Invesco Asset Management Ltd.

Allegations: ON JANUARY 2, 2024, INVESCO ASSET MANAGEMENT LIMITED RECEIVED A NOTICE FROM THE COMMISSIONE NAZIONALE PER LE SOCIETÀ E LA BORSA "CONSOB" THAT IT HAS COMMENCED A PROCEEDING IN CONNECTION WITH ALLEGED BREACHES OF CERTAIN PROVISIONS OF THE EU SHORT SELLING REGULATION PERTAINING TO THE EXECUTION OF AN UNCOVERED SHORT SALE AND FAILING TO REPORT THAT NET SHORT POSITION IN JULY 2022. Status: Final Sanction Detail: THE SETTLEMENT REQUIRED INVESCO ASSET MANAGEMENT LIMITED ("IAML"), PAY A MONETARY PENALTY OF EUR 250,000 ($272,750) AND PROFIT DISGORGEMENT OF EUR 94,680 ($103,296). IAML PAID THE MONETARY PENALTY AND PROFIT DISGORGEMENT ON OCTOBER 18, 2024. Summary: ON OCTOBER 14, 2024 THE CONSOB NOTIFIED IAML OF THE IMPOSITION OF A SANCTION REGARDING BREACHES OF THE EU SHORT SELLING REGULATION IN CONNECTION WITH EQUITY SELL TRADES UNDERTAKEN BY IAML IN ITALIAN-LISTED ISSUER SAIPEM SPA AHEAD OF A CAPITAL INCREASE THE COMPANY WAS UNDERTAKING. THE CONSOB FOUND THAT ON JULY 14, 2022 IAML EXECUTED AN UNCOVERED SHORT POSITION LASTING 1 DAY AMOUNTING TO 2.9% OF THE PRE-INCREASE SHARE-CAPITAL OF SAIPEM AND FAILED TO MAKE REQUIRED NOTIFICATIONS OF NET SHORT HOLDINGS. IAML HELD SAIPEM OPTION RIGHTS BUT THESE COULD NOT BE USED TO COVER THE SELL TRADES AS THEY GAVE THE RIGHT TO RECEIVE SHARES FUNGIBLE WITH OUTSTANDING SHARES ONLY ON JULY 19, 2022 AND THEREFORE NOT IN TIME FOR THE SETTLEMENT ON JULY 18, 2022 OF THE SHORT SALES EXECUTED ON JULY 14, 2022. AS SUCH, IAML INCURRED A SETTLEMENT FAIL FOR FAILING TO DELIVER THE SHARES SOLD SHORT IN ACCORDANCE WITH THE SETTLEMENT TERMS, WITH THE SHORT SALES OF SAIPEM SHARES BEING SETTLED 1 DAY LATE WITH THE NEW SHARES RESULTING FROM THE EXERCISE OF THE OPTION RIGHTS. CONSOB IMPOSED A PENALTY OF EUR 250,000 ($272,750), EUR 220,000 ($240,020) FOR BREACHING THE PROHIBITION ON NAKED SHORT SELLING AND EUR 30,000 ($32,730) FOR FAILING TO REPORT THE SHORT SELLS AS WELL AS EUR 94,680 ($103,296) DISGORGEMENT OF PROFITS FROM THE TRADES.

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 $309,595 USD AGAINST INVESCO LTD FOR %$ INCORRECT THRESHOLD FILINGS BETWEEN 05/2019 AND 10/2019. THE FINE WILL BE PAID BY THE JULY 2, 2021 DEADLINE.

