Amundi Us Investment Advisors Llc

Allegations: FOLLOWING AN INVESTIGATION CONDUCTED FROM 2017 TO 2019, THE FRENCH FINANCIAL MARKETS AUTHORITY (AUTORITÉ DES MARCHÉS FINANCIERS [AMF]) NOTIFIED AMUNDI OF GRIEVANCES ON JUNE 12, 2020. THE GRIEVANCES RELATE TO CERTAIN TRANSACTIONS CARRIED OUT BETWEEN 2014 AND 2015 BY TWO FORMER NON-US EMPLOYEES OF AMUNDI ASSET MANAGEMENT S.A.S. AND A NON-US AMUNDI ASSET MANAGEMENT S.A.S. AFFILIATE WHO HAVE SINCE BEEN DISMISSED. THE TRANSACTIONS IMPACTED ASSETS MANAGED ON BEHALF OF A NON-US INSTITUTIONAL CLIENT, WHO WAS COMPENSATED. Status: Final Sanction Detail: TWO FORMER AMUNDI EMPLOYEES WERE BANNED FROM THE FINANCIAL MARKETS FOR A PERIOD OF TEN YEARS STARTING AUGUST 5, 2021. TWO AFFILIATES, AMUNDI ASSET MANAGEMENT S.A.S. AND AMUNDI INTERMEDIATION, PAID A FINE OF 25 MILLION EURO AND 7 MILLION RESPECTIVELY. Summary: AFTER A PUBLIC HEARING HELD ON JULY 7, 2021, THE AMF ENFORCEMENT COMMITTEE ON AUGUST 4, 2021 IMPOSED A FINE OF 25 MILLION EURO ON AMUNDI ASSET MANAGEMENT S.A.S. AND 7 MILLION EURO ON AMUNDI INTERMEDIATION. THE ENFORCEMENT COMMITTEE SANCTIONED TWO FORMER NON-US EMPLOYEES, EACH BANNED FOR 10 YEARS, AND THE TWO NON-US AMUNDI GROUP COMPANIES FOR PRICE MANIPULATION ON THE EURO STOXX 50 FUTURES (FESX) MARKET AND OTHER BREACHES OF SEVERAL PROFESSIONAL OBLIGATIONS.

Allegations: THE EUROPEAN COMMISSION ANNOUNCED ON DECEMBER 20, 2018 THAT IT REACHED A PRELIMINARY VIEW THAT CERTAIN BANKS HAVE BREACHED EU ANTITRUST RULES. THE ALLEGATIONS RELATE TO THE TRADING OF USD-DENOMINATED SOVEREIGN, SUPRA-SOVEREIGN, AND AGENCY ("SSA") BONDS ON THE SECONDARY MARKET BETWEEN JANUARY 2013 AND MARCH 2015. CACIB AND CASA HAVE RECEIVED A STATEMENT OF OBJECTIONS FROM THE EUROPEAN COMMISSION. THE EUROPEAN COMMISSION'S PRESS RELEASE IS AVAILABLE HERE: HTTP://EUROPA.EU/RAPID/PRESS-RELEASE_IP-18- 6895_EN.HTM. CACIB AND CASA ARE CONSIDERING THE STATEMENT OF OBJECTIONS AND WILL HAVE AN OPPORTUNITY TO RESPOND. WE WILL PROVIDE FURTHER UPDATES AS NECESSARY. UPDATE AS OF MAY 2021: AS WE PREVIOUSLY INFORMED YOU WHEN CASA AND CA-CIB RECEIVED A STATEMENT OF OBJECTIONS IN DECEMBER 2018, THE