BENCHMARK STATEMENTMSCI Digital Assets
Benchmark Family –Benchmark Statement
November 2023

© 2023 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

MSCI DIGITAL ASSETS BENCHMARK FAMILY – BENCHMARK STATEMENT |MONTH YEAR

Contents
Benchmark Statement: MSCI Digital Assets Index Family ............................................ 3
1

Objective of the Indexes in the Family ................................................................... 3

2

Methodology and Index Design Guidelines and Reviews ....................................... 43

Index Content Governance .................................................................................... 44

Index Calculation and Discretion ........................................................................... 4

5

Corrections ........................................................................................................... 5

6

Consultations ....................................................................................................... 6

7

Index Terminations ............................................................................................... 7

8

Index Usage .......................................................................................................... 7

9Additional Information .......................................................................................... 810

ESG Disclosures ................................................................................................. 8

Appendix I – Key Terms ............................................................................................... 9
Appendix II – ESG Factors in the Benchmark Statement of BMR Benchmarks in the
MSCI digital assets benchmark family ....................................................................... 10© 2023 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

MSCI.COM | PAGE 2 OF 12

MSCI DIGITAL ASSETS BENCHMARK FAMILY – BENCHMARK STATEMENT |MONTH YEAR

Benchmark Statement: MSCI Digital Assets Index Family
1

Objective of the Indexes in the Family
The MSCI digital assets benchmark family is comprised of indexes whose aim is to accurately andobjectively measure performance of a market or economic reality defined as the performance of
single or multiple digital assets as represented by combinations of individual “component” indexes(“Component Indexes”). The Component Indexes are calculated from the prices of underlying digitalassets and are administered by a 3rd party.

1.1

Digital Asset indexes are constructed from Component Indexes that represent a particular market
segment, theme or a variety of investment strategies and objectives pertaining to the digital assets
class.

1.2

Examples of MSCI Indexes within this family include the MSCI Global Digital Assets Index, the MSCI
Global Digital Assets Top 20 Index, and the MSCI Global Digital Assets Smart Contract Index. Also in
scope are MSCI Indexes representing returns to a single digital asset as calculated from one or moreexisting indexes that, for example, may effectively average alternative market closes or that havediffering underlying venue selection, price filtering or market-close calculation.

1.3

MSCI Digital Assets Indexes are governed by a number of methodology documents, including thespecific Component Index methodology; the MSCI Index Calculation Methodology; and the relevant
MSCI Index Policies.

1.4

The MSCI digital assets benchmark family also may include custom indexes based on an MSCI
methodology with specifications agreed with clients.

1.5

The MSCI digital assets benchmark family contains only Non-Significant indexes as defined byRegulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016 onindexes used as benchmarks.

© 2023 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

MSCI.COM | PAGE 3 OF 12

MSCI DIGITAL ASSETS BENCHMARK FAMILY – BENCHMARK STATEMENT |MONTH YEAR

2

Methodology and Index Design Guidelines and Reviews

2.1

MSCI indexes in the MSCI digital assets benchmark family aim to accurately and objectively
measure performance of a market or economic reality as represented by an investment opportunity
set accessible to institutional investors based on a market, market segment, theme, or investment
strategy. MSCI indexes are constructed and maintained with the following prime objectives in mind:•

Representativeness•

Replicability•

Efficiency

2.2

The index design objectives are achieved through the use of a transparent rules-based
methodological approach to index construction and maintenance.

2.3

MSCI indexes are rebalanced on a regular schedule ranging from daily to annually. The vast majorityof the indexes are likely to be rebalanced on a quarterly basis. A rebalancing may also be triggeredby conditions specified in the relevant methodology.

2.4

As part of the regular index rebalancing process, MSCI indexes are reviewed relative to the market or
strategy they are designed to reflect. This assists in the evaluation of methodologies for bothconsistency and effectiveness and may highlight situations where changes in the methodology are
warranted to reflect changes in the underlying market opportunity.

3

Index Content Governance

3.1

MSCI’s Index Policy Committee (“IPC”) and Equity Index Committee (“EIC”) preside over content
matters relating to its indexes such as the development and interpretation of MSCI index
methodologies in the MSCI digital assets benchmark family.

3.2

The EIC is primarily responsible for supervising the design, development, approval and interpretationof index methodologies. EIC discussions may be informed by feedback from the investmentcommunity. Nonetheless, all decisions taken by the committees are the sole responsibility of its
members.

