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Northern Trust Statement Regarding Government Relations and Political Contributions

As a leading provider of asset servicing, fund administration, asset management, fiduciary, and banking solutions for corporations, institutions, families, and individuals worldwide, Northern Trust Corporation (“Northern Trust”) has a responsibility to support public policy positions that enhance the safety of client assets and promote the safety and soundness of the financial system and a strong global economy.

Northern Trust concentrates its public policy positions in areas most relevant to its businesses. Our public policy and lobbying focus includes, among other things, United States federal, state, and European Union financial regulatory reform efforts. We work with many trade associations of which we are a member, and we also meet directly with members of Congress, state legislators, regulators, and other government officials globally to discuss our positions and make recommendations for improved policy and regulation.

At the United States federal level, we focus on proposed regulatory and policy changes that will impact our businesses and support those changes that will enhance the safety of client assets and promote the safety and soundness of the financial system and a strong global economy. At the state level, we regularly meet with elected and appointed officials to discuss public policy positions that will impact the businesses of The Northern Trust Company, our principal subsidiary and the largest bank chartered in Illinois. In appropriate circumstances, we file comment letters to proposed federal regulations, copies of which are publicly available from regulatory agencies.

Political Contributions by Employees
Northern Trust expects employees to seek guidance and pre-clear certain individual political contributions. More detailed Northern Trust policies and procedures that apply to all employees or certain groups of employees are set forth in pre-clearance procedures and other documents, including a summary of state and local jurisdictions with “pay-to-play” restrictions on political contributions.

Corporate and PAC Political Contributions
Northern Trust engages in the political process in order to advance and protect its long-term interests. Meaningful engagement requires Northern Trust to participate in the legislative and regulatory process and support candidates through prudent political contributions.

Northern Trust contributes to candidates for public office in compliance with applicable law. Northern Trust contributes corporate funds to industry trade organizations relating to its public policy objectives. Participation in these organizations is important to gain industry insight, foster relationships and professional opportunities within the industry, and facilitate and collaborate on public policy topics of mutual interest.

Northern Trust sponsors both a federal-only political action committee and a multi-candidate political action committee (“Northern PACs”). Both are allowed to solicit a restricted class of Northern Trust’s U.S. employees for contributions, which then can be used to support candidates who support effective legislation important to Northern Trust. All contributions to Northern PACs are voluntary; employees are neither favored nor disadvantaged on the basis of their participation. Decisions about potential contributions are reviewed and approved by the respective leadership of the Northern PACs, based on the public policy interests of Northern Trust. Federal lobbying reports may be found at http://www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm and our financial contributions can be found at: http://www.fec.gov/finance/disclosure/candcmte_info.shtml.

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(Effective January 25, 2013)