SUBJECT MATTER OF THE INVESTIGATION, AND NOW THE DECISION DATED 4/28/21 IMPOSING A EURO 3,993,000 (OR USD 4,821,966.77) FINE ON CACIB, RELATES TO THE TRADING OF US DOLLAR DENOMINATED SSA BONDS ON THE SECONDARY MARKET. THE DURATION OF CASA AND CACIB'S PARTICIPATION IN THE ALLEGED CONDUCT IS BETWEEN JANUARY 2013 AND MARCH 2015. CASA AND CACIB ARE CONSIDERING THE DECISION CAREFULLY, AND ARE ACTIVELY CONSIDERING AN APPEAL. UPDATE AS OF AUGUST 2021: CASA AND CACIB FILED AN APPLICATION FOR ANNULMENT OF THE EUROPEAN COMMISSION'S DECISION, AND THE PENALTY IMPOSED, ON JULY 7,2021. Status: On Appeal Sanction Detail: N/A Summary: THE EUROPEAN COMMISSION ANNOUNCED ON DECEMBER 20, 2018 THAT IT REACHED A PRELIMINARY VIEW THAT CERTAIN BANKS HAVE BREACHED EU ANTITRUST RULES. THE ALLEGATIONS RELATE TO THE TRADING OF USD-DENOMINATED SOVEREIGN, SUPRA-SOVEREIGN, AND AGENCY ("SSA") BONDS ON THE SECONDARY MARKET BETWEEN JANUARY 2013 AND MARCH 2015. CACIB AND CASA HAVE RECEIVED A STATEMENT OF OBJECTIONS FROM THE EUROPEAN COMMISSION. THE EUROPEAN COMMISSION'S PRESS RELEASE IS AVAILABLE HERE: HTTP://EUROPA.EU/RAPID/PRESS-RELEASE_IP-18- 6895_EN.HTM. CACIB AND CASA ARE CONSIDERING THE STATEMENT OF OBJECTIONS AND WILL HAVE AN OPPORTUNITY TO RESPOND. WE WILL PROVIDE FURTHER UPDATES AS NECESSARY. UPDATE AS OF MAY 2021: AS WE PREVIOUSLY INFORMED YOU WHEN CASA AND CA-CIB RECEIVED A STATEMENT OF OBJECTIONS IN DECEMBER 2018, THE SUBJECT MATTER OF THE INVESTIGATION, AND NOW THE DECISION DATED 4/28/21 IMPOSING A EURO 3,993,000 (OR USD 4,821,966.77) FINE ON CACIB, RELATES TO THE TRADING OF US DOLLAR DENOMINATED SSA BONDS ON THE SECONDARY MARKET. THE DURATION OF CASA AND CACIB'S PARTICIPATION IN THE ALLEGED CONDUCT IS BETWEEN JANUARY 2013 AND MARCH 2015. CASA AND CACIB ARE CONSIDERING THE DECISION CAREFULLY, AND ARE ACTIVELY CONSIDERING AN APPEAL. UPDATE AS OF AUGUST 2021: CASAAND CACIB FILED AN APPLICATION FOR ANNULMENT OF THE EUROPEAN COMMISSION'S DECISION, AND PENALTY IMPOSED, ON JULY7, 2021. UPDATE AS OF JULY 2,2024: THERE IS NO UPDATED RULING ON THE CASE. DECISION FROM THE EUROPEAN COMMISSION IS EXPECTED ON NOVEMBER 2024.