3.3

The IPC is responsible for final decisions on market classifications and may be consulted on
selected index terminations and serves as an escalation point for the EIC. Relevant topics deemed tohave material importance, as determined by the EIC, are discussed and decided by the IPC.

4

Index Calculation and Discretion

4.1

MSCI indexes in the digital assets benchmark family are calculated by combining published
Component Index levels (Component Indexes) according to methodological rules. MSCI Digital
Assets Indexes do not use “contributed” input data.

4.2

The return of the indexes may be determined in a number of currencies including USD, EUR as wellas in terms of digital assets (“cryptocurrencies”) such as Bitcoin, Ethereum etc.

4.3

The MSCI Digital Assets Indexes rely on the continued availability of Component Index levels andpermission for MSCI to use such data for determining the MSCI Digital Assets Indexes. To the extent© 2023 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

MSCI.COM | PAGE 4 OF 12

MSCI DIGITAL ASSETS BENCHMARK FAMILY – BENCHMARK STATEMENT |MONTH YEAR

that such data is temporarily or permanently unavailable (whether as a result of a market disruption
event or otherwise), the MSCI index methodologies apply the fallback measures described below.
4.4

In case of the unavailability of a Component Index level used in the calculation of an MSCI Digital
Assets index level, MSCI carries forward the latest available Component Index level to calculate its
indexes. If MSCI determines that another level is more appropriate based on the circumstances, anannouncement would be sent to clients with the related information. All such determinations are
made by the EIC.

4.5

The rules for MSCI index construction, maintenance and calculation are contained in publicly
available methodology books and complemented with internal guidelines and operating procedures.
Each process is conducted by well-trained personnel according to documented rules and operatingprocedures.

4.6

MSCI’s rules-based index methodologies provide that discretion is not used in the production of theindexes except in unusual cases not effectively addressed by the methodology. These include, but
may not be limited to:•

Structural changes to the underlying markets,•

Operational issues experienced by Component Index providers,•Geo-political events,•

Events beyond human control

4.7

Where there may be a need to take an action that is not prescribed in the methodology, senior
members across the MSCI Index Research and Data Management departments will develop a
proposed approach with the goal of remaining consistent with the goals of the methodology andensuring timely calculation and distribution. These proposals are reviewed by the EIC. In cases whentime permits and the cases are deemed material, MSCI may consult with clients on the proposed
approach. MSCI will then announce the decided action to all market participants at the same time.

4.8

Typically, MSCI does not publish explicit ex-post analysis of decisions, other than through its regularreviews of indexes and methodologies, but always welcomes feedback from market participants on
decisions made.

4.9

The framework described above eliminates the exercise of discretion by an individual and ensures
any required exercise of discretion is managed through escalation to committees of experts. All
committees are governed by terms of reference and all decisions are appropriately documented andarchived. The IPC and EIC each have at least 6 members respectively and decisions are reached byconsensus.

5

Corrections

5.1

In the case of data errors that occur in the determination or calculation of an index in the MSCI
digital assets benchmark family, if the impact of the error is below a documented threshold1, no
historical index restatement is made.

1 Please refer to Correction Policy in MSCI Index Policies at http://www.msci.com/index-methodology© 2023 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

MSCI.COM | PAGE 5 OF 12

MSCI DIGITAL ASSETS BENCHMARK FAMILY – BENCHMARK STATEMENT |MONTH YEAR

5.2

If the impact of the error on performance is above this threshold at the index level, indexes arerestated historically.

5.3

MSCI applies a 12-month correction period for index errors. Errors discovered that are older than 12
months are generally not corrected.

5.4

Corrections related to regular index rebalancings are assessed on a case by case basis. MSCI
typically considers the following factors in determining the most appropriate corrective action: index
investability and replicability as well as potential reverse turnover.

5.5

All corrections are announced simultaneously to all market participants.

6

Consultations

6.1

MSCI indexes in the MSCI digital assets benchmark family are regularly reviewed and evaluated by
the Index Research team. MSCI conducts consultations before making any material changes to anindex methodology.

6.2

A consultation begins in general with an announcement giving the highlights of MSCI proposal(s)and indicating the location of the consultation document on MSCI’s website. The announcement is
widely distributed through multiple channels including the MSCI website, Bloomberg and Reutersand directly to MSCI’s clients. These consultations provide market participants the time andopportunity to comment on any potential changes to the index methodology.

