Ubs Asset Management (Americas) Llc

Event Detail: ONE FELONY COUNT OF CONSPIRACY TO DEFRAUD THE IRS. ON FEBRUARY 18, 2009, PURSUANT TO A DEFERRED PROSECUTION AGREEMENT WITH THE U.S. DEPARTMENT OF JUSTICE, UBS AG, AN AFFILIATE OF UBS ASSET MANAGEMENT (AMERICAS) INC., CONSENTED TO THE FILING OF A ONE-COUNT INFORMATION BY THE UNITED STATES ATTORNEY IN THE SOUTHERN DISTRICT OF FLORIDA CHARGING UBS AG WITH CONSPIRACY TO DEFRAUD THE INTERNAL REVENUE SERVICE IN VIOLATION OF TITLE 18 U.S.C. SECTION 371. Status: Final Disposition: THE DEPARTMENT OF JUSTICE DISMISSED ALL CRIMINAL CHARGES FOLLOWING UBS'S COMPLIANCE WITH THE DEFERRED PROSECTION AGREEMENT. Summary: CIRCUMSTANCES LEADING TO THE CHARGES WERE PROVIDED ON THE INITIAL FILING. THE CHARGES WERE DISMISSED AFTER UBS MET ALL OBLIGATIONS UNDER THE DEFERRED PROSECUTION AGREEMENT.

Event Detail: DECISION RENDERED ON THAT DATE, DECISION HAS BEEN APPEALED. Status: On Appeal Disposition: VERDICT IS SUSPENDED PENDING THE RESOLUTION OF THE APPEAL. Summary: ALLEGED ILLICIT CROSS-BORDER BUSINESS CONDUCT OF UBS AG INTO FRANCE AND COMPLICITY OF ITS FRENCH SUBSIDIARY IN THE PERIOD OF 2004 - TO 2012.

Event Detail: "CONSPIRACY TO COMMIT TAX FRAUD IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 371 - (1) ONE COUNT, (2) FELONY, (3) GUILTY, AND (4) NO PRODUCT TYPE" Status: Final Disposition: "(A)PLEA OF GUILTY PURSUANT TO PLEA AGREEMENT BETWEEN CREDIT SUISSE AG (CSAG) AND U.S. DEPARTMENT OF JUSTICE (DOJ),(B)MAY 19, 2014, (C)CRIMINAL FINE, SPECIAL ASSESSMENT, RESTITUTION TO INTERNAL REVENUE SERVICE (IRS), AND AGREEMENT TO LAWFULLY UNDERTAKE TO: (1)PROMPTLY DISCLOSE EVIDENCE AND INFORMATION RELATING TO THE CONDUCT UNDERLYING THE PLEA AGREEMENT (INCLUDING THE CONDUCT DESCRIBED IN ATTACHMENTS TO THE PLEA AGREEMENT) IN FORMAT REQUESTED BY DOJ;(2)PROVIDE, AT ITS OWN EXPENSE, FAIR AND ACCURATE TRANSLATIONS OF ANY FOREIGN LANGUAGE DOCUMENTS PRODUCED BY CSAG TO DOJ EITHER DIRECTLY OR THROUGH SWISS FEDERAL TAX ADMINISTRATION;(3)PROVIDE TESTIMONY OR INFORMATION AS REQUESTED BY DOJ;(4)PROVIDE ALL NECESSARY INFORMATION FOR DOJ TO DRAFT TREATY REQUESTS TO SEEK ACCOUNT RECORDS AND OTHER INFORMATION, AND COLLECT AND MAINTAIN ALL RECORDS THAT ARE POTENTIALLY RESPONSIVE TO SUCH TREATY REQUESTS TO FACILITATE PROMPT RESPONSES;(5)(I)CLOSE ACCOUNTS OF RECALCITRANT ACCOUNT HOLDERS; (II)IMPLEMENT PROCEDURES TO PREVENT ITS EMPLOYEES FROM ASSISTING RECALCITRANT ACCOUNT HOLDERS TO ENGAGE IN ACTS OF FURTHER CONCEALMENT IN CONNECTION WITH CLOSING ANY ACCOUNT OR TRANSFERRING ANY FUNDS AND (III) NOT OPEN ANY U.S. RELATED ACCOUNTS EXCEPT ON CONDITIONS THAT ENSURE THAT THE ACCOUNT WILL BE DECLARED TO DOJ AND WILL BE SUBJECT TO DISCLOSURE BY CSAG;(6)NO PORTION OF THE FINE OR OTHER PAYMENTS MADE PURSUANT TO THE PLEA AGREEMENT WILL SERVE AS A BASIS FOR CSAG TO CLAIM ANY TAX DEDUCTION, ANY TAX CREDIT, OR ANY OTHER OFFSET AGAINST THE U.S. FEDERAL, STATE, OR LOCAL TAX OR TAXABLE INCOME, (D)N/A, (E)N/A, (F)(I) CRIMINAL FINE OF $1,333,500,000, LESS A CREDIT OF $196,511,014 FOR CREDIT SUISSE GROUP AG'S PAYMENT TO THE COMMISSION PURSUANT TO ITS ORDER OF FEBRUARY 21, 2014 IN ADMINISTRATIVE PROCEEDING FILE NO. 3-15763 FOR A FINAL PAYMENT OF $1,136,998,986,(II) SPECIAL ASSESSMENT OF $400 AND (III) RESTITUTION TO IRS OF $666,500,000 AND (G)TO BE PAID WITHIN ONE WEEK OF SENTENCING DATE Summary: "PRIOR TO AND THROUGH IN OR ABOUT 2009, CREDIT SUISSE AG (""CSAG""), INCLUDING THROUGH ITS SUBSIDIARY CLARIDEN LEU, OPERATED A CROSSBORDER BANKING BUSINESS THAT AIDED U.S. CLIENTS IN OPENING AND MAINTAINING UNDECLARED ACCOUNTS AND CONCEALING FOREIGN ASSETS AND INCOME FROM THE IRS. PRIVATE BANKERS BASED IN SWITZERLAND SOLICITED U.S. CLIENTS TO OPEN UNDECLARED FINANCIAL ACCOUNTS BASED ON THE PROTECTION OFFERED BY SWISS BANK SECRECY LAWS, WHICH ALLOWED U.S. CLIENTS TO AVOID DISCLOSURE OF THEIR OWNERSHIP OF THE ACCOUNTS AND AVOID OBLIGATIONS TO PAY U.S. TAXES. CSAG ASSISTED SOME U.S. CLIENTS IN ENSURING THAT THEIR OWNERSHIP OF UNDECLARED FINANCIAL ACCOUNTS WOULD NOT BE APPARENT. DUE IN PART TO THE ASSISTANCE OF CSAG AND ITS RELATIONSHIP MANAGERS, NUMEROUS U.S. CLIENTS -- WITH KNOWLEDGE THAT SWISS BANK SECRECY LAWS WOULD PREVENT CSAG FROM DISCLOSING THEIR IDENTITIES TO THE INTERNAL REVENUE SERVICE (""IRS"") -- FILED FALSE TAX RETURNS WITH THE IRS THAT FAILED TO DISCLOSE THEIR INTERESTS IN UNDECLARED ACCOUNTS AND RELATED INCOME. NONE OF THE CONDUCT IS ATTRIBUTABLE TO CREDIT SUISSE ASSET MANAGEMENT, LLC OR ANY CSAG AFFILIATE THAT IS REGISTERED WITH THE COMMISSION AS AN INVESTMENT ADVISER OR BROKER-DEALER. ON MAY 19, 2014, THE U.S. DEPARTMENT OF JUSTICE FILED A ONE-COUNT CRIMINAL INFORMATION IN THE DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA CHARGING CSAG WITH CONSPIRACY TO COMMIT TAX FRAUD RELATED TO ACCOUNTS CSAG ESTABLISHED FOR CROSS-BORDER CLIENTS FROM 2002 UNTIL 2008 IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 371. CSAG AGREED TO RESOLVE THE ACTION BROUGHT BY THE U.S. DEPARTMENT OF JUSTICE THROUGH A PLEA AGREEMENT DATED MAY 19, 2014. UNDER THE PLEA AGREEMENT, CSAG PLEADED GUILTY TO THE CHARGE SET OUT IN THE INFORMATION. CSAG EXPECTS THAT THE DISTRICT COURT WILL ENTER A JUDGMENT OF CONVICTION AGAINST CSAG THAT WILL REQUIRE REMEDIES THAT ARE MATERIALLY THE SAME AS SET FORTH IN THE PLEA AGREEMENT."

Event Detail: ONE COUNT, FELONY, GUILTY, WIRE FRAUD Status: Pending Summary: ON MAY 20, 2015, THE DEPARTMENT OF JUSTICE CRIMINAL DIVISION TERMINATED A DECEMBER 19, 2012 NON-PROSECUTION AGREEMENT (THE NPA) WITH UBS AG. AS A RESULT, ON MAY 20, 2015, UBS AG ENTERED INTO A PLEA AGREEMENT WITH THE DEPARTMENT OF JUSTICE CRIMINAL DIVISION PURSUANT TO WHICH UBS AG AGREED TO AND DID PLEAD GUILTY TO A ONE-COUNT CRIMINAL INFORMATION FILED IN THE DISTRICT OF CONNECTICUT CHARGING UBS AG WITH ONE COUNT OF WIRE FRAUD IN VIOLATION OF 18 USC SECTIONS 1343 AND 1342. AS PART OF THE PLEA AGREEMENT, UBS AG AGREED TO PAY A $203 MILLION PENALTY. THE CRIMINAL INFORMATION CHARGES THAT BETWEEN APPROXIMATELY 2001 AND 2010, UBS AG ENGAGED IN SCHEME TO DEFRAUD COUNTERPARTIES TO INTEREST RATE DERIVATIVES TRANSACTIONS BY MANIPULATING BENCHMARK INTEREST RATES, INCLUDING YEN LIBOR. THE CRIMINAL DIVISION TERMINATED THE NPA BASED ON ITS DETERMINATION, IN ITS SOLE DISCRETION, THAT CERTAIN OF ITS EMPLOYEES COMMITTED CRIMINAL CONDUCT THAT VIOLATED THE NPA, INCLUDING FRAUDULENT AND DECEPTIVE CURRENCY TRADING AND SALES PRACTICES IN CONDUCTING CERTAIN FOREIGN EXCHANGE MARKET TRANSACTIONS WITH CUSTOMERS AND COLLUSION WITH OTHER PARTICIPANTS IN CERTAIN FX MARKETS.

Allegations: IN 2018, THE DOJ FILED A CIVIL COMPLIANT IN THE DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK. THE COMPLAINT SEEKS UNSPECIFIED CIVIL MONETARY PENALTIES UNDER THE FINANCIAL INSTITUTIONS REFORM, RECOVERY AND ENFORCEMENT ACT OF 1989 RELATED TOUBS'S ISSUANCE, UNDERWRITING AND SALE OF 40 RMBS TRANSACTIONS IN 2006 AND 2007. Status: Final Summary: THE PARTIES MUTUALLY AGREED TO SETTLE THE MATTER PER THE EXECUTED "AGREEMENT FOR SETTLEMENT AND RELEASE."

Allegations: PLAINTIFFS HAD ALLEGED THAT DEFENDANTS CONSPIRED TO BLOCK THE EVOLUTION OF THE STOCK LENDING MARKET FROM AN OVER0THE-COUNTER ENVIRONMENT, IN WHICH STOCK LOANS ARE INTERMEDIATED BY PRIME BROKERS, TO A MORE EXCHANGE-LIKE ENVIRONMENT. Status: Final Summary: THE PARTIES REACHED A SETTLEMENT WHICH HAS RECEIVED PRELIMINARY APPROVAL OF THE COURT. THERE WERE NO FINDINGS OR ADMISSIONS, AND DEFENDANTS AFFIRMATIVELY DENIED THE ALLEGATIONS IN THE SETTLEMENT.

Allegations: THE SEC FILED A COMPLAINT ON FEBRUARY 18, 2009 ALLEGING THAT UBS AG PROVIDED BROKER-DEALER AND INVESTMENT ADVISOR SERVICES TO CLIENTS IN THE UNITED STATES WITHOUT BEING REGISTERED WITH SEC, IN VIOLATION OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND THE INVESTMENT ADVISERS ACT OF 1940. Status: Final Summary: IN CONNECTION WITH THE SEC'S INVESTIGATION OF CROSS-BORDER SERVICES PROVIDED TO U.S. CLIENTS BY UBS AG, UBS AG ENTERED INTO A CONSENT DECREE WITH THE SEC WHICH PROVIDES, IN SUMMARY, THAT: UBS AG NEITHER ADMITS NOR DENIES THE ALLEGATIONS IN THE COMPLAINT; UBS AG IS PERMANENTLY ENJOINED FROM VIOLATIONS OF THE EXCHANGE ACT AND THE ADVISERS ACT. UBS AG WILL PAY DISGORGEMENT OF $200 MILLION TO THE SEC; AND UBS AG WILL TERMINATE ITS UNREGISTERED CROSS-BORDER BUSINESS IN THE U.S.

Allegations: "THE SEC FILED A COMPLAINT ON FEBRUARY 18, 2009 ALLEGING THAT UBS AG PROVIDED BROKER-DEALER AND INVESTMENT ADVISOR SERVICES TO CLIENTS IN THE UNITED STATES WITHOUT BEING REGISTERED WITH SEC, IN VIOLATION OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND THE INVESTMENT ADVISERS ACT OF 1940." Status: Final Summary: "IN CONNECTION WITH THE SEC'S INVESTIGATION OF CROSS-BORDER SERVICES PROVIDED TO U.S. CLIENTS BY UBS AG, UBS AG ENTERED INTO A CONSENT DECREE WITH THE SEC WHICH PROVIDES, IN SUMMARY, THAT: UBS AG NEITHER ADMITS NOR DENIES THE ALLEGATIONS IN THE COMPLAINT; UBS AG IS PERMANENTLY ENJOINED FROM VIOLATIONS OF THE EXCHANGE ACT AND THE ADVISERS ACT. UBS AG WILL PAY DISGORGEMENT OF $200 MILLION TO THE SEC; AND UBS AG WILL TERMINATE ITS UNREGISTERED CROSS-BORDER BUSINESS IN THE U.S."

Allegations: "THE ALLEGATIONS ARE RELATED TO ACCOUNTS CONTROLLED BY CREDIT SUISSE ASSET MANAGEMENT LLC (""CSAM"") EXCEEDING POSITION LIMIT RESTRICTIONS PLACED ON SPECULATIVE POSITIONS BY CHICAGO BOARD OF TRADE RULE 562" Status: Final Sanction Detail: - Summary: "CSAM OFFERED TO SETTLE THE ALLEGATIONS DETAILED IN RESPONSE TO QUESTION 7 ABOVE AND THE PANEL OF THE CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE CONCLUDED THAT CSAM VIOLATED CHICAGO BOARD OF TRADE RULE 562 AND ACCEPTED CSAM'S OFFER OF SETTLEMENT."

