for communications from issuers of U.S. securities and Proxymity Ltd for non U.S. securities. In order to offset the costs of this process with respect to U.S. securities, Rule 465 of the New York Stock Exchange sets forth certain approved rates of reimbursement that custodians and member organizations may charge issuers of U.S. securities to cover their internal and out-of-pocket costs. In addition to facilitating the communication from issuer to shareholder and shareholder to issuer on behalf of BNY, Broadridge also collects from each issuer the amount due pursuant to Rule 465, deducts its fee and remits the remaining balance to BNY. There is a similar reimbursement process for Canadian securities. With respect to other non U.S. securities, there is no similar rule to Rule 465 and issuers do not provide reimbursement to intermediaries, such as BNY, in the communication process. Rule 465 may be found by typing “465” into the search box at https://nyseguide.srorules.com/rules

Amounts Earned on Bank Deposits, Including Float

Amounts held by BNY (the “Bank”) in its deposit accounts are included on the Bank’s balance sheet and represent an obligation to the depositor. While the Bank earns compensation related to deposit accounts, it does not track the use or application of specific client or account balances. Cash from trust and custody accounts may be placed in a Bank deposit account in one of several instances. First, clients may select a deposit account for investment of cash. Second, cash may be transferred to or from an omnibus deposit account used by BNY Asset Servicing in its role as custodian or trustee for pending transactions. Third, revenue generated by the invested cash collateral in Asset Servicing’s securities lending program may be placed in a Bank deposit account pending allocation and distribution to participating borrowers and clients. The third instance is more fully described in the Disclosure of Float on Securities Lending Income, which is provided to clients participating in the Bank’s securities lending program. The first and second of these are described below.

Investment of Cash Held in Deposit Accounts

Amounts held by the Bank in its deposit accounts are subject to the deposit terms and conditions for the type of account. The difference between what the Bank earns in its proprietary capacity on the assets in its deposit accounts and the expenses directly related to those accounts, including the interest that the Bank pays to its depositors, is the Bank’s compensation and is called net interest revenue.

For incremental USD balances (ie: excess reserves) invested on a short term basis, the gross return earned by the Bank prior to any deduction for expenses most closely approximates the Interest on Reserve Balances Rate. This rate can be used to estimate the Bank’s gross earnings by taking the amount of the deposit times the Interest on Reserve Balances Rate for the date of the deposit divided by 360 days. To illustrate, where Asset Servicing receives cash for a US client’s account less than thirty minutes prior to the cut off time established by the client’s selected money market vehicle, the client may direct that the uninvested cash be transferred to an interest-bearing Bank deposit account called Cash Reserve for overnight investment. This overnight deposit is usually withdrawn the next day and transferred to the selected money market fund. To estimate the Bank’s gross earnings for such a short term deposit, if a 100,000 USD deposit were invested overnight in Cash Reserve on January 31, 2022 the calculation would be $100,000 x .001/360=$0.28

For incremental non-USD balances (although the Bank doesn’t earn on all non USD balances; e.g.: no earnings on most restricted currencies) invested on a short term basis, the gross return earned by the Bank prior to any deduction for expenses most closely approximates the overnight rate associated with that market or currency. A similar calculation to that for USD illustrated above can be performed to estimate the Bank’s gross earnings.

While amounts held in the Bank’s omnibus deposit account for any one client, or held in a Bank deposit product such as Cash Reserve, may fluctuate markedly on a short term basis, the Bank has determined that, when deposits are taken as a whole, a certain minimum balance tends to remain on deposit longer term. These “core deposits,” together with other proprietary Bank assets, form part of the Bank’s overall investment portfolio. Through the use of longer term investment strategies applied to its total portfolio, the Bank may enhance its net interest revenue over that which can be earned on a short term basis. The Bank’s net interest revenue for any quarter is disclosed on its financial statements.

Float Earned on Omnibus Deposit Account

Float occurs at times when cash is held outside of the client’s trust or custody account in a general, non-interest bearing omnibus Bank deposit account used by Asset Servicing to facilitate processing of transactions. The Bank may earn float in four instances:

Cash has been transferred to an omnibus Bank deposit account pending payment for the settlement of securities or foreign exchange purchases;
Cash has been transferred to an omnibus Bank deposit account pending disbursement for the payment of benefits or expenses or other authorized payments such as participant loans;
Cash, such as contributions, incoming funds transfers, dividends and class action proceeds, has been received by Asset Servicing and placed in an omnibus Bank deposit account(s) but cannot be allocated to a client’s trust or custody account because the cash is received too late for deposit, or because Asset Servicing has not received sufficient instructions to enable it to identify the trust or custody account to which the cash is to be deposited, or because additional time is required to allocate earnings for short term investment funds to the proper account; or
Cash has been received for a trust or custody account that utilizes a money market mutual fund as its cash sweep vehicle but cannot be invested by Asset Servicing on the date of receipt because (i) Asset Servicing was not notified at least thirty (30) minutes before the mutual fund’s cut-off time for investment that the cash is being sent to the account; (ii) the wire transfer does not contain all appropriate account specific information; and/or (iii) the wire transfer was not received at least thirty (30) minutes before the mutual fund’s cut-off time; and deposit to Cash Reserve has not been directed.

The specific cut-off time for the money market mutual fund selected as a cash sweep vehicle is disclosed in that fund’s prospectus.

The rate earned on USD balances held within the United States most closely approximates the Interest on Reserve Balances Rate. The float earned on balances held outside the United States through Asset Servicing’s subcustodian network most closely approximates the interest rate paid by the local subcustodian in each market.

BNY Asset Servicing’s Procedures Related to Float

Procedures with respect to the receipt of cash, pending investment direction

It is Asset Servicing’s practice to allocate cash received to the appropriate trust or custody account as soon as practical. All incoming wires are directed to a central wire facility that promptly records receipt of incoming wires and dollar amounts. Incoming wires which correctly identify the destination account and of which Asset Servicing received notice in accordance with its wire notification procedures are directed to the appropriate account for investment. If, however, an incoming wire does not clearly identify the destination account or Asset Servicing is not notified of the wire in a timeframe consistent with its wire notification procedures, a delay in crediting the amount to the account may result. During that period, Asset Servicing endeavors to identify the destination account and properly direct the cash as quickly as it can. It is Asset Servicing’s practice to return cash to the sender if the wires remain “unmatched” after a period of time.

Procedures with respect to distributions

The most common distribution activity relates to benefit payments. Many clients choose to use an automatic payment option, such as ACH, for all or some of their beneficiaries. When this option is chosen, there is no float period because the cash to make the disbursement is removed from the account on the payable date. For beneficiaries who prefer to receive actual checks, many clients choose to have Asset Servicing make periodic benefit disbursements through its omnibus checking account. Currently, approximately 4.5 % of our benefit disbursement payments are made by check. When the check option is chosen, there are several alternatives available to a client for funding the checking account. The method most commonly requested by clients is to have payment checks prepared, dated and mailed in advance of the payable date for receipt by the beneficiary on a specific date, such as the first of the month. The cash necessary to fund those checks is debited from the applicable account and credited to the checking account on the payable date indicated on the checks. A similar procedure is followed for lump sum payments (such as rollover distributions or expense payments) except payments of this type are typically not mailed in advance. The float period commences when the checking account is funded which is the payable date and ends on the date that the checks are presented to the Bank for payment.

Determining the approximate amount of float earned by the Bank with respect to an account

With respect to contributions pending investment, the Bank may earn float until such time as any incoming wire is directed to the appropriate account. A client can virtually eliminate this type of float by carefully observing the requirements detailed in the wire notification policy that Asset Servicing provides to each client. If there is a question as to whether an anticipated wire was properly credited to the appropriate account, a client can access Asset Servicing’s on-line tools or contact its BNY representative to verify that all funds directed to its trust or custody accounts have been posted as expected. To estimate the amount of float earned by the Bank, the amount of the funds held in the deposit account is multiplied by the Interest on Reserve Balances Rate divided by 360. If 100,000 USD were held overnight in Asset Servicing’s omnibus checking account on January 31, 2022, the Bank’s float would be $100,000 x .001/360=$0.28

With respect to distributions made from Asset Servicing’s omnibus account relating to benefit payments, Asset Servicing’s experience indicates that the Bank earns relatively little float on the disbursement account balances. On average, 54 % of all checks are cashed within 1-7seven days of payment date. An additional 25% of checks issued are cashed within eight to fourteen days of the payment date. Clients should refer to the outstanding check report provided monthly to review the actual amounts outstanding to estimate the float earned by the Bank from the client’s disbursement activity. The float earned by the Bank on any date is equal to the amount of the outstanding checks times the Effective Federal Funds Effective Rate for the date divided by 360 days.

Finally, with respect to cash transferred pending settlement of securities transactions, the potential for generating float depends upon whether the transaction is eligible for contractual settlement and whether interest is paid in the local market. For transactions subject to contractual settlement, sale proceeds and purchase withdrawals are transferred to and from client accounts to or from a Bank suspense account during each day. The Bank earns interest on funds pending contractual purchases.

The collective funds are included in the account and transaction figures represented above. To the extent that any assets are invested in collective funds managed by The Bank of New York, the calculations and percentages set forth above, as adjusted for the applicable percentage interest in each collective fund, will serve as the best estimate overall of the potential float income that the Bank might receive from the assets invested in this manner.

Compensation Paid Among Related Parties and Subcontractors

If your service provider for trust and custody services is a direct or indirect subsidiary of The Bank of New York Mellon Corporation (such as BNY Mellon Trust of Delaware; BNY Mellon Trust Company of Illinois; BNY Mellon, National Association; or The Bank of New York Mellon Trust Company, National Association), such subsidiary has contracted with its affiliate The Bank of New York Mellon to perform some or all of its custodial duties and responsibilities, including safekeeping of assets, processing of corporate actions, trade settlement, posting of income and other receipts, reporting of transactions, reporting of prices and similar custodial functions. Such subsidiary pays a portion of the compensation that it receives from its clients to The Bank of New York Mellon for performance of these custodial duties and responsibilities.

In addition, some of the compensation charged by our subcustodians for custodian services in various markets is set on a transaction basis. This transaction-based compensation is not paid directly by our clients but rather a portion of the compensation which BNY receives pursuant to the Fee Schedule is shared with our subcustodians in the various markets to cover the transaction based services. A list of subcustodians is available on NEXEN or upon request.

Referral Fees Related to FRT Class Action Services

BNY provides referrals to its clients for certain securities class action and antitrust litigation services offered by Financial Recoveries Technologies, LLC (“FRT”). BNY will not act as a fiduciary with respect to this service, and FRT is solely responsible for the provision of any such services. BNY clients are not required to engage FRT and FRT may not be able to successfully recover any money for the benefit of a client’s plan or account. If you choose to engage FRT, the following information is applicable: Under BNY’s agreement with FRT, BNY (including any BNY affiliate acting as your custodian) may receive indirect compensation from FRT in the form of a referral fee. BNY’s referral fee generally ranges from 15% to 50% of the fee you pay to FRT (which is either the net fee retained by FRT after proceeds are credited to your plan or account under FRT’s “contingency” pricing model, or the subscription fee you pay to FRT).

Miscellaneous Notes

Please note that the definition of fee/compensation does not include revenue earned by BNY from foreign exchange transactions entered into by you or your investment manager. When the bank enters into a foreign exchange transaction with the plan, it is acting as a principal counterparty in the transaction and is either buying or selling currency for its own account. It is not providing a service to the plan.

The information provided in this web site is privileged and confidential information between the Bank and its clients. It is provided exclusively for client internal use only and may not be copied, duplicated or distributed in any fashion without the express written permission of the Bank.

BNY Institute

BNY Institute

BNY is the corporate brand of The Bank of New York Mellon Corporation and may refer to the corporation or its affiliated entities.

BNY Institute is part of BNY and produces thought leadership that is not investment research. This material is provided for informational purposes only and does not constitute investment advice, a recommendation, an offer, or a solicitation. It does not consider individual objectives, financial situations, or needs. This communication is not intended to forecast or predict future events. Views are those of the authors, may differ from other BNY teams, and may change without notice. Information may change and is not guaranteed. Past performance is not a guide to future results.

BNY and its affiliates deliver regulated activities, products, and services for which they are appropriately authorized and regulated, which may relate to themes or issuers referenced in this material, and availability may be subject to local regulation, eligibility requirements, and jurisdictional limitations.

Sustainability Report Disclosure

Forward-Looking Statements

We have included in this report statements that may constitute “forward-looking statements.” Forward-looking statements are not historical facts or statements of current conditions, but instead represent only our beliefs regarding future events, many of which, by their nature, are inherently uncertain and outside our control. These statements are not guarantees of future results or performance and involve certain known and unknown risks, uncertainties and assumptions that are difficult to predict and are often beyond our control. These statements relate to, among other things, our goals, targets, aspirations, strategy, plans, intentions and objectives, and actual outcomes and results may differ materially from those expressed in, or implied by, any of these forward-looking statements. Factors that could cause our outcomes and results to differ from the forward-looking statements include global socio-demographic and economic trends, energy prices, technological innovations, climate-related conditions and weather events, our ability to gather and verify data regarding environmental impacts, our ability to successfully implement various initiatives throughout the company under expected timeframes, the compliance of various third parties with our policies and procedures, legislative and regulatory changes, and other unforeseen events or conditions. In addition, important factors that generally affect our business and operations can be found under “Risk Factors” in Part I, Item 1A of our Annual Report on Form 10-K for the year ended December 31, 2021, and in subsequent reports filed with the Securities and Exchange Commission (SEC).

Certain disclosures included in this report are being provided in connection with our application of guidelines and recommendations of the Global Reporting Initiative, the UN Global Compact, the Task Force on Climate-related Financial Disclosures and others. Our approach to the disclosures included in this report differs from our approach to the disclosures we include in our mandatory regulatory reports, including our filings with the SEC. While certain matters discussed in this report may be significant, any significance should not be read as necessarily rising to the level of materiality used for the purposes of complying with the U.S. federal securities laws and regulations, even if we use the word “material” or “materiality” in this report. This report is intended to provide information from a different perspective and in more detail than that required to be included in other regulatory reports, including our filings with the SEC.

All forward-looking statements speak only as of the date on which such statements are made, and BNY undertakes no obligation to update any statement to reflect events or circumstances after the date on which such forward-looking statement is made or to reflect the occurrence of unanticipated events.

Legal Notices and Disclosures

This material may not be reproduced or disseminated in any form without the express prior written permission of BNY. BNY will not be responsible for updating any information contained within this material and opinions and information contained herein are subject to change without notice. Trademarks, service marks, logos and other intellectual property marks belong to their respective owners.

BNY is the corporate brand of The Bank of New York Mellon Corporation and may be used as a generic term to reference the corporation as a whole and/or its various group entities. This material and any products and services may be issued or provided under various brand names of BNY Mellon in various countries by duly authorized and regulated subsidiaries, affiliates, and joint ventures of BNY, which may include any of those listed below:

The Bank of New York Mellon operates in the U.K. through its London branch (U.K. companies house numbers FC005522 and BR025038) at 160 Queen Victoria Street, London, EC4V 4LA and is subject to regulation by the Financial Conduct Authority (“FCA”) at 12 Endeavour Square, London, E20 1JN, U.K. and limited regulation by the PRA at Bank of England, Threadneedle St, London, EC2R 8AH, U.K. Details about the extent of our regulation by the PRA are available from us on request.

The Bank of New York Mellon SA/NV, a Belgian limited liability company, registered in the RPM Brussels with company number 0806.743.159, whose registered office is at Boulevard Anspachlaan 1, B-1000 Brussels, Belgium, authorized and regulated as a significant credit institution by the European Central Bank (“ECB”) at Sonnemannstrasse 20, 60314 Frankfurt am Main, Germany, and the National Bank of Belgium (“NBB”) at Boulevard de Berlaimont/de Berlaimontlaan 14, 1000 Brussels, Belgium, under the Single Supervisory Mechanism and by the Belgian Financial Services and Markets Authority (FSMA) at Rue du Congrès/Congresstraat 12-14, 1000 Brussels, Belgium for conduct of business rules, and is a subsidiary of The Bank of New York Mellon.

The Bank of New York Mellon SA/NV operates in Ireland through its Dublin branch at Riverside II, Sir John Rogerson's Quay Grand Canal Dock, Dublin 2, D02KV60, Ireland and is registered with the Companies Registration Office in Ireland No. 907126 & with VAT No. IE 9578054E. The Bank of New York Mellon SA/NV, Dublin Branch is subject to limited additional regulation by the Central Bank of Ireland at New Wapping Street, North Wall Quay, Dublin 1, D01 F7X3, Ireland for conduct of business rules and registered with the Companies Registration Office in Ireland No. 907126 & with VAT No. IE 9578054E.

The Bank of New York Mellon SA/NV is trading in Germany through its Frankfurt branch “The Bank of New York Mellon SA/NV, Asset Servicing, Niederlassung Frankfurt am Main”, and has its registered office at MesseTurm, Friedrich-Ebert-Anlage 49, 60327 Frankfurt am Main, Germany. It is subject to limited additional supervision by the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, Marie-Curie-Str. 24-28, 60439 Frankfurt, Germany) under registration number 122721.

The Bank of New York Mellon SA/NV operates in the Netherlands through its Amsterdam branch at Claude Debussylaan 7, 1082 MC Amsterdam, the Netherlands. The Bank of New York Mellon SA/NV, Amsterdam Branch is subject to limited additional supervision by the Dutch Central Bank (“De Nederlandsche Bank” or “DNB”) on integrity issues only (registration number 34363596). DNB holds office at Frederiksplein 61, 1017 XL Amsterdam, the Netherlands.

