Global Execution and Order Placement Disclosure

1. Background

The purpose of this document is to explain BlackRock’s Execution and Order Placement Policy (‘the Policy’), as required under the recast Markets in Financial Instruments Directive 2014/65/EU (MiFID) and Markets in Financial Instruments Regulation EU 600/2014 (MiFIR) (the Directive and Regulation together “MiFID II”) and the UK version of the regulation EU 600/2014, which is part of UK Law by virtue of the European Union (Withdrawal) Act 2018 UK (Onshoring of MiFID II in the UK).

Under such rules, BlackRock is required to take all sufficient steps to obtain the best possible result when executing clients’ orders. This is an obligation referred to as “best execution.”

This Policy sets out how BlackRock complies with its obligation to act in the best interests of its clients when directly executing orders on behalf of clients and additionally when placing orders with entities (such as brokers and dealers) for execution, pursuant to applicable regulation. References in this Policy to the execution of client orders include the execution of clients’ orders, and/or BlackRock’s decisions to execute orders on behalf of its clients.

All terms used in this document are defined in accordance with MiFID II and the Onshoring of MiFID II in the UK. Additionally, a Glossary of key terms can be found in Appendix 1.

2. Scope

This document applies to:

• BlackRock entities regulated by MiFID II and the Onshoring of MiFID II by the United Kingdom which execute client orders, place orders with, or transmit orders to, other entities for execution (listed below).
• BlackRock Investment Management (UK) Limited (“BIM”)
• BlackRock Advisors (UK) Limited (“BAL”)
• BlackRock International Limited (“BIL”)
• BlackRock (Netherlands) B.V. (“BNBV”)
• BlackRock Institutional Trust Company N.A, UK Branch (“BTC”)
• BlackRock Asset Management Deutschland AG (“BAMDE”)
• BlackRock France SAS (“BFS”)
• BlackRock Fund Managers Limited (“BFM”), a UCITS Management Company and Alternative Investment Fund Manager located in the United Kingdom, (only those sections of the policy required by relevant regulation) Orders executed for Professional Clients in relation to financial instruments defined by MiFID II.

3. BlackRock's Trade Execution Model

BlackRock’s trade execution model that involves the centralisation of its trading platform, whereby orders are routed to specialised trading desks. Maintaining a centralized execution model allows BlackRock to create a separation of duties between trading and portfolio management for most trading activity. It also allows BlackRock to seek to optimize trade execution which is beneficial to BlackRock’s clients, through a globally consistent operating model for order communication to facilitate Global Order Routing.

BlackRock’s centralized trading desks are separate from BlackRock’s portfolio management function, with certain exceptions due to the uniqueness of particular investment strategies and financial instruments and are operated by BlackRock regulated entities in each jurisdiction.

Dealing desks outside the European Economic Area (the “EEA”) and the United Kingdom follow similar policies, processes and procedures. However, the counterparties and trading methods used may vary from those used in the EEA and the United Kingdom given country specific practices.

BlackRock may match and cross orders received in opposite directions in the same financial instrument where permitted by applicable laws, regulations, and client agreements, and when BlackRock believes this is in the best interest of both clients. When this occurs, it is done in accordance with BlackRock's Global Crossing Policy and related procedures, which set out provisions and controls designed to manage potential conflicts of interests between clients participating in such cross trades. In the EEA and the United Kingdom, BlackRock typically identifies a crossing opportunity and executes the cross trade on a trading venue which facilitates that type of trade.

4. Order Handling Protocol

Client orders are typically executed in the order in which they are received by the trading desk unless the characteristics of the order or prevailing market conditions make this impractical, and not in the best interest of the client.

Subject to local regulatory requirements, and consistent with BlackRock’s duty to seek best execution, BlackRock may find it efficient and beneficial to aggregate contemporaneous orders for multiple clients. BlackRock’s Global Investment and Trading Allocation Policy sets out how BlackRock handles the aggregation of client orders and the fair allocation of financial instruments executed as part of an aggregated order over time.

5. Brokers/Counterparties & Execution Venues

In seeking best execution for its clients, BlackRock may use a variety of execution venues and methods including, but not limited to, brokers acting in an agency or principal capacity, block dealing, Request for Quote (“RFQ”) platforms, swap execution facilities, and sponsored access to the order books of major execution venues).