6.3

Once a consultation is closed and MSCI has gathered all required feedback, the EIC and if
appropriate the IPC, reviews the feedback and makes a decision. Any decision to implementchanges is announced publicly prior to implementation.

6.4

The final decision, including the rationale that has led to it and high level participation statistics, iscommunicated publicly to all market participants at once. Most consultation participants requestthat their feedback remains confidential. MSCI may nevertheless publicly disclose feedback if
specifically requested by respective market participants. In that case, the relevant feedback would
be published together with the final results of the consultation.

6.5

If the final decision is to change the methodology, it will be part of the announcement, including thetimeframe for the implementation of the change. Subsequently, MSCI will update the relevant
methodology books.

6.6

The length of a consultation and lead time provided for implementation varies depending on thecomplexity of the topic, breadth of client impact as well as impact on the index composition and isclearly communicated as part of the consultation process. The length of a consultation needs to be
sufficient for market participants to meaningfully review what is proposed and respond.

6.7

For custom indexes, changes to any client specifications are discussed directly with the relevantclient.

© 2023 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

MSCI.COM | PAGE 6 OF 12

MSCI DIGITAL ASSETS BENCHMARK FAMILY – BENCHMARK STATEMENT |MONTH YEAR

7

Index Terminations

7.1

While terminations of MSCI indexes in the MSCI digital assets benchmark family are expected to berare, MSCI has clear written policies to address them2. There may be certain circumstances where
the methodology cannot be adapted in which case terminating the index may be required. These
circumstances are generally not within MSCI’s control and may include significant changes to thestructure of underlying market, drastic changes to the market infrastructure, lack of access tonecessary data, geo‐political events, and regulatory changes. Additionally, factors such as
methodology convergence or low usage may result in MSCI’s proposal to terminate an index.

7.2

In all of these cases if an index termination is proposed or required, MSCI would proceed as follows:•

The EIC would review the appropriateness and impact of a potential termination.

•

MSCI may perform a consultation including a discussion of possible alternatives, if any.

•

MSCI would announce the termination of the index in advance.

•

If practicable, MSCI would continue to calculate the index for an announced period of time togive users the opportunity to transition to another index or otherwise prepare for the terminationof the MSCI index.

•

In the event that an appropriate alternative MSCI index is established, the details of themethodology governing this index as well as the timing of the transition would be publicly
announced in advance of the implementation.

7.3

The termination of a custom index is handled in consultation with the relevant client.

8

Index Usage

8.1

MSCI indexes in the MSCI digital assets benchmark family may be licensed for a variety of purposes,
including for research or use as the basis for index-linked investment products. They may be used bya variety of market participants including but not limited to asset owners, portfolio managers, brokerdealers, and researchers. Not all uses are appropriate for all users. Market participants should use
their judgment when selecting an index for a particular purpose.
MSCI indexes and the effectiveness of index methodologies can be affected by a number of factors,
most of which are beyond MSCI’s control. These may include, but are not limited to, structuralchanges to the underlying market including decreases in the size and liquidity of the relevant market
segment, infrastructure changes, geo‐political events, and regulatory changes. These circumstances
may result in a material change of the methodology as a result. In rare cases, these circumstances
may result in the termination of an index.

8.2

If financial product issuers or investment managers choose to use an MSCI index in the MSCI digitalassets benchmark family as the basis of an index-linked financial product or an investment fund,they should consider this possibility, including the potential need to terminate or modify the terms ofa financial product resulting from the termination of the calculation of the index.

8.3

MSCI assumes no responsibility for potential use of its indexes in the MSCI digital assets
benchmark family for a particular purpose by clients, whether that use is for research, benchmarking,2 Please refer to Index Termination Policy in MSCI Index Policies at http://www.msci.com/index-methodology© 2023 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

MSCI.COM | PAGE 7 OF 12

MSCI DIGITAL ASSETS BENCHMARK FAMILY – BENCHMARK STATEMENT |MONTH YEAR

the basis for an index-linked financial product or investment fund, or some other use. The effective
representation of a market or strategy is the primary aim for MSCI.

9Additional Information
Detailed methodology and policy documents, a search function to find the methodology documents
governing a specific MSCI index in the MSCI digital assets benchmark family and vendor reference
codes, if available, can be found on http://www.msci.com/index-methodology.