The Bank of New York Mellon SA/NV operates in France through its Paris branch at 7 Rue Scribe, Paris, Paris 75009, France. The Bank of New York Mellon SA/NV, Paris Branch is subject to limitted additional regulation by Secrétariat Général de l’Autorité de Contrôle Prudentiel at Première Direction du Contrôle de Banques (DCB 1), Service 2, 61, Rue Taitbout, 75436 Paris Cedex 09, France (registration number (SIREN) Nr. 538 228 420 RCS Paris - CIB 13733).

The Bank of New York Mellon SA/NV operates in Italy through its Milan branch at Via Mike Bongiorno no. 13, Diamantino building, 5th floor, Milan, 20124, Italy. The Bank of New York Mellon SA/NV, Milan Branch is subject to limiteed additional regulation by Banca d’Italia - Sede di Milano at Divisione Supervisione Banche, Via Cordusio no. 5, 20123 Milano, Italy (registration number 03351).

The Bank of New York Mellon SA/NV operates in England through its London branch at 160 Queen Victoria Street, London EC4V 4LA, U.K., registered in England and Wales with numbers FC029379 and BR014361. The Bank of New York Mellon SA/NV, London branch is authorized by the ECB (address above) and subject to limited regulation by the FCA (address above) and the PRA (address above).

Regulatory information in relation to the above BNY entities operating out of Europe can be accessed at the following website: https://www.bny.com/corporate/emea/en/regulatory-information.html.

The Bank of New York Mellon, Singapore Branch, is subject to regulation by the Monetary Authority of Singapore. For recipients of this information located in Singapore: This material has not been reviewed by the Monetary Authority of Singapore. The Bank of New York Mellon, Hong Kong Branch (a branch of a banking corporation organized and existing under the laws of the State of New York with limited liability), is subject to regulation by the Hong Kong Monetary Authority and the Securities & Futures Commission of Hong Kong. The Bank of New York Mellon, Seoul Branch is subject to regulation by the Financial Services Commission, the Financial Supervisory Service and The Bank of Korea. BNY Mellon in Japan is subject to regulation by the Financial Services Agency of Japan.

For clients located in Australia

The Bank of New York Mellon is exempt from the requirement to hold, and does not hold, an Australian financial services license as issued by the Australian Securities and Investments Commission under the Corporations Act 2001 (Cth) in respect of the financial services provided by it to persons in Australia. The Bank of New York Mellon is regulated by the New York State Department of Financial Services and the U.S. Federal Reserve under Chapter 2 of the Consolidated Laws, The Banking Law enacted April 16, 1914 in the State of New York, which differs from Australian laws.

The Bank of New York Mellon has various other branches in the Asia-Pacific Region which are subject to regulation by the relevant local regulator in that jurisdiction.

The Bank of New York Mellon Securities Company Japan Ltd, as intermediary for The Bank of New York Mellon.

The Bank of New York Mellon, DIFC Branch, regulated by the Dubai Financial Services Authority (“DFSA”) and located at DIFC, The Exchange Building 5 North, Level 6, Room 601, P.O. Box 506723, Dubai, UAE, on behalf of The Bank of New York Mellon, which is a wholly-owned subsidiary of The Bank of New York Mellon Corporation.

Disclosures in relation to certain other BNY group entities can be accessed at the following website: https://www.bny.com/corporate/emea/en/disclaimers/eu-disclosures.html

BNY Investments is the brand name for the investment management business of BNY and its investment firm affiliates worldwide. Products and services may be provided under various brand names and in various countries by subsidiaries, affiliates and joint ventures of The Bank of New York Mellon Corporation where authorized and regulated as required within each jurisdiction.

The investment products and services mentioned in this material are not insured by the FDIC (or any other state or federal agency), are not deposits of or guaranteed by any bank, and may lose value.

Insight Investment International Limited, Newton Investment Management Limited and Walter Scott & Partners Limited are authorized and regulated by the Financial Conduct Authority.

BNY Mellon Investment Advisers, Inc., Insight Investment International Limited, Insight North America LLC, Mellon Investments Corporation, Newton Investment Management Limited, Newton Investment Management North America LLC and Walter Scott & Partners Limited are SEC registered investment advisers.

ARX is the brand used to describe the Brazilian investment capabilities of BNY Mellon ARX Investimentos Ltda.

Mellon Investments Corporation (MIC) is a registered investment adviser and subsidiary of The Bank of New York Mellon Corporation (BNY). MIC is composed of two divisions; BNY Investments Mellon (Mellon), which specializes in index management, and BNY Investments Dreyfus (Dreyfus), which specializes in cash management and short duration strategies. Securities are offered through BNY Mellon Securities Corporation (BNYSC), a registered broker-dealer and affiliate of MIC.

Insight Investment's investment advisory services in North America are provided through two different investment advisers registered with the SEC, using the brand Insight Investment: Insight North America LLC and Insight Investment International Limited. The North American investment advisers are associated with other global investment managers that also (individually and collectively) use the corporate brand Insight Investment and may be referred to as ‘Insight’ or ‘Insight Investment’.

BNY Investments Newton is the name for a group of affiliated companies that provide investment management services under the trading name of 'Newton' or 'Newton Investment Management'. Investment management services are provided in the United Kingdom by Newton Investment Management Ltd (NIM), in the United States by Newton Investment Management North America LLC (NIMNA), and in Japan by Newton Investment Management Japan Limited (NIMJ). All firms are indirect subsidiaries of The Bank of New York Mellon Corporation ("BNY").

All investments involve risk including loss of principal. Past performance is not a guide to future performance of any instrument, transaction, strategy, or financial structure. Certain investments involve greater or unique risks that should be considered along with the objectives, fees, and expenses before investing. Calls and communications with BNY may be recorded, for regulatory and other reasons.

This material is intended for wholesale/professional clients (or the equivalent), is not intended for use by retail clients and no other person should act upon it. Persons who do not have professional experience in matters relating to investments should not rely on this material. BNY will only provide the relevant investment services to investment professionals.

Not all products and services are offered in all countries.

If distributed in the U.K., this material is a financial promotion. If distributed in the EU, this material is a marketing communication.

Some information contained in this report has been obtained from third-party sources and has not been independently verified by BNY. Information contained in this report may not be comprehensive or up-to-date and is subject to change without notice. BNY will not be responsible for updating any information in this report and opinions and information contained herein are subject to change without notice. BNY assumes no direct or consequential liability for any errors in or reliance upon this material.

This material may not be distributed or used for the purpose of providing any referenced products, services, or any security or an endorsement thereof or making any offers or solicitations in any jurisdiction or in any circumstances in which such products, services, offers or solicitations are unlawful or not authorized, or where there would be, by virtue of such distribution, new or additional registration requirements.

Any references to dollars are to U.S. dollars unless specified otherwise.

This material may not be reproduced or disseminated in any form without the prior written permission of BNY.

Trademarks, service marks, logos and other intellectual property marks belong to their respective owners.

The Bank of New York Mellon, member of the Federal Deposit Insurance Corporation (“FDIC”).

Corporate Trust

General Disclaimer

BNY is the corporate brand of The Bank of New York Mellon Corporation and may be used to reference the corporation as a whole and/or its various subsidiaries generally. This material and any products and services may be issued or provided under various brand names in various countries by duly authorised and regulated subsidiaries, affiliates, and joint ventures of BNY, which may include any of the following entities mentioned herein. The Bank of New York Mellon Trust Company, N.A., a national banking association organized and existing pursuant to the laws of the United States (member FDIC), which is supervised and regulated by the Comptroller of the Currency. The Bank of New York Mellon, located at 240 Greenwich Street, New York, New York, is a banking corporation organised pursuant to the laws of the State of New York and operating in England through its branch at 160 Queen Victoria Street, London EC4V 4LA, U.K., and registered in England and Wales with numbers FC005522 and BR025038. The Bank of New York Mellon is supervised and regulated by the New York State Department of Financial Services and the U.S. Federal Reserve and authorised by the Prudential Regulation Authority.

The Bank of New York Mellon, London Branch is subject to regulation by the Financial Conduct Authority and limited regulation by the Prudential Regulation Authority. Details about the extent of our regulation by the Prudential Regulation Authority are available from us on request.

The Bank of New York Mellon SA/NV, a Belgian limited liability company, registered in the RPM Brussels with company number 0806.743.159, whose registered office is at Multi Tower, Boulevard Anspachlaan 1, B-1000 Brussels, Belgium, is authorised and regulated as a significant credit institution by the European Central Bank (ECB) and the National Bank of Belgium (NBB) under the Single Supervisory Mechanism and supervised by the Belgian Financial Services and Markets Authority (FSMA) for conduct of business rules, and a subsidiary of The Bank of New York Mellon.

The Bank of New York Mellon SA/NV, operates in Ireland through its branch at Riverside 2, Sir John Rogerson’s Quay, Grand Canal Dock, Dublin 2, D02 KV60, Ireland, trading as The Bank of New York Mellon SA/NV, Dublin Branch, which is authorized by the ECB, regulated by the Central Bank of Ireland for conduct of business rules and registered with the Companies Registration Office in Ireland No. 907126 & with VAT No. IE 9578054E.

The Bank of New York Mellon SA/NV operates in Italy through its Milan branch at Via Mike Bongiorno no. 13, Diamantino building, 5th floor, Milan, 20124, Italy, enrolled with the Companies Register of Milan under number 09827740961 and enrolled as a "filiale di banca estera" under number 3351.4 of the register of banks held by the Bank of Italy pursuant to article 13 of the Consolidated Banking Act.

The Bank of New York Mellon SA/NV operates in Luxembourg through its Luxembourg Branch, at 2-4 rue Eugene Ruppert, Vertigo Building – Polaris, L- 2453, Luxembourg. The Bank of New York SA/NV, Luxembourg Branch is subject to residual regulation by the Commission de Surveillance du Secteur Financier (“CSSF”) at 283, route d’Arlon, L-1150 Luxembourg for conduct of business rules, and in its role as UCITS/AIF depositary and central administration agent.

The Bank of New York Mellon SA/NV operates in Spain through its Madrid branch with registered office at Calle José Abascal 45, Planta 4ª, 28003, Madrid, and is enrolled on the Reg. Mercantil de Madrid, Tomo 41019, folio 185 (M-727448). The Bank of New York Mellon SA/NV, Sucursal en España is registered with Banco de España (registration number 1573).

If this material is distributed in or from, the Dubai International Financial Centre (DIFC), it is communicated by The Bank of New York Mellon, DIFC Branch (the “DIFC Branch”) on behalf of BNY (as defined above). The DIFC Branch is regulated by the Dubai Financial Services Authority and is located at DIFC, The Exchange Building 5, North, Level 6, Room 601, P.O. Box 506723, Dubai, U.A.E.

This material is intended for Professional Clients and Market Counterparties only and no other person should act upon it. Past performance is not a guide to future performance of any instrument, transaction or financial structure and a loss of original capital may occur. Calls and communications with BNY may be recorded, for regulatory and other reasons.

In Asia-Pacific, The Bank of New York Mellon, Singapore Branch is subject to regulation by the Monetary Authority of Singapore. The Bank of New York Mellon, Hong Kong Branch is subject to regulation by the Hong Kong Monetary Authority and the Securities & Futures Commission of Hong Kong. The Bank of New York Mellon is regulated by the Australian Prudential Regulation Authority and also holds an Australian Financial Services Licence No. 527917 issued by the Australian Securities and Investments Commission to provide financial services to wholesale clients in Australia. This document is issued or distributed in Australia by The Bank of New York Mellon, on behalf of BNY Mellon Australia Pty Ltd (ACN 113 947 309) located at Level 2, 1 Bligh Street, Sydney NSW 2000, and relates to products and services of BNY Mellon Australia Pty Ltd or one of its subsidiaries. BNY Mellon Australia Pty Ltd is ultimately wholly-owned by The Bank of New York Mellon Corporation. The Bank of New York Mellon does not provide this product or service. None of BNY Mellon Australia Pty Ltd or its subsidiaries is an authorized deposit-taking institution and the obligations of BNY Mellon Australia Pty Ltd or its subsidiaries do not represent investments, deposits or other liabilities of The Bank of New York Mellon. Neither The Bank of New York Mellon nor any of its related entities stands behind or guarantees obligations of BNY Mellon Australia Pty Ltd.

The content contained in this material which may be considered advertising, is for general information and reference purposes only and is not intended to provide legal, tax, accounting, investment, financial or other professional advice on any matter, and is not to be used as such; you should obtain your own independent professional advice (including financial, tax and legal advice). The views expressed within this material are those of the contributors only and not those of The Bank of New York Mellon Corporation or any of its affiliates or subsidiaries, and no representation is made as to the accuracy, completeness, timeliness, merchantability or fitness for a specific purpose of the information provided in this material. No statement or expression is an offer or solicitation to buy or sell any products or services mentioned. Past performance is not indicative, nor a guarantee, of future results. The contents may not be comprehensive or up-to-date, and BNY will not be responsible for updating any information contained within this material. This material and the statements contained herein, are not an offer or solicitation to buy or sell any products (including financial products) or services or to participate in any particular strategy mentioned and should not be construed as such. This material is not intended for distribution to, or use by, any person or entity in any jurisdiction or country in which such distribution or use would be contrary to local law or regulation. Similarly, this material may not be distributed or used for the purpose of offers or solicitations in any jurisdiction or in any circumstances in which such offers or solicitations are unlawful or not authorized, or where there would be, by virtue of such distribution, new or additional registration requirements. Persons into whose possession this material comes are required to inform themselves about, and to observe any restrictions that apply to, the distribution of this document in their jurisdiction.

Some information contained in herein has been obtained from third party sources and has not been independently verified. BNY recommends that professional consultation should be obtained before using any service offered by BNY.

BNY assumes no liability whatsoever for any action taken in reliance on the information contained in this material, or for direct or indirect damages or losses resulting from use of this material, its content, or services. Any unauthorized use of material contained herein is at the user’s own risk. Reproduction, distribution, republication and retransmission of material contained herein is prohibited without the prior consent of BNY.

Trademarks and logos belong to their respective owners.

Defined Contribution

Defined Contribution Disclosure

This information is general in nature and is not intended to constitute tax or estate planning advice. Please consult your tax or estate planning advisor for more detailed information on these issues and advice on your specific situation.

BNY Investments is the brand name for the investment management business of The Bank of New York Mellon Corporation (BNY) and its investment firm affiliates worldwide. BNY is the corporate brand of The Bank of New York Mellon Corporation and may also be used as a generic term to reference the corporation as a whole or its various subsidiaries generally.

Depositary Receipts

BNY is the corporate brand of The Bank of New York Mellon Corporation (NYSE:BK) and may be used to reference the corporation as a whole and/or its various subsidiaries generally. The information and data provided herein are provided for general informational purposes only. BNY does not warrant or guarantee the accuracy, timeliness or completeness of any such information or data. BNY does not undertake any obligation to update or amend any information or data, and may change, update or amend any information or data at any time without prior notice.

BNY provides no advice, recommendation or endorsement with respect to any company or securities. No information or data is intended to provide legal, tax, accounting, investment, financial, trading or other advice on any matter, and is not to be used as such. This material has been prepared without taking into account your objectives, financial situation or needs and you should obtain independent professional financial advice that considers your circumstances before making any financial or investment decisions. We expressly disclaim any liability whatsoever for any loss howsoever arising from or in reliance upon any information or data, including market value loss on the sale or purchase of securities or other instruments or obligations. BNY assumes no direct or consequential liability for any errors in or reliance upon this material.

Nothing herein shall be deemed to constitute an offer to sell or a solicitation of an offer to buy securities.

BNY collects fees from DR holders pursuant to the terms and conditions of the DRs and any deposit agreement under which they are issued. From time to time, BNY may make payments to an issuer to reimburse and/or share revenue from the fees collected from DR holders, or waive fees and expenses to an issuer for services provided, generally related to costs and expenses arising out of the establishment and maintenance of the applicable DR program. BNY may pay a rebate to brokers in connection with unsponsored DR issuances; brokers may or may not disclose or pass back some or all of such rebate to the DR investor. BNY may also use brokers, dealers or other service providers that are affiliates and that may earn or share fees and commissions.

BNY may execute DR foreign currency transactions itself or through its affiliates, or the Custodian or the underlying issuer of securities underlying DRs may execute foreign currency transactions and pay U.S. dollars to BNY. In those instances where it executes DR foreign currency transactions itself or through its affiliates, BNY acts as principal counterparty and not as agent, advisor, broker or fiduciary. In such cases, BNY has no obligation to obtain the most favorable exchange rate, makes no representation that the rate is a favorable rate and will not be liable for any direct or indirect losses associated with the rate. BNY earns and retains revenue on its executed foreign currency transactions based on, among other things, the difference between the rate it assigns to the transaction and the rate that it pays and receives for purchases and sales of currencies when buying or selling foreign currency for its own account. The methodology used by BNY to determine DR conversion rates is available to registered Owners upon request or can be accessed here. In those instances where BNY's Custodian executes DR foreign currency transactions, the Custodian has no obligation to obtain the most favorable exchange rate or that the method by which the rate will be determined will be the most favorable rate, and BNY makes no representation that the rate is a favorable rate and will not be liable for any direct or indirect losses associated with the rate. In certain instances, BNY may receive dividends and other distributions from an issuer of securities underlying DRs in U.S. dollars rather than in a foreign currency. In such cases, BNY will not engage in or be responsible for any foreign currency transactions and it makes no representation that the rate obtained by an issuer is a favorable rate and it will not be liable for any direct or indirect losses associated with the rate.

BNY is a global investments company dedicated to helping its clients manage and service their financial assets throughout the investment lifecycle. Additional information is available on www.bny.com.

BNY's name, brand and/or trademarks may not be used, copied or reproduced without the prior express written consent of BNY.

