State Street Global Advisors Asia Limited was incorporated in Hong Kong on August 4, 1997. SSGAL is licensed by the Hong Kong Securities and Futures Commission under the Securities and Futures Ordinance for carrying out investment advisory activities; asset management activities including dealing in securities and futures contracts and marketing and distribution of collective investment schemes. SSAL is also licensed by the Financial Services Authority in South Korea as an offshore discretionary investment adviser and discretionary investment manager. The Adviser is a license holder of QFII (qualified foreign institutional investor). SSAL is staffed with investment, legal and compliance, marketing and client service, and operations personnel, providing clients with a wide array of investment strategies and innovative investment solutions in the region. SSAL is recognized as one of the largest institutional managers in Asia. SSAL is affiliated with State Street Global Advisors (“SSGA”), which was founded in 1978 as the investment management division of State Street Bank and Trust Company. State Street Bank and Trust Company was founded in 1792 and is a wholly-owned subsidiary of State Street Corporation (“State Street”). State Street is a publicly traded bank holding company whose shares are traded on the New York Stock Exchange under the symbol “STT.” SSGA, SSAL,and its advisory affiliates comprise the investment management arm of State Street. SSAL has an established client franchise in Hong Kong and Asia for Asian domiciled ETFs and has been providing discretionary management for indexed accounts since its establishment in 1997. SSAL has been managing ETFs in Asia since the inception of the Tracker Fund of Hong Kong in 1999 and has since increased its line-up of local funds with the first Asia Bond ETF (ABF Pan Asian bond Index Fund - PAIF) in 2005. SSAL works with its clients to provide customized solutions to their investment management needs, which may include customized indices, model portfolios, and screened portfolios. Clients may impose restrictions on investing in certain securities or types of securities. Pursuant to certain arrangements, SSAL is authorized to engage one or more sub-advisers for the performance of any of the services contemplated to be rendered by SSAL. SSAL is also authorized to act as sub-adviser for the performance of services contemplated to be rendered by its advisory affiliates including advisory in relation to active equity strategies. As of December 31, 2018, SSAL had $38,669,601,914 in regulatory assets under management on a discretionary basis.


please register to get more info

Advisory or sub-advisory fees are negotiated with each client and may vary depending upon the size and type of the mandate and the strategy selected. Advisory Fees: Fees are typically expressed as an annual percentage of a client’s average daily net assets managed by SSAL. With respect to funds, fees are deducted directly from fund assets. Separate account clients are billed for the fees; invoices are provided to clients for confirmation and fees are then generally deducted directly from client assets. Please refer to Item 6 – Performance Fees and Side-by-Side Management for an additional discussion regarding fees. Custodial, Administrative, or Securities Lending Agency Fees: Clients of SSAL are responsible for certain other fees and expenses, including, but not limited to, custodial, administrative, or securities lending agency fees. These fees may be paid to SSGAL or affiliates of SSAL, e.g., State Street Bank and Trust Company (“SSBT”). SSAL clients will also incur brokerage and other transaction costs. Please refer to Item 12 – Brokerage Practices for more information about brokerage. SSAL clients are not required to pay fees in advance. SSAL’s clients are primarily institutional clients; SSAL does not receive compensation in the form of asset-based sales charges or service fees from the sale of mutual funds. Please refer to Item 14 – Client Referrals and Other Compensation for more information. please register to get more info

SSAL typically charges an asset- based fee for its investment management services. SSAL generally does not enter into performance based fee arrangements; however, SSAL may accept such an arrangement under the appropriate circumstances. Potential conflicts of interest may exist when portfolio managers manage accounts with similar investment objectives and strategies. The portfolio managers managing the assets of a client generally manage other accounts in addition to the client’s, such as commingled funds and separate accounts. Conflicts of interest may potentially arise in SSAL’s side-by-side management of multiple accounts. SSAL seeks to treat all client accounts fairly and equitably. Examples of circumstances that may give rise to such potential conflicts of interest or the appearance of conflicts of interest include, but are not limited to:  Managing a portfolio that pays a performance fee alongside a portfolio that does not pay a performance fee;  Managing a U.S. registered ETF alongside a bank-maintained fund (e.g., a common trust fund or collective investment trust);  Managing a separate account alongside a commingled fund;  The use of “conflicting trades,” i.e., selling short for one client portfolio a security held long for another client portfolio; and  The execution of transactions shortly before or after related transactions in a different account. As discussed above, a potential conflict may arise when the portfolio manager is responsible for accounts that have different advisory fees. The difference in fees could create an incentive for the portfolio manager to favor one account over another, for example, in terms of access to investment opportunities. This conflict may be heightened if an account is subject to a performance-based fee. The Adviser has established processes and procedures for allocating investment opportunities among portfolios that are designed to provide a fair and equitable allocation.