10

ESG Disclosures
ESG disclosures are provided as per Commission Delegated Regulation (EU) 2020/1816 of 17 July
2020 supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council, as it
forms part of UK domestic law by virtue of the European Union (Withdrawal) Act 2018, as regards tothe explanation in the benchmark statement of how environmental, social and governance factors
are reflected in each benchmark provided and published.
Commission Delegated Regulation (EU) 2020/1816 includes the following sections:•••

Section 1 – Consideration of ESG factors
Section 2 – Additional disclosure requirements for EU Climate Transition and EU ParisAligned benchmarks
Section 3 – Disclosure of the alignment with the objectives of the Paris agreement

Refer to Appendix II for the details on disclosure pertaining to consideration of ESG factors for the
BMR Benchmarks in MSCI digital assets benchmark family. Section2 is not reported as there are no
EU Climate Transition or EU Paris-Aligned benchmarks in the MSCI digital assets benchmark family
as of the date of this report.

DATE OF PUBLICATION: November 24, 2023
DATE OF LAST UPDATE: November 24, 2023

© 2023 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

MSCI.COM | PAGE 8 OF 12

MSCI DIGITAL ASSETS BENCHMARK FAMILY – BENCHMARK STATEMENT |MONTH YEAR

Appendix I – Key Terms
Key term

Definition

Equity Index
Committee (EIC)The Equity Index Committee (EIC) is primarily responsible for thesupervision of the design, development, approval and interpretation ofindex methodologies. Decisions made by the EIC are the sole
responsibility of its members. The committee is staffed strictly by MSCI
employees.

Index Policy
Committee (IPC)

The Index Policy Committee (IPC) is responsible for final decisions withrespect to market classifications and may be consulted on selectedindex terminations and is an escalation point for the EIC. Relevant topics
deemed to have material importance, as determined by the EIC, arediscussed and decided by the IPC.

Component Indexes

Component Indexes are non-MSCI indexes representing performance ofan investment strategy in the underlying digital asset/s. These may
include, but are not limited to, reference indexes for single digital assets,baskets of multiple digital assets, indexes representing same underlying
asset but differentiated by timestamps, calculation methodologies anddata providers etc.

© 2023 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

MSCI.COM | PAGE 9 OF 12

MSCI DIGITAL ASSETS BENCHMARK FAMILY – BENCHMARK STATEMENT |MONTH YEAR

Appendix II – ESG Factors in the Benchmark Statement of BMR
Benchmarks in the MSCI digital assets benchmark family
Explanation of how ESG Factors are reflected in the Benchmark Statement of BMR Benchmarksin the MSCI digital assets benchmark family
Section 1 – Consideration of ESG Factors
Item 1. Name of the benchmark administrator

MSCI Limited

Item 2. Type of benchmark or family ofbenchmarks

Digital Assets

Item 3. Name of the benchmark or family ofbenchmarks

MSCI digital assets benchmark family

Item 4. Are there in the portfolio of thebenchmark administrator any EU Climate
Transition Benchmarks, EU Paris-aligned
Benchmarks, benchmarks that pursue ESG
objectives or benchmarks that take into
account ESG factors?

Yes

Item 5. Does the benchmark or family ofbenchmarks pursue ESG objectives?

No

Date on which information has last been
updated and reason for the update:

The information in this report was last updatedon November 24, 2023

© 2023 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document.

MSCI.COM | PAGE 10 OF 12

MSCI DIGITAL ASSETS BENCHMARK FAMILY – BENCHMARKSTATEMENT | MONTH YEAR

Contact us
msci.com/contact-us
AMERICAS

About MSCI

United States+ 1 888 588 4567 *Canada+ 1 416 687 6270

Brazil+ 55 11 4040 7830

Mexico+ 52 81 1253 4020

EUROPE, MIDDLE EAST & AFRICA
South Africa+ 27 21 673 0103

Germany+ 49 69 133 859 00

Switzerland+ 41 22 817 9777

United Kingdom + 44 20 7618 2222
Italy

+ 39 02 5849 0415

France+ 33 17 6769 810

ASIA PACIFIC
China+ 86 21 61326611

Hong Kong+ 852 2844 9333

India

+ 91 22 6784 9160

Malaysia

1800818185 *South Korea+ 82 70 4769 4231

Singapore+ 65 67011177

Australia+ 612 9033 9333

Taiwan008 0112 7513 *ThailandJapan

0018 0015 6207 7181 *+ 81 3 4579 0333

MSCI is a leading provider of critical decision
support tools and services for the global
investment community. With over 50 years ofexpertise in research, data and technology, we
power better investment decisions by enablingclients to understand and analyze key drivers of risk
and return and confidently build more effective
portfolios. We create industry-leading researchenhanced solutions that clients use to gain insight
into and improve transparency across theinvestment process.
To learn more, please visit www.msci.com.
The process for submitting a formal index
complaint can be found on the index regulation
page of MSCI’s website
at: https://www.msci.com/index-regulation.

