LIBOR Transition

Interbank Offered Rates (“IBOR”) have been used globally in financial markets as a key
benchmark to price and value loans, bonds, derivatives and a range of other financial
products. IBOR will no longer be used after 2021 due to changes in benchmark regulations.
The revised benchmark regulations will mean that alternative reference rates will be used as
benchmarks going forward. Financial regulators have been closely engaged with industry
working groups to identify these alternative replacement rates and have developed them on acurrency-by-currency basis.

What is LIBOR?
The London Interbank Offered Rate (“LIBOR”) is the most broadly used IBOR benchmark
in the world and is representative of the rates at which banks have historically been
prepared to lend among themselves and are available across a range of standardisedtime horizons, from overnight to 12 months ahead.

What is happening to LIBOR?
Following multiple high-profile legal cases related to the manipulation of LIBOR, thevulnerability of IBORs to fixing has been highlighted. This has led to global coordination
for a more robust alternative. Consequently in 2017 the Financial Conduct Authority(“FCA”) announced its intention to stop compelling banks to submit the rates required tocalculate LIBOR after the end of 2021. The FCA and other global regulators haveencouraged participants in the financial markets to take steps to stop using LIBOR by thisdate. LIBOR therefore will cease as at the end of 2021 and firms need to transition toalternative reference rates. There are industry groups created across several jurisdictions
that have identified these replacement benchmarks, and consultations are ongoing toestablish new rules as the transition approaches.

Which alternate rates have been identified?
JURISDICTION

WORKING GROUP

ALTERNATIVE RATE

RATE ADMINISTRATOR

UK

Working group on
Sterling Risk-Free
Reference Rates

Reformed Sterling
Overnight Index
Average (SONIA)

Bank or England

Euro Area

Working Group on Euro
Risk-Free Rates

Euro Short-Term Rate(€STR)

European Central Bank

Switzerland

The National Working
Group on Swiss Franc
Reference Rates

Swiss Average Rate
Overnight (SARON)SIX Swiss Exchange

Japan

Cross-Industry
Committee on
Japanese Yen Interest
Rate Benchmarks

Tokyo Overnight
Average Rate (TONA)Bank of JapanUSA

Alternative Reference
Rates Committee

Secured Overnight
Financing Rate (SOFR)

Federal Reserve Bank ofNew York

Russell Investments / EMEA Compliance/1What are Russell Investments doing to prepare?
Russell Investments, along with other investment managers, banks, brokerage firms andvendors in the financial services industry, has launched transition programs to implement
the switch to products linked to alternative reference rates before the end of 2021. In
addition, clearing houses have announced their intention to switch discounting andmargining interest rates to alternative reference rates during 2020, which is expected toserve as a catalyst towards wider acceptance and increased liquidity in all of the markets
affected by this change. We are closely following developments in this evolving area sothat we can adopt approaches that are consistent with industry best practice. We havestarted planning for effective management of the transition away from LIBOR and havededicated teams responsible for this task. As part of this, we will transition client and otherexposures from IBORs to alternative reference rates. This will include assessing andmanaging clients’ IBOR exposure in a way that protects their best interests.
We recognize the importance of this industry-led transition and are aware that it is ofinterest to our clients. The impact of the transition will not be the same for all investment
funds, portfolios and services and we are working towards understanding the specificimplications for each of our clients.
Any developments will be communicated to our clients to keep them informed of any
changes which may have significant impact for them. This documentt will be updated withall relevant changes.

Russell Investments / EMEA Compliance/2