please register to get more info

SSAL’s investment advisory clients consist primarily of institutional clients in the Asia region, Central Banks, Sovereign Wealth Funds, Pension Funds, and certain pooled investment vehicles including ETFs established in Asia, for which SSAL is either the named investment adviser or sub-adviser. SSAL maintains minimum account requirements for its separate accounts for each of its investment strategies. please register to get more info

As an investment adviser, SSAL engages numerous methods of analysis across a wide array of investment strategies when formulating investment advice or managing assets. SSAL does not rely on one type of analysis over another and does not recommend one particular type of security. SSAL seeks to utilize the most prudent methods of analysis based on the particular characteristics of the investment strategy and the current market conditions, as applicable. Methods of Analysis: Each strategy described below uses various methods of analysis as necessary for the respective strategy. The methods of analysis include:  Quantitative;  Fundamental;  Technical;  Cyclical;  Indexing;  Charting; and,  Other strategy specific methods described below.

Investment Strategies: The investment strategies deployed by SSAL are:  Active and Indexed Equity;  Private Equity; and  Multi Asset Class Solutions (Asset Allocation)

The following section includes a description of SSAL’s investment strategies and a discussion of the material risks of each strategy. The description of material risks listed under each strategy description below is not a complete enumeration or explanation of all the risks involved in purchasing shares of any Fund/account. An investment in a Fund/account employing one of the strategies described below may be subject to a number of risks not specifically mentioned. Clients should refer to a Fund’s prospectus and other offering documents for more detailed discussion of risks. Investing in securities involves risk of loss that clients should be prepared to bear.
Active and Indexed Equity
Strategy description: The Adviser has teams providing research and analysis into various Asian equity securities to advise the Adviser’s US affiliate in connection with active strategies designed to outperform relative to benchmarks while maintaining appropriate risk exposure. No active equity mandates are managed under the discretion of the Adviser. In addition to the Active strategies, the Adviser offers index equity strategies covering various capitalization segments; style portfolios; and sector portfolios, including U.S. indexing, global indexing, developed markets indexing, emerging markets indexing, and specific country mandates. The Adviser manages equity index portfolios to seek broad-based equity exposure and predictable variance around a relevant benchmark. Risks: The market prices of equity securities may go up or down, sometimes rapidly or unpredictably, for a number of reasons that may directly relate to the issuer and also may decline due to general industry or market conditions. Foreign securities are subject to political, regulatory, and economic risks not present in domestic investments, including risks associated with currency controls and differing accounting, auditing, legal and financial report standards. Investments in emerging markets are generally subject to a greater risk of loss than investments in developed markets due to, among other things, greater political and economic instability, greater volatility in currency exchange rates, and less developed securities markets as compared to those typically found in a developed market. An indexed fund is managed with an investment strategy that attempts to track the performance of an index of securities, regardless of the current or projected performance of the index or of the actual securities comprising the index. This differs from an actively-managed fund, which typically seeks to outperform a benchmark index. As a result, an indexed Fund’s performance may be less favorable than that of a portfolio managed using an active investment strategy. The structure and composition of the index will affect the performance, volatility, and risk of the index and, consequently, the performance, volatility, and risk of the Fund. Special Risk Considerations of Investing in the People’s Republic of China (“PRC”): Investments in securities of PRC issuers involves certain risks and considerations not typically associated with investing in securities of developed markets, including, among others: (i) the small size of the market for PRC securities and the low volume of trading, resulting in lack of liquidity and in price volatility, (ii) currency devaluations