Russell Investments Implementation Services LLC

Fees and Compensation and Item 12 – Brokerage Practices for additional information.

RUSSELL INVESTMENTS AFFILIATES

In certain cases, RIIS uses, suggests, and recommends its own services and those of its affiliates to clients, which may
create potential conflicts of interest. The arrangements between RIIS and our affiliates may involve sub-advisory
agreements, 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
advisers that are not required to be registered. In certain cases, these non-US affiliates provide portfolio management or
research services to the US registered entities 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 the US registered entities relying on its services 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, RIIS’s US clients.

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

Affiliated US Registered Investment Advisers

RICAP is an investment adviser registered with the SEC and is also a registered commodity pool operator (“CPO”) with the
CFTC and is a 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, RIIS shares
employees and investment personnel with RICAP.

RIM is an investment adviser registered with the SEC under the Advisers Act and is also a registered CPO with the CFTC
and is a member of the NFA. In general, RIM conducts the following services: (i) multi-manager investment advice, index-
based investment advice, fund-of funds investment advice, short term and fixed income investments advice, objective
setting, asset allocation, derivatives advice and other advisory services to affiliated investment companies, other pooled
investment vehicles, pension clients, and other institutional clients; and (ii) licensing of model securities portfolios to plan
sponsors, investment advisers and broker-dealers. Through intercompany agreements and/or “dual hatting”
arrangements, RIIS shares employees and investment personnel with RIM.

Affiliated US Registered Broker-Dealer

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 certain affiliated Funds.

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.

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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. Through
intercompany agreements and/or “dual hatting” arrangements, RIIS 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
agency and administration services to certain affiliated Funds.

Non-US Affiliates and Participating Affiliates

RIIS is part of the Russell Investments global organization, which includes affiliated investment advisers and financial
services firms located in Canada, the United Kingdom, Ireland, France, Australia, Japan, and other jurisdictions. The full list
of non-US affiliates can be found in RIIS’s Form ADV Part 1, Item 7.A.

While not material to RIIS’s advisory business, certain of these affiliates:

    •    are registered or authorized to provide investment management, advisory, or distribution services in their
         respective jurisdictions;
    •    may provide portfolio management, transition management, implementation, research, distribution, or
         administrative services; and
    •    may act as Participating Affiliates under applicable SEC no-action relief governing cross-border advisory
         arrangements.

Employees of certain non-US affiliates may be treated as associated persons of RIIS for purposes of providing advisory
services consistent with SEC no-action letters governing participating affiliate arrangements.

These affiliations create potential conflicts of interest because Russell Investments may benefit from the allocation of
business, compensation, or resources among affiliated entities. RIIS addresses these conflicts through internal compliance
controls, supervisory procedures, and policies designed to ensure services are provided in the best interests of clients.

    •    Russell Investment Group Ltd. is an investment adviser regulated by the New Zealand Financial Markets Authority
         that provides asset consulting and implemented consulting services to large institutional investors in New Zealand,
...

Item 7 – Types of Clients
We provide investment advisory services to qualified retirement portfolios, corporations, endowments and foundations,
state and municipal government entities, and other affiliated and non-affiliated Funds and Private Funds. We also provide
investment advice and brokerage services to other institutional clients including insurance companies, third-party money
managers, and Russell Investments’ US and global pooled fund complexes and foreign pension schemes.

We may provide advisory or brokerage services to Private Funds that are used in providing investment solutions to certain
clients. 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 Commodity Futures Trading Commission (“CFTC”) Rule 4.7. Investors should
review the offering documents for each Private Fund for further information with respect to the minimum requirements

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for investment. Minimum account sizes for all other accounts or products vary based on the types of services provided
and regulatory requirements.