Allegations: GRIEVANCE RELATING TO THE PUBLICATION ON THE AMUNDI WEBSITE FOR BELGIAN INVESTORS OF A COMMERCIAL DOCUMENTATION WHICH, IN ITS DUTCH VERSION, MENTIONED AN ANNUAL PERFORMANCE TARGET OF 7% WHILE, DURING THE APPROVAL PROCESS BASED ON A FRENCH WRITTEN TEMPLATE OF THE COMMERCIAL DOCUMENTATION, THE BELGIAN REGULATOR HAD EXPRESSLY REQUESTED THE DELETION OF THIS REFERENCE ON THE GROUNDS THAT IT WAS A SUBJECTIVE ASSESSMENT AND THEN COULD POTENTIALLY BE MISLEADING. THE FSMA NOTED IN PARTICULAR THAT AS SOON AS INFORMED BY THE FSMA OF THIS REFERENCE TO AN ANNUAL PERFORMANCE TARGET IN THE DUTCH VERSION, AMUNDI ASSET MANAGEMENT S.A.S. SENT A CORRECTED VERSION TO THE BELGIAN REGULATOR AND PUBLISHED THIS CORRECTED VERSION ON ITS WEBSITE. FOR AMUNDI THIS IS DUE TO A TRANSLATION ERROR AND THE FSMA ITSELF NOTED THAT THIS ERROR DID NOT APPEAR TO BE INTENTIONAL. Status: Final Sanction Detail: TRANSACTIONAL SETTLEMENT BETWEEN THE BELGIAN REGULATOR AND AMUNDI ASSET MANAGEMENT S.A.S. AND PAYMENT BY AMUNDI ASSET MANAGEMENT S.A.S. OF A SUM OF 60,000 EUROS TOGETHER WITH THE PUBLICATION OF THE SETTLEMENT ON THE FSMA WEBSITE. Summary: GRIEVANCE RELATING TO THE PUBLICATION ON THE AMUNDI WEBSITE FOR BELGIAN INVESTORS OF A COMMERCIAL DOCUMENTATION WHICH, IN ITS DUTCH VERSION, MENTIONED AN ANNUAL PERFORMANCE TARGET OF 7% WHILE, DURING THE APPROVAL PROCESS BASED ON A FRENCH WRITTEN TEMPLATE OF THE COMMERCIAL DOCUMENTATION, THE BELGIAN REGULATOR HAD EXPRESSLY REQUESTED THE DELETION OF THIS REFERENCE ON THE GROUNDS THAT IT WAS A SUBJECTIVE ASSESSMENT AND THEN COULD POTENTIALLY BE MISLEADING. THE FSMA NOTED IN PARTICULAR THAT AS SOON AS INFORMED BY THE FSMA OF THIS REFERENCE TO AN ANNUAL PERFORMANCE TARGET IN THE DUTCH VERSION, AMUNDI ASSET MANAGEMENT S.A.S. SENT A CORRECTED VERSION TO THE BELGIAN REGULATOR AND PUBLISHED THIS CORRECTED VERSION ON ITS WEBSITE. FOR AMUNDI THIS IS DUE TO A TRANSLATION ERROR AND THE FSMA ITSELF NOTED THAT THIS ERROR DID NOT APPEAR TO BE INTENTIONAL.

Allegations: THE LUXEMBOURG COMMISSION DE SURVEILLANCE DU SECTEUR FINANCIER (CSSF) CONFIRMED ON JULY 29TH, 2021 TO AMUNDI LUXEMBOURG THE CONCLUSIONS OF ITS ON-SITE INSPECTION, CARRIED OUT IN APRIL-MAY 2019, ON CORPORATE GOVERNANCE AND ANTI-MONEY LAUNDERING / COUNTER-TERRORIST FINANCING. Status: Final Sanction Detail: AMUNDI LUXEMBOURG PAID AN ADMINISTRATIVE FINE OF EUR 153,400. Summary: THE LUXEMBOURG COMMISSION DE SURVEILLANCE DU SECTEUR FINANCIER (CSSF) CONFIRMED ON JULY 29TH, 2021 TO AMUNDI LUXEMBOURG THE CONCLUSIONS OF ITS ON-SITE INSPECTION, CARRIED OUT IN APRIL-MAY 2019, ON CORPORATE GOVERNANCE AND ANTI-MONEY LAUNDERING / COUNTER-TERRORIST FINANCING.

