pg. 1

"In addition, Vanguard actively engages with portfolio companies and their boards to discuss material risks, ranging from business and operational risks to environmental and social risks. Vanguard’s investment stewardship activities encourage boards to properly oversee such material risks. We have established a formal procedure to identify and monitor portfolio companies whose direct involvement in crimes against humanity or patterns of egregious abuses of human rights would warrant engagement. We will continue to build out our monitoring of business practices and engage with companies where we believe that action is required."