Allegations: ICE CLEAR CREDIT LLC ("ICE") ALLEGED THAT ON NOVEMBER 16, 2012 AND DECEMBER 12, 2012, UBS AG UNWOUND FIRM TRADES MADE ON NOVEMBER 15, 2012 AND DECEMBER 11, 2012, RESPECTIVELY, WITH THE SAME COUNTERPARTY CLEARING PARTICIPANT AT THE ORIGINAL FIRM TRADE PRICES RATHER THAN THE THEN-CURRENT MARKET PRICES, IN VIOLATION OF ICE RULE 404(B) AND ICE'S END OF DAY PRICE DISCOVERY POLICIES AND PROCEDURES. Status: Final Sanction Detail: MONETARY FINE OF $10,290 IN RELATION TO THE NOVEMBER 16, 2012 OFFSETTING TRADE AND $20,661 IN RELATION TO THE DECEMBER 12, 2012 OFFSETTING TRADE. THESE AMOUNTS WERE PAID ON OCTOBER 31, 2013. Summary: PURSUANT TO ICE RULE 404(B) "MARK-TO-MARKET PRICE" AND THE ICE "END-OF-DAY PRICE DISCOVERY POLICIES AND PROCEDURES," CLEARING PARTICIPANTS OF ICE MAY BE REQUIRED TO ENTER INTO TRANSACTIONS ("FIRM TRADES") WITH OTHER CLEARING PARTICIPANTS AS A RESULT OF ICE'S END-OF-DAY ("EOD") SETTLEMENT PRICE DISCOVERY PROCESS. ALTHOUGH ICE DOES NOT REQUIRE THAT A CLEARING PARTICIPANT MAINTAIN A FIRM TRADE AS AN OUTSTANDING POSITION FOR ANY PARTICULAR LENGTH OF TIME, IF A CLEARING PARTICIPANT ELECTS TO OFFSET A FIRM TRADE, IT MUST DO SO ON TERMS REFLECTING THE THEN-CURRENT MARKET PRICE. ON NOVEMBER 15, 2012 AND DECEMBER 11, 2012, ICE REQUIRED UBS AG, AN ICE CLEARING PARTICIPANT, TO ENTER FIRM TRADES WITH ANOTHER CLEARING PARTICIPANT, WHICH FIRM TRADES UBS AG UNWOUND ON NOVEMBER 16, 2012 AND DECEMBER 12, 2012, RESPECTIVELY, WITH THE SAME COUNTERPARTY CLEARING PARTICIPANT AT THE ORIGINAL FIRM TRADE PRICES. ICE ALLEGED THAT THE FIRM TRADE PRICES DID NOT REPRESENT THE MARKET PRICES AT THE TIME OF UBS AG'S OFFSETTING TRADES, AND THAT THE TRADES THEREFORE VIOLATED ICE RULE 404(B) AND ICE'S EOD SETTLEMENT POLICIES AND PROCEDURES. WITHOUT ADMITTING OR DENYING GUILT, AND HAVING TAKEN REASONABLE MEASURES TO ENSURE THAT UBS AG PERSONNEL IN THE PERTINENT LINE OF BUSINESS AND WITH REPONSIBILITY FOR THE PURCHASE AND SALE OF CREDIT DEFAULT SWAPS CLEARED THROUGH ICE ARE FULLY INFORMED OF THEIR RESPONSIBILITIES UNDER ICE'S RULES AND PROCEDURES, INCLUDING ICE RULE 404(B) AND ICE'S EOD PRICE DISCOVERY POLICIES AND PROCEDURES, UBS AG COMPROMISED AND SETTLED THE MATTER AND AGREED TO THE SANCTIONS SPECIFIED ABOVE.

Allegations: THE ICE FUTURES EUROPE EXCHANGE ALLEGES THAT UBS AG WERE IN BREACH OF THE FOLLOWING EXCHANGE RULES: G.17.1, G.17.4 AND G.17.5. Status: Final Sanction Detail: UBS WILL PAY A TOTAL SETTLEMENT AMOUNT OF 36,666.67 (APPROX. $50,000) THIS COMPRISES: (1) A FINE OF 55,000 FOR THE BEACHES OF THE RULES DESCRIBED AT SECTION 7 ABOVE; (2) A DISCRETIONARY 1/3 DISCOUNT FROM 55,000 FOR EARLY SETTLEMENT. Summary: UBS AND THE SRO HAVE AGREED THE CONTENT OF A DRAFT CIRCULAR CAPTURING THE SETTLEMENT WHICH WILL BE PUBLISHED BY THE SRO IN DUE COURSE. THIS PROVIDES FOR THE ABOVE SETTLEMENT AMOUNT AND CONFIRMS THAT UBS DID BREACH RULES G.17.1, G.17.4, AND G.17.5. THE DATE OF PAYMENT HAS NOT BEEN AGREED.

Allegations: "ON SEPTEMBER 30, 2015, THE BUSINESS CONDUCT COMMITTEE FOR THE CBOE FUTURES EXCHANGE ACCEPTED A LETTER OF CONSENT FROM CREDIT SUISSE AG RELATING TO CERTAIN ALLEGED TECHNICAL VIOLATIONS OF CFE RULE 412B (REPORTABLE POSITIONS). THE SETTLEMENT AGREEMENT, WHICH CREDIT SUISSE AG ENTERED INTO ON A WITHOUT-ADMITTING-OR-DENYING BASIS, (A) INCLUDES FINDINGS THAT ON VARIOUS OCCASIONS FROM OCTOBER 2013 THROUGH MAY 2015, CREDIT SUISSE AG FAILED TO FILE LARGE TRADER REPORTABLE POSITIONS TO THE CBOE FUTURES EXCHANGE ELECTRONICALLY, VIA THE SECURITIES INDUSTRY AUTOMATION CORPORATION (""SIAC"") IN VIOLATION OF CFE RULE 412B; AND (B) REFLECTS CREDIT SUISSE AG'S AGREEMENT TO PAY A $15,000 FINE." Status: Final Sanction Detail: - Summary: "CREDIT SUISSE AG CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS, TO A SETTLEMENT WITH CBOE FUTURES EXCHANGE (CFE) OF POTENTIAL CHARGES ARISING OUT OF ALLEGED TECHNICAL VIOLATIONS OF CFE RULE 412B (REPORTABLE POSITIONS) FOR THE PERIOD OCTOBER 2013 THROUGH MAY 2015. AS PART OF THE SETTLEMENT, CREDIT SUISSE AG AGREED TO PAY A $15,000 FINE."

Allegations: ON 25 MAY 2021, UBS AG INADVERTENTLY CONDUCTED PARTIALLY UNCOVERED SHORT SELLING IN KOREA.THIS IS A ONE-OFF INCIDENT INVOLVING MIS-BOOKING BY HUMAN ERROR WHICH OCCURRED AS RESULT OF A STANDARD MANUAL PROCESS REQUIRED WHEN GLOBAL ONE (THE GLOBAL BOOKS AND RECORDS FOR STOCK, BORROW & LENDING) WAS OFFLINE FOR ITS DAILY BATCH RUNS. THIS LED TO AN INCORRECT LEVEL OF AVAILABLE INVENTORY RECORDED, RESULTING IN THE UNCOVERED TRADES. REMEDIATION ACTIONS HAVE BEEN PUT IN PLACE TO ENHANCE SYSTEMS CONFIGURATIONS TO AVOID THE MANUAL PROCESS. Status: Final Sanction Detail: THE RESTRICTION AND PRE-MARGINING REQUIREMENT IMPOSED ON UBS AG (AS DETAILED IN THERESPONSE TO ITEM 12B ABOVE) WAS COMMUNICATED BY KRX ON 28 JULY 2021, WITH THE EFFECTIVE START DATE OF THE 80-DAY RESTRICTION OF 29 JULY 2021. Summary: UBS AG HAS REQUESTED CLIENTS THAT UTILIZE SYNTHETIC SHORT ACCESS PRODUCT RELATED TO KOREA MARKET OFFERED BY UBS AG TO TRADE THROUGH ALTERNATIVE PROVIDERS DURING THIS PERIOD.

Allegations: THE OFFICE OF THE COMPTROLLER OF THE CURRENCY FOUND THAT UBS AG, NEW YORK BRANCH, UBS AG, STAMFORD BRANCH, UBS AG, MIAMI BRANCH, (COLLECTIVELY, THE "UBS BRANCHES" HAD DEFICIENCIES IN THEIR BANK SECRECY ACT AND ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM THAT RESULTED IN VIOLATIONS OF 12 C.F.R. SECTION 21.21 AND 12 C.F.R. SECTION 21.11 AND OTHER VIOLATIONS. Status: Final Sanction Detail: ON MAY 31, 2018, THE UBS BRANCHES ENTERED INTO A CONSENT ORDER WITH THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC"), WHICH FOUND DEFICIENCIES IN THE BRANCHES' BANK SECRECY ACT AND ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM THAT RESULTED IN VIOLATIONS OF 12 C.F.R. SECTION 21.21 AND 12 CFR SECTION 21.11 AND OTHER VIOLATIONS. WITHOUT ADMITTING OR DENYING THE OCC'S FINDINGS, THE UBS BRANCHES CONSENTED TO THE ENTRY OF THE CONSENT ORDER PURSUANT TO WHICH THE UBS BRANCHES SHALL COMPLY WITH THE UNDERTAKINGS SET FORTH IN THE CONSENT ORDER. Summary: PURSUANT TO THE MAY 31, 2018 CONSENT ORDER, THE UBS BRANCHES SHALL COMPLY WITH THE UNDERTAKINGS SET FORTH THEREIN, INCLUDING SUBMITTING WRITTEN PROPOSALS FOR APPROVAL BY THE OCC, COVERING THE UBS BRANCHES' BANK SECRECY ACT AND ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM.

Allegations: "THE FEDERAL RESERVE BANK OF NEW YORK (FRBNY) HAS DETERMINED THAT (1) IN VIOLATION OF ITS CONTRACT WITH THE FRBNY TO DISTRIBUTE AND REPATRIATE THE U.S. CURRENCY, UBS AG ENGAGED IN U.S. DOLLAR BANKNOTE TRANSACTIONS WITH COUNTERPARTIES IN JURISDICTIONS SUBJECT TO U.S. SANCTIONS AND (2) IN VIOLATION OF LAW, CERTAIN FORMER OFFICERS AND EMPLOYEES OF UBS ENGAGED IN INTENTIONAL ACTS AIMED AT CONCEALING THOSE BANKNOTE TRANSACTIONS FROM THE FRBNY INCLUDING FALSIFICATION OF REPORTS OF THE FRBNY." Status: Final Sanction Detail: - Summary: "UBS AG, WITHOUT ADMITTING TO ANY ALLEGATIONS, CONSENTED TO THE ISSUANCE OF AN ORDER, BY THE FEDERAL RESERVE BOARD, OF ASSESSMENT OF CIVIL MONEY PENALTY IN THE AMOUNT OF $100,000,000.00."

Allegations: THE INVESTIGATION CONCERNED WHETHER UBS AG BREACHED PROVISIONS OF THE STOCK EXCHANGE RULES ON AD HOC PUBLICITY IN THE PERIOD FROM 2007 TO THE END OF 2008 AND THE DIRECTIVE ON INFORMATION RELATING TO CORPORATE GOVERNANCE IN CONNECTION WTIH UBS'S 2008 ANNUAL REPORT. Status: Final Sanction Detail: CONVERTED FROM 100,000 CHF Summary: UBS ACKNOWLEDGES THE DECISION BY THE SIX SANCTIONS COMMISSION AND WILL PAY THE FINE.

Allegations: ON 11 NOVEMBER 2014, THE UK FINANCIAL CONDUCT AUTHORITY ISSUED A FINAL NOTICE TO UBS AG CONCERNING G10 SPOT FX TRADING IN ZURICH. THE FCA DETERMINED THAT UBS AG DID NOT HAVE ADEQUATE SYSTEMS AND CONTROLS IN PLACE IN RELATION TO ITS ZURICH VOICE TRADING OPERATIONS IN THE G10 SPOT FX MARKET AND IMPOSED A PENALTY OF GBP 334,020,000 AND GAVE A 30% DISCOUNT FOR EARLY SETTLEMENT, PRODUCING A FINAL FIGURE OF GBP 233,814,000. Status: Final Sanction Detail: PENALTY OF GBP 334,020,000 WITH A 30% DISCOUNT FOR EARLY SETTLEMENT, PRODUCING A FINAL FIGURE OF GBP 233,814,000. CONVERTED TO $366,169,091. Summary: ON 11 NOVEMBER 2014, THE UK FINANCIAL CONDUCT AUTHORITY ISSUED A FINAL NOTICE TO UBS AG CONCERNING G10 SPOT FX TRADING IN ZURICH. THE FCA DETERMINED THAT UBS AG DID NOT HAVE ADEQUATE SYSTEMS AND CONTROLS IN PLACE IN RELATION TO ITS ZURICH VOICE TRADING OPERATIONS IN THE G10 SPOT FX MARKET AND IMPOSED A PENALTY OF GBP 334,020,000 AND GAVE A 30% DISCOUNT FOR EARLY SETTLEMENT, PRODUCING A FINAL FIGURE OF GBP 233,814,000. PENALTY OF GBP 334,020,000 WITH A 30% DISCOUNT FOR EARLY SETTLEMENT, PRODUCING A FINAL FIGURE OF GBP 233,814,000. CONVERTED TO $366,169,091.

Allegations: THE FSA FOUND THAT UBS AG LONDON BRANCH FAILED TO TAKE REASONABLE CARE TO ENSURE THE SUITABILITY OF ITS ADVICE TO ITS CUSTOMERS TO INVEST IN THE FUND, AND ALSO FAILED TO PAY DUE REGARD TO THE INTERESTS OF ITS CUSTOMERS. FURTHER, THE BREACH WAS IN RELATION, AND LIMITED TO, UBS AG LONDON BRANCH'S BUSINESS IN THE UK IN THIS PARTICULAR PRODUCT. Status: Final Sanction Detail: FSA IMPOSED A FINE OF GBP 9.45 MILLION, WHICH CONVERTED TO USD 14.93 MILLION AS OF 2/08/2013. Summary: THE FSA FOUND THAT UBS AG LONDON BRANCH FAILED TO TAKE REASONABLE CARE TO ENSURE THE SUITABILITY OF ITS ADVICE TO ITS CUSTOMERS TO INVEST IN THE FUND, AND ALSO FAILED TO PAY DUE REGARD TO THE INTERESTS OF ITS CUSTOMERS. FURTHER, THE BREACH WAS IN RELATION, AND LIMITED TO, UBS AG LONDON BRANCH'S BUSINESS IN THE UK IN THIS PARTICULAR PRODUCT. FSA IMPOSED A FINE OF GBP 9.45 MILLION, WHICH CONVERTED TO USD 14.93 MILLION AS OF 2/08/2013.

