Invesco Senior Secured Management, Inc.

Allegations: INVESCO LTD AND AIM INTERNATIONAL MUTUAL FUNDS FAILED TO SUBMIT VOTING RIGHTS NOTIFICATIONS TO BAFIN AND THE ISSUERS BY THE REQUIRED DEADLINE. BAFIN ISSUED A NOTICE OF HEARING ON JULY 30, 2020 TO INVESCO LTD ALLEGING THAT VIOLATIONS OF THE VOTING RIGHTS REQUIREMENTS OCCURED ON 26 OCCASSIONS RELATING TO THE VOTING RIGHTS NOTIFICATIONS OF INVESCO LTD AND ON 28 OCCASIONS RELATING TO VOTING RIGHTS NOTIFICATIONS OF AIM INTERNATIONAL MUTUAL FUNDS. Status: Final Sanction Detail: DECISION TO IMPOSE A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 USD) AGAINST INVESCO LTD WILL BE PAID BY THE JULY 2, 2021 DEADLINE. Summary: BAFIN IMPOSED A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 US DOLLARS) AGAINST INVESCO LTD FOR 54 INCORRECT THRESHOLD FILINGS BETWEEN 05/2019 AND 10/2019. THE FINE WILL BE PAID BY THE JULY 2, 2021 DEADLINE.

Allegations: THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI") AND INVESCO DISTRIBUTORS, INC. ("IDI") FAILED TO ADEQUATELY PRESERVE CERTAIN ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. Status: Final Sanction Detail: THE SETTLEMENT REQUIRED INVESCO ADVISERS, INC. ("IAI") AND INVESCO DISTRIBUTORS, INC. ("IDI") TO PAY A CIVIL MONETARY PENALTY OF $35 MILLION AND COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING THE RETENTION OF A COMPLIANCE CONSULTANT. INVESCO PAID THE CIVIL MONETARY PENALTY ON OCTOBER 1, 2024. Summary: ON SEPTEMBER 24, 2024, INVESCO ADVISERS, INC. ("IAI"), AN INVESTMENT ADVISORY AFFILIATE OF INVESCO SENIOR SECURED MANAGEMENT, INC. AND INVESCO DISTRIBUTORS, INC. ("IDI"), AN AFFILIATED BROKER-DEALER (TOGETHER, WITH IAI, "INVESCO") ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES & EXCHANGE COMMISSION (SEC) IN CONNECTION WITH THE AGENCY'S INDUSTRY-WIDE INVESTIGATION INTO THE MAINTENANCE AND PRESERVATION OF ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. THE SETTLEMENT CENSURES INVESCO AND REQUIRES THAT INVESCO CEASE AND DESIST FROM ANY EXISTING AND FUTURE VIOLATIONS, PAY A CIVIL MONETARY PENALTY OF $35,000,000 AND RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT, FOLLOWING THE FORMAT FOR ALL OTHER RECENT ELECTRONIC COMMUNICATIONS SETTLEMENTS. INVESCO COOPERATED WITH THE GOVERNMENT'S INQUIRY AND HAS ALREADY TAKEN SIGNIFICANT STEPS TO FURTHER STRENGTHEN THE FIRM'S COMPLIANCE ENVIRONMENT AS IT RELATES TO ELECTRONIC COMMUNICATIONS, INCLUDING BY ENHANCING ITS POLICIES AND PROCEDURES, IMPLEMENTING INCREASED TRAINING REGARDING THE USE OF ELECTRONIC COMMUNICATIONS, AND BEGINNING TO IMPLEMENT CHANGES TO THE TECHNOLOGY AVAILABLE TO EMPLOYEES.

Allegations: THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI"), AN INVESTMENT ADVISORY AFFILIATE OF INVESCO SENIOR SECURED MANAGEMENT, INC., LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO ALLEGED THAT IAI MADE MISLEADING STATEMENTS CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS ESG INTEGRATED. Status: Final Sanction Detail: THE SETTLEMENT REQUIRED INVESCO ADVISERS, INC. ("IAI"), AN INVESTMENT ADVISORY AFFILIATE OF INVESCO SENIOR SECURED MANAGEMENT, INC., TO PAY A CIVIL MONETARY PENALTY OF $17.5 MILLION. IAI PAID THE CIVIL MONETARY PENALTY ON NOVEMBER 14, 2024. Summary: ON NOVEMBER 8, 2024, INVESCO ADVISERS, INC. ("IAI"), AN INVESTMENT ADVISORY AFFILIATE OF INVESCO SENIOR SECURED MANAGEMENT, INC., ENTERED INTO A SETTLEMENT WITH THE SEC REGARDING IAI'S ENVIRONMENTAL, SOCIAL AND GOVERNANCE ("ESG") POLICIES AND PROCEDURES. THE SEC FOUND THAT IAI LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO FOUND THAT IAI MADE MISLEADING STATEMENTS CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS ESG INTEGRATED. IAI WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM VIOLATING SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULES 206(4)-1, 206(4)-7 AND 206(4)-8 THEREUNDER. IAI AGREED TO PAY A PENALTY OF $17.5 MILLION.