DEPOSITARY RECEIPTS ARE NOT INSURED BY THE FDIC OR ANY OTHER GOVERNMENT AGENCY, ARE NOT DEPOSITS OR OTHER OBLIGATIONS OF, AND ARE NOT GUARANTEED BY, BNY AND ARE SUBJECT TO INVESTMENT RISKS INCLUDING POSSIBLE LOSS OF PRINCIPAL AMOUNT INVESTED.

This material, which may be considered advertising, is for general information and reference purposes only and is not intended to provide legal, tax, accounting, investment, financial or other professional advice on any matter, and is not to be used as such. BNY does not warrant or guarantee the accuracy or completeness of, nor undertake to update or amend the information or data contained herein. We expressly disclaim any liability whatsoever for any loss howsoever arising from or in reliance upon any of this information or data. We provide no advice nor recommendation or endorsement with respect to any company or securities. Nothing herein shall be deemed to constitute an offer to sell or a solicitation of an offer to buy securities. If distributed in the U.K. or EMEA, this material may be a financial promotion and is for distribution only to persons to whom it may be communicated without breach of applicable law.

This material is not intended for distribution to, or use by, any person or entity in any jurisdiction in which such distribution or use would be contrary to local law or regulation. Similarly, this material may not be distributed or used for the purpose of offers or solicitations in any jurisdiction or in any circumstances in which such offers or solicitations are unlawful or not authorized, or where there would be, by virtue of such distribution, new or additional registration requirements. Persons into whose possession this material comes are required to inform themselves about and to observe any restrictions that apply to the distribution of this material in their jurisdiction. The information contained in this material is for use by wholesale clients only and is not to be relied upon by retail clients. BNY, including The Bank of New York Mellon, has various subsidiaries, affiliates, branches and representative offices in the Asia Pacific Region that are subject to regulation by the relevant local regulator in that jurisdiction.

This material does not constitute an offer to sell or the solicitation of an offer to buy any products or services in the People’s Republic of China (PRC) to any person to whom it is unlawful to make the offer or solicitation in the PRC. BNY does not represent that this material may be lawfully distributed, or that any products may be lawfully offered, in compliance with any applicable registration or other requirements in the PRC, or pursuant to an exemption available thereunder, or assume any responsibility for facilitating any such distribution or offering. In particular, no action has been taken by the issuer which would permit a public offering of any products or distribution of this material in the PRC. Accordingly, the products are not being offered or sold within the PRC by means of this material or any other material. Neither this material nor any advertisement or other offering material may be distributed or published in the PRC, except under circumstances that will result in compliance with any applicable laws and regulations. Products may be offered or sold to PRC investors outside the territory of the PRC provided that such PRC investors are authorized to buy and sell the products in the offshore market. Potential PRC investors are responsible for obtaining all relevant approvals from the PRC government authorities, including but not limited to the State Administration of Foreign Exchange, and compliance with all applicable laws and regulations, including but not limited to those of the PRC, before purchasing the products.

BNY is not a licensed bank or branch operating in Turkey under the applicable banking and capital market regulations. Therefore, it does not provide any banking or capital market activities or any other regulated services in Turkey.

This material is intended only for issuers and not any type of investor in Israel; it may not be reproduced or used for any other purpose, nor be furnished to any person other than to whom it was sent; and in any case, any offer or placement of DRs issued by BNY shall not be made to the public in Israel.

BNY is not registered or licensed in Ukraine, does not provide financial services in Ukraine and has not made and will not make any offer of its products to the public by way of a public offer of securities in Ukraine, and it is not engaged in the placement and/or circulation (such as selling, underwriting or trading) of securities within the territory of Ukraine.

This material has not been and will not be lodged or registered with the Central Bank of Azerbaijan of the Republic of Azerbaijan (“CBA”). The contents herein is not intended to create, maintain or increase interest in, nor does it aim to promote or facilitate the sale of foreign securities or derivatives therefrom or licensable services in the Republic of Azerbaijan.

Depositary Receipts:

NOT FDIC, STATE OR FEDERAL AGENCY INSURED

MAY LOSE VALUE

NO BANK, STATE OR FEDERAL AGENCY GUARANTEE

Global Payments & Trade

bny.com

BNY is the corporate brand of The Bank of New York Mellon Corporation and may also be used as a generic term to reference the corporation as a whole or its various subsidiaries generally and may include The Bank of New York Mellon, a banking corporation organized and existing pursuant to the laws of the State of New York.

This material and any products and services may be issued or provided under various brand names in various countries by duly authorised and regulated branches, subsidiaries, affiliates, and joint ventures of BNY, which may include any of the following: The Bank of New York Mellon, operating in the United States at 240 Greenwich Street, New York, NY 10286 and operating in the UK and EU through its branches The Bank of New York Mellon -London Branch at 160 Queen Victoria Street, London EC4V 4LA, England,  registered in England and Wales with numbers FC005522 and BR025038. The Bank of New York Mellon Frankfurt Branch at Friedrich-Ebert-Anlage 49, 60327 Frankfurt am Main Germany, registered in Germany with Registration No. HRB 12731.

The Bank of New York Mellon is supervised and regulated by the New York State Department of Financial Services and the US Federal Reserve and authorised by the Prudential Regulation Authority. The Bank of New York Mellon, London Branch is subject to regulation by the Financial Conduct Authority and the Prudential Regulation Authority. The Bank of New York Mellon Frankfurt Branch is bank under the German Banking Act and subject to regulation by BaFin. BNY has various subsidiaries, affiliates, branches and representative offices in the Asia Pacific Region which are subject to regulation by the relevant local regulator in that jurisdiction. The Bank of New York Mellon, Singapore Branch, subject to regulation by the Monetary Authority of Singapore. The Bank of New York Mellon, Hong Kong Branch, subject to regulation by the Hong Kong Monetary Authority and the Securities & Futures Commission of Hong Kong. If this material is distributed in Japan, it is distributed by The Bank of New York Mellon Securities Company Japan Ltd, as intermediary for The Bank of New York Mellon. If this material is distributed in, or from, the Dubai International Financial Centre (“DIFC”), it is communicated by The Bank of New York Mellon, DIFC Branch, regulated by the DFSA and located at DIFC, The Exchange Building 5 North, Level 6, Room 601, P.O. Box 506723, Dubai, UAE, on behalf of The Bank of New York Mellon, which is a wholly-owned subsidiary of The Bank of New York Mellon Corporation. The Bank of New York Mellon is regulated by the Australian Prudential Regulation Authority and also holds an Australian Financial Services Licence No. 527917 issued by the Australian Securities and Investments Commission to provide financial services to wholesale clients in Australia.

BNY has various subsidiaries, affiliates, branches and representative offices in the Latin America Region which are subject to specific regulation by the relevant local regulator in each jurisdiction. This material does not constitute an offer to sell or the solicitation of an offer to buy any products or services in the People’s Republic of China (PRC) to any person to whom it is unlawful to make the offer or solicitation in the PRC. BNY does not represent that this material may be lawfully distributed, or that any products may be lawfully offered, in compliance with any applicable registration or other requirements in the PRC, or pursuant to an exemption available thereunder, or assume any responsibility for facilitating any such distribution or offering. In particular, no action has been taken by the issuer which would permit a public offering of any products or distribution of this material in the PRC. Accordingly, the products are not being offered or sold within the PRC by means of this material or any other document. Neither this material nor any advertisement or other offering material may be distributed or published in the PRC, except under circumstances that will result in compliance with any applicable laws and regulations. Products may be offered or sold to PRC investors outside the territory of the PRC provided that such PRC investors are authorized to buy and sell the products in the offshore market. Potential PRC investors are responsible for obtaining all relevant approvals from the PRC government authorities, including but not limited to the State Administration of Foreign Exchange, and compliance with all applicable laws and regulations, including but not limited to those of the PRC, before purchasing the products.

The information contained in this material is for use by wholesale clients only and is not to be relied upon by retail clients. Not all products and services are offered at all locations. This material, which may be considered advertising, is for general information and reference purposes only and is not intended to provide legal, tax, accounting, investment, financial or other professional advice on any matter, and is not to be used as such. BNY does not warrant or guarantee the accuracy or completeness of, nor undertake to update or amend the information or data contained herein. BNY expressly disclaims any liability for any loss arising from or in reliance upon any of this information or data.

Trademarks and logos belong to their respective owners.

Individual Retirement

Individual Retirement Disclosure

Investors should consider the investment objectives, risks, charges and expenses of any mutual fund carefully before investing. Contact your financial professional or visit https://www.bny.com/investments.html to obtain a prospectus or a summary prospectus, if available, that contains this and other information on a fund. Read it carefully before investing.

Asset allocation and diversification do not guarantee a profit or protect against a loss.

This information is general in nature and is not intended to constitute tax or estate planning advice. Please consult your legal or tax advisor for more detailed information on legal or tax issues and advice on your specific situation. There are fees, expenses, taxes and penalties associated with IRAs.

All investment products involve risk of principal loss.

BNY Investments personnel act as licensed representatives of BNY Mellon Securities Corporation (a registered broker-dealer) to offer securities. This material is not intended as an offer to sell or a solicitation of an offer to buy any security, and it is not provided as a sales or advertising communication and does not constitute investment advice. BNY Mellon Securities Corporation, a registered broker-dealer, FINRA member and subsidiary of The Bank of New York Mellon Corporation, has entered into agreements to offer securities in the U.S. on behalf of certain BNY Investments firms.

BNY Investments

Investment Management

This material should not be considered as investment advice or a recommendation of any investment manager or account arrangement, and should not serve as a primary basis for investment decisions. Any statements and opinions expressed are those of the author as at the date of publication, are subject to change as economic and market conditions dictate, and do not necessarily represent the views of BNY or any of its affiliates. The information has been provided as a general market commentary only and does not constitute legal, tax, accounting, other professional counsel or investment advice, is not predictive of future performance, and should not be construed as an offer to sell or a solicitation to buy any security or make an offer where otherwise unlawful. The information has been provided without taking into account the investment objective, financial situation or needs of any particular person. BNY and its affiliates are not responsible for any subsequent investment advice given based on the information supplied. This is not investment research or a research recommendation for regulatory purposes as it does not constitute substantive research or analysis. This information may contain projections or other forward-looking statements regarding future events, targets or expectations, and is only current as of the date indicated. There is no assurance that such events or expectations will be achieved, and actual results may be significantly different from that shown here. The information is based on current market conditions, which will fluctuate and may be superseded by subsequent market events or for other reasons. References to specific securities, asset classes and financial markets are for illustrative purposes only and are not intended to be and should not be interpreted as recommendations. Past performance is no guarantee of future results. Information and opinions presented have been obtained or derived from sources which BNY believed to be reliable, but BNY makes no representation to its accuracy and completeness. BNY accepts no liability for loss arising from use of this material.

All investments involve risk including loss of principal.

Not for distribution to, or use by, any person or entity in any jurisdiction or country in which such distribution or use would be contrary to local law or regulation. This information may not be distributed or used for the purpose of offers or solicitations in any jurisdiction or in any circumstances in which such offers or solicitations are unlawful or not authorized, or where there would be, by virtue of such distribution, new or additional registration requirements. Persons into whose possession this information comes are required to inform themselves about and to observe any restrictions that apply to the distribution of this information in their jurisdiction.

Issuing entities

This material is only for distribution in those countries and to those recipients listed, subject to the noted conditions and limitations: • United States: by BNY Mellon Securities Corporation (BNYSC), 240 Greenwich Street, New York, NY 10286. BNYSC, a registered broker-dealer and FINRA member, and subsidiary of BNY, has entered into agreements to offer securities in the U.S. on behalf of certain BNY Mellon Investment Management firms. • Europe (excluding Switzerland): BNY Mellon Fund Management (Luxembourg) S.A., 2-4 Rue EugèneRuppertL-2453 Luxembourg. • U.K., Africa and Latin America (ex-Brazil): BNY Mellon Investment Management EMEA Limited, BNY Mellon Centre, 160 Queen Victoria Street, London EC4V 4LA. Registered in England No. 1118580. Authorised and regulated by the Financial Conduct Authority. • South Africa: BNY Mellon Investment Management EMEA Limited is an authorised financial services provider. • Switzerland: BNY Mellon Investments Switzerland GmbH, Bärengasse 29, CH-8001 Zürich, Switzerland. • Middle East: DIFC branch of The Bank of New York Mellon. Regulated by the Dubai Financial Services Authority. • Singapore: BNY Mellon Investment Management Singapore Pte. Limited Co. Reg. 201230427E. Regulated by the Monetary Authority of Singapore. • Hong Kong: BNY Mellon Investment Management Hong Kong Limited. Regulated by the Hong Kong Securities and Futures Commission. • Japan: BNY Mellon Investment Management Japan Limited. BNY Mellon Investment Management Japan Limited is a Financial Instruments Business Operator with license no 406 (Kinsho) at the Commissioner of Kanto Local Finance Bureau and is a Member of the Investment Trusts Association, Japan and Japan Investment Advisers Association and Type II Financial Instruments Firms Association. • Brazil: ARX Investimentos Ltda., Av. Borges de Medeiros, 633, 4th floor, Rio de Janeiro, RJ, Brazil, CEP 22430-041. Authorized and regulated by the Brazilian Securities and Exchange Commission (CVM). • Canada: BNY Mellon Asset Management Canada Ltd. is registered in all provinces and territories of Canada as a Portfolio Manager and Exempt Market Dealer, and as a Commodity Trading Manager in Ontario.

BNY Company Information

BNY Investments is the brand name for the investment management business of The Bank of New York Mellon Corporation (BNY) and its investment firm affiliates worldwide. BNY is the corporate brand of The Bank of New York Mellon Corporation and may also be used as a generic term to reference the corporation as a whole or its various subsidiaries generally. • Mellon Investments Corporation (MIC) is a registered investment advisor and subsidiary of The Bank of New York Mellon Corporation. MIC is composed of two divisions: BNY Investments Mellon, which specializes in index management, and BNY Investments Dreyfus, which specializes in cash management and short duration strategies. • Insight Investment - Investment advisory services in North America are provided through two different investment advisers registered with the Securities and Exchange Commission (SEC) using the brand Insight Investment: Insight North America LLC (INA) and Insight Investment International Limited (IIIL). The North American investment advisers are associated with other global investment managers that also (individually and collectively) use the corporate brand Insight. Insight is a subsidiary of BNY. • BNY Investments Newton is the name for a group of affiliated companies that provide investment management services under the trading name of 'Newton' or 'Newton Investment Management'. Investment management services are provided in the United Kingdom by Newton Investment Management Ltd (NIM), in the United States by Newton Investment Management North America LLC (NIMNA), and in Japan by Newton Investment Management Japan Limited (NIMJ). All firms are indirect subsidiaries of The Bank of New York Mellon Corporation ("BNY"). • ARX is the brand used to describe the Brazilian investment capabilities of BNY Mellon ARX Investimentos Ltda. ARX is a subsidiary of BNY. • Walter Scott & Partners Limited (Walter Scott) is an investment management firm authorized and regulated by the Financial Conduct Authority, and a subsidiary of BNY. • BNY Mellon Advisors, Inc. is an investment adviser registered as such with the U.S. Securities and Exchange Commission (“SEC”) pursuant to the Investment Advisers Act of 1940, as amended. All BNY Investments’ firms are indirect subsidiaries of the Bank of New York Mellon Corporation.

No part of this material may be reproduced in any form, or referred to in any other publication, without express written permission. All information contained herein is proprietary and is protected under copyright law.

NOT FDIC INSURED | NO BANK GUARANTEE | MAY LOSE VALUE |

BNY Markets

BNY & Pershing Disclaimers and Disclosures

Global Disclaimer

The Bank of New York Mellon also operates in the U.K. through its London branch (Companies House number FC005522 and U.K. establishment number BR025038) with registered office at 160 Queen Victoria Street, London, EC4V 4LA, U.K., and is subject to regulation by the Financial Conduct Authority (“FCA”) and limited regulation by the PRA. Details about the extent of our regulation by the PRA are available from us on request.

The Bank of New York Mellon operates in Germany through its Frankfurt branch The Bank of New York Mellon Filiale Frankfurt am Main and has its registered office at Friedrich-Ebert-Anlage 49, 60327 Frankfurt am Main, Germany (Zweigniederlassung registered in Germany with Registration No. HRB 12731). It is under the supervision of the German Central Bank and the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, (“BaFin”), Marie-Curie-Str. 24-28, 60439 Frankfurt, Germany) under BaFin-ID 10100253.

The Bank of New York Mellon SA/NV, a Belgian public limited liability company, organized and existing under the laws of Belgium, registered with the Crossroad Bank for Enterprises under number 0806.743.159, whose registered office is at Boulevard Anspachlaan 1, B-1000 Brussels, Belgium, authorized and regulated as a significant credit institution by the European Central Bank (“ECB”) under the prudential supervision of the National Bank of Belgium (“NBB”) and under the supervision of the Belgian Financial Services and Markets Authority (“FSMA”) for conduct of business rules, is a subsidiary of The Bank of New York Mellon.

The Bank of New York Mellon SA/NV operates in Ireland through its Dublin branch at The Shipping Office, 20-26 Sir John Rogerson’s Quay, Dublin 2, D02Y049, Ireland and is registered with the Companies Registration Office in Ireland No. 907126 & with VAT No. IE 9578054E. The Bank of New York Mellon SA/NV, Dublin Branch is subject to additional regulation by the Central Bank of Ireland for Depository Services and for conduct of business rules.