Allegations: THE MAS HAS IMPOSED A CIVIL PENALTY ON UBS AG (UBS), FOR ACTS OF ITS CLIENT ADVISORS THAT CONTRAVENED SECTION 201(B) OF THE SECURITIES AND FUTURES ACT (SFA). UBS CLIENT ADVISORS HAD ENGAGED IN ACTS THAT DECEIVED OR WERE LIKELY TO DECEIVE CLIENTS ABOUT THE SPREADS AND/OR INTERBANK PRICES FOR TRANSACTIONS IN OVER-THE-COUNTER (OTC) BONDS AND STRUCTURED PRODUCTS. THE ENFORCEMENT ACTION FOLLOWED UBS'S REPORTING OF THE MISCONDUCT TO MAS, AND MAS'S SUBSEQUENT INVESTIGATIONS. THE ENFORCEMENT ACTION AND PENALTY TOOK INTO ACCOUNT THE FACT THAT UBS HAS UNDERTAKEN TO COMPENSATE AFFECTED CLIENTS AND THE FACT THAT THE BANK RENDERED FULL COOPERATION TO MAS DURING THE INVESTIGATION. Status: Final Sanction Detail: CIVIL PENALTY OF SGD11.2 MILLION WAS PAID ON 14 NOVEMBER 2019. Summary: THE MAS HAS IMPOSED A CIVIL PENALTY ON UBS AG (UBS), FOR ACTS OF ITS CLIENT ADVISORS THAT CONTRAVENED SECTION 201(B) OF THE SECURITIES AND FUTURES ACT (SFA). UBS CLIENT ADVISORS HAD ENGAGED IN ACTS THAT DECEIVED OR WERE LIKELY TO DECEIVE CLIENTS ABOUT THE SPREADS AND/OR INTERBANK PRICES FOR TRANSACTIONS IN OVER-THE-COUNTER (OTC) BONDS AND STRUCTURED PRODUCTS. THE ENFORCEMENT ACTION FOLLOWED UBS'S REPORTING OF THE MISCONDUCT TO MAS, AND MAS'S SUBSEQUENT INVESTIGATIONS. THE ENFORCEMENT ACTION AND PENALTY TOOK INTO ACCOUNT THE FACT THAT UBS HAS UNDERTAKEN TO COMPENSATE AFFECTED CLIENTS AND THE FACT THAT THE BANK RENDERED FULL COOPERATION TO MAS DURING THE INVESTIGATION.

Allegations: THE SFC FINED AND REPRIMANDED UBS AG (UBS) FOR OVERCHARGING SOME CLIENTS OVER A TEN-YEAR PERIOD AND FOR RELATED SERIOUS SYSTEMIC INTERNAL CONTROL FAILURES. THE SFC'S INVESTIGATIONS REVEALED THAT BETWEEN 2008 AND 2015, THE CLIENT ADVISORS AND CLIENT ADVISORS' ASSISTANTS IN UBS'S WEALTH MANAGEMENT DIVISION HAD OVERCHARGED CLIENTS WHEN CONDUCTING BOND AND STRUCTURED NOTE TRADES BY INCREASING THE SPREAD CHARGED AFTER THE EXECUTION OF TRADES WITHOUT CLIENTS' KNOWLEDGE; BETWEEN 2008 AND 2017, UBS HAD ALSO CHARGED ITS CLIENTS FEES IN EXCESS OF ITS STANDARD DISCLOSURES OR RATES. THE ENFORCEMENT ACTIONS FOLLOWED UBS'S REPORTING TO THE RELEVANT REGULATORS IN HONG KONG IN 2016 AND SFC'S SUBSEQUENT INVESTIGATIONS. UBS HAS AGREED TO REPAY THE AFFECTED CLIENTS BY REPAYING THEM THE FULL VALUE OF THE OVERCHARGED AMOUNT TOGETHER WITH INTEREST. UBS HAS ALREADY COMMENCED THE REPAYMENT PROCESS TO AFFECTED CLIENTS ON 29 NOVEMBER 2019. Status: Final Sanction Detail: AS PART OF THE SETTLEMENT, UBS AG HAS AGREED TO REPAY THE CLIENTS ALL OVERCHARGES, INCLUDING INTEREST. AMOUNT: ~$ 51,000,000.00 (HK$400M) Summary: THE SFC FINED AND REPRIMANDED UBS AG (UBS) FOR OVERCHARGING SOME CLIENTS OVER A TEN-YEAR PERIOD AND FOR RELATED SERIOUS SYSTEMIC INTERNAL CONTROL FAILURES. THE SFC'S INVESTIGATIONS REVEALED THAT BETWEEN 2008 AND 2015, THE CLIENT ADVISORS AND CLIENT ADVISORS' ASSISTANTS IN UBS'S WEALTH MANAGEMENT DIVISION HAD OVERCHARGED CLIENTS WHEN CONDUCTING BOND AND STRUCTURED NOTE TRADES BY INCREASING THE SPREAD CHARGED AFTER THE EXECUTION OF TRADES WITHOUT CLIENTS' KNOWLEDGE; BETWEEN 2008 AND 2017, UBS HAD ALSO CHARGED ITS CLIENTS FEES IN EXCESS OF ITS STANDARD DISCLOSURES OR RATES. THE ENFORCEMENT ACTIONS FOLLOWED UBS'S REPORTING TO THE RELEVANT REGULATORS IN HONG KONG IN 2016 AND SFC'S SUBSEQUENT INVESTIGATIONS. UBS HAS AGREED TO REPAY THE AFFECTED CLIENTS BY REPAYING THEM THE FULL VALUE OF THE OVERCHARGED AMOUNT TOGETHER WITH INTEREST. UBS HAS ALREADY COMMENCED THE REPAYMENT PROCESS TO AFFECTED CLIENTS ON 29 NOVEMBER 2019.

Allegations: THE TURKISH CAPITAL MARKETS BOARD ALLEGED THAT UBS ENTERED INTO CERTAIN TRANSACTIONS ON 1JULY 2020 THAT CONSTITUTED SHORT SELLING AND WERE NOT DISCLOSED AS SHORT SALES AS REQUIREDUNDER TURKISH REQUIREMENTS. Status: Final Sanction Detail: TOTAL AMOUNT OF FINE IMPOSED ON UBS AG LONDON BRANCH WAS TRY 328,706 AND WAS DUE FOR PAYMENT BY 2 JULY 2021. IF THE FINE IS PAID BY 2 JULY 2021, THE FINE IS DISCOUNTED BY 25% AND THE AMOUNT PAYABLE IS TRY 246,529. Summary: UBS AG LONDON BRANCH HAS WRITTEN TO THE CMB TO NOTE THAT PAYMENT OF THE FINE IS NOT TO BE INTERPRETED AS: (I) ACCEPTANCE OF THE ALLEGED BREACHES; OR (II) SUBMISSION TO THE JURISDICTION OF THE CMB. SUBJECT TO FURTHER CORRESPONDENCE FROM THE CMB, UBS CONSIDERS THIS MATTER TO BE CLOSED.

Allegations: THE SFC FINED AND REPRIMANDED UBS AG AND UBS SECURITIES ASIA LIMITED (COLLECTIVELY "UBS") HK$9.8M AND HK$1.75M RESPECTIVELY OVER VARIOUS REGULATORY BREACHES WHICH CONCERNED UBS'S SYSTEMS AND CONTROLS. THE SFC FOUND THAT UBS FAILED TO: - MAKE PROPER DISCLOSURE OF ITS FINANCIAL INTERESTS IN SOME HONG KONG LISTED COMPANIES COVERED IN ITS RESEARCH REPORTS DUE TO MULTIPLE DATA FEED LOGIC ERRORS IN A LEGACY DATA SOURCE USED BY UBS FOR TRACKING ITS SHAREHOLDING POSITIONS. - OBTAIN VALID STANDING AUTHORITIES FROM 91 CLIENTS WHO WERE NOT QUALIFIED AS PROFESSIONAL INVESTORS AND ISSUE CONTRACT NOTES TO THEM IN RESPECT OF 913 SECURITIES POOLED LENDING TRANSACTIONS ENTERED INTO WITH THESE CLIENTS. - RECORD CLIENT ORDER INSTRUCTIONS RECEIVED THROUGH 35 TELEPHONE LINES. - FOLLOW APPLICABLE REGULATORY GUIDELINES RELATING TO ASSESSMENT OF CLIENTS' DERIVATIVES KNOWLEDGE. - DISCLOSE TO 15 CLIENTS A KEY FEATURE OF A STRUCTURED NOTE BEFORE SELLING THEM THE NOTE. Status: Final Sanction Detail: AS PART OF THE SETTLEMENT, UBS HAS AGREED TO PAY A FINE TO THE SFC IN THE AMOUNT OFHKD11.55M (~USD 1.48M). Summary: THE SFC FINED AND REPRIMANDED UBS AG AND UBS SECURITIES ASIA LIMITED (COLLECTIVELY "UBS") HK$9.8M AND HK$1.75M RESPECTIVELY OVER VARIOUS REGULATORY BREACHES WHICH CONCERNED UBS'S SYSTEMS AND CONTROLS. THE SFC FOUND THAT UBS FAILED TO: -MAKE PROPER DISCLOSURE OF ITS FINANCIAL INTERESTS IN SOME HONG KONG LISTED COMPANIES COVERED IN ITS RESEARCH REPORTS DUETO MULTIPLE DATA FEED LOGIC ERROS IN A LEGACY DATA SOURCE USED BY UBS FOR TRACKING ITS SHAREHOLDING POSITIONS. -OBTAIN VALID STATNDING AUTHORITIES FROM 91 CLIENTS WHO WERE NOTQUALIFIED AS PROFESSIONAL INVESTORS AND ISSUE CONTRACT NOTES TO THEM IN RESPECT OF 913SECURITIES POOLED LENDING TRANSACTIONS ENTERED INTO WITH THESE CLIENTS. -RECORD CLIENT ORDERINSTRUCTIONS RECEIVED THROUGH 35 TELEPHONE LINES. -FOLLOW APPLICABLE REGULATORY GUIDELINES RELATING TO ASSESSMENT OF CLIENTS' DERIVATIVES KNOWLEDGE. -DISCLOSE TO 15 CLIENTS A KEY FEATURE OF A STRUCTURED NOTE BEFORE SELLING THEM THE NOTE.

Allegations: IN 2017, THE COMISSAO DE VALORES MOBILIARIOS (CVM), OR THE BRAZIL SECURITIES COMMISSION, REVIEWED CERTAIN TRADES OCCURRING IN APRIL 2014 BY A NUMBER OF FINANCIAL INSTITUTIONS, ALLEGING THAT SUCH TRADING WAS IN VIOLATION OF CVM INSTRUCTION 530/2012, WHICH GENERALLY PROHIBITS INVESTORS FROM SHORT SELLING SHARES IN A COMPANY DURING CERTAIN DATES JUST PRIOR TO THE COMPANY'S ANNOUNCEMENT OF A PUBLIC OFFERING OF CERTAIN SHARES AT CERTAIN PRICES. THE SHARES AT ISSUE WERE OIBR3 AND OIBR4 IN BRAZILIAN COMPANY OI S.A. Status: Final Sanction Detail: ADMINISTRATIVE FINE OF 300,00 BRAZILIAN REALS (BR) (APPROXIMATELY $53,000) WAS PAID BY UBS LONDON BRANCH ON MARCH 4, 2021, WITH RECEIPT OF PAYMENT ACKNOWLEDGED BY THE CVM ON MARCH 16, 2021, AND PROOF OF SOURCE OF FUNDS USED FOR PAYMENT OF THE FINE ESTABLISHED ON APRIL 23, 2021. NO PORTION WAS WAIVED. Summary: UBS AG LONDON BRANCH MAINTAINED ITS POSITION THAT ITS APRIL 2014 TRADES IN OIBR3 AND OIBR4 WERE TO BE DISTINGUISHED FROM THOSE OF OTHER FINANCIAL INSTITUTIONS ACTING AS INVESTOR, AS UBS AG LONDON BRANCH ACTED EXCLUSIVELY IN THE CAPACITY OF BROKER PROVIDING GLOBAL SYNTHETIC PRIME BROKERAGE SERVICES. THE MATTER WITH UBS AG LONDON BRANCH SETTLED WITH AN ADMINISTRATIVE FINE LEVIED IN THE AMOUNT OF 300,000 BRAZILIAN REALS (APPROXIMATELY $53,000),WITHOUTUBS AG LONDON BRANCH ADMITTING OR DENYING ANY FACTUAL FINDINGS OR ANY LIABILITY, AND WITHOUT FURTHER PROCEEDINGS OR HEARING. UPON RECEIPT OF PROOF OF SOURCE OF FUNDS USED FOR PAYMENT OF THE FINE, AS REQUIRED UNDER BRAZIL REGULATION, CVM CONFIRMED THE MATTER SATISFIED, FINAL AND CLOSED AS TO UBS AG LONDON BRANCH, ON APRIL 23, 2021, WHILE THE LARGER MATTER REMAINS OPEN AS TO ONE OR MORE OF THE OTHER FINANCIAL INSTITUTIONS.

Allegations: "MATTER 1:THE CCO HAS DETERMINED THAT CREDIT SUISSE AG, SYDNEY BRANCH (""CS-AG"") DID NOT COMPLY WITH ASX CLEAR (FUTURES) OPERATING RULE (""ASX CFR"") 46.5 AND RULE 46.5 OF THE ASX CLEAR (FUTURES) PROCEDURES, DETERMINATIONS AND PRACTICE NOTES (THE ""DIRECTION""), BY FAILING TO CLOSE OUT BACK-TO-BACK OPEN POSITIONS IN ACCORDANCE WITH THE DIRECTION, RESULTING IN ITS REPORTED DAILY BENEFICIAL OWNERSHIP REPORT (""DBOR"") DAY 1 POSITIONS BEING INACCURATE IN CONTRAVENTION OF ASX 24 OPERATING RULE 6704 (EACH A ""CONTRAVENTION""). MATTER 2: CS AG CONDUCTED A REVIEW OF THE PRE-SUBMISSION RECONCILIATION CHECK FOR DBOR REPORTING. THE REVIEW IDENTIFIED THAT THE SAME OMNIBUS ACCOUNT SYSTEM SHOWED A POSITION OF 1 LONG AND 1 SHORT IN PARTICULAR CONTRACT FOR A RELATED ENTITY, WHILE IN CS-AG'S SYSTEM THESE TWO POSITIONS WERE NETTED TO ZERO. CS-AG WENT ON TO IDENTIFY FOUR AFFILIATED ENTITIES." Status: Final Sanction Detail: - Summary: THE FIRM PAID THE FINE ON OCTOBER 3, 2017.