Allegations: ON DECEMBER 7, 2016, THE EUROPEAN COMMISSION (THE "COMMISSION") ANNOUNCED THAT IT FINED CRÉDIT AGRICOLE S.A. ("CASA") AND CRÉDIT AGRICOLE CORPORATE AND INVESTMENT BANK ("THE BANK"), HSBC, AND JPMORGAN CHASE FOR ANTICOMPETITIVE PRACTICES CONCERNING BENCHMARK INTEREST RATES. THE COMMISSION CLAIMS THAT THE BANK AND SEVEN OTHER BANKS COLLUDED ON EURO INTEREST RATE DERIVATIVE PRICING ELEMENTS AND EXCHANGED SENSITIVE INFORMATION FOR THE PURPOSE OF DISTORTING THE NORMAL COURSE OF PRICING COMPONENTS FOR EURO INTEREST RATE DERIVATIVES, IN BREACH OF EUROPEAN UNION ANTITRUST RULES. THE COMMISSION FOUND THAT THERE WAS A CARTEL IN PLACE BETWEEN SEPTEMBER 2005 AND MAY 2008 INVOLVING A TOTAL OF SEVEN BANKS (BARCLAYS, HSBC, JPMORGAN CHASE, DEUTSCHE BANK, RBS, SOCIÉTÉ GÉNÉRALE, AND THE BANK) OVER VARYING TIME PERIODS. THE COMMISSION FOUND THAT THE BANK PARTICIPATED IN THE CARTEL FOR A DURATION OF 5 MONTHS AND FINED THE BANK 114,654,000 EUROS. THE COMMISSION'S DECISION WAS RELEASED PUBLICLY ON APRIL 9, 2019. THE BANK HAS APPEALED THE DECISION OF THE COMMISSION BEFORE THE GENERAL COURT OF THE EUROPEAN UNION. Status: On Appeal Sanction Detail: NONE Summary: THE EUROPEAN COMMISSION RELEASED ITS DECISION ON DECEMBER 7, 2016, WITH SUCH DECISION BECOMING PUBLIC ON APRIL 9, 2019. THE BANK, WHICH HAD PREVIOUSLY ANNOUNCED ITS DECISION TO APPEAL, LODGED ITS APPEAL AND FILED ITS SUBMISSION ON THE MERITS ON FEBURARY 19, 2017 BEFORE THE GENERAL COURT OF THE EUROPEAN UNION. UPDATE: BY ORDER OF 16 JULY 2020, THE PRESIDENT OF THE EUROPEAN COURT OF JUSTICE (ECJ) GRANTED CRÉDIT AGRICOLE (CASA AND CACIB) LEAVE TO INTERVENE IN SUPPORT OF HSBC IN ITS PENDING PROCEEDINGS BEFORE THE ECJ. UPDATE AS OF JULY 2, 2024: ON DECEMBER 20, 2023,THE GENERAL COURT OF THE EUROPEAN UNION ISSUED A JUDGEMENT. THE GENERAL COURT REDUCED THE AMOUNT OF CACIB AND CASA'S FINE TO EUR 110M ANDHAD UPHELD MOST OF THE COMMISSION'S DECISION OF DECEMBER 2016. ON MARCH 8, 2024, CASA AND CACIB HAVE APPEALED THE RULING BEFORE THE ECJ.

Allegations: CRÉDIT AGRICOLE S.A. (CASA) AND ITS SUBSIDIARY CRÉDIT AGRICOLE CORPORATE AND INVESTMENT BANK (CACIB) HAVE REACHED AGREEMENTS WITH THE U.S. AND NEW YORK AUTHORITIES THAT HAVE BEEN CONDUCTING INVESTIGATIONS REGARDING U.S. DOLLAR TRANSACTIONS BETWEEN 2003 AND 2008 SUBJECT TO U.S. ECONOMIC SANCTIONS AND CERTAIN RELATED NEW YORK STATE LAWS. CACIB AND CASA, WHICH COOPERATED WITH THE U.S. AND NEW YORK AUTHORITIES IN CONNECTION WITH THEIR INVESTIGATIONS, HAVE AGREED TO PAY A TOTAL PENALTY AMOUNT OF $787.3MM. THE PAYMENT OF THIS PENALTY WILL BE ALLOCATED TO THE PRE-EXISTING RESERVE THAT HAS