BlackRock will either:

1. Execute an order for a client on an execution venue, or with brokers acting as market makers, liquidity providers or in a principal capacity, or
2. Place orders with brokers for them to execute on the execution venue.

A current list of Execution Venues and brokers used by BlackRock can be found in Appendix 2. This list is subject to change and may be revised from time to time.

With our clients’ consent and unless there is a regulatory obligation to trade certain financial instruments on Trading Venues, we may execute trades in financial instruments traded on Trading Venues outside such venues. This enables us to access a wider range of sources of liquidity and it is particularly desirable when trading illiquid financial instruments and/or large sizes, where we would likely aim to minimize the risk of information leakage or signalling to the market, to avoid a poor execution outcome. In these cases, we may find it more desirable to trade with a broker acting as a systematic internaliser or in a principal capacity.

Although there are benefits to executing trades outside of a trading venue, it should be noted that there is a risk that a broker will fail to meet its obligations in relation to the transaction (‘Counterparty Risk’). While contractual remedies would be available in these circumstances, protections which may be available when trading on venues (such as buy-in procedures) may not be available. Clients can request additional information from BlackRock about the consequences of transactions being executed outside a Trading Venue.

6. Broker/Counterparty Approval Process

All prospective and existing counterparties require the approval of BlackRock’s Counterparty Risk Group (“CRG”), which operates under BlackRock’s independent risk management function, Risk & Quantitative Analysis Department (“RQA”).

The CRG is independent from the trading and investment functions, and is responsible for developing, implementing and updating, firmwide counterparty credit policies and procedures (collectively the “Counterparty Credit Risk Policy”) that are designed to identify and evaluate counterparty credit risks and establish appropriate practices to manage these risks. All employees responsible for trade execution are required to comply with the Counterparty Credit Risk Policy.

The Global Trading and Investment Teams are required to submit all prospective trading counterparty requests to the CRG for an independence credit assessment. These views are undertaken at the legal entity level and consider the intrinsic credit quality of the trading counterparty, together with the expected transaction activities.

7. Ongoing Monitoring of Brokers/Counterparties

The CRG maintains a list of approved trading counterparties and reviews the list on an on-going basis via a number of sources including but not limited to audited and interim financial reports, rating agency reports and bulletins where available, various databases and news media and, if covered, output from the BlackRock Credit Research Group. All trading counterparties undergo a cyclical formal review and renewal on a 12 to 18-month basis. Additional interim trading counterparty reviews may be completed in accordance with local regulatory requirements. Periodic updates are presented to the relevant best execution governance forums on counterparty risk matters, as appropriate.

8. Best Execution Obligation and Relevant Factors

BlackRock performs its best execution obligation to take all sufficient steps to obtain consistently over time the best possible results for our clients when executing or placing, or transmitting, client orders by assessing the relative weight and importance of various execution factors and other relevant considerations under the particular circumstances.

A. Execution Factors

BlackRock may consider any one or more of the following execution factors, as relevant:

• price of the relevant financial instrument net of brokers’ commissions, Execution Venues’ fees and other applicable execution costs;
• costs incurred in execution of the transaction;
• speed of execution;
• likelihood of execution and settlement;
• market conditions
• instrument liquidity
• size of the order;
• nature of the order; and
• any other relevant factors.

The relative importance of the execution factors for individual orders varies depending on the characteristics of the order, the financial instrument, the Execution Venues available for execution or placement of that order and the specific market conditions at the time of the trade, such as signals (e.g., indications of interest or axes) about the availability of natural liquidity.

B. Execution Factors and Characteristics of the Order

When generating an order, BlackRock’s PMs specify instructions relating to the strategy they are pursuing on behalf of clients and for the nature of the order that they are generating. For example, their instructions may vary depending on whether the order was driven by cash inflows or outflows or by changes in the PM’s view regarding a particular investment or type of exposure. Such instructions help influence the prioritization of the execution factors by BlackRock’s traders. The instructions of PMs typically fall into one of the following categories:

Forward Benchmarks

These orders target execution at a price specified by reference to a point in time in the future (such as “market on close” for stocks or WMR Benchmark Rate for currencies) when the calculation of the price will take place, often by way of an auction mechanism.

This type of benchmark is widely used by index sponsors for index calculation and it is also generally used by managers when executing orders for passive strategies in order to minimize their tracking error. Trading is typically concentrated around the specified future point in time, unless a trader believes there will be insufficient liquidity in the auction or at the close of the market; in such cases a trader may extend the trading window to execute outside of the auction while still seeking to manage tracking error appropriately.