and other currency exchange rate fluctuations, (iii) limitations on the use of brokers, (iv) greater political, economic and social uncertainty, and (v) custody risks associated with investing through a QFII or RQFII. Please refer to Item 12 – Brokerage Practices for a discussion regarding risks related to PRC Brokers. Special Risk Considerations Relating to the QFII and RQFII Regimes and Investments in China A Shares: If SSAL’s QFII or RQFII quota is or becomes inadequate to meet the investment needs of a fund investing in the China A Shares market or if SSAL is unable to maintain its QFII or RQFII status, the Adviser may seek to gain exposure to China A Shares by investing, as applicable, in securities not included in a fund’s index, futures contracts, swaps and other derivative instruments and other pooled investment vehicles, including foreign and/or affiliated funds, that provide exposure to China A Shares until additional QFII or RQFII quota can be obtained. A reduction in or elimination of the applicable quota may not only adversely affect the ability of a fund to invest directly in China A Shares, but also the performance of pooled investment vehicles linked to the performance of China A Shares. Therefore, any such reduction or elimination may have a material adverse effect on the ability of a fund to achieve its investment objective. These risks are compounded by the fact that at present there are only a limited number of firms and counterparties that have QFII or RQFII status or are otherwise able to obtain China A Shares quota. In addition, the QFII or RQFII quota may be reduced or revoked by Chinese regulators if, among other things, SSAL fails to observe State Administration of Foreign Exchange and other applicable Chinese regulations, which could also lead to other adverse consequences, including the requirement that a fund dispose of its China A Shares holdings.
Private Equity
The Manager provides research and analysis into various private equity offerings to advise the Adviser’s US affiliate in connection with management of private equity mandates. No private equity mandates are managed under the discretion of the Adviser. Multi Asset Class Solutions Strategy description: The Multi Asset Class Solutions strategies employ an asset allocation model as a method of diversification which aims to position assets among major investment categories. When employing a certain asset allocation methodology, the Adviser will have discretion to adjust portfolio positioning. This method is used in an effort to manage risk and enhance returns. It does not, however, guarantee a profit or protect against loss. Risks: Risks associated with the Multi Asset Class Solution strategies are a function of the multiple asset classes in which the Funds’ assets are allocated. Subject to the asset class allocation, the risks will be similar to those described in the other strategies. Please refer to the Prospectus, Statements of Additional Information, or other offering documents for the funds/accounts for more detailed discussion about risks. please register to get more info

On 15 June 2016, the Securities and Futures Commission (“SFC”) reprimanded and fined SSAL HK $4,000,000 for its failure to comply with regulatory requirements in the management of the Tracker Fund of Hong Kong (“TraHK”). The SFC found that, in managing the cash balances of TraHK during 1 December 2008 to 30 June 2013, SSAL failed to: (a) ensure that interest received on TraHK’s deposit from its connected person was at a rate not lower than the prevailing commercial rate for a deposit of that size and term; (b) manage TraHK’s deposits in accordance with the terms of TraHK’s constitutive documents; (c) have adequate policies and procedures in place to comply with the regulatory requirements and TraHK’s constitutive documents regarding TraHK’s deposits; (d) provide accurate information regarding the deposit accounts in annual and interim reports of TraHK’s; and (e) avoid situations where conflicts of interest may arise, and/or failed to manage and minimize the conflict by putting appropriate safeguards and measures in place where the conflict could not be avoided, in order to protect investors’ interests. Throughout the SFC’s investigations, SSAL had co-operated with the SFC in resolve the SFC’s concerns, agreed to make a voluntary payment of $318,315 into TraHK, and agreed to engage an independent reviewer to conduct an internal controls review of the cash management policy and procedures of SFC-authorized funds managed by SSAL. For additional information, please refer to State Street’s current report on Form 10-K, on file with the Securities and Exchange Commission. please register to get more info