* toll-free© 2023 MSCI Inc. All rights reserved.

MSCI.COM | PAGE 11 OF 12

MSCI DIGITAL ASSETS BENCHMARK FAMILY – BENCHMARK STATEMENT |MONTH YEAR

Notice and disclaimer
This document and all of the information contained in it, including without limitation all text, data, graphs, charts (collectively, the “Information”) is the property of
MSCI Inc. or its subsidiaries (collectively, “MSCI”), or MSCI’s licensors, direct or indirect suppliers or any third party involved in making or compiling any Information(collectively, with MSCI, the “Information Providers”) and is provided for informational purposes only. The Information may not be modified, reverse-engineered,
reproduced or redisseminated in whole or in part without prior written permission from MSCI. All rights in the Information are reserved by MSCI and/or its Information
Providers.
The Information may not be used to create derivative works or to verify or correct other data or information. For example (but without limitation), the Information
may not be used to create indexes, databases, risk models, analytics, software, or in connection with the issuing, offering, sponsoring, managing or marketing of any
securities, portfolios, financial products or other investment vehicles utilizing or based on, linked to, tracking or otherwise derived from the Information or any other
MSCI data, information, products or services.
The user of the Information assumes the entire risk of any use it may make or permit to be made of the Information. NONE OF THE INFORMATION PROVIDERS
MAKES ANY EXPRESS OR IMPLIED WARRANTIES OR REPRESENTATIONS WITH RESPECT TO THE INFORMATION (OR THE RESULTS TO BE OBTAINED BY THE USE
THEREOF), AND TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, EACH INFORMATION PROVIDER EXPRESSLY DISCLAIMS ALL IMPLIEDWARRANTIES (INCLUDING, WITHOUT LIMITATION, ANY IMPLIED WARRANTIES OF ORIGINALITY, ACCURACY, TIMELINESS, NON-INFRINGEMENT,COMPLETENESS, MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE) WITH RESPECT TO ANY OF THE INFORMATION.
Without limiting any of the foregoing and to the maximum extent permitted by applicable law, in no event shall any Information Provider have any liability regarding
any of the Information for any direct, indirect, special, punitive, consequential (including lost profits) or any other damages even if notified of the possibility of suchdamages. The foregoing shall not exclude or limit any liability that may not by applicable law be excluded or limited, including without limitation (as applicable), any
liability for death or personal injury to the extent that such injury results from the negligence or willful default of itself, its servants, agents or sub-contractors.
Information containing any historical information, data or analysis should not be taken as an indication or guarantee of any future performance, analysis, forecast
or prediction. Past performance does not guarantee future results.
The Information may include “Signals,” defined as quantitative attributes or the product of methods or formulas that describe or are derived from calculations using
historical data. Neither these Signals nor any description of historical data are intended to provide investment advice or a recommendation to make (or refrain frommaking) any investment decision or asset allocation and should not be relied upon as such. Signals are inherently backward-looking because of their use of historical
data, and they are not intended to predict the future. The relevance, correlations and accuracy of Signals frequently will change materially.
The Information should not be relied on and is not a substitute for the skill, judgment and experience of the user, its management, employees, advisors and/or clients
when making investment and other business decisions. All Information is impersonal and not tailored to the needs of any person, entity or group of persons.
None of the Information constitutes an offer to sell (or a solicitation of an offer to buy), any security, financial product or other investment vehicle or any trading
strategy.
It is not possible to invest directly in an index. Exposure to an asset class or trading strategy or other category represented by an index is only available through third
party investable instruments (if any) based on that index. MSCI does not issue, sponsor, endorse, market, offer, review or otherwise express any opinion regarding
any fund, ETF, derivative or other security, investment, financial product or trading strategy that is based on, linked to or seeks to provide an investment return related
to the performance of any MSCI index (collectively, “Index Linked Investments”). MSCI makes no assurance that any Index Linked Investments will accurately trackindex performance or provide positive investment returns. MSCI Inc. is not an investment adviser or fiduciary and MSCI makes no representation regarding theadvisability of investing in any Index Linked Investments.
Index returns do not represent the results of actual trading of investible assets/securities. MSCI maintains and calculates indexes, but does not manage actual
