Regulatory Disclosure – Shareholder Rights Directive II

Date: September 3, 2020

This disclosure pertains to State Street Bank and Trust Company and each of its branches, affiliates and subsidiaries that provide custody and depositary services including State Street Bank International GmbH and each of its branches,  State Street Custodial Services (Ireland) Limited, State Street Custodial Services (Jersey) Limited, State Street Trustees Limited, State Street Australia Limited, State Street Trust Company Canada, State Street Trust and Banking Company Limited and State Street Trust (SG) Limited each in its capacity as custodian or depositary (collectively, “State Street”) with respect to services provided for shares of companies that have their registered office in a Member State and is valid as of the date indicated above. Please note this disclosure may be updated from time to time, including in the event that State Street changes its practices for charging (or not charging) fees or expenses in a manner which impacts the information provided below.

Article 3d of the Shareholder Rights Directive (Directive (EU) 2017/828) (“SRD II”) requires intermediaries to disclose publicly any applicable charges for certain services provided under the Directive. State Street qualifies as an intermediary when acting as a custodian or depositary. In such role, State Street performs the following functions covered by SRD II:

• Identification of shareholders (Article 3a)
• Transmission of information (Article 3b)
• Facilitation of the exercise of shareholder rights (Article 3c)
  

Identification of shareholders

State Street does not currently charge with respect to this function in any of the Member States.

Transmission of information and facilitation of the exercise of shareholder rights

State Street’s global custody service includes monitoring, notifying and facilitating corporate action events and, in markets where voting by proxy is allowed and where procedurally possible, the facilitation of voting at shareholder meetings on behalf of our clients in accordance with their instructions. State Street’s charges for these services are generally included in our standard custody fee agreed to with our clients directly in the negotiated fee schedule and are not billed as separate services. In many instances, out-of-pocket expenses are incurred by State Street in connection with the facilitation of proxy voting, which charges can be comprised of a fee per vote as well as out-of-pocket expenses incurred by the subcustodian, such as travel and documentation expenses. In such cases, State Street may pass along such actual amounts billed to State Street as agreed with the client in the negotiated fee schedule.

Please note that, as a value-added service offering, different fees for the intermediary functions above may apply with respect to agency securities lending; however, additional fees are not currently charged.

Please contact your State Street client service representative if you have any questions regarding the above.