Allegations: "THE FSA FOUND THAT UBS AG LONDON BRANCH FAILED TO TAKE REASONABLE CARE TO ENSURE THE SUITABILITY OF ITS ADVICE TO ITS CUSTOMERS TO INVEST IN THE FUND, AND ALSO FAILED TO PAY DUE REGARD TO THE INTERESTS OF ITS CUSTOMERS. FURTHER, THE BREACH WAS IN RELATION, AND LIMITED TO, UBS AG LONDON BRANCH'S BUSINESS IN THE UK IN THIS PARTICULAR PRODUCT." Status: Final Sanction Detail: - Summary: "THE FSA FOUND THAT UBS AG LONDON BRANCH FAILED TO TAKE REASONABLE CARE TO ENSURE THE SUITABILITY OF ITS ADVICE TO ITS CUSTOMERS TO INVEST IN THE FUND, AND ALSO FAILED TO PAY DUE REGARD TO THE INTERESTS OF ITS CUSTOMERS. FURTHER, THE BREACH WAS IN RELATION, AND LIMITED TO, UBS AG LONDON BRANCH'S BUSINESS IN THE UK IN THIS PARTICULAR PRODUCT. FSA IMPOSED A FINE OF GBP 9.45 MILLION, WHICH CONVERTED TO USD 14.93 MILLION AS OF 2/08/2013."

Allegations: "BASED ON AN ON-SITE AML INSPECTION OF CREDIT SUISSE AG SINGAPORE BRANCH (""CSSB""), THE MONETARY AUTHORITY OF SINGAPORE (""MAS"") IDENTIFIED CERTAIN AML CONTROL WEAKNESSES THAT IT CONCLUDED AMOUNTED TO SEVEN CATEGORIES OF BREACHES OF SINGAPORE'S PRINCIPAL AML REGULATION, MAS NOTICE 626. THESE FINDINGS PERTAIN TO WEAKNESSES IN AML CONTROLS GENERALLY AND ARE NOT LIMITED TO THE MANAGEMENT AND MONITORING OF ANY PARTICULAR ACCOUNTS." Status: Final Sanction Detail: - Summary: "THE MAS CONCLUDED THAT CSSB BREACHED MAS NOTICE 626 IN THE FOLLOWING SEVEN WAYS IN RELATION TO THE PARTICULAR ACCOUNTS THAT WERE THE SUBJECT OF THE MAS'S INSPECTION: (1) REQUIREMENT TO OBSERVE CONDUCT OF ACCOUNT AND TRANSACTIONS TO ENSURE CONSISTENCY WITH THE BANK'S KNOWLEDGE OF THE CUSTOMER PROFILE; (2) REQUIREMENT TO PAY SPECIAL ATTENTION TO ALL COMPLEX OR UNUSUALLY LARGE TRANSACTIONS/UNUSUAL PATTERNS OF TRANSACTIONS THAT HAVE NO APPARENT ECONOMIC PURPOSE; (3) REQUIREMENT TO INQUIRE INTO THE BACKGROUND AND PURPOSE OF THE UNUSUALLY LARGE TRANSACTIONS/UNUSUAL PATTERNS OF TRANSACTIONS AND DOCUMENTING THIS INFORMATION SO THAT IT IS AVAILABLE TO THE COMPETENT AUTHORITIES IF ASKED FOR; (4) REQUIREMENT TO INCLUDE IN MESSAGE OR PAYMENT INSTRUCTION FOR CROSS-BORDER TRANSFERS EXCEEDING SGD 2,000 EVERY WIRE TRANSFER ORIGINATOR'S ADDRESS/UNIQUE IDENTIFICATION NUMBER; (5) REQUIREMENT TO INCLUDE IN MESSAGE OR PAYMENT INSTRUCTION FOR CROSS-BORDER TRANSFERS EXCEEDING SGD 1,500 EVERY WIRE TRANSFER ORIGINATOR'S ADDRESS/UNIQUE IDENTIFICATION NUMBER; (6) REQUIREMENT TO DEVELOP AND IMPLEMENT ADEQUATE INTERNAL POLICIES, PROCEDURES AND CONTROLS FOR DETECTION OF UNUSUAL AND/OR SUSPICIOUS TRANSACTIONS; AND (7) REQUIREMENT TO DEVELOP AND IMPLEMENT ADEQUATE INTERNAL POLICIES, PROCEDURES AND CONTROLS TO MEET THE REQUIREMENT OF THE NOTICE 626 FOR THE PREVENTION OF MONEY LAUNDERING AND TERRORISM FINANCING. CSSB IS TAKING THE FINDINGS SERIOUSLY AND HAS MADE A COMMITMENT TO THE MAS TO IMPLEMENT SPECIFIC MEASURES TO STRENGTHEN ITS AML CONTROLS AND PROCESSES (IN ADDITION TO RECENT ENHANCEMENTS WHICH HAVE ALREADY BEEN MADE OVER THE PAST 12 MONTHS). THE MAS HAS FINED CSSB S$1.7M FOR ALL THE IDENTIFIED BREACHES OF MAS NOTICE 626 FOLLOWING THE AML INSPECTION. THE MAS HAS ATTRIBUTED S$700K OF THIS FINE TO BREACHES OF AML REQUIREMENTS AND SUSPICIOUS TRANSACTIONS THAT MAY BE CONNECTED TO 1MDB AND IT IS THIS S$700K FINE THAT WAS PUBLICLY ANNOUNCED. HOWEVER, THE MAS DID NOT DETECT PERVASIVE CONTROL WEAKNESSES WITHIN CS. THE FINE WILL NOT AFFECT CSSB'S OPERATIONS AND THE BANK DOES NOT EXPECT ANY FURTHER ENFORCEMENT ACTION BY MAS ON THE MATTER."

Allegations: "ON FEBRUARY 8, 2018, THE HONG KONG SECURITIES AND FUTURES COMMISSION ANNOUNCED IT HAD REACHED A RESOLUTION WITH THE THREE HONG KONG CREDIT SUISSE ENTITIES LISTED ABOVE TO RESOLVE VARIOUS HISTORICAL REGULATORY BREACHES AND INTERNAL CONTROL FAILURES RELATING TO CREDIT SUISSE'S HONG KONG-BASED EQUITIES AND PRIVATE BANKING BUSINESSES. THE RESOLUTION RELATES TO THE FOLLOWING AREAS: 1) SHORT POSITION REPORTING; 2) SEGREGATION OF CLIENT SECURITIES; 3) REGULATORY REPORTING OF DIRECT BUSINESS TRANSACTIONS; 4) SHORT SELLING ACTIVITIES; 5) ENSURING SUITABILITY OF RISK MISMATCH TRANSACTIONS FOR PRIVATE BANKING CLIENTS; 6) ELECTRONIC TRADING; AND 7) DISCLOSURE OF INFORMATION IN CONTRACT NOTES AND CHARGING OF COMMISSIONS TO PRIVATE BANKING CLIENTS. TO FACILITATE THE SFC'S INVESTIGATION AND RESOLUTION OF THIS MATTER, THE SFC AND CREDIT SUISSE JOINTLY ENGAGED VARIOUS INDEPENDENT REVIEWERS TO REVIEW CREDIT SUISSE'S INTERNAL SYSTEMS AND CONTROLS IN RESPECT OF THE ABOVE AREAS. IN REACHING THE RESOLUTION, THE SFC TOOK INTO ACCOUNT, AMONG OTHER THINGS, THAT CREDIT SUISSE HAD SELF-REPORTED ITS REGULATORY BREACHES AND INVOLVED SENIOR MANAGEMENT AT AN EARLY STAGE TO ADDRESS THE SFC'S CONCERNS, THAT CREDIT SUISSE HAD FULLY COOPERATED IN THE SFC'S INQUIRIES AND IN RESOLVING THE SFC'S REGULATORY CONCERNS, AND HAD TAKEN REMEDIAL ACTIONS TO STRENGTHEN ITS INTERNAL CONTROLS AND SYSTEMS." Status: Final Sanction Detail: - Summary: THE FINE WAS PAID ON FEBRUARY 8, 2018.

Allegations: "ON JULY 21, 2023, THE UK PRUDENTIAL REGULATION AUTHORITY ISSUED A FINAL NOTICE TO CREDIT SUISSE INTERNATIONAL (CSI) AND CREDIT SUISSE SECURITIES (EUROPE) LTD (CSSEL) CONCERNING VARIOUS RISK MANAGEMENT AND GOVERNANCE FAILINGS ASSOCIATED WITH THE MANAGEMENT OF CREDIT SUISSE'S RELATIONSHIP WITH ARCHEGOS CAPITAL MANAGEMENT LP (ARCHEGOS) PRIOR TO ARCHEGOS' DEFAULT IN MARCH 2021. THE FINAL NOTICE INCLUDED FINDINGS OF BREACHES OF PRA FUNDAMENTAL RULES 2, 3, 5 AND 6 BETWEEN JANUARY 1, 2020 AND MARCH 31, 2021, WITH THE PRINCIPAL FAILINGS REFERENCED RELATING TO INADEQUATE ESCALATION AND OVERSIGHT OF THE RISKS RELATED TO ARCHEGOS, INSUFFICIENT STEPS BEING TAKEN TO MITIGATE OR REDUCE THE RISKS ARISING FROM THE RELATIONSHIP WITH ARCHEGOS AND INSUFFICIENT OWNERSHIP OF RISK WITHIN THE FIRST LINE ." Status: Final Sanction Detail: - Summary: "ON JULY 21, 2023, CREDIT SUISSE SETTLED AT AN EARLY STAGE OF THE PRA'S INVESTIGATION TO QUALIFY FOR A DISCOUNTED FINANCIAL PENALTY, AGREEING TO PAYMENT OF A MONETARY FINE OF GBP 87,082,000; THE AGREEMENT RESOLVED CLAIMS OF RISK MANAGEMENT AND GOVERNANCE FAILURES IN CONNECTION WITH THE FIRMS' EXPOSURES TO ARCHEGOS."

Allegations: "ON NOVEMBER 13, 2019, THE FINANCIAL SUPERVISORY SERVICE OF KOREA (""FSS"") IMPOSED AN ADMINISTRATIVE FINE ON AN EMPLOYEE OF ONE OF REGISTRANT'S ADVISORY AFFILIATES. THE FSS FOUND THAT SUCH ADVISORY AFFILIATE EMPLOYEE ENGAGED IN SHORT SALES BY SWAP TRANSACTION BEFORE THE PUBLIC DISCLOSURE OF THE INFORMATION AND, AS A RESULT, GAINED AN UNJUST PROFIT AMOUNTING TO KRW 582.7 MILLION." Status: Final Sanction Detail: - Summary: SEE ABOVE - FINAL

Allegations: ON JUNE 17, 2009, UBS AG MADE A SUBSTANTIAL SHAREHOLDING DISCLOSURE IN THE ISSUER PETROLEUM GEO-SERVICES ASA 3 DAYS LATE Status: Final Sanction Detail: ACTUAL FINE WAS 200,000 NORWEGIAN KRONERS, FINE AMOUNT ABOVE IS A CONVERSION TO US DOLLARS AT TODAY'S RATE. Summary: ON JUNE 17, 2009, UBS AG MADE A SUBSTANTIAL SHAREHOLDING DISCLOSURE IN THE ISSUER PETROLEUM GEO-SERVICES ASA 3 DAYS LATE. MATTER WAS CLOSED WITH (AWC) AND FINE.

Allegations: THE EUROPEAN COMMISSION ("EC") FOUND THAT UBS AG INFRINGED ARTICLE 101 OF THE TREATY ANDARTICLE 53 OF THE EUROPEAN ECONOMIC AREA AGREEMENT. THE EC FOUND THAT UBS AG ENGAGED INRESTRICTION AND/OR DISTORTION OF COMPETITION IN THE SECTOR OF FOREIGN EXCHANGE SPOT TRADINGOF G10 CURRENCIES. UBS RECEIVED FULL IMMUNITY FROM FINES FOR REPORTING THE CONDUCT TO THE EC. Status: Final Sanction Detail: UBS RECEIVED FULL IMMUNITY FROM FINES FOR REPORTING THE CONDUCT TO THE BC. Summary: N/A

Allegations: ON MAY 20, 2015, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ISSUED AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONETARY PENALTY ISSUED UPON CONSENT (THE "FEDERAL RESERVE ORDER") TO UBS AG. AS PART OF THE FEDERAL RESERVE ORDER, UBS AG AGREED TO PAY A $342 MILLION CIVIL MONETARY PENALTY. THE FEDERAL RESERVE'S ORDER IS BASED ON THE FEDERAL RESERVE'S FINDING THAT UBS AG HAD DEFICIENT POLICIES AND PROCEDURES THAT PREVENT UBS AG FROM DETECTING AND ADDRESSING UNSAFE AND UNSOUND CONDUCT BY FOREIGN EXCHANGE TRADERS AND SALESPEOPLE, INCLUDING DISCLOSURES TO TRADERS OF OTHER INSTITUTIONS OF CONFIDENTIAL CUSTOMER INFORMATION, AGREEMENTS WITH TRADERS OF OTHER INSTITUTIONS TO COORDINATE FOREIGN EXCHANGE TRADING IN A MANNER TO INFLUENCE THE WM/R AND ECB FOREIGN EXCHANGE BENCHMARKS FIXES AND MARKET PRICES, TRADING STRATEGIES THAT RAISED POTENTIAL CONFLICTS OF INTEREST, POSSIBLE AGREEMENTS WITH TRADERS OF OTHER INSTITUTIONS REGARDING BID/OFFER SPREADS OFFERED TO FOREIGN EXCHANGE CUSTOMERS, THE PROVISION OF INFORMATION TO CUSTOMERS REGARDING PRICE QUOTES, AND THE PROVISION OF NFORMATION TO CUSTOMERS ABOUT HOW A CUSTOMER'S FOREIGN EXCHANGE ORDER IS FILLED. Status: Final Sanction Detail: $342 MILLION CIVIL MONETARY PENALTY AND CEASE AND DESIST ORDER. Summary: ON MAY 20, 2015, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ISSUED AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONETARY PENALTY ISSUED UPON CONSENT (THE "FEDERAL RESERVE ORDER") TO UBS AG. AS PART OF THE FEDERAL RESERVE ORDER, UBS AG AGREED TO PAY A $342 MILLION CIVIL MONETARY PENALTY. THE FEDERAL RESERVE'S ORDER IS BASED ON THE FEDERAL RESERVE'S FINDING THAT UBS AG HAD DEFICIENT POLICIES AND PROCEDURES THAT PREVENT UBS AG FROM DETECTING AND ADDRESSING UNSAFE AND UNSOUND CONDUCT BY FOREIGN EXCHANGE TRADERS AND SALESPEOPLE, INCLUDING DISCLOSURES TO TRADERS OF OTHER INSTITUTIONS OF CONFIDENTIAL CUSTOMER INFORMATION, AGREEMENTS WITH TRADERS OF OTHER INSTITUTIONS TO COORDINATE FOREIGN EXCHANGE TRADING IN A MANNER TO INFLUENCE THE WM/R AND ECB FOREIGN EXCHANGE BENCHMARKS FIXES AND MARKET PRICES, TRADING STRATEGIES THAT RAISED POTENTIAL CONFLICTS OF INTEREST, POSSIBLE AGREEMENTS WITH TRADERS OF OTHER INSTITUTIONS REGARDING BID/OFFER SPREADS OFFERED TO FOREIGN EXCHANGE CUSTOMERS, THE PROVISION OF INFORMATION TO CUSTOMERS REGARDING PRICE QUOTES, AND THE PROVISION OF NFORMATION TO CUSTOMERS ABOUT HOW A CUSTOMER'S FOREIGN EXCHANGE ORDER IS FILLED.

