pg. 2

"- Any third-party investment management is subject to a due diligence processes prior to the commencement of any business relationship with Russell Investments and there is a robust governance arrangement around the process of selecting third-party investment managers. Thereafter, on an ongoing basis the arrangement is subject to periodic risk management checks taking into account compliance with laws and regulations. Any investment manager will also be asked to contractually agree to complying with relevant regulatory requirements and applicable laws."