COMPLIANCE STATEMENT

Solactive AG is registered with and regulated by
the German Federal Financial Supervisory
Authority (BaFin)

Compliance Statement

COMPLIANCE STATEMENT
This document represents the Compliance Statement pursuant to Article 26(3) of Regulation (EU) 2016/1011 (the“Benchmark Regulation” or “BMR”) of Solactive AG, an administrator of non-signiﬁcant benchmarks. The table in Section B contains a list of the provisions of the BMR that Solactive has chosen not to apply, accompaniedby an explanation for each provision stating why it is not appropriate for Solactive to comply with it. This Compliance Statement has been drawn up in accordance with the template for the compliance statement in Annex
II of the Commission Implementing Regulation (EU) 2018/1106.

A. GENERAL INFORMATION
Item

Text ﬁeld

1. Date of creation of the Compliance Statement and, where applicable, of the latest
update to it

1. Created: October 6, 2021
Last Updated: February 13, 2023

2. Name of the administrator

2. Solactive AG

B. SPECIFIC INFORMATION
Solactive AG chooses to not apply the following provisions of Regulation (EU) 2016/1011 inrespect of its non-signiﬁcant benchmarks identiﬁed below

1. The benchmark or benchmarks in respectof which the provision(s) do not apply

1. Solactive L\&G Enhanced ESG Europe ex UK Index TR
ISIN: DE000SL0EA40

2. (i) The provision or provisions of Regulation (EU) 2016/1011 that do not apply(ii) For each provision, the reasons why it
is appropriate for the administrator not tocomply with that provision2Compliance Statement

Article 5(3)(a) of the BMR:
The oversight function shall operatewith integrity and shall have the following responsibilities, which shall be adjusted by the administrator based on thecomplexity, use and vulnerability of thebenchmark: (a) reviewing the benchmark’s deﬁnition and methodology atleast annually.

Solactive has implemented a detailed New Index Approval Process (NINA) to ensure the integrity of its benchmarks and to minimize the need for any adjustment of
the index methodology. As such, Solactive will only review the benchmark’s deﬁnition and methodology on anad hoc basis and not on a periodic basis, such as the “atleast annually” period proposed in the BMR.

Article 5(3)(e) of the BMR:
The oversight function shall operatewith integrity and shall have the following responsibilities, which shall be adjusted by the administrator based on
the complexity, use and vulnerability ofthe benchmark: (e) overseeing any third
party involved in the provision of thebenchmark, including calculation or dissemination agents.

Due to the fact that the members of the oversight committee are from different business units, it is Solactive’s
opinion that the oversight of third parties involved in theprovision of the benchmark would be conducted much
more efﬁciently by the Compliance department together
with the Operations Team.

Article 6(5) of the BMR:
The control framework shall be documented, reviewed and updated as appropriate and made available to the relevant competent authority and, upon request, to users.

As the control framework of Solactive contains protected/internal business data, it has been decided thatthe control framework will not be published or madeavailable to third parties.

Article 7(2) of the BMR:
An administrator shall designate an internal function with the necessary capability to review and report on the administrator’s compliance with the benchmark methodology and this Regulation.

It is the opinion of Solactive that, due to the implemented
New Index Approval Process (NINA) and the new control
framework, an additional control function to review andreport compliance with the methodology of the benchmark and the BMR is not needed and would not be appropriate (also in the view of the size of the company).
3Compliance Statement

Article 11(1) of the BMR1 :The input data referred to in point (a)shall be veriﬁable;

The benchmark is continuously calculated during a speciﬁed period on a business day. Due to the high calculation frequency of intraday values, it is not possible toverify the input data used in each case. The implementation of procedures to allow for such intraday veriﬁcation would not be appropriate and would make it impossible to continue to calculate the benchmark in thecurrent frequency. In addition, ﬁnancial instruments, ﬁnancial contracts and investment funds that reference
the benchmark generally use the end-of-day value of thebenchmark to determine the values derived from thebenchmark.
For input data based on end-of-day values for the assets
underlying the benchmark, Solactive has a procedure inplace to verify such input data.
Spot foreign exchange rates used for conversions ofprices and values of components of the benchmark
quoted in a currency other than the currency of thebenchmark cannot be veriﬁed due to the lack of alternative available sources. Furthermore, the transparencyof these exchange rates, which is achieved through theirpublication, has the effect of veriﬁcation through existing market mechanisms.

1Article 11 (1) (b) BMR makes reference to Article 11 (1) (a) of the BMR

4

Compliance Statement©Solactive AG, 2021. All rights reserved.

“Solactive”, “Solactive GBS”, “German Index Engineering” and the logo
marks of Solactive AG.

are registered trade-

This document constitutes the Compliance Statement in accordance with Article 26(3) of the BMR
and Annex II of the Commission Implementing Regulation (EU) 2018/1106. The information inthis document does not constitute tax, legal or investment advice. The Compliance Statement isproprietary to Solactive AG. Its content may not be modified, reproduced, redistributed or stored
in a retrieval system in whole or in part without the prior written consent of Solactive AG.

5CONTACTSolactive AG
German Index Engineering
Platz der Einheit 160327 Frankfurt am Main
Germany
Tel.:
Fax:
Email:
Website:+49 (0) 69 719 160 00+49 (0) 69 719 160 25
info@solactive.com
www.solactive.com© Solactive AG