Allegations: ON MARCH 19, 2015, FINANSTILSYNET, THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY, ISSUED A VIOLATION PENALTY ON INVESCO ASSET MANAGEMENT LIMITED, PURSUANT TO SECTION 4-3, REF. SECTION 17-4, OF THE SECURITIES TRADING ACT (STA). THE ISSUE RELATED TO THE LATE NOTIFICATION OF A SALE OF STOCK THAT TOOK THE RELEVANT HOLDING BELOW 5% REPORTING THRESHOLD. THE PENALTY TO BE PAID TO THE NORWEGIAN TREASURY WAS 100,000 NORWEGIAN KRONE. Status: Final Sanction Detail: FINANSTILSYNET, THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY IMPOSED A FINANCIAL PENALTY OF APPROXIMATELY $12,686.73. Summary: ON MARCH 19, 2015, FINANSTILSYNET, THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY, ISSUED A VIOLATION PENALTY ON INVESCO ASSET MANAGEMENT LIMITED, PURSUANT TO SECTION 4-3, REF. SECTION 17-4, OF THE SECURITIES TRADING ACT (STA). THE ISSUE RELATED TO THE LATE NOTIFICATION OF A SALE OF STOCK THAT TOOK THE RELEVANT HOLDING BELOW 5% REPORTING THRESHOLD. THE PENALTY TO BE PAID TO THE NORWEGIAN TREASURY WAS 100,000 NORWEGIAN KRONE.

Allegations: ON APRIL 28, 2014, THE FINANCIAL CONDUCT AUTHORITY (FCA), THE UK FINANCIAL SERVICES REGULATOR, ANNOUNCED THE SETTLEMENT OF AN INVESTIGATION OF INVESCO ASSET MANAGEMENT LIMITED AND INVESCO FUND MANAGERS LIMITED (TOGETHER INVESCO PERPETUAL) THAT INCLUDED THE IMPOSITION OF A FINANCIAL PENALTY OF £18.6 MILLION. THE ISSUES IDENTIFIED BY THE FCA RELATED TO THE PERIOD MAY 2008 TO NOVEMBER 2012 AND INCLUDED THE FOLLOWING: (1)INVESTMENT RESTRICTION BREACHES IN UK-DOMICILED RETAIL FUNDS MANAGED BY INVESCO PERPETUAL. SUCH BREACHES HAD BEEN IDENTIFIED BY INVESCO PERPETUAL AND REPORTED TO FCA, AND THE FUNDS WERE PROMPTLY REIMBURSED WHERE NECESSARY. (2)DISCLOSURES REGARDING THE USE OF, AND RISKS ASSOCIATED WITH, DERIVATIVES WERE NOT MADE OR INADEQUATELY MADE IN DISCLOSURE DOCUMENTS FOR TWO UK-DOMICILED RETAIL FUNDS MANAGED BY INVESCO PERPETUAL. THESE DISCLOSURE FAILINGS WERE CORRECTED IN AUGUST 2012. (3)INVESCO PERPETUAL FAILED TO ADEQUATELY DOCUMENT ALLOCATIONS OF FIXED INCOME SECURITIES WHEN AGGREGATING CLIENT ORDERS. A REVIEW BY INVESCO PERPETUAL DETERMINED THERE WAS NO EVIDENCE THAT THIS IMPACTED INVESTORS. (4) CERTAIN FIXED INCOME TRANSACTIONS WERE NOT POSTED ON A TIMELY BASIS. THIS DID NOT RESULT IN ANY NEED TO REPRICE FUNDS. Status: Final Sanction Detail: THE FINANCIAL CONDUCT AUTHORITY IMPOSED A FINANCIAL PENALTY OF APPROXIMATELY $31.1 MILLION. Summary: ON APRIL 28, 2014, THE FINANCIAL CONDUCT AUTHORITY (FCA), THE UK FINANCIAL SERVICES REGULATOR, ANNOUNCED THE SETTLEMENT OF AN INVESTIGATION OF INVESCO ASSET MANAGEMENT LIMITED AND INVESCO FUND MANAGERS LIMITED (TOGETHER INVESCO PERPETUAL) THAT INCLUDED THE IMPOSITION OF A FINANCIAL PENALTY OF £18.6 MILLION. THE ISSUES IDENTIFIED BY THE FCA RELATED TO THE PERIOD MAY 2008 TO NOVEMBER 2012 AND INCLUDED THE FOLLOWING: (1)INVESTMENT RESTRICTION BREACHES IN UK-DOMICILED RETAIL FUNDS MANAGED BY INVESCO PERPETUAL. SUCH BREACHES HAD BEEN IDENTIFIED BY INVESCO PERPETUAL AND REPORTED TO FCA, AND THE FUNDS WERE PROMPTLY REIMBURSED WHERE NECESSARY. (2)DISCLOSURES REGARDING THE USE OF, AND RISKS ASSOCIATED WITH, DERIVATIVES WERE NOT MADE OR INADEQUATELY MADE IN DISCLOSURE DOCUMENTS FOR TWO UK-DOMICILED RETAIL FUNDS MANAGED BY INVESCO PERPETUAL. THESE DISCLOSURE FAILINGS WERE CORRECTED IN AUGUST 2012. (3)INVESCO PERPETUAL FAILED TO ADEQUATELY DOCUMENT ALLOCATIONS OF FIXED INCOME SECURITIES WHEN AGGREGATING CLIENT ORDERS. A REVIEW BY INVESCO PERPETUAL DETERMINED THERE WAS NO EVIDENCE THAT THIS IMPACTED INVESTORS. (4) CERTAIN FIXED INCOME TRANSACTIONS WERE NOT POSTED ON A TIMELY BASIS. THIS DID NOT RESULT IN ANY NEED TO REPRICE FUNDS.