Allegations: ON DECEMBER 19, 2012, FINMA ANNOUNCED THAT IT CONCLUDED ITS ADMINISTRATIVE PROCEEDINGS AGAINST UBS AG IN CONNECTION WITH THE SUBMISSION OF BENCHMARK INTEREST RATES. IN ITS ORDER, FINMA ESTABLISHED THAT UBS AG VIOLATED SWISS FINANCIAL MARKET LEGISLATION, IMPOSED SUPERVISORY MEASURES AND DISGORGEMENT OF CHF 59 MILLION TO THE SWISS CONFEDERATION. Status: Final Sanction Detail: DISGORGEMENT OF CHF 59 MILLION TO THE SWISS CONFEDERATION PLUS CHF 1.6 MILLION IN PROCEDURAL COSTS TO FINMA. Summary: ON DECEMBER 19, 2012, FINMA ANNOUNCED THAT IT CONCLUDED ITS ADMINISTRATIVE PROCEEDINGS AGAINST UBS AG IN CONNECTION WITH THE SUBMISSION OF BENCHMARK INTEREST RATES. IN ITS ORDER, FINMA ESTABLISHED THAT UBS AG VIOLATED SWISS FINANCIAL MARKET LEGISLATION, IMPOSED SUPERVISORY MEASURES AND DISGORGEMENT OF CHF 59 MILLION TO THE SWISS CONFEDERATION, PLUS CHF 1.6 MILLION IN PROCEDURAL COSTS TO FINMA.

Allegations: "THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY (""FINMA"") BROUGHT AN ACTION AGAINST CREDIT SUISSE INTERNATIONAL, CREDIT SUISSE SECURITIES (EUROPE) LTD., AND CREDIT SUISSE GROUP AG IN CONNECTION WITH THREE INTERCONNECTED TRANSACTIONS FROM 2013 - 2016: (I) A SYNDICATED LOAN TO A MOZAMBICAN STATE-OWNED ENTITY; (II) AN OFFERING OF INTEREST-BEARING LOAN PARTICIPATION NOTES (""LPNS"") USED TO FINANCE DEBT OFFERED TO ANOTHER MOZAMBICAN STATE-OWNED ENTITY; AND (III) AN EXCHANGE OFFERING PURSUANT TO WHICH HOLDERS OF THE LPNS WERE PERMITTED TO EXCHANGE LPNS FOR NEW SOVEREIGN BONDS ISSUED BY THE GOVERNMENT OF MOZAMBIQUE. CERTAIN PERSONNEL EMPLOYED BY AN AFFILIATE OF CS GROUP, CREDIT SUISSE SECURITIES (EUROPE) RECEIVED KICKBACKS AND CERTAIN MOZAMBICAN GOVERNMENT OFFICIALS WERE PAID BRIBES IN CONNECTION WITH THE SYNDICATED LOAN AND LPN TRANSACTIONS. IN RESPECT OF THESE TRANSACTIONS WITH MOZAMBIQUE BETWEEN 2013 AND 2016, CREDIT SUISSE VIOLATED THE DUTY TO FILE A SUSPICIOUS ACTIVITY REPORT AS THE FILING IN 2019 WAS CONSIDERED TOO LATE. FINMA NOTED THAT CREDIT SUISSE DID NOT PAY ENOUGH ATTENTION TO THE RISKS ARISING FROM SPECIFIC SOVEREIGN LENDING TRANSACTIONS, AND ORDERED THE BANK TO REMEDIATE ALL DEFICIENCIES IDENTIFIED IN CONNECTION WITH THESE TRANSACTIONS BY JUNE 30, 2022. FINMA IMPOSED A BUSINESS RESTRICTION UNTIL AN IMPLEMENTATION AUDITOR REVIEWED AND APPROVED ALL MEASURES TAKEN." Status: Final Sanction Detail: - Summary: "THIS ACTION IS CONSIDERED FINAL AS OF OCTOBER 19, 2021 AND CONSIDERED RESOLVED ALTHOUGH FINMA HAS NOT REMOVED ITS BUSINESS RESTRICTION (TRANSPARENCY MEASURE). "

Allegations: "ON JUNE 7, 2007, THE FRENCH REGULATORY AUTHORITY, AUTORITE DES MARCHES FINANCIERS (AMF), FOUND UBS O'CONNOR LIMITED VIOLATED FRENCH SECURITIES LAW WITH RESPECT TO CERTAIN TRADES MADE IN NOVEMBER OF 2002 AND FINED UBS O'CONNOR LIMITED 1,500,000 EUROS." Status: Final Sanction Detail: - Summary: "ON JUNE 7, 2007, THE FRENCH REGULATORY AUTHORITY, AUTORITE DES MARCHES FINANCIERS (AMF), FOUND UBS O'CONNOR LIMITED VIOLATED FRENCH SECURITIES LAW WITH RESPECT TO CERTAIN TRADES MADE IN NOVEMBER OF 2002 AND FINED UBS O'CONNOR LIMITED 1,500,000 EUROS. THIS FINE WAS PAID ON DECEMBER 13, 2007."

Allegations: "UBS AG, REGISTRANT'S ADVISORY AFFILIATE, ON MAY 10, 2004, WAS ASSESSED A CIVIL MONEY PENALTY OF $100,000,000 BY THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE ""BOARD""). THE BOARD PRINCIPALLY DETERMINED THAT UBS AG ENTERED INTO U.S. DOLLAR BANK NOTE TRANSACTIONS IN ZURICH, SWITZERLAND, WITH COUNTERPARTIES WHO WERE SUBJECT TO SANCTIONS BY THE OFFICE OF FOREIGN ASSETS CONTROL. IT SHOULD BE NOTED THAT REGISTRANT WAS NOT INVOLVED WITH OR A PARTY TO THE TRANSACTIONS IN QUESTION." Status: Final Sanction Detail: - Summary: PLEASE SEE ABOVE.

Allegations: "UBS TAIPEI BRANCH (A BRANCH OF UBS AG,) WAS ALLEGED TO HAVE BREACHED PARAGRAPH 45-1 OF THE BANKING LAW, AS PERMITTED UNDER ARTICLE 123 OF THE SAME LAW, IN NOT HAVING ESTABLISHED OR NOT HAVING PROPERLY IMPLEMENTED ADEQUATE INTERNAL CONTROLS. IN ADDITION, IN ACCORDANCE WITH ARTICLE 61-1 OF THE BANKING LAW, UBS WAS ORDERED TO DISMISS A FOREIGN EXCHANGE DEALER." Status: Final Sanction Detail: - Summary: UBS TAIPEI BRANCH WAS FINED TWD 5 MILLION, CONVERTED TO USD $159,250 AS OF 4/28/2005.

Allegations: "THE FSA ALLEDGED BREACH OF RULE 5.49 OF THE SECURITIES AND FUTURES ASSOCIATION (""SFA"") RULES AND SUP 17.4R AND SUP 15.61R OF THE FSA RULES." Status: Final Sanction Detail: - Summary: "UBS AG HAS A WEALTH MANAGEMENT DIVISION THAT CARRIES OUT TRANSACTIONS ON BEHALF OF ITS CLIENTS WHICH ARE REQUIRED TO BE REPORTED IN ACCORDANCE WITH SUP 17.4R. SINCE OCTOBER 1999, ALL HAD BEEN INCORRECTLY HARD CODED AS PRINCIPAL WHEN THEY SHOULD HAVE BEEN REPORTED AS AGENCY."

Allegations: "THE UNITED KINGDOM FINANCIAL CONDUCT AUTHORITY (""FCA"") BROUGHT AN ACTION AGAINST CREDIT SUISSE INTERNATIONAL, CREDIT SUISSE SECURITIES (EUROPE) LTD., AND CREDIT SUISSE GROUP AG IN CONNECTION WITH THREE INTERCONNECTED TRANSACTIONS FROM 2013 - 2016: (I) A SYNDICATED LOAN TO A MOZAMBICAN STATE-OWNED ENTITY; (II) AN OFFERING OF INTEREST-BEARING LOAN PARTICIPATION NOTES (""LPNS"") USED TO FINANCE DEBT OFFERED TO ANOTHER MOZAMBICAN STATE-OWNED ENTITY; AND (III) AN EXCHANGE OFFERING PURSUANT TO WHICH HOLDERS OF THE LPNS WERE PERMITTED TO EXCHANGE LPNS FOR NEW SOVEREIGN BONDS ISSUED BY THE GOVERNMENT OF MOZAMBIQUE. CERTAIN PERSONNEL EMPLOYED BY AN AFFILIATE OF CS GROUP, CREDIT SUISSE SECURITIES (EUROPE), RECEIVED KICKBACKS AND CERTAIN MOZAMBICAN GOVERNMENT OFFICIALS WERE PAID BRIBES IN CONNECTION WITH THE SYNDICATED LOAN AND LPN TRANSACTIONS. CREDIT SUISSE AGREED THAT IN RESPECT OF THESE TRANSACTIONS WITH MOZAMBIQUE BETWEEN 2013 AND 2016, ITS UK OPERATIONS HAD FAILED TO CONDUCT ITS BUSINESS WITH DUE SKILL, CARE AND DILIGENCE IN BREACH OF PRINCIPLE 2. ITS UK OPERATIONS HAD ALSO FAILED TO TAKE REASONABLE CARE TO ORGANIZE AND CONTROL ITS AFFAIRS RESPONSIBLY AND EFFECTIVELY, WITH ADEQUATE RISK MANAGEMENT SYSTEMS IN BREACH OF PRINCIPLE 3 AND SYSC 6.1.1R. CREDIT SUISSE AGREED TO PAY A PENALTY OF USD 200,664,504 AND AGREED TO FORGIVE USD 200 MILLION OF DEBT OWED BY MOZAMBIQUE." Status: Final Sanction Detail: - Summary: "THIS ACTION IS CONSIDERED FINAL AS OF OCTOBER 19, 2021. CREDIT SUISSE PAID A PENALTY OF USD 200,664,504 AND FORGAVE USD 200 MILLION OF DEBT OWED BY MOZAMBIQUE."

Allegations: "THE ALLEGATIONS ARE RELATED TO CREDIT SUISSE AG'S OPERATION OF AN ILLEGAL CROSS-BORDER BANKING BUSINESS THAT AIDED AND ASSISTED U.S. CLIENTS IN OPENING AND MAINTAINING UNDECLARED ACCOUNTS AND CONCEALING THEIR OFFSHORE ASSETS AND INCOME FROM THE INTERNAL REVENUE SERVICE AND NEW YORK AUTHORITIES. NONE OF THE ALLEGED CONDUCT IS ATTRIBUTABLE TO CREDIT SUISSE ASSET MANAGEMENT, LLC OR ANY CREDIT SUISSE AG AFFILIATE THAT IS REGISTERED WITH THE COMMISSION AS AN INVESTMENT ADVISER OR BROKER-DEALER." Status: Final Sanction Detail: - Summary: "ON MAY 19, 2014, THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (THE ""DFS"") AND CREDIT SUISSE AG (""CSAG"") ENTERED INTO A CONSENT ORDER (THE ""ORDER"") TO RESOLVE THE DFS' FINDINGS DESCRIBED ABOVE. THE ORDER, AMONG OTHER THINGS, (I) REQUIRES CSAG TO PAY THE DFS A $715,000,000 CIVIL MONETARY PENALTY, (II) REQUIRES CSAG TO ENGAGE AN INDEPENDENT MONITOR SELECTED BY THE DFS TO CONDUCT A COMPREHENSIVE REVIEW OF CSAG'S COMPLIANCE PROGRAMS, POLICIES AND PROCEDURES AND RECOMMEND ADDITIONAL REMEDIAL MEASURES BASED ON THE FINDINGS OF THAT REVIEW AND (III) REQUIRES THE TERMINATION OF, AND PLACES RESTRICTIONS ON, THE EMPLOYMENT OF CERTAIN EMPLOYEES INVOLVED IN THE MISCONDUCT."

Allegations: "THE ALLEGATIONS ARE RELATED TO CREDIT SUISSE AG'S NEW YORK REPRESENTATIVE OFFICE BEING ENGAGED IN INVESTMENT ADVISORY ACTIVITIES THAT WERE NOT PERMISSIBLE FOR A REPRESENTATIVE OFFICE TO CONDUCT UNDER THE PROVISIONS OF THE INTERNATIONAL BANKING ACT AND REGULATION K OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM, AND OPENING FOREIGN ACCOUNTS FOR U.S. TAXPAYERS THAT, IN CERTAIN INSTANCES, WERE NOT REPORTED TO THE U.S. GOVERNMENT AS REQUIRED BY LAW. NONE OF THE ALLEGED CONDUCT IS ATTRIBUTABLE TO CREDIT SUISSE ASSET MANAGEMENT, LLC OR ANY CSAG AFFILIATE THAT IS REGISTERED WITH THE COMMISSION AS AN INVESTMENT ADVISER OR BROKER-DEALER." Status: Final Sanction Detail: - Summary: "ON MAY 19, 2014, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE ""FEDERAL RESERVE BOARD"") AND CREDIT SUISSE AG (""CSAG"") AGREED TO THE ISSUANCE OF A CONSENT CEASE AND DESIST ORDER AND CIVIL MONEY PENALTY ASSESSMENT (THE ""ORDER"") AGAINST CSAG TO RESOLVE THE FEDERAL RESERVE BOARD'S FINDINGS DESCRIBED ABOVE. THE ORDER, AMONG OTHER THINGS, (I) REQUIRES CSAG TO TAKE CERTAIN ACTIONS WITH RESPECT TO CORPORATE GOVERNANCE AND MANAGEMENT OVERSIGHT, (II) PLACES A LIMITATION ON CSAG REPRESENTATIVE OFFICE ACTIVITIES, (III) REQUIRES THE TERMINATION OF, AND PLACES RESTRICTIONS ON, THE EMPLOYMENT OF EMPLOYEES INVOLVED IN THE MISCONDUCT, AND (IV) PROVIDES FOR A CIVIL MONEY PENALTY IN THE AMOUNT OF $100,000,000."