Other Financial Industry Affiliations
SSAL has relationships or arrangements with various related persons including: broker-dealers, various funds, banking institutions, and other investment advisers.
SSAL is affiliated with State Street Bank and Trust Company (“SSBT”), which is a wholly-owned subsidiary of State Street. SSBT
is a Massachusetts state chartered bank. SSBT, its affiliates, and branch offices provide, in accordance with applicable law, custody, accounting, securities lending, trustee, and administrative services to accounts/funds for which SSAL has investment discretion. In addition, SSBT became a provisionally registered swap dealer in December of 2012. SSAL is affiliated with State Street Global Markets, LLC (“SSGM”), a wholly-owned subsidiary of State Street. SSGM is registered as a broker-dealer with the SEC, and is a member of the Financial Industry Regulatory Authority, the National Futures Association, the Municipal Securities Rulemaking Board, Securities Investors Protection Corporation (“SIPC”), and various exchanges. SSAL may use the services of SSGM or its broker/dealer affiliates to effect securities transactions for its clients. SSAL may also, either directly or in connection with effecting transactions with SSGM, use the services of other State Street subsidiaries or joint ventures involving State Street or its affiliates (or similar businesses involving State Street) whose businesses are designed to facilitate the purchase and sale of portfolio assets of client accounts. SSAL may use SSGM in cases where SSAL is required to obtain authorization of a client before using SSGM to effect securities transactions for a client. SSAL first obtains such authorizations to execute transactions for its clients in compliance with applicable laws, regulations, and SSAL and client specific policies. Please refer to Item 6 – Performance Based Fees and Side-by-Side Management for a discussion of potential conflicts of interests. SSAL is affiliated with several SEC-registered and non-registered investment advisers. SSAL, SSGA, and its advisory affiliates comprise the investment management arm of State Street. SSGA has a global trading desk with regional trading desks located in Boston, London and Hong Kong (SSAL). The SSGA trading desk locations were chosen for access to markets where SSGA, SSAL, and its advisory affiliates invest and proximity to where SSGA, SSAL, and its advisory clients are. In some instances, one or more of these advisers may assist SSAL in the management of, or trade execution for, a client portfolio and vice versa. These portfolios may include UCITS funds, U.S. registered investment companies, and CTFs. Please refer to Item 11 – Code of Ethics, for a discussion of additional conflicts of interests. please register to get more info