Allegations: ON 25 AUGUST 2022 COFECE, THE MEXICAN FEDERAL ECONOMIC COMPETITION COMMISSION, ANNOUNCED IT HAD FINED INVESCO ASSET MANAGEMENT LTD ("IAML") $45,000 FOR CLERICAL ERRORS IN RELATION TO A PRE-MERGER CLEARANCE FILING MADE IN 2021 AND REQUESTED IAML SUBMIT A NEW FILING IN RESPECT OF ALL INVESCO FUNDS AND ACCOUNTS INVOLVED IN THE TRANSACTION. THE OVERSIGHT OCCURRED BECAUSE INVESCO USED AN INCORRECT DATA SOURCE FOR COMPLETION OF THE PAPERWORK. THE CORRECT DATA SOURCE TO USE IN ALL INSTANCES GOING FORWARD HAS SINCE BEEN IDENTIFIED AND THIS HAS BEEN COMMUNICATED TO THE RELEVANT TEAM. NO CLIENTS WERE IMPACTED. Status: Final Sanction Detail: COFECE HAS FINED IAML $45,000 FOR CLERICAL ERRORS IN RELATION TO A PRE-MERGER CLEARANCE FILING MADE IN 2021 AND HAS REQUESTED IAML SUBMIT A NEW FILING IN RESPECT TO ALL INVESCO FUNDS AND ACCOUNTS INVOLVED IN THE TRANSACTION. IAML WILL PAY THE FINE IN FULL BY THE REQUIRED DEADLINE. Summary: ON 25 AUGUST 2022 COFECE, THE MEXICAN FEDERAL ECONOMIC COMPETITION COMMISSION, ANNOUNCED IT HAD FINED INVESCO ASSET MANAGEMENT LTD ("IAML") $45,000 FOR CLERICAL ERRORS IN RELATION TO A PRE-MERGER CLEARANCE FILING MADE IN 2021 AND REQUESTED IAML SUBMIT A NEW FILING IN RESPECT OF ALL INVESCO FUNDS AND ACCOUNTS INVOLVED IN THE TRANSACTION. THE OVERSIGHT OCCURRED BECAUSE INVESCO USED AN INCORRECT DATA SOURCE FOR COMPLETION OF THE PAPERWORK. THE CORRECT DATA SOURCE TO USE IN ALL INSTANCES GOING FORWARD HAS SINCE BEEN IDENTIFIED AND THIS HAS BEEN COMMUNICATED TO THE RELEVANT TEAM. NO CLIENTS WERE IMPACTED.