The Bank of New York Mellon SA/NV operates in Germany through its Frankfurt branch The Bank of New York Mellon SA/NV, Asset Servicing, Niederlassung Frankfurt am Main, and has its registered office at MesseTurm, Friedrich-Ebert-Anlage 49, 60327 Frankfurt am Main, Germany (Zweigniederlassung registered in Germany with registration No. HRB 87912). It is subject to limited additional supervision by the Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht (“BaFin”), Marie-Curie-Str. 24-28, 60439 Frankfurt, Germany) under BaFin ID 10122721.

The Bank of New York Mellon SA/NV operates in the Netherlands through its Amsterdam branch at Tribes SOM2 Building, Claude Debussylaan 7, 1082 MC Amsterdam, the Netherlands, registered with the Dutch Chamber of Commerce under registration number 34363596. The Bank of New York Mellon SA/NV, Amsterdam Branch is subject to limited additional supervision by the Dutch Central Bank (“De Nederlandsche Bank” or “DNB”) on integrity issues only. DNB holds office at Frederiksplein 61, 1017 XL Amsterdam, the Netherlands.

The Bank of New York Mellon SA/NV operates in Luxembourg through its Luxembourg branch at 2-4 rue Eugene Ruppert, Vertigo Building – Polaris, L- 2453, Luxembourg. The Bank of New York Mellon SA/NV, Luxembourg Branch (registered with the Luxembourg Registre de Commerce et des Sociétés under number B105087) is subject to limited additional regulation by the Commission de Surveillance du Secteur Financier at 283, route d’Arlon, L-1150 Luxembourg for conduct of business rules, and in its role as depositary and administration agent for undertakings for collective investments (UCIs).

The Bank of New York Mellon SA/NV operates in Denmark as The Bank of New York Mellon SA/NV, Copenhagen Branch, filial af The Bank of New York Mellon SA/NV, Belgien, CVR no. 41820063, and has its registered office at Strandvejen 125 DK-2900 Hellerup, Denmark. It is subject to limited additional regulation by the Danish Financial Supervisory Authority (Finanstilsynet,Strandgade 29, DK-1401 Copenhagen K, Denmark).

The Bank of New York Mellon (International) Limited is registered in England & Wales with Company No. 03236121 with its Registered Office at 160 Queen Victoria Street, London EC4V 4LA. The Bank of New York Mellon (International) Limited is authorized by the PRA and regulated by the FCA and the PRA.

BNY Mellon Fund Services (Ireland) Designated Activity Company is registered with Company No 218007, having its registered office at The Shipping Office, 20-26 Sir John Rogerson’s Quay, Dublin 2, D02Y049, Ireland. It is regulated by the Central Bank of Ireland.

Regulatory information in relation to the above BNY entities operating out of Europe can be accessed at the following website: https://www.bny.com/RID.

For clients located in Switzerland

To the extent no financial instruments or financial services are being provided under the Swiss Financial Services Act ("FinSA") the information provided herein does not constitute an offer of financial instrument or an offer to provide financial service in Switzerland pursuant to or within the meaning of the FinSA and its implementing ordinance.

In respect of (i) non-financial instruments/services and/or OTC derivatives and (ii) financial instruments/services within the meaning of FinSA (other than OTC derivatives): This is solely an advertisement pursuant to or within the meaning of FinSA and its implementing ordinance. This contains an advertisement pursuant to or within the meaning of FinSA and its implementing ordinance.In respect of OTC derivatives, including FX: Please be informed that The Bank of New York Mellon and The Bank of New York Mellon SA/NV enter into OTC derivative transactions as a counterparty, i.e. acting for their own account or for the account of one of their affiliates. As a result, where you enter into any OTC derivative transactions (including (i) OTC derivatives and (ii) financial instruments/services within the meaning of FinSA (other than OTC derivatives)) with us, you will not be considered a "client" (within the meaning of the FinSA) and you will not benefit from the protections otherwise afforded to clients under FinSA. Accordingly, this should not be considered an advertisement with respect to such transactions pursuant to or within the meaning of FinSA and its implementing ordinance.

The Bank of New York Mellon, Singapore Branch, is subject to regulation by the Monetary Authority of Singapore. The Bank of New York Mellon, Hong Kong Branch (a branch of a banking corporation organized and existing under the laws of the State of New York with limited liability), is subject to regulation by the Hong Kong Monetary Authority and the Securities & Futures Commission of Hong Kong.

For recipients of this information located in Singapore: This material has not been reviewed by the Monetary Authority of Singapore.

The Bank of New York Mellon, Shanghai Branch (Financial Licence No. B0078B231000001) and the Bank of New York Mellon, Beijing Branch (Financial Licence No. B0078B211000001) are licensed foreign bank branches registered in the People’s Republic of China and are supervised and regulated by the National Financial Regulatory Administration.

Where a document is issued or distributed in Australia by The Bank of New York Mellon on behalf of BNY Mellon Australia Pty Ltd (ACN 113 947 309) located at Level 2, 1 Bligh Street, Sydney NSW 2000, and relates to products and services of BNY Mellon Australia Pty Ltd or one of its subsidiaries, note that The Bank of New York Mellon does not provide these products or services. None of BNY Mellon Australia Pty Ltd or its subsidiaries is an authorized deposit-taking institution and the obligations of BNY Mellon Australia Pty Ltd or its subsidiaries do not represent investments, deposits or other liabilities of The Bank of New York Mellon. Neither The Bank of New York Mellon nor any of its related entities stands behind or guarantees obligations of BNY Mellon Australia Pty Ltd.

The Bank of New York Mellon, Tokyo Branch, is a licensed foreign bank branch in Japan and regulated by the Financial Services Agency of Japan. The Bank of New York Mellon Trust (Japan), Ltd., is a licensed trust bank in Japan and regulated by the Financial Services Agency of Japan. The Bank of New York Mellon Securities Company Japan Ltd. is a registered type 1 financial instruments business operator in Japan and regulated by the Financial Services Agency of Japan.

The Bank of New York Mellon, DIFC Branch, regulated by the Dubai Financial Services Authority (“DFSA”) and located at DIFC, The Exchange Building 5 North, Level 6, Room 601, P.O. Box 506723, Dubai, UAE, on behalf of The Bank of New York Mellon, which is a wholly-owned subsidiary of The Bank of New York Mellon Corporation.

The Bank of New York Mellon, Abu Dhabi Global Market Branch, regulated by the Abu Dhabi Global Market Financial Services Regulatory Authority (financial services permission number 190021) located at Level 4, Al Maryah Tower, Al Maryah Island, Abu Dhabi on behalf of The Bank of New York Mellon, which is a wholly owned subsidiary of The Bank of New York Mellon Corporation.

The Bank of New York Mellon has various subsidiaries and representative offices in the Latin America Region which are subject to specific regulation by the relevant local regulator in each jurisdiction.

BNY Pershing is the umbrella name for Pershing LLC (member FINRA, SIPC and NYSE), Pershing Advisor Solutions (member FINRA and SIPC), Pershing Holdings (U.K.) Limited, Pershing Limited (U.K.), Pershing Securities Limited (U.K.), Pershing Securities International Limited (Ireland), Pershing (Channel Islands) Limited, Pershing Securities Singapore Private Limited, and Pershing India Operational Services Pvt Ltd. BNY Pershing businesses also include Pershing X, Inc. a technology provider. Pershing LLC is a member of SIPC, which protects securities customers of its members up to $500,000 (including $250,000 for claims for cash). Explanatory brochure available upon request or at sipc.org. SIPC does not protect against loss due to market fluctuation. SIPC protection is not the same as, and should not be confused with, FDIC insurance.

Pershing Securities Limited, a subsidiary of BNY. Registered Office: The Royal Liver Building, Pier Head, Liverpool, L3 1LL. Authorised and regulated by the Financial Conduct Authority, No. 146576. Member of the London Stock Exchange. Registered in England under No. 2474912.

Pershing Securities International Limited, a subsidiary of BNY. Registered Office: The Shipping Office, 20-26 Sir John Rogerson’s Quay, Dublin 2, D02Y049, Ireland. Registered in Ireland under No. 367098. Regulated by The Central Bank of Ireland.

Disclosures in relation to certain other BNY group entities can be accessed at the following website: https://www.bny.com/corporate/emea/en/disclaimers/eu-disclosures.html.

Not all products and services are offered in all countries.

If distributed in the U.K., this material is a financial promotion. If distributed in the EU, this material is a marketing communication.

This material, which may be considered advertising (but shall not be considered advertising under the laws and regulations of Singapore), is for general information purposes only and is not intended to provide legal, tax, accounting, investment, financial or other professional counsel or advice on any matter. This material does not constitute a recommendation or advice by BNY of any kind. Use of our products and services is subject to various regulations and regulatory oversight. You should discuss this material with appropriate advisors in the context of your circumstances before acting in any manner on this material or agreeing to use any of the referenced products or services and make your own independent assessment (based on such advice) as to whether the referenced products or services are appropriate or suitable for you.

This material may not be comprehensive or up to date and there is no undertaking as to the accuracy, timeliness, completeness or fitness for a particular purpose of information given. BNY will not be responsible for updating any information contained within this material and opinions and information contained herein are subject to change without notice. BNY assumes no direct or consequential liability for any errors in or reliance upon this material.

Any references to dollars are to U.S. dollars unless specified otherwise.

This material may not be reproduced or disseminated in any form without the prior written permission of BNY. Trademarks, logos and other intellectual property marks belong to their respective owners.

The Bank of New York Mellon, member of the Federal Deposit Insurance Corporation (“FDIC”). Please note that many products and affiliates of The Bank of New York Mellon are NOT covered by FDIC insurance.

BNY Markets

Capital Markets LLC Disclaimers and Disclosures

BNY Mellon Capital Markets, LLC

BNY Mellon Capital Markets, LLC (“Capital Markets LLC”) is a full service registered broker-dealer and an indirect wholly owned non-bank subsidiary of The Bank of New York Mellon Corporation (“BNY”). BNY and its affiliates lend and provide other products and services to issuers and others, and provide and receive related fees and compensation. Capital Markets LLC is a member of FINRA and SIPC, which protects securities customers of its members up to $500,000 (including $250,000 for claims for cash). Explanatory brochure available upon request or at www.sipc.org. SIPC does not protect against loss due to market fluctuation. SIPC protection is not the same as, and should not be confused with, FDIC insurance.

This material is for reference purposes only and not intended to be a recommendation with respect to, or solicitation or offer to buy or sell, any particular financial instrument, including but not limited to BNY stock, or to participate in any particular trading strategy and is not tax, legal, investment or accounting advice. Nor is it an offer or solicitation in any jurisdiction in which such an offer or solicitation would be illegal. Capital Markets LLC does not make representations as to the actual value to be received in connection with a transaction. Although information is from sources believed reliable, there is no undertaking as to accuracy and opinions and information contained herein are subject to change without notice. Difficulties in the mortgage and broader credit markets have led to a substantial decrease in the availability of credit. The extent and duration of any future continued weakening of U.S. and global credit and financial markets, higher costs of borrowing, and disruptions in debt and equity markets potentially make it more difficult to liquidate an investment, or determine the impact, if any, on the performance and prospects of particular issuers or securities. A client should not enter into any transactions unless it has fully understood all risks and that not all investments will be suitable, and has independently determined that such transactions are appropriate, for the client. Prices may fluctuate and it is possible that such fluctuations may be substantial in response to many factors including, without limitation, general market and market sector conditions, U.S. and global, in addition to company specific conditions. Past performance is not a guide to future performance of any instrument, transaction or financial structure, and a loss of original capital may occur. Calls and communications with Capital Markets LLC may be recorded, for regulatory and other reasons.

Disclosures in relation to certain other BNY group entities can be accessed at the following website: https://www.bny.com/corporate/emea/en/disclaimers/eu-disclosures.html.

This material is intended for institutional clients (or the equivalent only), and is not intended for use by retail clients and no other person should act upon it. Persons who do not have professional experience in matters relating to investments should not rely on this material. Capital Markets LLC will only provide the relevant investment services, and this material is only being distributed, to investment professionals.

BNY Mellon Capital Markets, LLC is not an “authorised person” in the U.K. under the Act. Please note that the individual with whom you are communicating, has the authority to issue communications on behalf of more than one entity within The Bank of New York Mellon Corporation group entities, and may not be employed by BNY Mellon Capital Markets, LLC. Please consult an authorised person if in doubt. The communication is not covered by U.K. regulatory regime protections.

This communication is exempt from the general restriction in Section 21 of the Act on the communication of invitations or inducements to engage in investment activity on the grounds that it is being issued to and/or directed at only the types of person referred to above.

The content of this communication has not been approved by an authorised person and such approval is, save where this communication is directed at or issued to the types of person referred to above, required by Section 21 of the Act.

Any contractual terms will be subject to approval by BNY Mellon Capital Markets, LLC.

For recipients of this information located in Singapore: This material has not been reviewed by the Monetary Authority of Singapore.

BNY has various other subsidiaries, affiliates, branches and representative offices in the Asia-Pacific Region which are subject to regulation by the relevant local regulator in that jurisdiction.

BNY has various subsidiaries and representative offices in the Latin America Region which are subject to specific regulation by the relevant local regulator in each jurisdiction.

This material may not be reproduced or disseminated in any form without the prior written permission of BNY.

Securities Products: Not FDIC-Insured – Subject to Loss in Value – Not a Deposit of or Guaranteed by a Bank or any Bank Affiliate.

Disclosures

FINANCIAL INFORMATION

BNY Mellon Capital Markets, LLC Business Monthly FOCUS Reports (Rolling 12 months)

DISCLOSURES

SEC Rule 605 - Public Disclosure of Order Execution
SEC Rule 606 - Quarterly Disclosure of Order Routing
SEC Rule 605 - Public Disclosure of Order Execution (prior to October 2024)
SEC Rule 606 - Quarterly Disclosure of Order Routing (prior to October 2024)

BNY Markets

Capital Markets EMEA Disclaimers and Disclosures

Capital Markets EMEA

About BNY Markets – Capital Markets EMEA

BNY Markets – Capital Markets EMEA provides brokerage and trading services for fixed income and equity securities to Professional Clients and Eligible Counterparties (in each case as defined in the FCA Rules or in Irish S.I. No. 375/ 2017- European Union (Markets in Financial Instruments) Regulations 2017 (“Irish MiFID II Regulations”), as applicable) through Pershing Securities Limited, Pershing Securities International Limited, and in the case of fixed income securities through The Bank of New York Mellon, London Branch.

Services are provided in the United Kingdom by The Bank of New York Mellon, London Branch or Pershing Securities Limited. Services are provided in Ireland by Pershing Securities International Limited. Not all products and services are offered at all locations.

The Bank of New York Mellon is a wholly owned subsidiary of The Bank of New York Mellon Corporation (BNY). BNY and its affiliates lend and provide other products and financial services to issuers and others, and provide and receive related fees and compensation.

This material may not be distributed or used for the purpose of providing any referenced products or services or making any offers or solicitations in any jurisdiction or in any circumstances in which such products, services, offers or solicitations are unlawful or not authorized, or where there would be, by virtue of such distribution, new or additional registration requirements.

The Bank of New York Mellon is a banking corporation organized pursuant to the laws of the State of New York, whose registered office is at 240 Greenwich St, NY, NY 10286, USA. The Bank of New York Mellon is supervised and regulated by the New York State Department of Financial Services and the Federal Reserve and is authorized by the Prudential Regulation Authority (“PRA”) (Firm Reference Number: 122467).

The Bank of New York Mellon operates in the U.K. through its London branch (Companies House number FC005522 and U.K. establishment number BR025038) with registered office at 160 Queen Victoria Street, London, EC4V 4LA, U.K., and is subject to regulation by the Financial Conduct Authority (“FCA”) and limited regulation by the PRA. Details about the extent of our regulation by the PRA are available from us on request.

Pershing Securities Limited, a subsidiary of The Bank of New York Mellon Corporation. Registered Office: The Royal Liver Building, Pier Head, Liverpool, L3 1LL. Authorised and regulated by the Financial Conduct Authority, No. 146576. Member of the London Stock Exchange. Registered in England under No. 2474912.

Pershing Securities International Limited, a subsidiary of The Bank of New York Mellon Corporation. Registered Office: The Shipping Office, 20-26 Sir John Rogerson’s Quay, Dublin 2, D02Y049, Ireland. Registered in Ireland under No. 367098. Regulated by The Central Bank of Ireland.

© 2025 Pershing Limited, a subsidiary of The Bank of New York Mellon Corporation (BNY). Pershing Securities Limited, authorised and regulated by the Financial Conduct Authority, No. 146576. Pershing (Channel Islands) Limited is regulated by the Jersey Financial Services Commission. Pershing Securities International Limited is regulated by the Central Bank of Ireland. For professional use only. Not intended for use by the general public. BNY Pershing does not provide investment advice. Trademark(s) belong to their respective owners. The information contained herein, including any attachments, is proprietary to, and constitutes confidential information of BNY Pershing. It may not be reproduced, retransmitted or redistributed in any manner without the express written consent of BNY Pershing.

For clients located in Switzerland

To the extent no financial instruments or financial services are being provided under the Swiss Financial Services Act ("FinSA") the information provided herein does not constitute an offer of financial instrument or an offer to provide financial service in Switzerland pursuant to or within the meaning of FinSA and its implementing ordinance. This is solely an advertisement pursuant to or within the meaning of FinSA and its implementing ordinance.

For clients located in Jordan

These materials do not constitute a public offering prospectus under the laws of Jordan. These materials are intended solely for use on a confidential basis by those persons to whom it is transmitted. These materials will be transmitted to potential investors in Jordan: (a) upon their request and confirmation that they understand that the contemplated securities have not been approved or licensed by or registered with the Jordan Securities Commission or any other relevant licensing authorities or governmental agencies in Jordan; and (b) on the condition that this document and the information contained herein will not be provided to any person other than the original recipient. These materials are not for general circulation in Jordan and may not be reproduced or used for any other purpose. The investments being marketed through this material have not been meant to be offered, sold or delivered in Jordan. The contemplated securities described in these materials are not intended to be offered, sold or delivered in Jordan.