Personal Trading
SSGAL has adopted a Code of Ethics (the “Code”) that is designed to comply with the requirements of Rule 204A-1 under the Advisers Act and Rule 17j-1 under the 1940 Act. The Code imposes restrictions on the purchase or sale of securities for SSGAL’s employees’ own accounts and the accounts of certain affiliates of employees. The Code imposes substantive trading restrictions, including but not limited to the requirement to pre-clear trades in Covered Securities, a prohibition on participating in IPOs, a requirement to pre-clear private placements, a 60-day short-term profit prohibition (with some exceptions), and a blackout rule that prohibits an Investment Person from trading a Covered Security within seven days before or after a trade in the same or equivalent security in a client portfolio with which such Investment Person is associated (subject to a de minimis exception of $5,000). In addition, the Code requires employees to pre‐clear and report transactions and holdings in mutual funds advised or sub‐advised by SSGAL and certain affiliates. Employees are required to report transactions and/or holdings in Covered Securities in initial, quarterly and annual reports. On an annual basis, each employee is required to certify that he or she has read, understands, and is in compliance with the Code. The foregoing discussion is a summary and is qualified in its entirety by the Code. Each client or prospective client is provided with a copy of the Code upon request. SSGAL follows State Street’s Political Contributions and Activities Policy, which contains provisions related to “pay-to-play” laws, including Rule 206(4)-5 under the Investment Advisers Act of 1940, as amended from time to time. The policy sets forth the basic principles and practices concerning State Street and its affiliates with regard to corporate and personal political contributions and other political activities. The policy requires pre-clearance of personal political contributions for certain employees, including employees of SSGAL. Potential Conflicts: The Adviser has identified potential conflicts of interest that arise in the ordinary course of its investment advisory activities. Generally, these conflicts include those relating to the Adviser’s employees’ personal trading activities; relationships that the Adviser has with, and/or payments it may receive from, affiliated entities; trading in multiple client accounts in the same or similar investment strategies; the fee structure of certain accounts; and proxy voting. The Adviser has adopted policies and procedures to address these topics. Conflicts may arise from the personal trading activities of the Adviser’s employees. These potential conflicts of interest are primarily addressed in the Code (described above) and the State Street Standard of Conduct (the “Standard of Conduct”). The Standard of Conduct also contains important provisions pertaining to insider trading and tipping and supplements the Adviser’s Inside Information/Information Barriers Policy and Procedure.
Conflicts may arise as a result of the Adviser’s dealings with affiliated entities. SSGAL’s affiliates are among the service
providers for SSGAL’s clients. A conflict may exist because SSGAL may earn more revenue if a client selects a service provider affiliated with SSGAL. These affiliations are disclosed to clients. Conflicts may arise as a result of the aggregation of clients’ trades and allocations to client accounts. There is a potential conflict when transactions in a specific security may not be effected for all client accounts at the same time or at the same price for various reasons. There could be incentive to allocate transactions in a manner that favors one client over another. Conflicts may arise as a result of the allocation of scarce investment opportunities, such as in demand securities, because of the possibility that the Adviser could allocate scarce investment opportunities in a manner that favors one client over another. There is theoretically an incentive to allocate desirable securities to clients that pay a performance fee. Conflicts may arise as a result of principal trading and cross trading activities. The potential conflict is that the Adviser could use these transactions for the benefit of the Adviser or to favor one client over another. Conflicts may arise as a result of correcting trade errors. The potential conflict is that the Adviser may seek to protect its own economic interest by not acknowledging that errors have occurred, by failing to fully compensate clients for damages they inc ur as a result of such errors (by not covering their losses), or by keeping client gains. Conflicts may arise as a result of simultaneous management of multiple accounts by the Adviser’s investment professionals. For example, differences in the advisory fee structure may create the appearance of actual or potential conflicts of interest because such differences could create pecuniary incentives for the Adviser to favor one account over another. Please refer to Item 6 – Performance-Based Fees and Side-By-Side Management. Conflicts may arise as a result of exercising proxies. For example, the Adviser or its affiliates may provide services to a company whose management is soliciting proxies, or to another entity that is a proponent of a particular proxy proposal. Another example could arise when SSGAL or an affiliate has business or other relationships with participants involved in proxy contests, such as a candidate for a corporate directorship. Please refer to Item 17 – Voting Client Securities for information about the Adviser’s Proxy Voting Policy. please register to get more info

SSAL seeks best execution of client transactions, subject to any client-imposed restrictions (e.g., if the client has mandated the use of specified counterparties for certain transactions) viewed in terms either of the particular transaction or in terms of SSAL’s overall responsibilities with respect to the accounts as to which it exercises investment discretion and has the authority to select the executing broker-dealer or other counterparty.  SSAL refers to and selects from the list of approved trading counterparties maintained by SSGA Credit Risk Management. In selecting a trading counterparty for a particular trade, the Adviser seeks to weigh relevant factors including, but not limited to the following: Prompt and reliable execution;  The financial strength, stability, and/or reputation of the broker-dealer;  The willingness and ability of the executing bank/broker-dealer to execute transactions (and commit capital) of size in liquid and illiquid markets without disrupting the market for the security;  Adherence to local laws, regulations, or restrictions, particularly related to the following of attestations and training for Electronic Trading platforms and services;  The ability of the executing broker-dealer to maintain confidentiality;  The availability (depending on asset class) and capability of Electronic Trading Services for the purpose of execution, as well as third-party execution venues, including electronic communications networks (“dark pools”), as well as trading and execution management systems for use by SSAL;