assets. The calculation of indexes and index returns may deviate from the stated methodology. Index returns do not reflect payment of any sales charges or fees
an investor may pay to purchase the securities underlying the index or Index Linked Investments. The imposition of these fees and charges would cause theperformance of an Index Linked Investment to be different than the MSCI index performance.
The Information may contain back tested data. Back-tested performance is not actual performance, but is hypothetical. There are frequently material differences
between back tested performance results and actual results subsequently achieved by any investment strategy.
Constituents of MSCI equity indexes are listed companies, which are included in or excluded from the indexes according to the application of the relevant index
methodologies. Accordingly, constituents in MSCI equity indexes may include MSCI Inc., clients of MSCI or suppliers to MSCI. Inclusion of a security within an MSCI
index is not a recommendation by MSCI to buy, sell, or hold such security, nor is it considered to be investment advice.
Data and information produced by various affiliates of MSCI Inc., including MSCI ESG Research LLC and Barra LLC, may be used in calculating certain MSCI indexes.
More information can be found in the relevant index methodologies on www.msci.com.
MSCI receives compensation in connection with licensing its indexes to third parties. MSCI Inc.’s revenue includes fees based on assets in Index Linked Investments.
Information can be found in MSCI Inc.’s company filings on the Investor Relations section of msci.com.
MSCI ESG Research LLC is a Registered Investment Adviser under the Investment Advisers Act of 1940 and a subsidiary of MSCI Inc. Neither MSCI nor any of its
products or services recommends, endorses, approves or otherwise expresses any opinion regarding any issuer, securities, financial products or instruments or
trading strategies and MSCI’s products or services are not a recommendation to make (or refrain from making) any kind of investment decision and may not be
relied on as such, provided that applicable products or services from MSCI ESG Research may constitute investment advice. MSCI ESG Research materials, including
materials utilized in any MSCI ESG Indexes or other products, have not been submitted to, nor received approval from, the Uni ted States Securities and Exchange
Commission or any other regulatory body. MSCI ESG and climate ratings, research and data are produced by MSCI ESG Research LLC, a subsidiary of MSCI Inc.
MSCI ESG Indexes, Analytics and Real Estate are products of MSCI Inc. that utilize information from MSCI ESG Research LLC. MSCI Indexes are administered by
MSCI Limited (UK).
Please note that the issuers mentioned in MSCI ESG Research materials sometimes have commercial relationships with MSCI ESG Research and/or MSCI Inc.
(collectively, “MSCI”) and that these relationships create potential conflicts of interest. In some cases, the issuers or their affiliates purchase research or otherproducts or services from one or more MSCI affiliates. In other cases, MSCI ESG Research rates financial products such as mutual funds or ETFs that are managed
by MSCI’s clients or their affiliates, or are based on MSCI Inc. Indexes. In addition, constituents in MSCI Inc. equity indexes include companies that subscribe to
MSCI products or services. In some cases, MSCI clients pay fees based in whole or part on the assets they manage. MSCI ESG Research has taken a number ofsteps to mitigate potential conflicts of interest and safeguard the integrity and independence of its research and ratings. More information about these conflict
mitigation measures is available in our Form ADV, available at https://adviserinfo.sec.gov/firm/summary/169222.
Any use of or access to products, services or information of MSCI requires a license from MSCI. MSCI, Barra, RiskMetrics, IPD and other MSCI brands and productnames are the trademarks, service marks, or registered trademarks of MSCI or its subsidiaries in the United States and other jurisdictions. The Global Industry
Classification Standard (GICS) was developed by and is the exclusive property of MSCI and S&P Global Market Intelligence. “Global Industry Classification Standard(GICS)” is a service mark of MSCI and S&P Global Market Intelligence.
MIFID2/MIFIR notice: MSCI ESG Research LLC does not distribute or act as an intermediary for financial instruments or structured deposits, nor does it deal on its
own account, provide execution services for others or manage client accounts. No MSCI ESG Research product or service supports, promotes or is intended tosupport or promote any such activity. MSCI ESG Research is an independent provider of ESG data.
Privacy notice: For information about how MSCI collects and uses personal data, please refer to our Privacy Notice at https://www.msci.com/privacy-pledge.

© 2023 MSCI Inc. All rights reserved.

MSCI.COM | PAGE 12 OF 12