For recipients of this information located in Singapore: This material has not been reviewed by the Monetary Authority of Singapore.

The Bank of New York Mellon is regulated by the Australian Prudential Regulation Authority and also holds an Australian Financial Services Licence No. 527917 issued by the Australian Securities and Investments Commission to provide financial services to wholesale clients in Australia.

The Bank of New York Mellon has various other subsidiaries, affiliates, branches and representative offices in the Asia-Pacific Region which are subject to regulation by the relevant local regulator in that jurisdiction.

The Bank of New York Mellon has various subsidiaries and representative offices in the Latin America Region which are subject to specific regulation by the relevant local regulator in each jurisdiction.

BNY Mellon Saudi Financial Company is licensed and regulated by the Capital Market Authority, License number 20211-04, located in Alfaisaliah Tower, 18th Floor, King Fahad Road, P.O. Box 99936 Riyadh 11625, Kingdom of Saudi Arabia.

BNY Pershing is the umbrella name for Pershing LLC (member FINRA, SIPC and NYSE), Pershing Advisor Solutions (member FINRA and SIPC), Pershing Holdings (U.K.) Limited, Pershing Limited (U.K.), Pershing Securities Limited (U.K.), Pershing Securities International Limited (Ireland), Pershing (Channel Islands) Limited, Pershing Securities Singapore Private Limited, and Pershing India Operational Services Pvt Ltd. BNY Pershing businesses also include Pershing X, Inc. a technology provider. Pershing LLC is a member of SIPC, which protects securities customers of its members up to $500,000 (including $250,000 for claims for cash). Explanatory brochure available upon request or at sipc.org. SIPC does not protect against loss due to market fluctuation. SIPC protection is not the same as, and should not be confused with, FDIC insurance.

Past performance is not a guide to future performance of any instrument, transaction or financial structure and a loss of original capital may occur. Calls and communications with BNY may be recorded, for regulatory and other reasons.

Disclosures in relation to certain other BNY group entities can be accessed at the following website: https://www.bny.com/corporate/emea/en/disclaimers/eu-disclosures.html.

This material is intended for wholesale/professional clients (or the equivalent only), and is not intended for use by retail clients and no other person should act upon it. Persons who do not have professional experience in matters relating to investments should not rely on this material. BNY will only provide the relevant investment services, and this material is only being distributed, to investment professionals.

Not all products and services are offered in all countries.

If distributed in the U.K., this material is a financial promotion. If distributed in the EU, this material is a marketing communication.

This material, which may be considered advertising (but shall not be considered advertising under the laws and regulations of Singapore), is for general information purposes only and is not intended to provide legal, tax, accounting, investment, financial or other professional counsel or advice on any matter. This material does not constitute a recommendation or advice by BNY of any kind. Use of our products and services is subject to various regulations and regulatory oversight. You should discuss this material with appropriate advisors in the context of your circumstances before acting in any manner on this material or agreeing to use any of the referenced products or services and make your own independent assessment (based on such advice) as to whether the referenced products or services are appropriate or suitable for you.

For Qualified Clients in Israel

The Bank of New York Mellon, London Branch offers and provides securities trading services in Israel only to Qualified Investors, as defined under the First Addendum of the Israeli Securities Law, 1968, as amended (the “Securities Law”), and in accordance with a permit under Alternative A described in the Conditions of a General Permit under Section 49A to the Securities Law, New Version (December 2020) with respect to Section 49A of the Securities Law. Such services are designed exclusively for such Qualified Investors. The permit holder’s operations are not subject to the supervision of the Israel Securities Authority. The permit does not constitute an opinion regarding the quality of the services rendered by the permit holder or the risks that such services entail.

Pursuant to Title VII of The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 and the applicable rules thereunder, The Bank of New York Mellon is registered as a swap dealer with the Commodity Futures Trading Commission, is a swap dealer member of the National Futures Association (NFA ID 0420990) and is conditionally registered as a security-based swap dealer with the Securities Exchange Commission.

This material and the information and any statements contained herein is for general information and reference purposes only. It is not a recommendation with respect to, or solicitation or offer to buy or sell, any products (including financial products) or services, including but not limited to BNY stock, or to participate in any particular trading strategy, including in any jurisdiction in which such an offer or solicitation or trading strategy, would be illegal, and should not be construed as such. The information herein is not intended to provide tax, legal, investment, accounting, financial or other professional advice on any matter, and should not be used or relied upon as such. The contents may not be comprehensive or up to date and there is no undertaking as to the accuracy, timeliness, completeness or fitness for a particular purpose of information given. The Bank of New York Mellon, London Branch will not be responsible for updating any information contained within this material, and opinions and information contained herein are subject to change without notice. Neither The Bank of New York Mellon, London Branch nor any BNY affiliate assumes any direct or consequential liability for any errors in or reliance upon this information, and are not responsible for any third party website or website content (including, without limitation, any advertising appearing therein) which can be accessed through any of the following websites at:

https://www.bny.com/corporate/global/en/solutions/capital-markets-liquidity-financing.html; https://www.bny.com/corproate/emea/en/regulatory-information.html; and https://www.bny.com/corporate/global/en/disclaimers/business-disclaimers.html.

The Bank of New York Mellon, London Branch, Pershing Securities Limited and Pershing Securities International Limited includes links to other websites for information purposes only and makes no representation whatsoever about any such link, website or consent.

The Bank of New York Mellon, London Branch, Pershing Securities Limited and Pershing Securities International Limited does not make any representations as to the actual value to be received in connection with a transaction. Difficulties in the mortgage and broader credit markets have generally led to a substantial decrease in the availability of credit. The extent and duration of any future continued weakening of U.S. and global credit and financial markets, higher costs of borrowing, and disruptions in debt and equity markets potentially make it more difficult to liquidate an investment, or determine the impact, if any, on the performance and prospects of particular issuers or securities. A person should not enter into any transactions unless they have fully understood all risks, understands that not all investments will be suitable, and has independently determined (by way of having obtained, where required, its own independent legal, financial, tax and other professional advice), or that such transactions are appropriate. Prices may fluctuate and it is possible that such fluctuations may be substantial in response to many factors including, without limitation, general market and market sector conditions, U.S. and global, in addition to company specific conditions. Dividends are not guaranteed and are subject to change or elimination. There are risks generally associated with foreign investments, such as economic and political developments, seizure or nationalization of deposits, currency limitations, imposition of taxes or other restrictions on the payment of principal and interest. Make sure you understand all risks before investing in any financial instrument. Past performance is not a guide to future performance of any instrument, transaction or financial structure, and a loss of original capital may occur. Calls and communications with The Bank of New York Mellon, London Branch may be recorded, for regulatory and other reasons.

Investment in any floating rate instrument presents unique risks, including the discontinuation of the floating rate reference or any successors or fallbacks thereto. BNY does not guarantee and is not responsible for the availability or continued existence of a floating rate reference associated with any particular instrument. Before investing in any floating rate instrument, please evaluate the risks independently with your financial, tax and other advisors as you deem necessary.

Any references to dollars are to U.S. dollars unless specified otherwise.

This material may not be reproduced or disseminated in any form without the prior written permission of BNY. Trademarks, logos and other intellectual property marks belong to their respective owners.

Trademarks and logos belong to their respective owners. The terms of this disclaimer are subject to English law and to the exclusive jurisdiction of the English courts.

The Bank of New York Mellon, member of the Federal Deposit Insurance Corporation (“FDIC”). Please note that many products and affiliates of The Bank of New York Mellon are NOT covered by FDIC insurance.

©2025 The Bank of New York Mellon Corporation. All rights reserved.

BNY Markets

Buy Side Trading Solutions

General Disclaimers

Buy-Side Trading Solutions and Portfolio Transition Services (together, “BTS”) are offered through BNY Mellon Capital Markets, LLC (“BNYCM”) only to Institutional Clients in the United States (“U.S.”) and select countries where permitted by local law.

Buy-Side Trading Solutions are offered through Pershing Securities Limited (“PSL“) in the United Kingdom (“UK”) and select countries where permitted by law, and in all cases only to Eligible Counterparties and Professional Clients (as defined in the rules of the UK Financial Conduct Authority (“FCA”)).

Not all products and services are offered in all countries.

BNYCM is a full-service U.S. registered broker-dealer and an indirect wholly owned non-bank subsidiary of The Bank of New York Mellon Corporation (“BNY”). PSL is authorised and regulated by the Financial Conduct Authority, No. 146576. BNY and its affiliates lend and provide other products and services to issuers and others and provide and receive related fees and compensation. Neither BNYCM nor PSL is acting as an investment adviser. In relation to Portfolio Transition Services, BNYCM and will not be providing any investment advice or recommendations, or other otherwise exercise investment discretion or act as fiduciary, with respect to the decision to transition or liquidate any assets or purchase or select any assets. BNYCM will be acting as a “fiduciary” under ERISA solely with respect to the exercise of discretion as to the price, timing and venue of the liquidation, sale or purchase transactions that are directed by Portfolio Transition Services clients.

This material is intended for wholesale/professional clients (or the equivalent only), and is not intended for use by retail clients and no other person should act upon it. Persons who do not have professional experience in matters relating to investments should not rely on this material. BNYCM and PSL will only provide the relevant investment services, and this material is only being distributed, to investment professionals. Not all products and services are offered in all countries. If distributed in the UK, this material is a financial promotion. If distributed in the EU, this material is a marketing communication.

BNYCM is a member of FINRA and SIPC, which protects securities customers of its members up to $500,000 (including $250,000 for claims for cash). Explanatory brochure available upon request or at www.sipc.org. SIPC does not protect against loss due to market fluctuation. SIPC protection is not the same as, and should not be confused with, FDIC insurance.

This material is not to be distributed in any jurisdiction in which such distribution would be illegal. BNYCM, PSL and their affiliates do not make representations as to the actual value to be received in connection with a transaction. Although information is from sources believed reliable, there is no undertaking as to accuracy and opinions and information contained herein are subject to change without notice.

A client should not enter into any transactions unless it has fully understood all risks and that not all investments will be suitable, and has independently determined that such transactions are appropriate, for the client. Prices may fluctuate and it is possible that such fluctuations may be substantial in response to many factors including, without limitation, general market and market sector conditions, U.S. and global, in addition to company specific conditions. Past performance is not a guide to future performance of any instrument, transaction or financial structure, and a loss of original capital may occur.

The Bank of New York Mellon, London Branch (“BNYLB”) is not providing any facilitation or arranging services to you in connection with products/services referenced in this communication. The services will be contracted with and delivered by BNYCM and/or PSL alone and recipients of the services will be entering into the BNYCM and PSL contractual documents directly with BNYCM and PSL respectively (not BNYLB). Any contractual terms will be subject to approval by BNYCM and/or PSL (as the case may be).

Fixed Income Securities. Fixed income investments, including municipal bonds, are subject to various risks including changes in interest rates, call features, credit quality, possible default, difficulty in market valuations, liquidity, prepayments, early redemption, tax ramifications, inflation and other factors.

Equity Securities. Prices may fluctuate and it is possible that such fluctuations may be substantial in response to many factors including, without limitation, general market and market sector conditions, U.S. and global, in addition to company specific conditions. Dividends are not guaranteed and are subject to change or elimination.

Derivatives Disclosure. Where distribution of material is subject to the rules of the U.S. Commodity Futures Trading Commission (the “CFTC”), it shall be considered a “solicitation” of derivatives business generally, as such term is used within CFTC Rule 1.71 and 23.605, pursuant to the U.S. Commodity Exchange Act. Derivatives and Options carry a high level of risk and are not suitable for all investors. In particular, an option holder may lose the entire amount paid for the option in a relatively short period of time and an options writer may incur significant loss if the price of the underlying interest declines.

Past performance is not indicative of, nor a guarantee of future performance and a loss of original capital may occur. You should not enter into any transactions unless you have fully understood all risks, that not all investments will be suitable, and you have independently determined that such transactions are appropriate, for you. Investing in securities involves risk, including loss of the principal amount invested.

Additional information is provided on FINRA’s Web site at https://www.finra.org/investors/learn-to-invest/key-investing-concepts/evaluating-investment-performance.

BNYCM and/or PSL (including its broker-dealer affiliates) may have long or short positions in any currency, derivative or instrument discussed herein. BNYCM and/or PSL have included data in this material from information generally available to the public from sources believed to be reliable. Any price or other data used for illustrative purposes may not reflect actual current conditions. No representations or warranties are made, and neither BNYCM nor PSL assumes no liability, as to the suitability of any products and services described herein for any particular purpose or the accuracy or completeness of any information or data contained in this material. Price and other data are subject to change at any time without notice.  

This material may not be reproduced or disseminated in any form without the prior written permission of BNY.

Trademarks, service marks and logos are the property of their respective owners.

Securities Products: Not FDIC-Insured – Subject to Loss in Value – Not a Deposit of or Guaranteed by a Bank or any Bank Affiliate.

BNY Markets

Product-specific Disclaimers

Markets

(a) Cross line of business Markets Products

Please also refer to the BNY Global Disclaimer here.

The terms of any products or services provided by BNY to a client, including without limitation any administrative, valuation, trade execution or other services shall be solely determined by the definitive agreement relating to such products or services. Any products or services provided by BNY shall not be deemed to have been provided as fiduciary or adviser except as expressly provided in such definitive agreement. BNY may enter into a foreign exchange transaction, derivative transaction or collateral arrangement as a counterparty to a client, and its rights as counterparty or secured party under the applicable transactional agreement or collateral arrangement shall take precedence over any obligation it may have as fiduciary or adviser or as service provider under any other agreement.

Pursuant to Title VII of The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 and the applicable rules thereunder, The Bank of New York Mellon is registered as a swap dealer with the Commodity Futures Trading Commission, is a swap dealer member of the National Futures Association (NFA ID 0420990) and is conditionally registered as a security-based swap dealer with the Securities Exchange Commission.

BNY (including its broker-dealer affiliates) may have long or short positions in any currency, derivative or instrument discussed herein. BNY has included data in this material from information generally available to the public from sources believed to be reliable. Any price or other data used for illustrative purposes may not reflect actual current conditions. No representations or warranties are made, and BNY assumes no liability, as to the suitability of any products and services described herein for any particular purpose or the accuracy or completeness of any information or data contained in this material. Price and other data are subject to change at any time without notice.

Pershing Prime Services is a service of Pershing LLC, member FINRA, NYSE, SIPC, a wholly owned subsidiary of The Bank of New York Mellon Corporation (“BNY”). Member of SIPC. Securities in your account protected up to $500,000. For details, please see www.sipc.org.

(b) Foreign Exchange

Please also refer to the BNY Global Disclaimer here.

(i) FX products and services

The Bank of New York Mellon SA/NV only provides its services outside of Hong Kong. Any transactions that are intermediated by The Bank of New York Mellon, Hong Kong Branch are carried on through The Bank of New York Mellon, Hong Kong Branch in compliance with the “dealing through” (or other) exemption, and not directly by The Bank of New York Mellon SA/NV.

Investment in any floating rate instrument presents unique risks, including the discontinuation of the floating rate reference or any successors or fallbacks thereto. BNY does not guarantee and is not responsible for the availability or continued existence of a floating rate reference associated with any particular instrument. Before investing in any floating rate instrument, please evaluate the risks independently with your financial, tax and other advisors as you deem necessary.

Neither BNY nor any of its respective officers, employees or agents are, by virtue of providing the materials or information contained herein, acting as an adviser to any recipient (including a “municipal advisor” within the meaning of Section 15B of the Securities Exchange Act of 1934, as amended, “Section 15B”), do not owe a fiduciary duty to the recipient hereof pursuant to Section 15B or otherwise, and are acting only for their own interests.

None of BNY, any data vendors used by BNY, nor their sources (“Vendors"), warrants the accuracy or completeness or timeliness of any of the derivatives valuations supplied by BNY or the Vendors. Although the derivatives valuations may be referred to as “valuations” or “prices”, they are prepared by Vendors and in the case of BNY’s proprietary valuation services, by BNY based on inputs from such Vendors through the application of methods, standards of judgment and proprietary models used and developed by each Vendor or BNY, as applicable, and these derivatives valuations may not conform in any way to actual trading prices, prices you may obtain in a sale or purchase, or information available from third parties. A derivatives valuation represents only one view as to the estimated general value of a derivatives instrument at a particular point in time, and therefore is subject to change at any time without notice. Derivatives valuations may incorporate information from the most active markets to which a Vendor or BNY, as applicable, has access and, consequently, may not represent an estimate of the value of the particular derivatives instrument in all or other markets to which BNY or others may have access. None of BNY or the Vendors makes any warranties, express or implied, including but not limited to any warranty of merchantability or fitness for a particular purpose or use or non-infringement in connection with any of the data or anything done or supplied by the Vendors through BNY or by BNY though its proprietary valuation services. Derivatives valuations are being provided by BNY at the client’s request for information purposes only and are not intended as an offer or solicitation for the purchase or sale of a security or a contractual obligation with respect to any derivatives instrument.

(ii) Interest and/or FX rates

Neither BNY nor any other third party provider shall be liable for any errors in or delays in providing or making available the data (including rates, WM/Refinitiv Intra-Day Spot Rates and WM/Refinitiv Intra-Day Forward Rates) contained within this service or for any actions taken in reliance on the same, except to the extent that the same is directly caused by its or its employees’ negligence. The WM/Refinitiv Intra-Day Spot Rates and WM/Refinitiv Intra-Day Forward Rates are provided by Refinitiv Benchmark Services Limited (“RBSL”). RBSL shall not be liable for any errors in or delays in providing or making available the data contained within this service or for any actions taken in reliance on the same, except to the extent that the same is directly caused by its or its employees’ negligence.

