FinSA - Client Categorisation and Information

On 1 January 2020, the new Swiss Financial Services Act dated 15 June 2018 (“FinSA”) as well as the new Financial Institutions Act dated 15 June 2018 (“FinIA”), including their respective ordinances, as well as the revision of the Collective Investment Schemes Act (“CISA”) and the Collective Investment Schemes Ordinance (“CISO”) entered into force, with transitional period ending 31st of December 2021. Due to FinSA entities providing financial services to clients in Switzerland are thereby subject to a new regulatory framework which is designed to enhance client protection (similar to the MiFID II directive), inter alia through introduction of new rules regarding client categorization (retail/professional and institutional), as well conduct and organizational standards. The FinSA also has an important impact on the fund distribution activity.

This notwithstanding, and for the benefit of its clients, State Street Global Advisors (“SSGA”) fully complies with the requirements since 1 January 2021.

Against this background, SSGA would like to inform you of the following:

1. Information about the Financial Services Providers

Switzerland:
State Street Global Advisors AG
Beethovenstrasse 19
8027 Zürich
Switzerland

State Street Global Advisors AG acts as sales and distribution platform for SSGA investment funds in Switzerland and the Principality of Liechtenstein. As such, State Street Global Advisors AG is not subject to a regulatory approval requirement in Switzerland, and therefore not subject to prudential supervision by the Swiss Financial Markets Authority FINMA. State Street Global Advisors AG is registered in the Commercial Register of the Canton Zürich under the registration number CHE-105.078.458.

United Kingdom:
State Street Global Advisors Limited
20 Churchill Place
Canary Wharf
London E14 5HJ
United Kingdom

State Street Global Advisors Limited acts as investment manager with respect to portfolios of – amongst others – Swiss clients and moreover acts in the area of sales and distribution for SSGA investment funds in various jurisdictions including Switzerland. State Street Global Advisors Limited is licensed by the UK Financial Conduct Authority (“FCA”) inter alia for Managing Investments, Advising on Investments, Arranging Deals in Investments, and making Arrangements with a view to Transactions in Investments as defined by the FCA, and is, in such capacity, supervised by the FCA. State Street Global Advisors Limited is registered under the Companies House Number 2509928.]

United States of America:
State Street Global Advisors Trust Company
One Iron Street
Channel Center Building
Boston, MA 02210-1641
USA

State Street Global Advisors Trust Company acts as investment manager with respect to portfolios of – amongst others – Swiss clients. State Street Global Advisors Trust Company is authorized to conduct trust and fiduciary services under chapter 167G of the Massachusetts General Law and is supervised by the Massachusetts Division of Banks. State Street Global Advisors Trust Company incorporated in the state of Massachusetts.

Germany:

With respect to Sales and Distribution of SSGA investment funds in Switzerland, SSGA AG is supported by

State Street Global Advisors Europe Limited
Germany Branch
Brienner Strasse 59
80333 Munich
Germany

State Street Global Advisors Europe Limited is authorized by the Central Bank of Ireland as a UCITS and AIF management company under the Irish UCITS and AIFM Regulations (S.I. No. 352 of 2011 and S.I. 257 of 2013) and has passported its permissions to conduct Investment Advice as well as Reception and Transmission of Orders in relation to financial instruments to the Germany Branch under the EU passporting procedure. The Germany Branch is further permitted to conduct marketing activities in accordance with Art. 32 of the AIFM Directive (2011/61/EU) and Art. 17 od the UCITS Directive (2009/65/EU). State Street Global Advisors Europe Limited has its registered seat at 78 Sir John Rogerson's Quay, Grand Canal Dock, Dublin, D02 HD32, Ireland, Company Number 49934. State Street Global Advisors Europe Limited, Germany Branch, is registered in the Munich trade register with company number HRB 266158.

2. Information about the Financial Services

The Financial Services provided to you can be either categorized as

a. acquisition or disposal of financial instruments according to Art. 3 lit. c No. 1 FinSA. SSGA does not provide you with personal recommendations on transactions with financial instruments within the meaning of Art. 3 lit. a FinSA. SSGA is not required to assess the appropriateness and suitability under FinSA; or

b. administration of financial instruments (portfolio management) according to Art. 3 lit. c No. 3 FinSA in conjunction with the acquisition or disposal of financial instruments according to Art. 3 lit. c No. 1 FinSA. Regarding the acquisition or disposal of financial instruments according to Art. 3 lit. c No. 1 FinSA, SSGA does not provide you with personal recommendations on transactions with financial instruments within the meaning of Art. 3 lit. a FinSA. In this regard, SSGA is not required to assess the appropriateness and suitability under FinSA.


3. Risk Information

Investing involves risk including the risk of loss of principal.

With respect to risks from your investments in SSGA products, please refer to the specific risk disclosures in the official prospectus, which can be obtained from the main distributor in Switzerland, State Street Global Advisors AG, Beethovenstrasse 19, 8027 Zurich, as well as / or to the relevant disclosures on ssga.com.


4. Information about Economic Relationships

State Street Global Advisors AG is a subsidiary of State Street Corporation, State Street Financial Center, One Lincoln Street, Boston, Massachusetts 02111-2900, USA, registered with the US Federal Reserve as a bank holding company pursuant to the Bank Holding Company Act of 1956.

State Street Global Investors Limited is a subsidiary of State Street Corporation, State Street Financial Center, One Lincoln Street, Boston, Massachusetts 02111-2900, USA, registered with the US Federal Reserve as a bank holding company pursuant to the Bank Holding Company Act of 1956.

State Street Global Advisors Trust Company is a subsidiary of State Street Corporation, State Street Financial Center, One Lincoln Street, Boston, Massachusetts 02111-2900, USA, registered with the US Federal Reserve as a bank holding company pursuant to the Bank Holding Company Act of 1956.

State Street Global Advisors Europe Limited (including its Germany Branch) is a subsidiary of State Street Corporation, State Street Financial Center, One Lincoln Street, Boston, Massachusetts 02111-2900, USA, registered with the US Federal Reserve as a bank holding company pursuant to the Bank Holding Company Act of 1956.

SSGA has taken appropriate measures in line with applicable regulation to mitigate any conflicts of interest.


5. Information about affiliation with a Swiss Ombudsman

State Street Global Advisors AG, State Street Global Advisors Limited (UK), State Street Global Advisors Europe Limited and State Street Global Advisors Trust Company have appointed the following ombudsman for any kind of disputes for according mediation:

Verein Ombudsstelle Finanzdienstleister (OFD)
Bleicherweg 10
CH-8002 Zürich
www.ofdl.ch
E-Mail: ombudsmann@ofdl.ch

Ombudsman proceedings are conducted on a confidential basis and in any official language of the Swiss Confederation chosen by you.

6. Contact Details

In case of questions, kindly contact your responsible Client Relationship Manager, or, alternatively

Adrian Marx
c/o State Street Global Advisors AG
Beethovenstrasse 19
8027 Zürich
Switzerland

adrian_marx@ssga.com
Tel. +41442457026

AdTrax: 3938884.1.2.EMEA.INST
Exp. Date: 31/12/2022