Allegations: THE FRB CONSENT ORDER, ARISING FROM RISK MANAGEMENT FAILINGS ASSOCIATED WITH THE MARCH 2021 DEFAULT OF ARCHEGOAS CAPITAL MANAGEMENT LP, ALLEGES VIOLATIONS UNDER SECTION 8(I)(2) OF THE FEDERAL DEPOSIT INSURANCE ACT, AS WELL AS SECTIONS 252.155-157 OF REGULATION YY OF THE BOARD OF GOVERNORS; THE ALLEGATIONS ARE BASED ON FINDINGS THAT CREDIT SUISSE HAD DEFICIENCES IN RISK MANAGEMENT, LACKING ADEQUATE GOVERNANCE, EXPERIENCED STAFF WITH SUFFICIENT STATURE, AND SUFFICIENT DATA QUALITY AND MODEL RISK MANAGEMENT TO ENSURE THAT ACTIVITIES CONDUCTED BY ARCHEGOS WERE PROPERLY RISK-MANAGED. Status: Final Sanction Detail: THE BOARD OF GOVERNORS JOINTLY ASSESSED CS AND UBS A CIVIL MONETARY FINE IN THE AMOUNT OF $4,268,494,109.20, WHICH WAS PAID ON JULY 24, 2023. Summary: ON JULY 21, 2023 CREDIT SUISSE AND UBS AGREED TO THE ISSUANCE OF A CEASE AND DESIST ORDER AND CIVIL MONEY PENALTY ASSESSMENT ISSUED BY THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM, AGREEING TO PAYMENT OF A CIVIL MONEY PENALTY IN THE AMOUNT OF $268,494,109.20; ACCOUNTABILITY FOR EMPLOYEES INVOLVED IN MISCONDUCT; AND ADOPTION OF A WRITTEN MANAGEMENT OVERSIGHT PLAN. THE AGREEMENT RESOLVED CLAIMS THAT CS FAILED TO ADDRESS IDENTIFIED RISKS ASSOCIATED WITH ARCHEGOS' PORTFOLIO.

Allegations: "ON FEBRUARY 18, 2009, FINMA, THE SWISS FINANCIAL MARKETS SUPERVISORY AUTHORITY, PUBLISHED THE RESULTS OF THE INVESTIGATION OF UBS AG'S CROSS-BORDER BUSINESS IN THE U.S. BY THE SWISS FEDERAL BANKING COMMISSION (""EBK""). THE EBK CONCLUDED THAT UBS AG HAD OPERATED ITS US. CROSS-BORDER BUSINESS IN A MANNER THAT ""VIOLATED ITS WARRANTY AND ORGANIZATION REQUIREMENTS"" UNDER THE SWISS BANKING ACT. THE EBK ENJOINED UBS FROM FURTHER OPERATING ITS CROSS-BORDER PRIVATE BANKING BUSINESS WITH PERSONS HAVING THEIR RESIDENCE OR DOMICILE IN THE US THROUGH ANY UBS ENTITIES NOT REGISTERED WITH THE SEC. 8. CURRENT STATUS? PENDING ON APPEAL FINAL 9. IF ON APPEAL, REGULATORY ACTION APPEALED TO (SEC, SRO, FEDERAL OR STATE COURT) AND DATE APPEAL FILED: IF FINAL OR ON APPEAL, COMPLETE ALL ITEMS BELOW. FOR PENDING ACTIONS, COMPLETE ITEM 13 ONLY. 10. HOW WAS MATTER RESOLVED: ORDER 11. RESOLUTION" Status: Final Sanction Detail: - Summary: "ON FEBRUARY 18, 2009, FINMA, THE SWISS FINANCIAL MARKETS SUPERVISORY AUTHORITY, PUBLISHED THE RESULTS OF THE INVESTIGATION OF UBS AG'S CROSS-BORDER BUSINESS IN THE U.S. BY THE SWISS FEDERAL BANKING COMMISSION (""EBK""). THE EBK CONCLUDED THAT UBS AG HAD OPERATED ITS US. CROSS-BORDER BUSINESS IN A MANNER THAT ""VIOLATED ITS WARRANTY AND ORGANIZATION REQUIREMENTS"" UNDER THE SWISS BANKING ACT. THE EBK ENJOINED UBS FROM FURTHER OPERATING ITS CROSS-BORDER PRIVATE BANKING BUSINESS WITH PERSONS HAVING THEIR RESIDENCE OR DOMICILE IN THE USA THROUGH ANY UBS ENTITIES NOT REGISTERED WITH THE SEC."

Allegations: ON 12 NOVEMBER 2014, THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ANNOUNCED THAT IT HAD ISSUED AN ORDER CONCERNING UBS AG'S FOREIGN EXCHANGE AND PRECIOUS METALS TRADING IN ZURICH, SWITZERLAND. FINMA CONCLUDED THAT UBS AG HAD VIOLATED THE REGULATORY REQUIREMENTS FOR ENSURING PROPER BUSINESS CONDUCT, IMPOSED SUPERVISORY MEASURES, AND ORDERED DISGORGEMENT OF CHF 133.9 MILLION. Status: Final Sanction Detail: IMPOSED SUPERVISORY MEASURES, AND ORDERED DISGORGEMENT OF CHF 133.9 MILLION. Summary: ON 12 NOVEMBER 2014, THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ANNOUNCED THAT IT HAD ISSUED AN ORDER CONCERNING UBS AG'S FOREIGN EXCHANGE AND PRECIOUS METALS TRADING IN ZURICH, SWITZERLAND. FINMA CONCLUDED THAT UBS AG HAD VIOLATED THE REGULATORY REQUIREMENTS FOR ENSURING PROPER BUSINESS CONDUCT, IMPOSED SUPERVISORY MEASURES, AND ORDERED DISGORGEMENT OF CHF 133.9 MILLION.

Allegations: THE FSA FOUND THAT BETWEEN JANUARY 1, 2005 AND DECEMBER 31, 2010, UBS AG BREACHED PRINCIPLES 3 AND 5 OF THE FSA'S PRINCIPLES FOR BUSINESSES THROUGH MISCONDUCT RELATING TO THE CALCULATION OF LIBOR AND EURIBOR. Status: Final Sanction Detail: ON DECEMBER 19, 2012, UBS AG ENTERED INTO A SETTLEMENT AGREEMENT WITH THE FSA PURSUANT TO WHICH UBS AGREED TO PAY A FINE OF GBP 160,000,000 TO THE FSA, CONVERTED TO USD 259,984,000 AT THE DECEMBER 19, 2012 CONVERSION RATE. Summary: THE FSA FOUND THAT BETWEEN JANUARY 1, 2005 AND DECEMBER 31, 2010, UBS AG BREACHED PRINCIPLES 3 AND 5 OF THE FSA'S PRINCIPLES FOR BUSINESSES THROUGH MISCONDUCT RELATING TO THE CALCULATION OF LIBOR AND EURIBOR. ON DECEMBER 19, 2012, UBS AG ENTERED INTO A SETTLEMENT AGREEMENT WITH THE FSA PURSUANT TO WHICH UBS AGREED TO PAY A FINE OF GBP 160,000,000 TO THE FSA.

Allegations: "THE DFS'S ALLEGATIONS RELATE TO CREDIT SUISSE'S FOREIGN EXCHANGE (FX) VOICE AND ELECTRONIC TRADING BUSINESSES, INCLUDING THAT (1) CREDIT SUISSE FX VOICE TRADERS MAY HAVE MANIPULATED FX RATES BY ENGAGING IN COORDINATED TRADING OR SHARING CONFIDENTIAL INFORMATION, (2) CREDIT SUISSE INAPPROPRIATELY USED AND DISCLOSED A TRADING FEATURE KNOWN AS ""LAST LOOK,"" AND (3) CREDIT SUISSE PROGRAMMED AN ALGORITHM THAT MAY HAVE FRONT RUN CLIENT ORDERS." Status: Final Sanction Detail: - Summary: FINE WAS PAID ON NOVEMBER 21, 2017.

Allegations: UBS AG ENGAGED IN U.S. DOLLAR BANKNOTE TRANSACTIONS WITH COUNTERPARTIES IN JURISDICTIONS SUBJECT TO U.S. SANCTIONS, AND CERTAIN FORMER OFFICERS AND EMPLOYEES OF UBS AG ENGAGED IN INTENTIONAL ACTS AIMED AT CONCEALING THOSE BANKNOTE TRANSACTIONS FROM THE FEDERAL RESERVE BANK OF NEW YORK ("FRBNY") INCLUDING FALSIFICATION OF REPORTS TO FRBNY. Status: Final Sanction Detail: WITHOUT ADMITTING TO ANY ALLEGATIONS, UBS AG CONSENTED TO THE ISSUANCE OF AN ORDER AND PAID A CIVIL MONEY PENALTY OF $100,000,000 ON MAY 10, 2004. Summary: WITHOUT ADMITTING TO ANY ALLEGATIONS, UBS AG CONSENTED TO THE ISSUANCE OF AN ORDER AND PAID A CIVIL MONEY PENALTY OF $100,000,000 ON MAY 10, 2004.

Allegations: ON OR ABOUT JULY 24, 2023, THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY (FINMA) CONCLUDED PROCEEDINGS AGAINST CREDIT SUISSE, FINDING THAT CREDIT SUISSE HAS SERIOUSLY AND SYSTEMATICALLY VIOLATED FINANCIAL MARKET LAW IN ITS RELATIONSHIP WITH THE ARCHEGOS FAMILY OFFICE TO TO VARIOUS ORGANIZATIONAL DEFINICIENCIES AND INSUFFICIENT RISK MANAGEMENT. Status: Final Sanction Detail: FINMA IS ORDERING CORRECTIVE MEASURES DIRECTED AT CREDIT SUISSE AG AND UBS GROUP AG, AS THE LEGAL SUCCESSOR OF CREDIT SUISSE GROUP AG, UPON COMPLETION OF THE MERGER BETWEEN THE TWO BANKS. FINMA REQUIRED UBS TO APPLY ITS RESTRICTIONS/LIMITS ON PROPRIETARY POSITIONS RELATING TO INDIVIDUAL CLIENTS THROUGHOUT THE ENTIRE FINANCIAL GROUP. ADDITIONALLY, THE COMPENSATION SYSTEM OF THE ENTIRE FINANCIAL GROUP MUST PROVIDE FOR BONUS ALLOCATION CRITERIA THAT TAKE INTO ACCOUNT RISK APPETITE. UBS HAS CORRESPONSING RULES IN PLACE, WHICH FINMA ORDERS TO BE LEGALLY BINDING FOR THE ENTIRE FINANCIAL GROUP. Summary: SEE ABOVE RESPONSES.

Allegations: THE CFTC ALLEGED THAT DURING THE RELEVANT PERIOD (JULY 8, 2019 TO DECEMBER 23, 2019) UBS AG FAILED TO KEEP REQUIRED VOICE RECORDING FILES CONTAINING ORAL COMMUNICATIONS RELATEDTOREGULATED SWAP ACTIVITY AND PRE-EXECUTION TRADE INFORMATION FROM, DESPITE THE ONE-YEAR RETENTION PERIOD REQUIRED UNDER REGULATION 23.203(B)(2), 17 C.F.R. § 23.203(B)(2) (2020) ANDTHATTHESE FAILURES VIOLATED SECTION 4S(G)(1) OF THE ACT AND REGULATIONS 23.201(A)(1), 23.202(A)(1)AND 23.203(B)(1). Status: Final Sanction Detail: FINE WAS PAID ON OR ABOUT NOVEMBER 10, 2021. Summary: THE ORDER FINDS THAT PRIOR TO JUNE 2019, UBS, TO COMPLY WITH ITS RECORDKEEPING OBLIGATIONS AS A SWAP DEALER, IMPLEMENTED MULTIPLE SOFTWARE SYSTEMS TO: (1) OPERATE ITS TRADER TURRET COMMUNICATION DEVICES; (2) RECORD CALLS OCCURRING ON THESE TRADER TURRETS;AND (3) STORE THE VOICE RECORDING FILES THAT WERE GENERATED FROM THE RECORDED CALLS. THE RECORDING SYSTEM HAD A KNOWN FAILURE IN WHICH, AT TIMES, THE MULTIPLE SYSTEMS FAILED TO SYNCHRONIZE CERTAIN CALL DATA, INCLUDING THE UBS TRADER'S IDENTITY, WHICH WOULD NOT TRANSFER TO UBS'S VOICE RECORDING SYSTEM ALONG WITH THE CORRESPONDING VOICE RECORDING. THIS SYNCHRONIZATION FAILURE CREATED A POPULATION OF VOICE RECORDING FILES THAT WERE NOT ASSIGNED TO A PARTICULAR TRADER. THESE UNASSIGNED VOICE RECORDING FILES, CATEGORIZED AS "TRADER 0" RECORDINGS, WERE TRANSFERRED TO UBS AG'S LONG-TERM STORAGE SYSTEMS WHERE THEY WERE TO BE RETAINED FOR FIVE YEARS. AS OF JULY 8,2019, UBS BEGAN PREMATURELY DELETING, AFTER ONLY ONE DAY OF RETENTION, VOICE RECORDING FILES WHICH INCLUDED VOICE RECORDINGS CONTAINING PRE-EXECUTION SWAPS TRADE INFORMATION THAT WERE REQUIRED TO BE RETAINED FOR ONE YEAR. THIS WAS A RESULT OF A TECHNOLOGY ANALYST BELIEVING THAT THE VOICE RECORDINGS WERE TEST FILES THAT DID NOT NEED TO BE RETAINED AND RE-DESIGNATING THOSE FILES WHICH RESET THE RETENTION PERIOD FOR THESE FILES FROM FIVE YEARS TO ONE DAY. IN DECEMBER 2019, UBS INADVERTENTLY LEARNED ABOUT THE PREMATURE DELETION OF THESE AUDIO FILES FROM ITS SYSTEMS WHILE IT WAS SEARCHING FOR, BUT NOT FINDING, SPECIFIC VOICE RECORDING FILES THAT IT KNEW SHOULD HAVE BEEN IN ITS RETENTION SYSTEMS. UPON DISCOVERY OF THE ERRONEOUS DELETIONS OF RECORDINGS, UBS DID AN INTERNAL REVIEW TO DETERMINE THE UNIVERSE OF IMPACTED VOICE RECORDING FILES. THE ANALYST'S ERROR RESULTED IN THEDELETION OF OVER 1,000 HOURS, OR ROUGHLY 2.76 PERCENT OF TOTAL U.S. RECORDED VOLUME, DURING JULY 8, 2019 THROUGH DECEMBER 23, 2019. THE DELETED FILES INCLUDED VOICE RECORDINGS CONTAINING PRE-EXECUTION SWAPS INFORMATION SUCH AS QUOTES, SOLICITATIONS, BIDS, OFFERS, INSTRUCTIONS, TRADING, AND PRICES THAT LEAD TO THE EXECUTION OF SWAPS, ALL OF WHICH ARE REQUIRED BY COMMISSION REGULATIONS TO BE RETAINED. UPON DISCOVERING ITS POTENTIAL VIOLATION OF CFTC REGULATIONS, UBS PROMPTLY SELF-REPORTED THIS VIOLATION TO CFTC STAFF VIA TELEPHONE, FOLLOWED BY FORMALLY SUBMITTING A COMPREHENSIVE WRITTEN SELF-REPORT. UBS COOPERATED WITH CFTC STAFF IN ITS INVESTIGATION AND PROACTIVELY ENGAGED IN REMEDIAL PROCEDURES TO ENSURE NO "TRADER 0" RECORDINGS ARE PREMATURELY DELETED IN THE FUTURE.