 Market share;  Liquidity;  Price;  Quantitative evidence of the historical quality of execution of orders;  Likelihood of execution and settlement;  Clearance and settlement capabilities, especially in high volume market environments;  Sophistication of the broker-dealer’s trading capabilities and infrastructure/facilities;  The operational efficiency with which transactions are processed and cleared, taking into account the order size and complexity;  Responsiveness to SSAL;  Access to IPOs and other offerings;  Access to secondary markets;  The relative value SSGA places on the proprietary research provided by various broker-dealers;  Counterparty exposure; and  Any other consideration relevant to the execution of the order. In selecting a trading counterparty, ongoing execution quality related to transactions the price of the transaction and costs related to the execution of the transaction typically merit a high relative importance, depending on the circumstances. The Adviser does not necessarily select a trading counterparty based upon price and costs but may take other relevant factors into account if it believes that these are important in taking reasonable steps to obtain the best possible result for the client under the circumstances. The following matters may influence the relative importance that the Adviser places upon the relevant factors:  The nature and characteristics of the order or transaction. For example, size of order, market impact of order, limits or other instructions relating to the order;  The characteristics of the financial instrument(s) or other assets which are the subject of that order. For example, whether the order pertains to an equity, fixed income, derivative or convertible instrument;  The characteristics of the execution venues to which that order can be directed, if relevant. For example, availability and capabilities of electronic trading systems;  Whether the transaction is a ‘delivery versus payment’ or ‘over the counter’ transaction. The creditworthiness of the trading counterparty, the amount of existing exposure to a trading counterparty and trading counterparty settlement capabilities may be given a higher relative importance in the case of ‘over the counter’ transactions.  Whether, in the case of certain Currency and Fixed Income trades, constraints are placed on any given counterparty’s exposure to any given instrument, as per mandated agreements  Any other circumstances relevant at the time. The process by which trading counterparties are selected to effect transactions is designed to exclude consideration of: the value of any credits generated or to be generated by trading through a broker-dealer; any third party services that SSGA may receive from utilizing such credits; or if applicable, the sales efforts conducted by broker-dealers in relation to mutual funds managed by SSAL. People’s Republic of China (“PRC”) Brokers: SSAL is responsible for selecting PRC Brokers to execute transactions for certain funds in the PRC markets. In accordance with Qualified Foreign Institutional Investors (QFII) and Renminbi QFII (RQFII) schemes and implementation rules, SSAL may only appoint a maximum of three PRC brokers in respect of each stock exchange in the PRC (the Shanghai Stock Exchange and the Shenzhen Stock Exchange). If, however, A Share transactions are affected through the Stock Connect program, and not QFII/RQII, this restriction on brokers is not applicable, and an appropriate number can be selected, at the discretion of the SSAL trading desk. As such, a fund may investing in the China A Shares market only rely on a limited number of PRC Brokers to execute transactions on behalf of the fund. However, in its selection of a PRC Broker(s), SSAL will consider factors such as the ability to offer Electronic Trading Services, size of the relevant orders and ongoing execution and operational/settlement standards. Research and Other Soft Dollar Benefits: SSAL and its affiliates retain the right to use “soft” or commission dollars for the purchase of third party research and brokerage services consistent with the parameters of Section 28(e) of the Securities Exchange Act of 1934, as amended and other applicable laws, but at present time does not maintain such a program. SSAL and its affiliates will obtain research and brokerage services as needed for servicing managed accounts directly from broker-dealers and vendors (and directly from broker-dealers as a result of equity commissions as described below). Research and brokerage services furnished to the Adviser may be used in furnishing investment or other advice to all or some subset of the Adviser’s (and/or its affiliates) clients. The Adviser may share some or all of the brokerage and research services received by each of them with affiliates. In addition, SSAL and its affiliates employ a standard negotiated equity commission schedule. All equity commission rates are the same regardless of account, market or broker, including a prime broker. SSAL does not pay any broker-dealer a greater commission than another as compensation for the value of any proprietary research that broker-dealer may provide to SSAL. However, while all these standardized, negotiated equity commission rates are “execution-only” rates, in some cases certain funds will pick up an amount of compensation for brokerage and research services provided by the broker-dealers (known as a “tack-on rate”, invoked operationally downstream), which is often unsolicited. Proprietary research received by the Adviser and its affiliate(s) typically includes research reports and analysis, personal interviews with analysts or company officials, certain trade analytics, and market data. The value attributed to any research is determined, in part, by a “broker vote” process. Products and Services: SSAL and its affiliates receive proprietary research or brokerage services on the basis of transactions effected with or through broker-dealers on behalf of their clients. Proprietary research received by SSGAL and its affiliates typically includes research reports and analysis, personal interviews with analysts or company officials, pricing services, certain trade analytics, and market data. In addition, SSGA and its affiliates receive similar third-party research and brokerage services on the basis of transactions effected by it for its clients. Transactions effected for clients of SSAL may be aggregated with those transactions, although SSGAL client transactions do not give rise to credits used to obtain those third-party services. SSAL and its clients may or may not benefit from those services. SSAL and SSGA may share some or all of the brokerage and research services received or generated by each of them with affiliates. The process by which broker-dealers are selected is designed to limit consideration of the value of any third-party services that SSAL may receive from broker-dealers. Brokerage for Client Referrals: SSAL does not consider whether it or a related person receives client referrals from a broker-dealer or third party in selecting or recommending broker-dealers. SSAL may use broker-dealers that invest, or whose clients invest, in pooled vehicles sponsored or advised by SSAL or its affiliates, or may provide other consideration to those broker dealers. Directed Brokerage: SSAL does not currently recommend, request, or require that clients direct the execution of transactions to specified executing broker-dealers. From time to time, clients may direct SSAL to use a particular broker/dealer to effect transactions consistent with SSAL’s internal policies, as they may be in effect from time to time. As a result, for example, a client may pay higher transaction costs because SSAL may not be able to aggregate the client’s orders with other orders. A client might miss investment opportunities because the broker- dealer to whom a transaction is directed may not have access to certain securities, such as new issues or limited inventory bonds. Directed brokerage may affect the timing of the client’s transaction (for example, there may be times when the client’s trade will not be effected until all non-directed brokerage orders are completed), and may affect the processing of the transaction. The direction of transactions may result in additional credit and/or settlement risk. Trade Aggregation: SSGA and SSAL may identify investment transactions that may be appropriate for two or more accounts for purpose of execution. If an aggregated investment transaction is consistent with SSGA and SSAL’s duties to each such account and permitted by applicable laws and regulations, advisory contracts and investment objectives, then SSGA and SSAL will attempt, but is not required, to acquire or sell a sufficient amount of securities to satisfy all such accounts. SSGA and SSAL may consider the tax status, the nature and size of the aggregated investment, excess cash, and other appropriate factors under the circumstances. When a trade for the same security is placed for more than one account, which also may include accounts and funds of advisory affiliates, it is SSGA and SSAL’s normal practice that such trades will be placed as a block, unless fund restrictions, or the restrictive nature of the market (for example, where trading IDs are required, e.g. China, Korea, Taiwan), prevent from doing so. please register to get more info

