Statement in Relation to the Shareholder Rights Directive II

Where PanAgora manages accounts which include shares with a listing on an EEA market or on a comparable market outside the EEA, PanAgora’s shareholder engagement is generally limited to the responsible exercise of voting rights in accordance with PanAgora’s policies and procedures. Specifically, where proxy voting authority is granted to PanAgora, PanAgora has adopted policies and procedures reasonably designed to ensure that PanAgora votes client securities in the best interest of clients. PanAgora has engaged Institutional Shareholder Services Inc. (“ISS”) as a third-party proxy service provider. While PanAgora retains final authority to determine how each proxy is voted, in most instances, PanAgora follows the proxy voting policies and recommendations (the “Guidelines”) of ISS. ISS tracks each proxy that PanAgora is authorized to vote on behalf of its clients and makes a recommendation to PanAgora management as to how ISS recommends voting such proxy per its Guidelines. Unless otherwise directed by PanAgora, ISS will vote on such matters on PanAgora’s behalf in accordance with its recommendations.

PanAgora has adopted procedures to oversee and monitor the services provided by any third-party proxy voting agents, such as ISS. PanAgora retains the right to override specific recommendations and/or may modify the application of ISS’ Guidelines in the future. The best interest of PanAgora’s clients is the primary consideration in determining how proxies should be voted. Certain proxy voting proposals may raise conflicts between the interests of PanAgora’s clients and the interests of PanAgora and its employees. If PanAgora identifies a proxy voting proposal that presents a conflict of interest, it will decide whether it presents a material conflict of interest and review to ensure that the proxy is voted in the best interest of the client. Additional information regarding PanAgora’s practices with respect to voting client securities can be found in Item 17 of PanAgora’s Form ADV Part 2A.

PanAgora has chosen at this stage not to implement an engagement policy pursuant to the Article 3g requirements of SRD II or report on such implementation on an annual basis.

This statement will be reviewed annually and, if applicable, updated to reflect changes in circumstances and practice.