pg. 3

"Training

Russell Investments provides training to its associates on Anti-Bribery, Anti-Corruption, Anti-Money Laundering and the FCA Conduct Rules. This training is mandatory. Where an associate does not complete mandatory training by the due date (in the absence of mitigating circumstances), this is recorded as a conduct violation and reported to the Russell Investments board of directors.

Russell Investments provides a training programme, Promoting Equality and Diversity to team leaders, managers and supervisors on raising awareness and how to develop a culture that encourages diversity and equal opportunities in the workplace."