Market-on-close orders typically prioritize the execution factors of likelihood and speed of execution at the required time.

Explicit Price Benchmarks

These orders (such as limit or stop orders) specify a price point at which (or at a more advantageous price than which) to buy or sell the relevant amount of a financial instrument. An explicit price benchmark can be used by active investment strategies to help mitigate total expenses. It can also be used by passive strategies, which, for similar reasons, may choose to participate in end-of-day auctions subject to a limit.

Explicit price benchmarks orders inherently prioritise price as the primary execution factor for consideration. If the explicit price benchmark can be satisfied for the order, a trader may prioritise additional execution factors that will most likely lead to complete execution of the order based on prevailing market conditions.

Best Efforts Benchmarks

For orders that are made available to trade immediately, with benchmarks such as arrival price, price at the time of execution or market price at the point in time when the PM assigns the order to the trading desk, are used where available and unless otherwise specified.

PMs may assign a higher degree of importance to one factor over another. For example, for orders where fulfilment of the entire trade is of highest importance, the likelihood of execution is prioritized. This is more often the case when executing orders for active strategies when the PM has a particularly strong view (whether as a result of fundamental analysis or strong quantitative signals) and tends to be less price sensitive to achieve fast execution.

Where the trader has full discretion in the execution of the order, all execution factors are considered and prioritization varies depending on prevailing market conditions, with total consideration and likelihood of execution typically having higher importance.

Contingent Orders

Contingent orders consider the interdependency of two or more financial instruments on one another, such as the roll of futures contracts or the hedging of a credit instrument. In these cases, it is the collective benchmark of the package that drives the execution factors for consideration, rather than the application of the execution factors to the individual financial instruments that form part of the package or contingent order.

Similarly, traders may also need to consider the impact an order imparts on the overall investment outcome. For example, the execution of an order, which is part of larger basket of orders, may result in a particular investment outcome in the absence of the other orders in the basket also being executed. In such a situation, the calibration of execution timing with regard to the other orders that form the larger basket of orders may drive the consideration of execution factors, so as to minimize or eliminate unwanted market exposure. Further, investment objectives and constraints may limit PMs’ and traders’ ability to prioritise the execution factors.

C. Execution Factors and Characteristics of Financial Instruments

The hierarchy of execution factors that is expressed by a particular type of instruction is complemented by consideration of the characteristics of the financial instrument, as well as consideration of the size of the order, the market conditions at the time of execution of the order, and other relevant facts and circumstances, such that the execution strategy employed for a particular order may differ significantly from executions effected in the same class of financial instruments (and even in the same security) but for different trade sizes and/or in different market conditions at the time of execution.

Listed Financial Instruments

Financial instruments listed on or executed on regulated markets or execution venues that display bids and offers, including both securities and listed derivatives, are typically subject to a high degree of price transparency, which typically limits the need for extensive price discovery. This allows traders to focus more on the execution mechanisms that are available from brokers and whether they can easily facilitate prompt execution while mitigating the impact on the market.

When the order size is considered large relative to the average daily trading volume of the relevant financial instrument, traders will have to manage the risk of signalling to the market the existence of a large trading interest to avoid the potential detrimental impact that this may have on the execution price. Traders may therefore prioritize the use of block trading channels that manage large order sizes.

For illiquid financial instruments (or financial instruments for which liquidity is not concentrated on regulated markets or venues that display bid and offers), the need for price discovery is evaluated against the risk that information leakage might impact the overall execution outcome negatively, which may result in traders requesting quotes from market participants known to offer liquidity in the specific financial instrument to be traded.

Over the Counter (‘OTC’) Financial Instruments

OTC financial instruments that trade in a decentralized market, including both unlisted securities and OTC derivatives, have varying degrees of price transparency. For liquid financial instruments within a reasonable range of tradeable market sizes, traders prioritize trading venues that facilitate price discovery through requests for quotes from multiple market participants. Alternatively, traders may rely on the pricing information contained in alternative pricing sources when selecting a single broker to request a quote for the relevant financial instrument.

For less liquid financial instruments or when the order size is considered large, traders may choose their counterparty based on its perceived ability to reduce the market impact of the execution.

For the execution of trades in illiquid financial instruments, brokers who trade in the same securities or securities with similar characteristics may be prioritized.