ALREADY BEEN TAKEN AND WILL NOT AFFECT THE ACCOUNTS FOR THE SECOND HALF OF 2015. THE AGREEMENTS WITH THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (FEDERAL RESERVE) AND THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (NYDFS) ARE WITH CASA AND CACIB. THE AGREEMENT WITH THE OFFICE OF FOREIGN ASSETS CONTROL (OFAC) OF THE U.S. DEPARTMENT OF THE TREASURY IS WITH CACIB. CACIB ALSO ENTERED INTO SEPARATE DEFERRED PROSECUTION AGREEMENTS (DPAS) WITH THE UNITED STATES ATTORNEY'S OFFICE FOR THE DISTRICT OF COLUMBIA (USAO) AND THE DISTRICT ATTORNEY OF THE COUNTY OF NEW YORK (DANY), THE TERMS OF WHICH ARE THREE YEARS. THE USAO AND DANY HAVE AGREED TO TAKE NO FURTHER ACTION AGAINST CACIB, CASA, OR ANY OF CACIB'S SUBSIDIARIES OR AFFILIATES REGARDING THE CONDUCT SUBJECT TO THIS INVESTIGATION IF CACIB COMPLIES WITH ITS OBLIGATIONS UNDER THE DPAS. ON OCTOBER 19, 2018, THE UNITED STATES DISTRICT COURT OF COLUMBIA ENTERED A FINAL ORDER DISMISSING WITH PREJUDICE THE INFORMATION THAT THE USAO FILED IN 2015 IN CONNECTION WITH THE AGREEMENTS. Status: Final Sanction Detail: NO ADDITIONAL DETAILS ARE AVAILABLE Summary: CIVIL ORDER AND SANCTIONS OF $787.3 MILLION

Allegations: THIS PENALTY WAS IMPOSED FOR BREACH OF THE PROCEDURE LAID DOWN IN ARTICLE 26(3) OF REGULATION (EU)NO 575/2013 OF THE EUROPEAN PARLIAMENT BY CLASSIFYING CAPITAL INSTRUMENTS AS COMMON EQUITY TIER 1 INSTRUMENTS DURING THREE (FIVE FOR CASA) CONSECUTIVE QUARTERLY REPORTING PERIODS AND TWO (THREE FOR CASA) PUBLIC DISCLOSURES IN 2015 AND 2016 WITHOUT THE PRIOR PERMISSION OF THE COMPETENT AUTHORITY. Status: Final Sanction Detail: ADMINISTRATIVE PENALTY ON CRÉDIT AGRICOLE CORPORATE AND INVESTMENT BANK (CACIB) AND ITS PARENT, CRÉDIT AGRCICOLE S.A. (CASA), AMOUNTING TO EUR 300,000 AND 4.3 MILLION RESPECTIVELY. Summary: THE EUROPEAN CENTRAL BANK (ECB) DECIDED ON JULY 16, 2018 TO IMPOSE AN ADMINISTRATIVE PENALTY ON CRÉDIT AGRICOLE CORPORATE AND INVESTMENT BANK (CACIB) AND ITS PARENT, CRÉDIT AGRICOLE S.A. (CASA), AN AMOUNT OF EUR 300,000 AND 4.3 MILLION RESPECTIVELY. THIS PENALTY WAS IMPOSED FOR BREACH OF THE PROCEDURE LAID DOWN IN ARTICLE 26(3) OF REGULATION (EU)NO 575/2013 OF THE EUROPEAN PARLIAMENT BY CLASSIFYING CAPITAL INSTRUMENTS AS COMMON EQUITY TIER 1 INSTRUMENTS DURING THREE (FIVE FOR CASA) CONSECUTIVE QUARTERLY REPORTING PERIODS AND TWO (THREE FOR CASA) PUBLIC DISCLOSURES IN 2015 AND 2016 WITHOUT THE PRIOR PERMISSION OF THE COMPETENT AUTHORITY. THE SHORT SUMMARY OF THE DECISION IS FOUND ON THE ECB WEBSITE AT HTTPS://WWW.BANKINGSUPERVISION.EUROPA.EU/BANKING/SANCTIONS/SHARED/PDF/SSM.180820_1_PUBLICATION_TEMPLATE.EN.PDF