All investment management accounts are reviewed regularly, but no less than annually, by the portfolio managers for performance and compliance with applicable investment objectives, guidelines, restrictions and applicable regulatory requirements. Accounts are also routinely reviewed by SSAL’s investment oversight personnel for compliance with investment guidelines, restrictions, and applicable regulatory requirements. Each investment strategy is also reviewed periodically by the State Street Global Advisors Investment Strategy Review Committee with specific emphasis on risk and return characteristics and performance evaluation. Reporting: SSAL provides clients with reports and information as agreed to with the client. The frequency (daily, monthly, or quarterly) is determined by the nature of the report and the needs of the client. Reports may include data relating to purchases and sales, specific regulatory requirements, account holdings, performance, market values and issuer / sector / country exposures as well as commentary on the market and the applicable investment mandate. Reports and information provided vary from client to client and are most often provided in a format requested by the client. please register to get more info

The Adviser does not make payments for referrals of investment advisory clients. please register to get more info

SSAL is affiliated with SSBT which provides custody services to certain non-US clients. please register to get more info

SSAL generally has full investment and discretion for each Fund that it manages, subject to the Fund’s investment objectives, policies, guidelines and restrictions, as well as certain securities, tax and other laws that may, for example, require diversification of investments and impose other limitations. SSAL also has clients for which it only provides investment advice and is not responsible for brokerage execution or account management. please register to get more info