(iii) iFlow® and/or FX market commentary

The products and services described herein may contain or include certain “forecast” statements that may reflect possible future events based on current expectations. Forecast statements are neither historical facts nor assurances of future performance. Forecast statements typically include, and are not limited to, words such as “anticipate”, “believe”, “estimate”, “expect”, “future”, “intend”, “likely”, “may”, “plan”, “project”, “should”, “will”, or other similar terminology and should NOT be relied upon as accurate indications of future performance or events. Because forecast statements relate to the future, they are subject to inherent uncertainties, risks and changes in circumstances that are difficult to predict.

iFlow® is a registered trademark of The Bank of New York Mellon Corporation under the laws of the United States of America and other countries. iFlow captures select data flows from the firm’s base of assets under custody, as well as from its trading activity with non-custody clients, on an anonymized and aggregated basis.

This document is intended for private circulation. Persons accessing, or reading, this material are required to inform themselves about and to observe any restrictions that apply to the distribution of this information in their jurisdiction.

(iv) FX Overlay/Currency Administration

FX Overlay is provided under and subject to the terms of a definitive agreement between BNY and the client. BNY exercises no investment discretion thereunder, but acts solely pursuant to the instructions in such agreement or otherwise provided by the client. Unless provided by definitive agreement, BNY is not an agent or fiduciary thereunder, and acts solely as principal in connection with related foreign exchange transactions.

(v) FX Hedge Direct

BNY is the corporate brand of The Bank of New York Mellon Corporation and may be used to reference the corporation as a whole and/or its various group entities. This material and any products and services may be issued or provided under various brand names of BNY in various countries by duly authorized and regulated subsidiaries, affiliates, and joint ventures of BNY, which may include any of those listed below.

Relevant entities and regulators

The Bank of New York Mellon also operates in the UK through its London branch (Companies House number FC005522 and UK establishment number BR025038) with registered office at 160 Queen Victoria Street, London, EC4V 4LA and is subject to regulation by the Financial Conduct Authority (“FCA”) and limited regulation by the PRA. Details about the extent of our regulation by the PRA are available from us on request.

Pursuant to Title VII of The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 and the applicable rules thereunder, The Bank of New York Mellon is registered as a swap dealer with the Commodity Futures Trading Commission (“CFTC”), is a swap dealer member of the National Futures Association (NFA ID 0420990) and is conditionally registered as a security-based swap dealer with the Securities Exchange Commission.

BNY Mellon Capital Markets, LLC (“BNYCM”) is a full-service U.S. registered broker-dealer and U.S. registered introducing broker and an indirect wholly owned non-bank subsidiary of The Bank of New York Mellon Corporation (“BNY”). BNY and its affiliates lend and provide other products and services to issuers and others and provide and receive related fees and compensation. BNYCM is a member of FINRA and SIPC, which protects securities customers of its members up to $500,000 (including $250,000 for claims for cash). Explanatory brochure available upon request or at www.sipc.org. SIPC does not protect against loss due to market fluctuation. SIPC protection is not the same as, and should not be confused with, FDIC insurance.

Disclosures in relation to certain other BNY group entities can be accessed at the following website: https://www.bny.com/corporate/emea/en/disclaimers/eu-disclosures.html.

Disclosures relating to this material

Any proposal in this material is for discussion purposes only, does not bind BNY in any way and is subject to change. Final terms will be agreed and included in a definitive contract.

If distributed in the UK, this material is a financial promotion. If distributed in the EU, this material is a marketing communication. This material is intended for wholesale/professional clients (or the equivalent only), and is not intended for use by retail clients. Persons who do not have professional experience in matters relating to investments should not rely on this material. BNY will only provide the relevant investment services, and this material is only being distributed, to investment professionals and no other person should act upon it.

This material is for general information purposes only and is not intended to provide legal, tax, accounting, investment, financial or other professional counsel or advice on any matter and should not be used or relied upon as such. This material does not constitute a recommendation or advice by BNY of any kind. Use of our products and services is subject to various regulations and regulatory oversight. You should discuss this material with appropriate advisors in the context of your circumstances before acting in any manner on this material or agreeing to use any of the referenced products or services and make your own independent assessment (based on such advice) as to whether the referenced products or services are appropriate or suitable for you.

Not all products and services are offered in all countries.

Any references to dollars are to US dollars unless specified otherwise.

Calls and communications with BNY may be recorded, for regulatory and other reasons.

Risk information

A client should not enter into any transactions unless it has fully understood all risks and that not all investments will be suitable, and has independently determined that such transactions are appropriate, for the client. Investing in securities and other financial instruments involves risk, including loss of the principal amount invested. Prices may fluctuate and it is possible that such fluctuations may be substantial in response to many factors including, without limitation, general market and market sector conditions, U.S. and global, in addition to company specific conditions. Past performance is not a guide to or indicative of, nor a guarantee of, future performance of any instrument, transaction or financial structure and a loss of original capital may occur. Additional information is provided on FINRA’s Web site at https://www.finra.org/investors/learn-to-invest/key-investing-concepts/evaluating-investment-performance.

Further information on foreign exchange transactions can be found at:
https://www.bny.com/corporate/global/en/disclaimers/foreign-exchange-disclosures.html.

Derivatives Disclosure. Where distribution of material is subject to the rules of the CFTC, it shall be considered a “solicitation” of derivatives business generally, as such term is used within CFTC Rule 1.71 and 23.605, pursuant to the U.S. Commodity Exchange Act. Derivatives and options carry a high level of risk and are not suitable for all investors. In particular, an option holder may lose the entire amount paid for the option in a relatively short period of time and an options writer may incur significant loss if the price of the underlying interest declines.

Nature of BNY’s role

The Bank of New York Mellon, London Branch (“BNYLB”) is not providing any facilitation or arranging services to you in connection with products/services referenced in this communication. The services will be contracted with and delivered by BNYCM alone and recipients of the services will be entering into the BNYCM contractual documents directly with BNYCM respectively (not BNYLB). Any contractual terms will be subject to approval by BNYCM.

Liability

BNYCM and its affiliates do not make representations as to the actual value to be received in connection with a transaction. The views expressed within this material are those of the contributors and not necessarily those of BNY. BNY has not independently verified the information contained in this material and makes no representation as to the accuracy, completeness, timeliness, merchantability or fitness for a specific purpose of the information provided in this material. BNY assumes no direct or consequential liability for any errors in or reliance upon this material.

No representations or warranties are made, and BNY assumes no liability, as to the suitability of any products and services described herein for any particular purpose.

Neither BNY nor any other third party provider shall be liable for any errors in or delays in providing or making available the data (including rates, WMR Intraday Spot Rates and WMR Intraday Forward Rates) contained within a service or for any actions taken in reliance on the same, except to the extent that the same is directly caused by its or its employees’ negligence. The WMR Intraday Spot Rates and WMR Intraday Forward Rates are provided by the London Stock Exchange Group plc and/or its group undertakings (“LSEG”). LSEG shall not be liable for any errors in or delays in providing or making available the data contained within this service or for any actions taken in reliance on the same, except to the extent that the same is directly caused by its or its employees’ negligence.

Specific disclosure relating to iFlow®

For Material that relates to, originates from or refers to iFlow® or the currency strategy team (for example FX market commentary), the products and services described herein may contain or include certain “forecast” statements that may reflect possible future events based on current expectations. Forecast statements are neither historical facts nor assurances of future performance. Forecast statements typically include, and are not limited to, words such as “anticipate”, “believe”, “estimate”, “expect”, “future”, “intend”, “likely”, “may”, “plan”, “project”, “should”, “will”, or other similar terminology and should NOT be relied upon as accurate indications of future performance or events. Because forecast statements relate to the future, they are subject to inherent uncertainties, risks and changes in circumstances that are difficult to predict. iFlow® is a registered trademark of The Bank of New York Mellon Corporation under the laws of the United States of America and other countries. iFlow captures select data flows from the firm’s base of assets under custody, as well as from its trading activity with non-custody clients, on an anonymized and aggregated basis. This document is intended for private circulation. Persons accessing, or reading, this material are required to inform themselves about and to observe any restrictions that apply to the distribution of this information in their jurisdiction.

Specific disclosure relating to FX Overlay

For Material that relates to, originates from or refers to FX Overlay/Currency Administration, FX Overlay is provided under and subject to the terms of a definitive agreement between BNY and the client. BNY exercises no investment discretion thereunder, but acts solely pursuant to the instructions in such agreement or otherwise provided by the client. Unless provided by definitive agreement, BNY is not an agent or fiduciary thereunder, and acts solely as principal in connection with related foreign exchange transactions.

Securities Products: Not FDIC-Insured – Subject to Loss in Value – Not a Deposit of or Guaranteed by a Bank or any Bank Affiliate.

(c) Liquidity & Finance

Please also refer to the BNY Global Disclaimer here.

(i) Agency Securities Lending

Neither BNY nor any of its respective officers, employees or agents are, by virtue of providing the materials or information contained herein, acting as an adviser to any recipient (including a “municipal advisor” within the meaning of Section 15B of the Securities Exchange Act of 1934, as amended, “Section 15B”), do not owe a fiduciary duty to the recipient hereof pursuant to Section 15B or otherwise, and are acting only for their own interests.

(ii) Liquidity DIRECT

Money market fund shares are not a deposit or obligation of BNY. Investments in money market funds are not insured, guaranteed, recommended or otherwise endorsed in any way by BNY, the Federal Deposit Insurance Corporation or any other government agency. Although a money market fund seeks to preserve the value of your investment at $1.00 per share, fund shares are subject to investment risk and your investment may lose value. Money market fund yield performance represents past performance, which is no guarantee of future results and investment returns will fluctuate. Before investing, investors should carefully consider the investment objectives, risks, charges, tax impact and expenses of the fund that are explained in each fund’s prospectus. The following factors, among many, could reduce any one fund’s income level and/or share price: interest rates could rise sharply, causing the value of the fund’s investments and its share price to drop; interest rates could drop, thereby reducing the fund’s yield; any of the fund’s holdings could have its credit rating downgraded or could default; and there are risks generally associated with concentrating investments in any one industry. Investments in instruments of non-U.S. issuers are subject to the risks of certain domestic events—such as political upheaval, financial troubles, nationalization (certain assets, entities or sectors) or natural disasters—that may weaken a country’s securities markets. Country risk may be especially high in emerging markets. Such investments may be affected by market risk on a global scale based on responses of certain foreign markets to markets of other countries or global market sectors. Foreign-currency denominated securities are subject to fluctuations in exchange rates that could have an adverse effect on the value or price of, or income derived from, the investment. Investments in foreign instruments are subject to the risk that the value of a foreign investment will decrease because of unfavorable changes in currency exchange rates.

(iii) Liquidity DIRECT ESG rated products

The data (including any market data, indices, baskets, classifications, ESG assessments or derived data) available via this Portal ("Data") are provided for investment professionals to assess critically and are not suitable for individuals or consumers. The Data may be inaccurate, subjective, delayed or incomplete or otherwise unsuitable for your purposes. Assessments of ESG criteria may be subjective and may not include ESG factors important to you. The criteria used for ESG assessments, their weightings and the inclusion of issuers or securities in an index or other information product may change without notice. Information provided by issuers to ESG Data providers may be inaccurate or subjective. You should not rely on or base any decision on the Data. You must comply with applicable laws and regulations when using the Data. Any indices in the Data may not be authorised or registered in the EU or U.K. for use as benchmarks under the EU Benchmarks Regulation or equivalent U.K. rules. To the maximum extent permitted by law, neither the Bank of New York Mellon nor its affiliates shall be liable for any loss or damage suffered by you or any other person resulting from any usage or non-availability of Data. The Bank of New York Mellon and its affiliates have no responsibility for Data from third parties. You must comply with third party terms and disclaimers, including the disclaimers at https://www.msci.com/notice-and-disclaimer. Your usage of this Portal is subject to the relevant terms agreed between you and the Bank of New York Mellon and/or its affiliates.

(iv) For Offerings of a subset of Money Market Funds
Please also refer to the BNY Global Disclaimer here.

Please note that there are other investment options available to you in addition to those referenced above. We would be happy to provide you with additional market information upon request (we shall have no responsibility for the accuracy of any market information provided). The Bank of New York Mellon is not an investment advisor and is not providing you with investment advice. If you require investment advice, please consult with an investment advisor. Investments in securities, including mutual funds, (i) are not insured in the relevant jurisdictions, (ii) are not bank-guaranteed, and (iii) may lose value.

The information we are providing regarding the BNY Funds (including Insight Funds etc) is only for your consideration. It is not a recommendation or an endorsement by us, nor are we providing you with investment advice. The BNY Funds are also not obligations of or guaranteed in any way by The Bank of New York Mellon (BNY) or its affiliates, or any other bank.

You should carefully read the KIIDs and other relevant docs of each fund (including for BNY Funds) for more information.

(d) CollateralOne
Please also refer to the BNY Global Disclaimer here.

Money market fund shares are not a deposit or obligation of BNY. Investments in money market funds are not insured, guaranteed, recommended or otherwise endorsed in any way by BNY, the Federal Deposit Insurance Corporation or any other government agency. Although a money market fund seeks to preserve the value of your investment at $1.00 per share, fund shares are subject to investment risk and your investment may lose value. Money market fund yield performance represents past performance, which is no guarantee of future results and investment returns will fluctuate. Before investing, investors should carefully consider the investment objectives, risks, charges, tax impact and expenses of the fund that are explained in each fund’s prospectus. The following factors, among many, could reduce any one fund’s income level and/or share price: interest rates could rise sharply, causing the value of the fund’s investments and its share price to drop; interest rates could drop, thereby reducing the fund’s yield; any of the fund’s holdings could have its credit rating downgraded or could default; and there are risks generally associated with concentrating investments in any one industry. Investments in instruments of non-U.S. issuers are subject to the risks of certain domestic events—such as political upheaval, financial troubles, nationalization (certain assets, entities or sectors) or natural disasters—that may weaken a country’s securities markets. Country risk may be especially high in emerging markets. Such investments may be affected by market risk on a global scale based on responses of certain foreign markets to markets of other countries or global market sectors. Foreign currency denominated securities are subject to fluctuations in exchange rates that could have an adverse effect on the value or price of, or income derived from, the investment. Investments in foreign instruments are subject to the risk that the value of a foreign investment will decrease because of unfavorable changes in currency exchange rates.

Securities instruments and services other than money market mutual funds and off-shore liquidity funds are offered by BNY Mellon Capital Markets, LLC.

You should carefully read the KIIDs and other relevant docs of each fund (including for BNY Funds) for more information.

Global Clearing & Global Collateral

Global Disclaimer

The Bank of New York Mellon SA/NV operates in Luxembourg through its Luxembourg branch at 2-4 rue Eugene Ruppert, Vertigo Building – Polaris, L- 2453, Luxembourg. The Bank of New York Mellon SA/NV, Luxembourg Branch (registered with the Luxembourg Registre de Commerce et des Sociétés under number B105087) is subject to limited additional regulation by the Commission de Surveillance du Secteur Financier at 283, route d’Arlon, L-1150 Luxembourg for conduct of business rules, and in its role as depositary and administration agent for undertakings for collective investments (UCIs).

BNY Mellon Fund Services (Ireland) Designated Activity Company is registered with Company No 218007, having its registered office at One Dockland Central, Guild Street, IFSC, Dublin 1, Ireland. It is regulated by the Central Bank of Ireland.

Regulatory information in relation to the above BNY entities operating out of Europe can be accessed at the following website: https://www.bny.com/RID.

For clients located in Switzerland

For recipients of this information located in Singapore: This material has not been reviewed by the Monetary Authority of Singapore.

The Bank of New York Mellon, Tokyo Branch, is a licensed foreign bank branch in Japan and regulated by the Financial Services Agency of Japan. The Bank of New York Mellon Trust (Japan), Ltd., is a licensed trust bank in Japan and regulated by the Financial Services Agency of Japan. The Bank of New York Mellon Securities Company Japan Ltd. is a registered type 1 financial instruments business operator in Japan and regulated by the Financial Services Agency of Japan.

Disclosures in relation to certain other BNY group entities can be accessed at the following website: https://www.bny.com/corporate/emea/en/disclaimers/eu-disclosures.html.

Not all products and services are offered in all countries.

If distributed in the U.K., this material is a financial promotion. If distributed in the EU, this material is a marketing communication.

Any references to dollars are to U.S. dollars unless specified otherwise.

This material may not be reproduced or disseminated in any form without the prior written permission of BNY. Trademarks, logos and other intellectual property marks belong to their respective owners.

Global Collateral ESG rated products

Although MSCI ESG Research LLC and its affiliates ("MSCI ESG Parties") provide information, including ESG ratings, scores and other information (collectively, "Information") to BNY Mellon and its affiliates (“BNY”) based on data and sources they consider reliable, none of the MSCI ESG Parties guarantee or warrant the originality, accuracy and/or completeness of any Information or data and expressly disclaim all express or implied warranties, including those of merchantability and fitness for a particular purpose. The Information may only be used for your internal use, may not be reproduced or redisseminated in any form and may not be used as a basis for, or a component of, any financial instruments or products or indices. Further, none of the Information can in and of itself be used to determine which securities to buy or sell or when to buy or sell them. None of the MSCI ESG Parties nor BNY shall have any liability for any errors or omissions in connection with any Information or data herein, or any liability for any direct, indirect, special, punitive, consequential or any other damages (including lost profits) even if notified of the possibility of such damage.

Capital Markets

Please also refer to the Capital Markets LLC Disclaimers and Disclosures here or the Capital Markets EMEA Disclaimers and Disclosures here, as the case may be.

