March 7, 2022

Statement Regarding NTAM Investments in Russian Securities

As with so many around the world, Northern Trust is deeply concerned by the invasion of Ukraine and the suffering it has caused. We are taking action through a number of steps to appropriately manage our clients' very limited exposure to Russian securities which is primarily through index funds

As with so many around the world, Northern Trust is deeply concerned by the invasion of Ukraine and the suffering it has caused. We are taking action through a number of steps to appropriately manage our clients' very limited exposure to Russian securities which is primarily through index funds, including:

Engaging with index providers, at their request, to inform their decisions on the appropriate treatment of Russian securities. All providers of indices tracked by Northern Trust Asset Management, including Northern Trust’s own indices, have announced they are in the process of removing such securities. In terms of impact, these securities comprised less than 1% of global indexes pre-invasion.
Suspending purchases of Russian securities across all asset classes and all strategies where NTAM has investment discretion.
Full compliance with sanctions and other market restrictions.
Convening our pricing, valuation and governance resources regularly to establish appropriate fair value for Russian securities which may lead to pricing at zero value.* Pre-invasion, NTAM’s holdings in such securities comprised less than 1% of the firm’s AUM.
While market illiquidity currently makes it difficult if not impossible to divest from Russian securities, we continually monitor market conditions and will liquidate positions that no longer meet account objectives or are not compliant with applicable sanctions as soon as practicable.
A Northern Trust donation of $250,000 has been made to humanitarian relief efforts in Ukraine, and employee contributions are being matched dollar-for-dollar.

We continue to monitor developments closely as we hope for a swift end to the war.

*Note, fair value is subject to change without notice given the extraordinary circumstances leading to fluid and fast moving market conditions.

The information is not intended for distribution or use by any person in any jurisdiction where such distribution would be contrary to local law or regulation. Northern Trust and its affiliates may have positions in and may effect transactions in the markets, contracts and related investments different than described in this information. This information is obtained from sources believed to be reliable, and its accuracy and completeness are not guaranteed. Information does not constitute a recommendation of any investment strategy, is not intended as investment advice and does not take into account all the circumstances of each investor. Opinions and forecasts discussed are those of the author, do not necessarily reflect the views of Northern Trust and are subject to change without notice.

This report is provided for informational purposes only and is not intended to be, and should not be construed as, an offer, solicitation or recommendation with respect to any transaction and should not be treated as legal advice, investment advice or tax advice. Recipients should not rely upon this information as a substitute for obtaining specific legal or tax advice from their own professional legal or tax advisors. References to specific securities and their issuers are for illustrative purposes only and are not intended and should not be interpreted as recommendations to purchase or sell such securities. Indices and trademarks are the property of their respective owners. Information is subject to change based on market or other conditions.

All securities investing and trading activities risk the loss of capital. Each portfolio is subject to substantial risks including market risks, strategy risks, adviser risk and risks with respect to its investment in other structures. There can be no assurance that any portfolio investment objectives will be achieved, or that any investment will achieve profits or avoid incurring substantial losses. No investment strategy or risk management technique can guarantee returns or eliminate risk in any market environment. Risk controls and models do not promise any level of performance or guarantee against loss of principal. Any discussion of risk management is intended to describe Northern Trust’s efforts to monitor and manage risk but does not imply low risk.

Northern Trust Asset Management is composed of Northern Trust Investments, Inc. Northern Trust Global Investments Limited, Northern Trust Fund Managers (Ireland) Limited, Northern Trust Global Investments Japan, K.K, NT Global Advisors, Inc., 50 South Capital Advisors, LLC, Belvedere Advisors LLC and investment personnel of The Northern Trust Company of Hong Kong Limited and The Northern Trust Company.