As an investment manager, SSGAL has discretionary proxy voting authority over most of its client accounts, and SSGAL votes these proxies in the manner that we believe will best protect and promote the long-term economic value of client investments. Oversight: The State Street Global Advisors Asset Stewardship Team is responsible for implementing the Proxy Voting Guidelines, case-by-case voting items, issuer engagement activities, and research and analysis of governance and sustainability-related issues. The implementation of the Proxy Voting Guidelines is overseen by the State Street Global Advisors Global Proxy Review Committee (“PRC”), a committee of investment, compliance and legal professionals, who provide guidance on proxy issues as described in greater detail below. Oversight of the proxy voting process is ultimately the responsibility of the State Street Global Advisors Investment Committee. The State Street Global Advisors Investment Committee reviews and approves amendments to the Proxy Voting Guidelines. The State Street Global Advisors PRC reports to the State Street Global Advisors Investment Committee, and may refer certain significant proxy items to that committee. Proxy Voting Process: In order to facilitate SSGAL’s proxy voting process, SSGAL retains Institutional Shareholder Services Inc. (“ISS”), a firm with expertise in proxy voting and corporate governance. SSGAL utilizes ISS’ services in three ways: (1) as SSGAL’s proxy voting agent (providing SSGAL with vote execution and administration services); (2) for applying SSGAL‘s Proxy Voting Guidelines; and (3) as providers of research and analysis relating to general corporate governance issues and specific proxy items. The State Street Global Advisors Asset Stewardship Team reviews its Proxy Voting Guidelines with ISS on an annual basis or on a case-by-case basis as needed. ISS affects the proxy votes in accordance with SSGAL’s Proxy Voting Guidelines. Voting matters that are nuanced or that require additional analysis are referred to and reviewed by members of State Street Global Advisors’ Asset Stewardship Team. State Street Global Advisors Environmental, Social and Governance (“ESG”) analysts evaluate the proxy solicitation to determine how to vote based on facts and circumstances, and consistent with SSGAL’s Proxy Voting Guidelines, that seeks to maximize the value of our client accounts. In some instances, the State Street Global Advisors Asset Stewardship Team may refer significant issues to the State Street Global Advisors PRC for a determination of the proxy vote. In addition, in determining whether to refer a proxy vote to the State Street Global Advisors PRC, the State Street Global Advisors Asset Stewardship Team will consider whether a material conflict of interest exists between the interests of our client and those of SSGAL or its affiliates. SSGAL will review a proxy which may present a potential conflict of interest. Although various relationships could be deemed to giv e rise to a conflict of interest, SSGAL has determined that a material conflict of interest is a conflict between the interests of our client and those of SSGAL or its affiliates. In circumstances where either (i) the matter does not fall clearly within the Proxy Voting Guidelines or (ii) SSGAL determines that voting in accordance with such policies or guidance is not in the best interests of its clients, the State Street Global Advisors Asset Stewardship Team will determine whether a material relationship exists. If so, the matter is referred to the State Street Global Advisors PRC, which then reviews the matter and determines whether a conflict of interest exists, and if so, how to best resolve such conflict. For example, the State Street Global Advisors PRC may (i) determine that the proxy vote does not give rise to a conflict due to the issues presented, (ii) refer the matter to the SSGA Investment Committee for further evaluation, or (iii) retain an independent fiduciary to determine the appropriate vote. SSGAL votes in all markets where it is feasible; however, SSGAL may refrain from voting meetings when power of attorney documentation is required, where voting will have a material impact on our ability to trade the security, or where issuer-specific special documentation is required or various market or issuer certifications are required. SSGAL is unable to vote proxies when certain custodians, used by our clients, do not offer proxy voting in a jurisdiction or when they charge a meeting specific fee in excess of the typical custody service agreement. Information about how SSGAL voted a Fund’s proxies during the most recent 12-month period ended June 30 can be obtained on the SEC’s website at http://www.sec.gov. please register to get more info

SSAL has no financial commitment or condition that is reasonably likely to impair its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding.
Item 19 – Requirements for State-Registered Advisers
SSAL is not registering or registered with any state securities authorities. please register to get more info