Russell Investment Management LLC

Item 5 – Fees and Compensation and Item 6 – Performance-Based Fees and Side-By-Side Management.

RUSSELL INVESTMENTS AFFILIATES

In certain cases, RIM uses, suggests, and recommends its own services and those of its affiliates to clients, which may
create potential conflicts of interest. The arrangements between RIM and our affiliates may involve sharing or joint
compensation, or separate compensation, subject to the requirements of applicable laws. Some of these affiliates also are
registered with the SEC, FINRA, and/or the CFTC; however, other affiliates are non-US affiliates that are not required to
be registered. In certain cases, these non-US affiliates provide portfolio management or research services to RIM for use
with US clients in such a capacity referred to as “Participating Affiliates.” The Participating Affiliates operate in reliance on
a series of SEC no action relief letters which mandate that Participating Affiliates remain subject to the regulatory
supervision of RIM and the jurisdiction of the SEC. Participating Affiliates may recommend to their own clients, or invest
on behalf of their own clients in, securities that are also the subject of recommendations to, or discretionary trading on
behalf of, RIM’s US clients.

RIM has or intends to have a co-advisory or sub-advisory relationship with its affiliates, and/or participating affiliate
relationships with the Participating Affiliates. RIM at its discretion, in certain circumstances, may delegate all or a portion
of its advisory or other functions (including placing trades on behalf of client accounts) to certain affiliates that are
registered with the SEC as investment advisers and/or broker-dealers, or to certain Participating Affiliates. Further, certain
functions and services are performed by employees of the US-registered entities who also are employees of such affiliates.

Relationships between RIM and its affiliates may include, but are not limited to, those discussed below. The full list of
affiliates can be found in RIM’s Form ADV Part 1, Item 7.A.

Affiliated US Registered Broker-Dealers

RIIS is registered with the SEC as a broker-dealer and is a member of FINRA. RIIS is also registered as an investment adviser
with the SEC and is an exempt commodity trading advisor with the CFTC. RIIS provides execution services, effected on an

Russell Investment Management, LLC / Form ADV Part 2A                                                                      / 44

agency basis, for RIM and its clients. RIIS works with third-party broker-dealers and other trading venues to provide market
access, infrastructure, and/or clearing services. Clients who affect brokerage transactions through RIIS pay RIIS
commissions or other compensation for securities transactions, transition management mandates, and/or FX transactions
in addition to any advisory fees paid to RIM. Because RIIS is an affiliate, its receipt of commissions or other transaction-
based compensation in connection with client transactions creates a material conflict of interest. RIM has an incentive to
utilize RIIS for execution because such use may increase overall compensation within the Russell Investments organization.
RIM addresses this conflict through policies and procedures designed to seek best execution and through various oversight
mechanisms. Please see Item 5 – Fees and Compensation and Item 12 – Brokerage Practices for additional information.
RIIS also provides investment advisory services for institutional clients. Through intercompany agreements and/or “dual
hatting” arrangements, RIM shares employees and investment personnel with RIIS.

Russell Investments Financial Services, LLC (“RIFIS”) is an SEC-registered broker-dealer and is a member of FINRA. RIFIS
acts as the principal underwriter and distributor of RIM Advised Registered Funds.

Affiliated US Registered Investment Advisers

RICAP is an investment adviser registered with the SEC and is also a registered CPO with the CFTC and member of the NFA.
RICAP provides investment advisory, consulting, and administrative services to institutional clients and Private Funds.
Through intercompany agreements and/or “dual hatting” arrangements, RIM shares employees and investment personnel
with RICAP. As described above, RIIS is also registered as an investment adviser with the SEC.

Russell Investments Credit Adviser, LLC (“RICA”) and Russell Investments Infrastructure Adviser, LLC (“RIIA”) are registered
investment advisers with the SEC and are wholly-owned subsidiaries of RIM. RICA and RIIA are expected to provide
investment advisory services to certain affiliated registered credit and infrastructure funds, respectively. Through
intercompany agreements and/or “dual hatting” arrangements, RIM shares employees and investment personnel with
RICA and RIIA.

Other US Affiliated Entities

Russell Investments Funds Management, LLC (“RIFM”) is the managing member of certain Private Funds. The managing
member has primary authority over the operation of such Private Funds and is responsible for the appointment of the
investment manager and other parties who may provide, from time to time, services to such Private Funds.

Russell Investments Trust Company (“RITC”) is a Washington State non-depository trust company providing
comprehensive trust and investment management services to corporate employee benefit plans, retirement plans
maintained by government units, other forms of pension plans, and foundations and endowments. RITC’s investment
management services are provided through common or collective funds, and/or separate accounts. RITC also serves as
Trustee to certain Private Funds advised by RIM. Through intercompany agreements and/or “dual hatting” arrangements,
RIM shares employees and investment personnel with RITC.

Russell Investments Funds Services, LLC (“RIFUS”) is registered with the SEC as a transfer agent and provides transfer
...

Item 7 – Types of Clients
We provide investment advisory services to a variety of Funds, including Registered Funds and Private Funds. We also
provide investment advisory services to institutional clients including employee benefit plans such as public pension funds,
corporate pension funds, defined contribution and profit-sharing plans, and Taft-Hartley plans, as well as insurance
companies, third-party investment advisers and other financial intermediaries.

For institutional clients, it is the responsibility of the client or its staff, advisor, or consultant to evaluate their investment
objectives, risk tolerance, and financial standing and determine whether a RIM strategy and the investment guidelines are
suitable for the client.

We also serve as the investment manager to certain affiliated Private Funds. Interests in the Private Funds are offered
pursuant to applicable exemptions from registration under the Securities Act of 1933, as amended (“Securities Act”), and
the Investment Company Act. Investors in the Private Funds must be "accredited investors" under Regulation D of the
Securities Act, “qualified purchasers” under the Investment Company Act, and "qualified eligible persons" under CFTC Rule
4.7. Investors should review the offering documents for each Private Fund for further information with respect to the
minimum requirements for investment. Minimum account sizes for all other accounts or products vary based on the types
of services provided and regulatory requirements.

RIM generally does not engage high net worth individuals or retail investors directly. Such investors may access RIM’s
advisory services by investing in a RIM Advised Registered Fund (subject to any qualification standards) or investing in
RIM’s PMA product or SMA Model offerings through their Financial Intermediary. Investors who invest in a PMA portfolio
or SMA Model through their Financial Intermediary are generally not considered investment advisory clients of RIM.