(a) For Material referring to Fixed Income Securities:

Fixed income investments, including municipal bonds, are subject to various risks including changes in interest rates, call features, credit quality, possible default, difficulty in market valuations, liquidity, prepayments, early redemption, tax ramifications, inflation and other factors.

(b) For Material referring to Floating Rates:

Investment in any floating rate instrument presents unique risks, including the discontinuation of the floating rate reference or any successors or fallbacks thereto. Capital Markets does not guarantee and is not responsible for the availability or continued existence of a floating rate reference associated with any particular instrument. Before investing in any floating rate instrument, please evaluate the risks independently with your financial, tax and other advisors as you deem necessary.

(c) For Material referring to Treasury and Government Agency Obligations:

Not all obligations of the U.S. government or its agencies and instrumentalities are backed by the full faith and credit of the U.S. Treasury. In addition, if not held to maturity, prices will rise and fall on interest rate movements in response to economic conditions.

(d) For Material referring to Corporate Debt:

Corporate debt securities are subject to risks including, but not limited to: early call or redemption risk, reinvestment risk, interest rate risk, credit risk, event risk, sector risk or market risk.

(e) For Material referring to Commercial Paper:

Commercial paper, an unsecured, short-term debt instrument, is not usually backed by any form of collateral, and although there may be back up lines of credit or back up liquidity, may still be subject to default by the issuer.

(f) For Material referring to Certificates of Deposit:

Certificates of Deposit are most suitable for holding until maturity. Early withdrawal of any CD may not be available and may be subject to applicable penalties.

(g) For Material referring to CDs: Limits on FDIC insurance:

If you have or will have money on deposit (such as a savings account) at the same insured institution that issues the CDs, the total value of your deposit accounts could exceed the amount of FDIC insurance to which your deposits (including CDs) are entitled.

(h) For Material referring to Yankee CDs/No FDIC Insurance:

Yankee CDs are not FDIC insured in whole or in part.

(i) For Material referring to Money Market Mutual Funds and Ultra Short Bond Funds:

Money market funds generally only invest in certain high-quality, short-term investments issued by the U.S. government, U.S. corporations and state and local governments and are subject to strict diversification and maturity standards. Ultra-short bond funds are not subject to these requirements. The net asset value (NAV) of an ultra-short bond fund will fluctuate, while money market funds seek to maintain a stable NAV of $1 per share, although there is no guarantee that they will achieve this goal.

(j) Not acting as Municipal Advisor, Financial Advisor or Fiduciary:

Capital Markets is providing the information contained in this document for discussion purposes only in anticipation of serving as an Underwriter, Broker-Dealer, CP Dealer or Remarketing Agent to the addressee and is not recommending any action to the addressee. The primary role of Capital Markets, as Underwriter, is to sell and purchase securities, as applicable, to and from investors, in arm's length commercial transactions; Capital Markets has financial and other interests that differ from those of the addressee. As such, Capital Markets is not acting as a municipal advisor, financial advisor or fiduciary to the addressee or any other person or entity in connection with the information provided. The information provided is not intended to be and should not be construed as "advice" within the meaning of Section 15B of the Securities Exchange Act of 1934 or the rules thereunder. The addressee should consult with its own financial and/or municipal, legal, accounting, tax and other advisors, as applicable, to the extent it deems appropriate. If the addressee would like a municipal advisor in a transaction that has legal fiduciary duties to the addressee, then the addressee is free to engage a municipal advisor to serve in that capacity.

(k) For Material referring to Mutual Funds:

Before investing in mutual funds, it is important to understand the sales charges, expenses, and management fees that you will be charged, as well as any available volume-based breakpoint discounts, and whether the mutual fund's investment strategy is compatible with your investment objectives.

(l) For Material referring to Equity Securities:

Prices may fluctuate and it is possible that such fluctuations may be substantial in response to many factors including, without limitation, general market and market sector conditions, U.S. and global, in addition to company specific conditions. Dividends are not guaranteed and are subject to change or elimination.

(m) For Material referring to Exchange-Traded Funds:

Exchange Traded Funds (“ETF”) generally represent an interest in a portfolio of securities and/or commodities, subjecting the investor to a substantial loss in principal and income due to market risk, interest rate risk, liquidity risk, currency exchange risk, and risks specific to a particular sector.

Estimated/Intraday Net Asset Value (eNAV/iNAV):

ETFs generally represent an interest in a portfolio of securities and/or commodities. The Net Asset Value (“NAV”) of an ETF is calculated by the ETF once per day as of the close of trading on the applicable exchange, based on the prices of the underlying assets of the ETF. The NAV of the ETF is the value of the ETF’s assets minus liabilities divided by the number of shares outstanding.

BNY Mellon Capital Markets, LLC (“Capital Markets LLC”) may, pursuant to an agreement with an ETF trust, transfer agent, and distributor, act as an authorized participant (“AP”) in the purchase or sale of fund shares directly from an ETF. Capital Markets LLC may accept orders to buy or sell ETF shares based on an Estimated or Intraday Net Asset Value (“eNAV” or “iNAV”, respectively) of the ETF, including plus or minus a spread mutually agreed to with the client. The eNAV or iNAV is an estimate of the net asset value of the ETF, based on the fair value of the underlying assets of the ETF at a given time during the day.

Capital Markets LLC will determine the best execution method for the order, consistent with applicable rules and regulations and using reasonable diligence of order and market factors. Capital Markets LLC will determine the eNAV and iNAV based on available execution prices of the underlying assets of the ETF. Where the underlying assets of the ETF include securities of The Bank of New York Mellon Corporation (“BNY”), a Capital Markets LLC affiliate, Capital Markets LLC will use the market price of BNY securities in determining the eNAV and iNAV.

The eNAV and iNAV may be impacted by market and other factors outside of Capital Markets LLC’s control. The iNAV will change and may fluctuate throughout the day based on the value of the underlying assets of the ETF prior to the close of trading, which may subject the client to a substantial loss in principal and income due to market volatility. The eNAV or iNAV may be higher than the highest traded price, or lower than the lowest traded price, of the ETF for the day. The eNAV or iNAV may be higher than the best offer, or lower than the best bid, of the ETF for the day. The eNAV and iNAV may also be impacted by the estimated versus actual cash holdings of the ETF. If the eNAV or iNAV deviates from the next NAV of the ETF after the order is received, impacting the order by more than the greater of 1 basis point or $10,000, Capital Markets LLC reserves the right to adjust the respective eNAV and iNAV provided for the order.

Capital Markets LLC may engage in trading to hedge the risk of orders to buy or sell ETF shares based on the eNAV or iNAV of the ETF using proprietary analytical models, market data, and information otherwise available to Capital Markets LLC. Capital Markets LLC’s hedging activity may include trading in ETFs that have underlying assets which include, among other assets, securities of BNY. This hedging activity may impact the market prices of the securities or financial instruments the client is buying or selling. Capital Markets LLC will employ reasonable means in an attempt to minimize market impact, where reasonably practicable under the circumstances, market conditions permitting.

ETFs may subject the client to a substantial loss in principal and income due to market risk, interest rate risk, liquidity risk, currency exchange risk, and risks specific to a particular sector. The ETF’s prospectus and/or offering documents are available through the ETF issuer’s website; the client should read these carefully before deciding to invest.

(n) For Material referring to Options:

Options carry a high level of risk and are not suitable for all investors. An option holder may lose the entire amount paid for the option in a relatively short period of time and an options writer may incur significant loss if the price of the underlying interest declines.

(o) Investment Banking and Public Finance:

The Company should discuss any financial instrument offering, engagement, or relationship with its own counsel and financial advisors. Capital Markets does not provide tax, legal, or accounting advice, and any information provided by Capital Markets does not include the legal, tax or accounting effects of consummating any transaction.

(p) No Tax, Legal or Accounting Advice:

Capital Markets does not provide tax, legal, or accounting advice. You should independently and carefully consider whether any information or investment instruments are suitable for your particular investment objectives and financial position and, if you believe it appropriate, seek professional advice, including tax, legal and accounting advice.

(q) For Material referring to past performance:

Past performance is not indicative of nor a guarantee of future performance and a loss of original capital may occur. You should not enter into any transactions unless you have fully understood all risks, that not all investments will be suitable, and you have independently determined that such transactions are appropriate, for you. Investing in securities involves risk, including loss of the principal amount invested. Additional information is provided on FINRA's Web site at https://www.finra.org/investors/learn-to-invest/key-investing-concepts/evaluating-investment-performance.

(r) For Material referring to Mortgage-Backed Securities (MBS):

Potential issuers of securities should discuss any financial instrument offering, engagement, or relationship with their own counsel and financial advisors. Beginning in the second half of 2007, difficulties in the mortgage and broader credit markets led to a substantial decrease in the availability of credit. As a result, U.S., European and global credit and financial markets in general have been, and are, experiencing difficulties. The extent and duration of any future continued weakening of these markets, higher costs of borrowing, and disruptions in debt and equity markets may potentially make it more difficult to issue a financial instrument, exit an investment or define the impact, if any, on the performance and prospects of particular issuers or securities. There can be no assurance that any of the governmental or private sector initiatives designed to strengthen the condition of the credit markets will be successful, and there is no way to know the effect that these initiatives will have on the performance of any particular securities or issuers.

Only GNMA is backed by the full faith and credit of the U.S. Government. Securities issued by Fannie Mae, Freddie Mac and MBS in general have recently experienced volatility and other increased risks due to homeowner defaults and severe problems in the housing market.

(s) For Material referring to Structured products:

Structured products are not suitable for all investors. Structured Products are subject to special risks and considerations. All relevant offering documents including, but not limited to, term sheets and prospectuses should be consulted and understood prior to investing. Investors should understand characteristics, risks, and potential rewards. Investors should contact their own accounting, tax or legal advisors to review the suitability of any investment.

(t) For Material referring to Securities Direct®:

Securities Direct® is the registered trademark of The Bank of New York Mellon Corporation.

BNY Markets

Material-specific Disclaimers

(a) Markets Sales and Trading Commentary

Please also refer to the BNY Global Disclaimer here.

This commentary has been prepared by a member of the sales and/or trading department of The Bank of New York Mellon. This content does not constitute a research report and is not produced or distributed by BNY’s strategy department, by any research department or any registered research analysts. Any opinions expressed in this commentary are solely those of the author, who is a member of either a BNY FX Sales or Trading desk, and may differ from opinions expressed by BNY Mellon’s strategy department or any research department/registered research analysts. This material is not investment research or a research recommendation (as referred to in Title 17 CFTC Regulation 23.605, Art. 36(1) of the MiFID II Delegated Regulation (EU) 2017/565, and the Financial Conduct Authority Handbook), and has not been prepared in accordance with legal requirements to promote the independence of research, including but not limited to, the prohibition on dealing ahead of dissemination of investment research. Commentary contained in this communication is not a recommendation with respect to, or solicitation or offer to buy or sell, any products or services, including but not limited to BNY stock, or to participate in any particular trading strategy, including in any jurisdiction where such an offer, solicitation or trading strategy may be contrary to permitted activity in such jurisdiction, and should not be construed as such. This communication is marketing material, desk strategy and/or trader commentary for sophisticated investors and market professionals, and any information or statements contained herein are for general information and reference purposes only, and not intended for retail customer use.

This material is provided for information purposes only and does not bind BNY in any way. It is not intended as a recommendation (except to the extent it is an “investment recommendation” under MAR (as defined below) or an offer or solicitation (except to the extent otherwise covered by Commodity Futures Trading Commission rules) for the purchase or sale of any security or financial instrument, or to enter into a transaction involving any financial instrument or trading strategy, or as a formal valuation of any transaction mentioned herein. Any pricing information provided is indicative only. BNY is not an advisor. Nothing in this material should be construed as investment, tax, legal, accounting, financial, regulatory or other professional advice (including within the meaning of Section 15B of the Securities Exchange Act of 1934) or as creating a fiduciary relationship.

Transactions involving securities, financial instruments and/or strategies mentioned herein may not be suitable for all clients. Clients are solely responsible for deciding whether any investment or transaction is suitable based upon respective investment goals, financial situations and risk-appetite. Clients should consider seeking independent professional advice to ascertain the investment, legal, tax, accounting, regulatory or other consequences before investing or transacting.

Variations in rates of exchange may have an adverse or beneficial effect on the value of investments or concepts referenced in materials provided by BNY personnel. Any analysis or forward-looking information provided is intended only to illustrate hypothetical results based on certain assumptions (which assumptions may or may not be specified), and actual events or conditions may differ from assumptions made in the materials provided; no result based upon reliance of any material is promised or guaranteed.

MAR Disclosure:

This material is not, and is not intended to be, an “investment recommendation” as that term is defined in Article 3(1)(35) of the EU Market Abuse Regulation (EU) No 596/2014 (“MAR”).

Research Disclosure:

This material is not, and is not intended to be, a “research report”, “investment research” or “independent research” as may be defined in applicable laws and regulations worldwide. However, it may constitute “research” as defined in Recital 28 of the Commission Delegated Directive (EU) 2017/593.

Derivatives Disclosure:

Where distribution of material is subject to the rules of the Commodity Futures Trading Commission (the “CFTC”), it shall be considered a “solicitation” of derivatives business generally, as such term is used within Title 17 CFTC Regulations 1.71 and 23.605, pursuant to the Commodity Exchange Act.

Options Disclosure:

Structured securities, options, futures and other derivatives are complex instruments and may involve a high degree of risk. Before entering into any such transactions, we encourage clients to read and understand the Options Clearing Corporation’s Characteristics and Risks of Standardized Options, also known as the options disclosure document (ODD) available at: http://www.theocc.com/about/publications/character-risks.jsp

Exchange Traded Fund (“ETF”) Disclosure:

Each U.S. registered ETF has filed a registration statement (including a prospectus) with the Securities and Exchange Commission. Each non-U.S. ETF will have its own offering documents as required by applicable law. No offer or sale of the ETFs described may be made except pursuant to the prospectus or offering documents, as applicable. The ETF’s prospectus and/or offering documents are available through the ETF issuer’s website; you should read these carefully before deciding to invest.

All market prices, data and other information (including that which may be derived from third party sources believed to be reliable) are not warranted as to completeness or accuracy, and are subject to change without notice. BNY disclaims any responsibility or liability to the fullest extent permitted by applicable law, whether in contract, tort (including, without limitation, negligence), equity or otherwise, for any loss or damage arising from any reliance on or the use of this material in any way. The contents may not be comprehensive or up to date and there is no undertaking as to the accuracy, timeliness, completeness or fitness for a particular purpose of information given. BNY does not undertake any obligation to update such information.

BNY is not responsible for any third party website or website content (including, without limitation, any advertising appearing therein) which can be accessed through the website at www.bny.com. BNY may include links to other websites for information purposes only and makes no representation whatsoever about any such link, website or consent.

BNY may have positions, effect transactions or make markets in securities or financial instruments mentioned in materials provided, or in related instruments, or may otherwise provide advice to legal entities referenced in any commentary. BNY Sales and Trading personnel who prepare this material may be compensated based on trading activity. This material should not be relied upon as either objective or independent from the interests of BNY, or from its associated affiliates and personnel.

Securities, financial instruments or strategies referenced in materials may not be available in all jurisdictions or to all clients. Clients should contact their salespersons at, and execute transactions through, a BNY entity appropriately licensed in the client’s respective jurisdiction unless governing law permits otherwise. This material is provided on a confidential basis and may not be reproduced, redistributed or disseminated, in whole or in part, without the prior consent of BNY. This commentary may not be used for the purpose of providing any services or making any offers or solicitations in any jurisdiction or in any circumstances in which such products, services, offers or solicitations are unlawful or not authorized, or where there would be, by virtue of such distribution, new or additional registration requirements. Trademarks, product names, company names, logos and other intellectual property marks belong to their respective owners.

For clients located in Switzerland

Please be informed that The Bank of New York Mellon and The Bank of New York Mellon SA/NV are entering into the OTC derivative transactions as a counterparty, i.e. acting for their own account or for the account of one of their affiliates. As a result, where you enter into any OTC derivative transactions with us, you will not be considered a "client" (within the meaning of the FinSA) and you will not benefit from the protections otherwise afforded to clients under FinSA. Accordingly, this should not be considered an advertisement pursuant to or within the meaning of FinSA and its implementing ordinance.

The Bank of New York Mellon, Singapore Branch, is subject to regulation by the Monetary Authority of Singapore.

For recipients of this information located in Singapore:

This material has not been reviewed by the Monetary Authority of Singapore.

Trademarks and logos belong to their respective owners.

(b) For iFlow 2.0 Material posted on the BNY Website:

Please also refer to the BNY Global Disclaimer here.

The content on this website has been prepared by members of the sales and/or trading department of The Bank of New York Mellon. The content on this website does not constitute a research report and is not produced or distributed by any strategy department, by any research department or any registered research analysts. Any opinions expressed in the commentary on this website are solely those of the author, who is a member of either a BNY FX Sales or Trading desk, and may differ from opinions expressed by BNY’s strategy department or any research department/registered research analysts. The material contained on this website is not investment research or a research recommendation (as referred to in Title 17 CFTC Regulation 23.605, Art. 36(1) of the MiFID II Delegated Regulation (EU) 2017/565 and the Financial Conduct Authority Handbook), and has not been prepared in accordance with legal requirements to promote the independence of research, including but not limited to, the prohibition on dealing ahead of dissemination of investment research. Commentary contained on this website is not a recommendation with respect to, or solicitation or offer to buy or sell, any products or services, including but not limited to BNY stock, or to participate in any particular trading strategy, including in any jurisdiction where such an offer, solicitation or trading strategy may be contrary to permitted activity in such jurisdiction, and should not be construed as such. The content on this website is marketing material, desk strategy and/or trader commentary for sophisticated investors and market professionals, and any information or statements contained herein are for general information and reference purposes only, and not intended for retail customer use.