Allegations: "THE SEC ORDER ALLEGES THAT BETWEEN 2007 AND 2013, EMPLOYEES OF CREDIT SUISSE (HONG KONG) LIMITED IN THE ASIA PACIFIC REGION PROVIDED EMPLOYMENT OPPORTUNITIES TO RELATIVES AND ASSOCIATES OF GOVERNMENT OFFICIALS AND STATE-0WNED ENTERPRISE EMPLOYEES IN CHINA AND HONG KONG TO INFLUENCE THE AWARDING OF INVESTMENT BANKING MANDATES." Status: Final Sanction Detail: - Summary: "CREDIT SUISSE GROUP AG PAID A TOTAL OF USD 29,823,904 AND CONSENTED TO THE ENTRY OF A CEASE-AND-DESIST ORDER TO SETTLE ALLEGATIONS THAT EMPLOYEES OF CREDIT SUISSE (HONG KONG) LIMITED PROVIDED EMPLOYMENT OPPORTUNITIES TO RELATIVES AND ASSOCIATES OF GOVERNMENT OFFICIALS AND STATE-0WNED ENTERPRISE EMPLOYEES IN CHINA AND HONG KONG TO INFLUENCE THE AWARDING OF INVESTMENT BANKING MANDATES. NO MONITORSHIP OR OTHER AFFIRMATIVE UNDERTAKINGS WERE IMPOSED ON ANY CREDIT SUISSE ENTITY."

Allegations: UBS AG EXCEEDED THE NYMEX'S POSITION LIMITS ON CERTAIN NATURAL GAS, HEATING OIL AND PLATINUM FUTURES CONTRACTS ON MORE THAN ONE OCCASION FROM, ON OR ABOUT DECEMBER 2006 THROUGH ON OR ABOUT MARCH 2008. Status: Final Sanction Detail: CEASE AND DESIST, MONETARY FINE Summary: THIS MATTER IS FINAL.

Allegations: UBS ASSET MANAGEMENT (AMERICAS) INC. ("UBS AM") MANAGED CERTAIN REGISTERED INVESTMENT COMPANIES ("FUNDS"). UBS AM WAS ALLEGED TO HAVE WILLFULLY AIDED AND ABETTED AND CAUSED THE FUNDS' VIOLATION, FOR SEVERAL DAYS IN 2008, OF RULE 22C-1 OF THE INVESTMENT COMPANY ACT. UBS AM WAS ALSO ALLEGED TO HAVE WILLFULLY AIDED AND ABETTED AND CAUSED THE FUNDS' VIOLATION OF RULE 38A-1 OF THE INVESTMENT COMPANY ACT. Status: Final Sanction Detail: UBS AM WAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULES 22C-1 AND 38A-1 UNDER THE INVESTMENT COMPANY ACT. UBS AM WAS ALSO CENSURED AND ORDERED TO PAY A CIVIL MONEY PENALTY OF $300,000. Summary: UBS AM MANAGED CERTAIN FUNDS AND WAS ALLEGED TO HAVE WILLFULLY AIDED AND ABETTED AND CAUSED THE FUNDS' VIOLATION OF RULE 22C-1 OF THE INVESTMENT COMPANY ACT. UBS AM WAS ALSO ALLEGED TO HAVE WILLFULLY AIDED AND ABETTED AND CAUSED THE FUNDS' VIOLATION OF RULE 38A-1 OF THE INVESTMENT COMPANY ACT. UBS AM SETTLED THE MATTER WITHOUT ADMITTING OR DENYING THE FINDINGS EXCEPT AS TO THE SEC'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THE PROCEEDINGS.

Allegations: "THE REGULATORY ACTION INVOLVED ALLEGED VIOLATION OF RULE 105 OF REGULATION M OF THE SECURITIES EXCHANGE ACT OF 1934 BASED ON REGISTRANT'S APPLICATION OF THE RULE'S SEPARATE ACCOUNT EXEMPTION. THE SEC ALLEGED THE REGISTRANT VIOLATED RULE 105 VARIOUS TIMES BETWEEN JANUARY 2009 AND MARCH 2011 BASED UPON ITS APPLICATION OF THE STATED EXEMPTION. RULE 105 GENERALLY PROHIBITS PURCHASING AN EQUITY SECURITY IN A REGISTERED SECONDARY OFFERING IF THE PURCHASER SOLD THE SAME SECURITY SHORT DURING A RESTRICTED PERIOD (GENERALLY DEFINED AS FIVE BUSINESS DAYS BEFORE THE PRICING OF THE OFFERING) WITHOUT THE AVAILABILITY OF AN EXCEPTION UNDER THE RULE." Status: Final Sanction Detail: - Summary: "ON JUNE 3, 2013, REGISTRANT VOLUNTARILY AGREED TO SETTLE AN SEC INQUIRY RELATING TO RULE 105 OF REGULATION M UNDER THE SECURITIES EXCHANGE ACT OF 1934 WITHOUT ADMITTING OR DENYING THE SEC'S ALLEGATIONS. RULE 105 GENERALLY PROHIBITS PURCHASING AN EQUITY SECURITY IN A REGISTERED SECONDARY OFFERING IF THE PURCHASER SOLD SHORT THE SAME SECURITY DURING A RESTRUCTURED PERIOD (USUALLY DEFINED AS FIVE BUSINESS DAYS BEFORE THE PRICING OF THE OFFERING). RULE 105'S PROHIBITION APPLIES IRRESPECTIVE OF ANY INTENT TO VIOLATE THE RULE AND THE ISSUE AT HAND INVOLVED REGISTRANT'S INTERPRETATION AND APPLICATION OF THE SEPARATE ACCOUNT EXEMPTION ALLOWED UNDER THE RULE. THE SEC'S ALLEGATIONS ARE DESCRIBED IN ITEM 7 ABOVE. DURING THE COURSE OF THE INVESTIGATION, REGISTRANT FULLY COOPERATED WITH THE SEC AT ALL TIMES, CHANGED ITS POLICIES AND PROVIDED ITS EMPLOYEES WITH TRAINING ON THE NEW POLICY. AS PART OF THE SETTLEMENT, REGISTRANT WAS CENSURED, AGREED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY FUTURE VIOLATIONS OF RULE 105 OF REGULATION M AND AGREED TO PAY A CIVIL MONEY PENALTY OF $1,140,000, DISGORGEMENT OF $3,787,590 AND PREJUDGMENT INTEREST OF $369,766 TO THE UNITED STATES TREASURY."

Allegations: ON 11 NOVEMBER 2014, THE CFTC ISSUED AN ORDER CONCERNING UBS AG'S FOREIGN EXCHANGE SPOT TRADING AROUND CERTAIN FOREIGN EXCHANGE BENCHMARKS. IN THE ORDER, THE CFTC FOUND THAT UBS AG VIOLATED CERTAIN SECTIONS OF THE COMMODITY EXCHANGE ACT, IMPOSED REMEDIAL SANCTIONS, AND IMPOSED A CIVIL MONETARY PENALTY OF $290 MILLION. Status: Final Sanction Detail: REMEDIAL SANCTIONS,CIVIL MONETARY PENALTY OF $290 MILLION. Summary: ON 11 NOVEMBER 2014, THE CFTC ISSUED AN ORDER CONCERNING UBS AG'S FOREIGN EXCHANGE SPOT TRADING AROUND CERTAIN FOREIGN EXCHANGE BENCHMARKS. IN THE ORDER, THE CFTC FOUND THAT UBS AG VIOLATED CERTAIN SECTIONS OF THE COMMODITY EXCHANGE ACT, IMPOSED REMEDIAL SANCTIONS, AND IMPOSED A CIVIL MONETARY PENALTY OF $290 MILLION.

Allegations: THE CFTC ALLEGED THAT UBS AG, BY AND THROUGH THE ACTS OF CERTAIN PRECIOUS METALS SPOT TRADERS, ATTEMPTED TO MANIPULATE THE PRICE OF PRECIOUS METALS FUTURES CONTRACTS THROUGH SPOOFING AND ATTEMPTED TO MANIPULATE THE PRICE OF PRECIOUS METALS FUTURES CONTRACTS IN ORDER TO TRIGGER CUSTOMER STOP LOSS ORDERS. Status: Final Sanction Detail: $15,000,000 CIVIL MONETARY PENALTY WAS PAID BY UBS AG ON FEBRUARY 6, 2018 Summary: THE CFTC CONDUCTED AN INVESTIGATION OF UBS'S PRECIOUS METALS TRADING. AS FAR AS UBS IS AWARE, THE CFTC'S INVESTIGATION BEGAN IN 2014. IT WAS RESOLVED ON JANUARY 29, 2018.

Allegations: "THE SECURITIES AND EXCHANGE COMMISSION (""SEC"") ENTERED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS (THE ""SEC ORDER"") AGAINST CREDIT SUISSE ASSET MANAGEMENT, LLC (""CSAM"") AND CERTAIN OF ITS AFFILIATES IN CONNECTION WITH CSAM CONTINUING TO SERVE AS INVESTMENT ADVISER TO REGISTERED INVESTMENT COMPANIES FOLLOWING THE ENTRY OF A NEW JERSEY STATE ORDER (""NJ ORDER""), ISSUED ON OCTOBER 24, 2022, AGAINST CERTAIN OF CSAM'S AFFILIATES BASED ON CSAM'S AND ITS AFFILIATES' POSITION AT THE TIME THAT THE NJ ORDER DID NOT TRIGGER THE DISQUALIFICATION PROVISIONS OF SECTION 9(A) OF THE 1940 ACT. CSAM CONSENTED TO THE SEC ORDER WITHOUT ADMITTING OR DENYING THE FINDINGS THEREIN. THE SEC ORDER STATES THAT THE NJ ORDER CAUSED CSAM TO BE DEEMED INELIGIBLE TO PROVIDE INVESTMENT ADVISORY SERVICES TO REGISTERED INVESTMENT COMPANIES AND EMPLOYEES' SECURITIES COMPANIES (""ESCS"") UNDER SECTION 9(A) OF THE INVESTMENT COMPANY ACT OF 1940, AS AMENDED (THE ""1940 ACT"") AND THAT, DURING THE PERIOD FROM OCTOBER 24, 2022 TO JUNE 7, 2023, CSAM ACTED AS AN INVESTMENT ADVISER TO REGISTERED INVESTMENT COMPANIES AND ESCS IN VIOLATION OF SECTION 9(A) OF THE 1940 ACT." Status: Final Sanction Detail: - Summary: "THIS ACTION IS CONSIDERED FINAL AS OF DECEMBER 13, 2023. CREDIT SUISSE PAID A DISGORGEMENT, PREJUDGMENT INTEREST AND CIVIL PENALTIES TOTALING USD 10,080,220."

Allegations: "THE ALLEGATIONS ARE RELATED TO CSAG'S SOLICITATION AND PROVISION OF BROKER-DEALER AND INVESTMENT ADVICE SERVICES TO CERTAIN U.S. CROSS-BORDER CLIENTS DURING A TIME WHICH CSAG WAS NOT REGISTERED WITH THE COMMISSION AS A BROKER-DEALER OR INVESTMENT ADVISER." Status: Final Sanction Detail: - Summary: "ON FEBRUARY 21, 2014, CSAG REACHED A SETTLEMENT WITH THE SEC THAT RESOLVES AN INVESTIGATION RELATING TO ITS SOLICITATION AND PROVISION OF BROKER-DEALER AND INVESTMENT ADVICE SERVICES TO CERTAIN U.S. CROSS-BORDER CLIENTS DURING A TIME WHICH CSAG WAS NOT REGISTERED WITH THE COMMISSION AS A BROKER-DEALER OR INVESTMENT ADVISER. NONE OF THE CONDUCT SUBJECT TO THE INVESTIGATION IS ATTRIBUTABLE TO CREDIT SUISSE SECURITIES (USA) LLC (""CSSU"") OR ANY CSAG AFFILIATE THAT IS REGISTERED WITH THE COMMISSION AS A BROKER-DEALER OR INVESTMENT ADVISER. IN A SETTLED ADMINISTRATIVE PROCEEDING, THE SEC CHARGED CSAG WITH VIOLATING THE REGISTRATION PROVISIONS OF THE SECURITIES EXCHANGE ACT OF 1934 AND THE INVESTMENT ADVISERS ACT OF 1940. AS PART OF THE SETTLEMENT OF THE INVESTIGATION, CSAG AGREED TO PAY APPROXIMATELY USD 196.5 MILLION, INCLUSIVE OF DISGORGEMENT OF $82,170,990, PREJUDGMENT INTEREST OF $64,340,024, AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $50,000,000."