The material provided on this website is provided for information purposes only and does not bind BNY in any way. It is not intended as a recommendation (except to the extent it is an “investment recommendation” under MAR (as defined below) or an offer or solicitation (except to the extent otherwise covered by Commodity Futures Trading Commission rules) for the purchase or sale of any security or financial instrument, or to enter into a transaction involving any financial instrument or trading strategy, or as a formal valuation of any transaction mentioned herein. Any pricing information provided is indicative only. BNY is not an advisor. Nothing on this website should be construed as investment, tax, legal, accounting, financial, regulatory or other professional advice (including within the meaning of Section 15B of the Securities Exchange Act of 1934) or as creating a fiduciary relationship.

MAR Disclosure:

The material contained on this website is not, and is not intended to be, an “investment recommendation” as that term is defined in Article 3(1)(35) of the EU Market Abuse Regulation (EU) No 596/2014 (“MAR”).

Research Disclosure:

The material contained on this website is not, and is not intended to be, a “research report”, “investment research” or “independent research” as may be defined in applicable laws and regulations worldwide. However, it may constitute “research” as defined in Recital 28 of the Commission Delegated Directive (EU) 2017/593.

Derivatives Disclosure:

Where distribution of material contained on this website is subject to the rules of the Commodity Futures Trading Commission (the “CFTC”), it shall be considered a “solicitation” of derivatives business generally, as such term is used within Title 17 CFTC Regulations 1.71 and 23.605, pursuant to the Commodity Exchange Act.

Exchange Traded Fund (“ETF”) Disclosure:

Each U.S. registered ETF has filed a registration statement (including a prospectus) with the Securities and Exchange Commission. Each non-U.S. ETF will have its own offering documents as required by applicable law. No offer or sale of the ETFs described may be made except pursuant to the prospectus or offering documents, as applicable. The ETF’s prospectus and/or offering documents are available through the ETF issuer’s website; you should read these carefully before deciding to invest.

BNY may have positions, effect transactions or make markets in securities or financial instruments mentioned in materials provided, or in related instruments, or may otherwise provide advice to legal entities referenced in any commentary. BNY Sales and Trading personnel who prepare the material contained on this website may be compensated based on trading activity. The material contained on this website should not be relied upon as either objective or independent from the interests of BNY, or from its associated affiliates and personnel.

Securities, financial instruments or strategies referenced in material contained on this website may not be available in all jurisdictions or to all clients. Clients should contact their salespersons at, and execute transactions through, a BNY entity appropriately licensed in the client’s respective jurisdiction unless governing law permits otherwise. The material contained on this website is provided on a confidential basis and may not be reproduced, redistributed or disseminated, in whole or in part, without the prior consent of BNY. The commentary contained on this website may not be used for the purpose of providing any services or making any offers or solicitations in any jurisdiction or in any circumstances in which such products, services, offers or solicitations are unlawful or not authorized, or where there would be, by virtue of such distribution, new or additional registration requirements. Trademarks, product names, company names, logos and other intellectual property marks belong to their respective owners.

For clients located in Switzerland

(c) Email disclaimers for dual-hatting arrangement in Capital Markets EMEA and FX transactions EMEA:

Please also refer to the BNY Global Disclaimer here and the BNY Capital Markets EMEA Disclaimer here.

The information contained in this e-mail, and any attachment, is confidential and is intended solely for information purposes only in its use by the intended recipient. No confidentiality or privilege is waived or lost by any mis-transmission. The information may not be accurate or complete; is subject to change; is not a recommendation or offer to buy/sell a financial instrument or adopt any investment strategy; is not legal, tax, credit or accounting advice; any pricing information given in this message is indicative only. Past performance not indicative of future returns. Any reference to the terms of executed transactions should be treated as preliminary only and subject to our formal written confirmation. BNY reserves the right to monitor all email communications through its networks. Any views expressed in this message are those of the individual sender, except where the message states otherwise and the sender is authorised to state them to be the views of any such entity. BNY may produce emails to regulatory agencies or others with a legal right to access such information.

Access to, copying or re-use of the e-mail or any attachment, or any information contained therein, by any other person is not authorised. If you are not the intended recipient please immediately return the e-mail to the sender and delete it from your computer including deleting all copies of it from your system, destroy any hard copies of it and notify the sender. Although we attempt to sweep e-mail and attachments for viruses, we do not guarantee that either are virus-free and accept no liability for any damage sustained as a result of viruses. Further details available at www.bny.com

Your personal information will be collected and held by BNY and will be used for the purpose(s) of maintaining our business relationship. This includes but is not limited to providing you with reporting where appropriate as well as generic business and Markets updates. Your personal information will be shared within BNY. Your personal information could be shared with third parties who help manage our business and deliver services. BNY will transfer or store your personal information in other countries, including those outside Europe, under the protection of appropriate safeguards. For more information about how we collect, use and share personal information and your legal rights, see BNY’s full privacy notice at www.bny.com/emea/en/data-privacy.html and the privacy section of www.pershing.com/europe. BNY is the corporate brand of The Bank of New York Mellon Corporation and may also be used as a generic term to reference the Corporation as a whole and/or its various subsidiaries generally.

Neither The Bank of New York Mellon, London Branch nor Pershing Securities Limited is providing any facilitation or arranging services to you in connection with products/services referenced in this communication and/or any products/services offered by the other legal entity or any other BNY legal entity.

For clients of The Bank of New York Mellon, London Branch in respect of FX transactions under any Custody FX Program, London Branch’s Terms of Business for FX Transactions or otherwise

This communication is sent to you by The Bank of New York Mellon, London Branch only, and NOT by any other BNY legal entity, please disregard reference to any other BNY legal entity not applying to you.

The Bank of New York Mellon, a banking corporation organized pursuant to the laws of the State of New York, whose registered office is at 240 Greenwich St, NY, NY 10286, USA. The Bank of New York Mellon is supervised and regulated by the New York State Department of Financial Services and the US Federal Reserve and is authorized by the Prudential Regulation Authority (“PRA”) (Firm Reference Number: 122467). The Bank of New York Mellon operates in the UK through its London branch (UK companies house numbers FC005522 and BR025038) at 160 Queen Victoria Street, London, EC4V 4LA and is subject to regulation by the Financial Conduct Authority (“FCA”) at 12 Endeavour Square, London, E20 1JN and limited regulation by the PRA at Bank of England, Threadneedle St, London, EC2R 8AH. Details about the extent of our regulation by the PRA are available from us on request.

For clients of The Bank of New York Mellon, London Branch under The Bank of New York Mellon, London Branch - Financial Instruments (Excluding Derivatives) Brokerage Terms and Conditions

The Bank of New York Mellon operates in the UK through its London branch (UK companies house numbers FC005522 and BR025038) at 160 Queen Victoria Street, London, EC4V 4LA and is subject to regulation by the Financial Conduct Authority (“FCA”) at 12 Endeavour Square, London, E20 1JN and limited regulation by the PRA at Bank of England, Threadneedle St, London, EC2R 8AH. Details about the extent of our regulation by the PRA are available from us on request.

For clients of Pershing Securities Limited under Pershing Securities Limited - Institutional Client Agency Brokerage Terms and Conditions

This communication is sent to you by Pershing Securities Limited only, and NOT by any other BNY legal entity, please disregard reference to any other BNY legal entity not applying to you.

Pershing Securities Limited, registered in England number 2474912, is authorised and regulated by the Financial Conduct Authority and is a member of the London Stock Exchange. Registered address: Royal Liver Building, Pier Head, Liverpool L3 1LL.

For clients who engage with both (i) The Bank of New York Mellon, London Branch in respect of FX transactions under any Custody FX Program, London Branch’s Terms of Business for FX Transactions or otherwise; and (ii) Pershing Securities Limited under Pershing Securities Limited - Institutional Client Agency Brokerage Terms and Conditions

Any communications, data or information sent to you in connection with executing a particular order or transaction or in respect of any order or transaction communicated through Nexus are sent to you by Pershing Securities Limited, and NOT by The Bank of New York Mellon, London Branch or any other BNY legal entity. Other communications, data or information are sent to you by the BNY legal entity providing the services to you to which the communications, data or information relate, and NOT by any other BNY legal entity.

For clients who engage with both (i) The Bank of New York Mellon, London Branch under The Bank of New York Mellon, London Branch - Financial Instruments (Excluding Derivatives) Brokerage Terms and Conditions; and (ii) Pershing Securities Limited under Pershing Securities Limited - Institutional Client Agency Brokerage Terms and Conditions

In respect of any transaction, any communications, data or information sent to you in connection with that transaction are sent to you by the BNY legal entity providing services to you in respect of that transaction, and NOT by any other BNY legal entity.

Pershing

Pershing Disclaimer

Pershing LLC, member FINRA, NYSE, SIPC, is a subsidiary of The Bank of New York Mellon Corporation (BNY). Pershing Advisor Solutions LLC, member FINRA, SIPC, and BNY Mellon, N.A., member FDIC, are affiliates of Pershing LLC. Pershing businesses also include its affiliate Pershing X, Inc., a technology provider. For professional use only. Not intended for use by the general public. Trademark(s) belong to their respective owners. For all disclosures, visit https://www.bny.com/pershing/us/en/disclosures.html.

©2024 Pershing LLC. All rights reserved.

Wealth Management

BNY Wealth Disclaimer

Consumer credit services, which are subject to application and credit approval, and banking services are provided by BNY Mellon, N.A., member FDIC. Commercial credit services, which are subject to application and credit approval, may be provided by The Bank of New York Mellon or BNY Mellon, N.A. Mortgage services are subject to credit approval and are provided by BNY Mellon, BNY Mellon Brokerage Services are provided by BNY Mellon Wealth Advisors who are registered representatives of BNY Mellon Securities Corporation (BNYMSC). BNYMSC is a dually registered investment adviser/broker-dealer and member FINRA and SIPC and an indirect wholly-owned subsidiary of BNY Mellon. BNY is an equal housing lender.

SIPC protects securities in customer accounts of its members up to $500,000 in securities (including $250,000 for claims for cash). Explanatory brochure available upon request or at www.sipc.org. SIPC does not protect against loss due to market fluctuation. SIPC protection is not the same as, and should not be confused with, FDIC insurance.

Wealth Management

Investment Management Disclaimer

Investment products (other than deposit products) referenced here (including money market funds) are not insured by the FDIC (or any other state or federal agency), are not deposits of or guaranteed by BNY or any bank or non-bank subsidiary thereof, and are subject to investment risk, including the loss of principal amount invested.

SIPC protects securities in customer accounts of its members up to $500,000 in securities (including $250,000 for claims for cash). Explanatory brochure available upon request or at www.sipc.org. SIPC does not protect against loss due to market fluctuation. SIPC protection is not the same as, and should not be confused with, FDIC insurance.

Wealth Management

Investment Servicing and Information Management Disclaimer

Investment products (other than deposit products) referenced here (including money market funds) are not insured by the FDIC (or any other state or federal agency), are not deposits of or guaranteed by BNY or any bank or non-bank subsidiary thereof, and are subject to investment risk, including the loss of principal amount invested.

Wealth Management

Wealth Management Online Banking

Electronic Account Documents - Agreement and Disclosure

With Online Banking, BNY Mellon, National Association (“BNY”) allows you the convenience of deciding how you would like to receive your account¹ related documents.

By enrolling to receive your account related documents online through Online Banking you will have access to an electronic copy that mirrors what has traditionally been sent via U.S. mail. For example, if you currently receive images of your checks in your monthly statement those same check images will be available to you online.

For your convenience, we offer two choices regarding delivery of your account related documents:

Online - If you select this option we will deliver your account related documents to you electronically and securely through Online Banking. Simply log in and the account related documents that you elect to receive online will be available for you to view, print, or save. With this option you will no longer receive paper copies of account related documents in the mail.

Important Note For Clients with Duplicate Statements - If you currently have duplicate paper account related documents, by selecting the Online-only option for electronic delivery, you will suppress paper copies of account related documents completely. As a result, duplicate account related documents will no longer be mailed. It is possible to request online access to account related documents for others, if needed, by contacting the BNY Phone Center at 1-800-830-0549.

Paper - If you select this option we will continue to mail you paper copies of account related documents. Note that if you select this option you will not have access to view your account related documents via Online Banking.

If you opt to receive electronic copies of your account related documents, after you enroll in this service you will receive a monthly email telling you when your account related documents are available for viewing/printing.

For your convenience, the message indicating that your account related documents are available for viewing/printing will be sent to you via the Online Banking Message Center as well as to the external email address you specify in Online Banking. Please note that for security reasons, at no time will we send you electronic account related documents via email. The only email we send is the reminder email that an account related document is available for viewing.

If you have selected "Online" delivery for your account related documents, once enrolled, you will be able to view any documents we have stored for you in our archive as well as any subsequent statements for eligible accounts.

In some cases, such as with new accounts, you will be able to view your account related documents online beginning with your next statement.

You can log into Online Banking at any time to change the delivery option of your account related documents. If you change your delivery option to "Paper" only, you will no longer have access to your account related documents online.

Hardware and Software Required to Use Service - To electronically access and retain your documents, you will need to have access to a computer with the latest version of Internet Explorer, Safari, Chrome or Firefox installed.

In addition, your computer must have Internet connectivity and you must maintain a working email account that enables you to receive, view and print or store email messages. In order to retain the documents provided to you electronically, your personal computer will also need to have the capability to save and store the documents.

Account related documents will be published in Portable Document Format (PDF). You may download and save the PDFs to your personal computer. To view the documents, you will need Adobe Acrobat Reader software. Adobe Acrobat Reader software is available online at http://www.adobe.com.

Acknowledgment - In considering whether to enroll to receive your account related documents online through Online Banking, you hereby acknowledge and agree with BNY as follows:

You have read the Electronic Account Documents - Agreement and Disclosure above in connection with the online delivery service and you have had an opportunity to ask any questions relating to it.
You have an account with an internet service provider, you have the hardware and software described above under “Hardware and Software Required to Use Service,” and you are able to receive email with hyperlinks to websites and to open, review, save and print documents in PDF format.
By completing this consent process and clicking “ACCEPT,” you represent and effectively demonstrate that you can access electronic documents through Online Banking.
By selecting electronic delivery through Online Banking for new documents and/or new accounts, you reaffirm acceptance of the Electronic Account Documents - Agreement and Disclosure. Such terms and conditions are subject to change without notice.
By clicking “Accept,” you hereby elect enroll in electronic delivery through Online Banking.
By clicking “Decline,” you hereby decline to subscribe to electronic delivery through Online Banking.

1. Accounts for which online delivery is available are subject to change solely at the discretion of BNY. To identify accounts for which online delivery is available, please refer to Online Banking, which will list all of your accounts that are eligible for online delivery of account related documents.

Wealth Management

Private Banking Disclaimer

Investment products referenced here (including money market funds) are not insured by the FDIC (or any other state or federal agency), are not deposits of or guaranteed by BNY or any bank or non-bank subsidiary thereof, and are subject to investment risk, including the loss of principal amount invested.

Consumer credit services, which are subject to application and credit approval, and banking services are provided by BNY Mellon, N.A., member FDIC. Commercial credit services, which are subject to application and credit approval, may be provided by The Bank of New York Mellon or BNY Mellon, N.A. Mortgage services are subject to credit approval and are provided by BNY Mellon, BNY Mellon Brokerage Services are provided by BNY Mellon Wealth Management Direct, a division of BNY Mellon Securities Corporation ("BNYMSC"). BNYMSC is a dually registered investment adviser/broker-dealer and member FINRA and SIPC and an indirect wholly-owned subsidiary of BNY Mellon. BNY is an equal housing lender.

Wealth Management

Wealth and Estate Planning Disclaimer

NON-BUSINESS/GENERAL DISCLAIMERS

BNY General Disclaimer

BNY is the corporate brand of The Bank of New York Mellon Corporation and may also be used to reference the Corporation as a whole or its various subsidiaries. Products and services may be provided under various brand names, including BNY Asset Servicing and BNY Investments . BNY Asset Servicing is the brand name encompassing BNY’s affiliated companies that provide the services referenced in this brochure. BNY Investments is the brand name encompassing BNY's affiliated investment management firms and global distribution companies. Products and services may be provided by various subsidiaries, affiliates, joint ventures and in some instances by third party providers of The Bank of New York Mellon Corporation where authorized and regulated as required within each jurisdiction, and may include The Bank of New York Mellon, One Wall Street, New York, New York 10286, a banking corporation organized and existing pursuant to the laws of the State of New York and operating in England through its branch at 160 Queen Victoria Street, London, EC4V 4LA, England. Registered in England and Wales with FC005522 and BR025038. The Bank of New York Mellon is supervised and regulated by the New York State Department of Financial Services and the Federal Reserve and authorized by the Prudential Regulation Authority. The Bank of New York Mellon London branch is subject to regulation by the Financial Conduct Authority and limited regulation by the Prudential Regulation Authority. Details about the extent of our regulation by the Prudential Regulation Authority are available from us on request. Not all products and services are offered at all locations.

European Email Disclaimer

The information contained in this email, and any attachment, is confidential and is intended solely for the use of the intended recipient. Access, copying or re-use of the email or any attachment, or any information contained therein, by any other person is not authorized. If you are not the intended recipient please return the email to the sender and delete it from your computer. Although we attempt to sweep email and attachments for viruses, we do not guarantee that either are virus-free and accept no liability for any damage sustained as a result of viruses.

Please refer to https://www.bny.com/corporate/global/en/disclaimers/eu-disclosures.html for certain disclosures relating to European legal entities.