Allegations: THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION") FOUND THAT FROM 2018 TO SEPTEMBER2022 ("RELEVANT PERIOD") UBS FINANCIAL SERVICES INC., UBS SECURITIES LLC, AND UBS AG(COLLECTIVELY "UBS" OR "RESPONDENTS") VIOLATED SECTIONS 4G,4S(F)(1)(C), 4S(G)(1) AND (3), AND4S(H)(1)(B) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. §§ 6G,6S(F)(1)(C), 6S(G)(1), (3), 6S(H)(1)(B), AND COMMISSION REGULATIONS ("REGULATIONS") 1.31, 1.35,23.201(A), 23.202(A)(1) AND (B)(1),23.602(A), AND 166.3, 17 C.F.R. §§ 1.31, 1.35, 23.201(A), 23.202(A)(1),(B)(1), 23.602(A), 166.3 (2021). THECOMMISSION FOUND THAT DURING THE RELEVANT PERIOD, UBS EMPLOYEES, INCLUDING THOSE AT SENIORLEVELS, COMMUNICATED BOTH INTERNALLY AND EXTERNALLY USING UNAPPROVED METHODS, INCLUDING VIAPERSONAL TEXT MESSAGES AND WHATSAPP MESSAGES. THE COMMISSION FOUND THAT THESE WRITTENCOMMUNICATIONS WERE BOTH SENT TO AND RECEIVED BY UBS EMPLOYEES, INCLUDING MESSAGES RELATEDTO RESPONDENTS' BUSINESS AS COMMISSION REGISTRANTS, THAT WERE REQUIRED TO BE MAINTAINEDUNDER COMMISSION-MANDATED RECORDKEEPING REQUIREMENTS, BUT THAT GENERALLY WERE NOTMAINTAINED AND PRESERVED BY UBS, AND THAT UBS GENERALLY WOULD NOT HAVE BEEN ABLE TO FURNISHPROMPTLY TO THE COMMISSION IF AND WHEN REQUESTED. THE COMMISSION ALSO FOUND THAT, AS ARESULT OF THE WIDESPREAD USE OF UNAPPROVED METHODS OF COMMUNICATION BY UBS EMPLOYEES, ANDUBS'S FAILURE TO MAINTAIN AND PRESERVE THOSE COMMUNICATIONS, UBS ALSO FAILED TO KEEP FULL,COMPLETE AND SYSTEMATIC RECORDS OF ALL TRANSACTIONS RELATING TO ITS BUSINESS OF DEALING INCOMMODITY INTERESTS, IN VIOLATION OF SECTION 4G OF THE ACT, AND REGULATION 1.35. BY FAILING TOKEEP ALL COMMISSION-REQUIRED RECORDS IN SUCH A MANNER AS TO MAKE THEM "READILY ACCESSIBLE,"UBS VIOLATED REGULATION 1.31. IN ADDITION, THE COMMISSION FOUND THAT THE CONDUCT DESCRIBEDABOVE VIOLATED UBS'S OWN POLICIES AND PROCEDURES, WHICH PROHIBITED SUCH COMMUNICATIONS,AND THAT UBS DID NOT MAINTAIN ADEQUATE INTERNAL CONTROLS OVER THE USE OF UNAPPROVEDCOMMUNICATION METHODS FOR BUSINESS-RELATED WRITTEN ELECTRONIC COMMUNICATIONS AND FAILEDTO IMPLEMENT A DILIGENT SUPERVISORY SYSTEM TO ENSURE COMPLIANCE WITH BOTH COMMISSIONRECORDKEEPING REQUIREMENTS AND THE FIRM'S OWN POLICIES AND PROCEDURES. ACCORDINGLY, THECOMMISSION FOUND THAT UBS FAILED TO DILIGENTLY SUPERVISE MATTERS RELATED TO ITS BUSINESS AS A COMMISSION REGISTRANT AND FAILED TO SUPERVISE DILIGENTLY ITS OFFICERS, EMPLOYEES, AND AGENTS,IN VIOLATION OF REGULATION 166.3. Status: Final Sanction Detail: THE FIRM SHALL CEASE AND DESIST FROM VIOLATING SECTION 4G OF THE ACT, 7 U.S.C. § 6G, ANDREGULATIONS 1.31, 1.35, AND 166.3, 17 C.F.R. §§ 1.31, 1.35, 166.3 (2021); SHALL PAY, JOINTLYANDSEVERALLY, A CIVIL MONETARY PENALTY IN THE AMOUNT OF $75,000,000 ("CMP OBLIGATION"),WITHIN FOURTEEN DAYS OF THE DATE OF THE ENTRY OF THIS ORDER; AND SHALL COMPLY WITH THECONDITIONS AND UNDERTAKINGS SET FORTH IN THE OFFER. RESPONDENTS TIMELY PAID, IN FULL, THECIVIL MONETARY PENALTY ON OCTOBER 7, 2022. Summary: RESPONDENTS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION ACCEPTED. THE FIRM FAILEDTO SUPERVISE DILIGENTLY ITS OFFICERS, EMPLOYEES, AND AGENTS IN VIOLATION OF REGULATION 166.3.ACCORDINGLY THE COMMISSION ORDERED THAT RESPONDENTS (I) CEASE AND DESIST FROM VIOLATINGSECTION 4G OF THE ACT, 7 U.S.C. § 6G, AND REGULATIONS 1.31, 1.35, AND 166.3, 17 C.F.R. §§ 1.31, 1.35,166.3 (2021); (II) PAY, JOINTLY AND SEVERALLY, A CIVIL MONETARY PENALTY IN THE AMOUNT OF$75,000,000, WITHIN 14 DAYS OF THE DATE OF ENTRY OF THE ORDER. RESPONDENTS TIMELY PAID, IN FULL,THE CIVIL MONETARY PENALTY ON OCTOBER 7, 2022. RESPONDENTS ARE ALSO ORDERED TO COMPLY WITH THE UNDERTAKINGS SET FORTH IN THE OFFER.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ALLEGED THAT UBS NEGLIGENTLY MADE MISLEADING STATEMENTS AND OMISSIONS IN THE OFFER OR SALE OF SECURITIES, WHICH VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. UBS HAS NEITHER ADMITTED OR DENIED THESE FINDINGS. Status: Final Sanction Detail: UBS AG WAS ISSUED A CEASE AND DESIST ORDER, AND ORDERED TO PAY (1) $10,000,000 IN DISGORGEMENT, (2) $1.5 MILLION IN PREJUDGMENT INTEREST; AND (3)8,000,000 CIVIL MONETARY PENALTY. Summary: THE SECURITIES AND EXCHANGE COMMISSION ALLEGED THAT UBS NEGLIGENTLY MADE MISLEADING STATEMENTS AND OMISSIONS IN THE OFFER OR SALE OF SECURITIES, WHICH VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. UBS HAS NEITHER ADMITTED OR DENIED THESE FINDINGS. UBS AG WAS ISSUED A CEASE AND DESIST ORDER, AND ORDERED TO PAY (1) $10,000,000 IN DISGORGEMENT, (2) $1.5 MILLION IN PREJUDGMENT INTEREST; AND (3)8,000,000 CIVIL MONETARY PENALTY.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS THEREIN, UBS AG AND UBS SECURITIES JAPAN CO. LTD. (UBSSJ) CONSENTED TO THE ENTRY OF THE CFTC ORDER MAKING FINDINGS THAT CERTAIN UBS PERSONNEL ENGAGED IN EFFORTS TO MANIPULATE SUBMISSIONS FOR CERTAIN BENCHMARK RATES TO BENEFIT TRADING POSITIONS; CERTAIN EMPLOYEES AT THE BANK COLLUDED WITH EMPLOYEES AT OTHER BANKS AND CASH BROKERS TO INFLUENCE CERTAIN BENCHMARK RATES TO BENEFIT THEIR TRADING POSITIONS; AND CERTAIN PERSONNEL GAVE INAPPROPRIATE DIRECTIONS TO UBS SUBMITTERS THAT WERE IN PART MOTIVATED BY A DESIRE TO AVOID UNFAIR AND NEGATIVE MARKET AND MEDIA PERCEPTIONS DURING THE FINANCIAL CRISIS. THE CONDUCT ENCOMPASSED BY THE SETTLEMENT INCLUDES YEN LIBOR, GBP LIBOR, CHF LIBOR, EURO LIBOR, USD LIBOR, EURIBOR AND EUROYEN TIBOR, ALTHOUGH THE NATURE AND EXTENT OF THE CONDUCT IN QUESTION VARIED SIGNIFICANTLY FROM ONE CURRENCY TO ANOTHER. Status: Final Sanction Detail: ON 19 DECEMBER 2012, THE CFTC ENTERED AN ORDER AGAINST UBS AG AND UBSSJ IN CONNECTION WITH THEIR INVESTIGATION OF LIBOR AND OTHER BENCHMARK INTEREST RATES. UBS AGREED TO PAY A TOTAL OF USD 700 MILLION TO THE CFTC, TO CEASE AND DESIST FROM FURTHER VIOLATIONS AS CHARGED, AND TAKE SPECIFIED STEPS TO ENSURE THE INTEGRITY AND RELIABILITY OF ITS LIBOR AND OTHER BENCHMARK INTEREST RATE SUBMISSIONS AND IMPROVE RELATED INTERNAL CONTROLS. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS THEREIN, UBS AG AND UBSSJ CONSENTED TO THE ENTRY OF THE CFTC ORDER MAKING FINDINGS AS DESCRIBED IN SECTION 7 ABOVE. THE CONDUCT ENCOMPASSED BY THE SETTLEMENT INCLUDES YEN LIBOR, GBP LIBOR, CHF LIBOR, EURO LIBOR, USD LIBOR, EURIBOR AND EUROYEN TIBOR, ALTHOUGH THE NATURE AND EXTENT OF THE CONDUCT IN QUESTION VARIED SIGNIFICANTLY FROM ONE CURRENCY TO ANOTHER. ON 19 DECEMBER 2012, THE CFTC ENTERED AN ORDER AGAINST UBS AG AND UBSSJ IN CONNECTION WITH THEIR INVESTIGATION OF LIBOR AND OTHER BENCHMARK INTEREST RATES. UBS AGREED TO PAY A TOTAL OF USD 700 MILLION TO THE CFTC, TO CEASE AND DESIST FROM FURTHER VIOLATIONS AS CHARGED, AND TAKE SPECIFIED STEPS TO ENSURE THE INTEGRITY AND RELIABILITY OF ITS LIBOR AND OTHER BENCHMARK INTEREST RATE SUBMISSIONS AND IMPROVE RELATED INTERNAL CONTROLS.

Allegations: "THE SECURITIES AND EXCHANGE COMMISSION (""SEC"") BROUGHT AN ENFORCEMENT ACTION AGAINST CREDIT SUISSE GROUP AG (""CS GROUP"") PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 (""SECURITIES ACT"") AND SECTION 21C OF THE SECURITIES EXCHANGE ACT OF 1934 (""EXCHANGE ACT""), WHICH ALLEGED THAT CS GROUP VIOLATED SECTIONS 10(B), 13(B)(2)(A) AND 13(B)(2)(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER, AND SECTIONS 17(A)(1), 17(A)(2), AND 17(A)(3) OF THE SECURITIES ACT IN CONNECTION WITH THREE INTERCONNECTED TRANSACTIONS FROM 2013 - 2016: (I) A SYNDICATED LOAN TO A MOZAMBICAN STATE-OWNED ENTITY; (II) AN OFFERING OF INTEREST-BEARING LOAN PARTICIPATION NOTES (""LPNS"") USED TO FINANCE DEBT OFFERED TO ANOTHER MOZAMBICAN STATE-OWNED ENTITY; AND (III) AN EXCHANGE OFFERING PURSUANT TO WHICH HOLDERS OF THE LPNS WERE PERMITTED TO EXCHANGE LPNS FOR NEW SOVEREIGN BONDS ISSUED BY THE GOVERNMENT OF MOZAMBIQUE. CERTAIN PERSONNEL EMPLOYED BY AN AFFILIATE OF CS GROUP, CREDIT SUISSE SECURITIES (EUROPE) RECEIVED KICKBACKS AND CERTAIN MOZAMBICAN GOVERNMENT OFFICIALS WERE PAID BRIBES IN CONNECTION WITH THE SYNDICATED LOAN AND LPN TRANSACTIONS. THE SEC ALLEGED THAT THE KICKBACK AND BRIBERY SCHEME OCCURRED AS A RESULT OF CS GROUP'S DEFICIENT INTERNAL ACCOUNTING CONTROLS ENVIRONMENT, UNREASONABLE RELIANCE ON PERSONNEL TO STRUCTURE THE TRANSACTIONS, AND INADEQUATE APPRECIATION OF BRIBERY RISKS THAT WERE UNCOVERED DURING THE COURSE OF DUE DILIGENCE. THE SEC FURTHER ALLEGED THAT, IN CONNECTION WITH THE OFFERING OF LPNS, CS GROUP FAILED TO DISCLOSE MATERIAL INFORMATION REGARDING THE TRUE LEVEL OF MOZAMBIQUE'S INDEBTEDNESS AND DRAFTED AND DISSEMINATED OFFERING MATERIALS THAT FALSELY REPRESENTED TO INVESTORS THE INTENDED USE OF THE PROCEEDS. FINALLY, THE SEC ALLEGED THAT CS GROUP COMMENCED THE EXCHANGE OFFERING DESPITE CS GROUP'S DISCOVERY OF SEVERAL IRREGULARITIES AND RISKS ASSOCIATED WITH THE OFFERING, FAILED TO DISCLOSE THE TRUE NATURE OF MOZAMBIQUE'S INDEBTEDNESS AND THE MAGNITUDE OF MISSING FUNDS FROM THE PRIOR OFFERING, AND FAILED TO DISCLOSE CS GROUP'S CONFLICTS OF INTEREST ARISING OUT OF THE LPN OFFERING AND THE EXCHANGE." Status: Final Sanction Detail: - Summary: "CS GROUP SUBMITTED AN OFFER OF SETTLEMENT (THE ""OFFER""), WHICH THE SEC DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE SEC, OR TO WHICH THE SEC IS A PARTY, CS GROUP AGREED TO CONSENT TO AN ORDER IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER (THE ""ORDER""). THE ORDER RESOLVED THE SEC'S ALLEGATIONS THAT ARE DESCRIBED ABOVE UNDER ITEM 7."

Allegations: "THE U.S SECURITIES AND EXCHANGE COMMISSION ORDER FINDS THAT, FROM THE FOURTH QUARTER OF 2011 THROUGH THE FOURTH QUARTER OF 2012, CREDIT SUISSE AG IN CERTAIN INSTANCES IMPROPERLY APPLIED ITS PROCESS FOR RECOGNIZING NNA IN A WAY THAT WAS INCONSISTENT WITH ITS DISCLOSURES. SPECIFICALLY, RATHER THAN EVALUATING EACH CLIENT AND DETERMINING WHAT WAS APPROPRIATELY RECOGNIZED AS NNA, CREDIT SUISSE AG, AT TIMES, TOOK A RESULTS-DRIVEN APPROACH THAT ALLOWED TARGETS TO INFLUENCE THE TIMING AND AMOUNT OF NNA RECOGNITION. THE SEC'S ORDER FIND THAT CREDIT SUISSE AG VIOLATED SECTION 17(A)(2) AND (3) OF THE SECURITIES ACT OF 1933 AND SECTION 13(A) AND (B)(2)(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES 13A-1, 13A-16, AND 12B-20." Status: Final Sanction Detail: - Summary: "CREDIT SUISSE AG ADMITS THE FACTS IN THE ORDER AND IS PLEASED TO RESOLVE THIS INVESTIGATION, WHICH ENDED WITHOUT ANY FINDINGS OF CLIENT HARM, WITHOUT ANY FINDINGS OF INTENTIONAL MISCONDUCT, AND WITHOUT ANY FINDINGS THAT ANY NNA WAS INCORRECTLY REALIZED."