For more complex or less liquid OTC products, where prices are not directly observable (e.g. convertible bonds or option packages), traders use available internal and external data or tools to assess the fairness of price, and the expected cost of trading, as accurately as possible under such circumstances.

D. Application of Execution Factors to Individual Classes of Financial Instruments

Listed Financial Instruments and Contracts for Difference

• Shares & Depositary Receipts
• Exchange Traded Products (Exchange Traded Funds, Exchange Traded Notes and Exchange Traded Commodities) (“ETP”)
• Contracts For Difference
• Securitized Derivatives – Listed Warrants & Certificates

In addition to best execution, all general Portfolio Management (“PM”) instructions and considerations based on the nature of the order apply to trades in listed instruments.

Orders for listed instruments with forward benchmarks are typically executed in the closing auction for markets where such a mechanism exists. If there is not sufficient liquidity in the auction, then trading might also take place earlier or later to mitigate market impact.

For orders with a best-efforts benchmark, BlackRock typically choose an execution method most suitable for balancing price and likelihood of execution.

Where the size of an order is significant relative to available liquidity in the secondary market, traders may prioritize execution channels which provide supplemental or surrogate sources of liquidity, such as broker capital or primary ETP markets.

Listed Futures and Options

• Interest Rate Derivatives – Listed Futures & Options
• Credit Derivatives – Listed Futures & Options
• Equity Derivatives – Listed Futures & Options
• Commodities Derivatives – Listed Futures & Options

In addition to best execution, all general PM instructions and considerations based on the nature of the order apply to trades in futures and listed options.

Orders for listed instruments with forward benchmarks are typically executed in the closing auction for markets where such a mechanism exists. If there is not sufficient liquidity in the auction, then trading might also take place earlier or later to mitigate market impact.

For orders with a best-efforts benchmark, BlackRock typically choose an execution method most suitable for balancing price and likelihood of execution.

Where the size of an order is significant relative to available liquidity in the secondary market, traders may prioritize execution channels which provide supplemental or surrogate sources of liquidity, such as broker capital markets.

For liquid options within a reasonable range of tradeable market sizes, traders will prioritize trading platforms that facilitate price discovery through requests for quotes from multiple market participants.

Debt Instruments

• Bonds
• Structured Finance Instruments

While some debt instruments are listed, they are commonly traded in a decentralized OTC manner.

All general PM instructions and considerations based on the nature of the order apply to trades in debt instruments.

Orders for debt instruments with forward benchmarks typically are executed around the point in time specified by the PM, since there is not an official closing auction in these markets. If sufficient liquidity is not available at that time, then trading might also take place earlier or later to mitigate market impact.

For orders with a best-efforts benchmark, BlackRock applies a variety of execution methods most suitable for balancing price and the impact of order size on transaction costs.

Money Market Instruments

The execution factors and criteria that BlackRock considers for money market instruments reflect the nature of these orders. Similar to the general considerations, the orders are primarily characterized by PM motivation.

For overnight funding transactions, such as time deposits, completion of the order is of highest importance. As such, likelihood of execution is prioritized, with consideration given to the number of available counterparties and capacity.

For orders where completion is at the trader’s discretion, price and the impact of order size on transaction costs are considered. (See Best Efforts Benchmarks)

OTC Derivatives

• OTC Derivatives
• Equity Derivatives
• Credit Derivatives
• Interest Rate Derivatives
• Currency Derivatives
• Commodity Derivatives
• Securitized Derivatives

While most derivative instruments are primarily traded in a decentralized OTC manner, some products may be to traded on a centralised trading venue.

In addition to best execution, all general PM instructions and considerations based on the nature of the order apply to trades in derivative instruments.

Orders for derivative instruments with forward benchmarks are typically executed at a point in time specified by the PM, because there is not an official closing mechanism in these markets. If sufficient liquidity is not available, then trading might also take place earlier or later to mitigate market impact.

For orders with a best-efforts benchmark, BlackRock applies a variety of execution methods suitable for balancing price and the impact of order size on transaction costs. Further, due to the OTC nature of these instruments, there is a varying degree of price transparency, so traders also need to reduce information leakage, signalling and market impact.

Different regulations could mandate that some of these instruments are required to be executed on a centralised traded on venue. Instruments that have a mandatory clearing mandate are centrally cleared with a central counterparty.

Other Structured Financial Instruments

From time to time, BlackRock may decide to enter into bespoke structured transactions. When it does so, it seeks to gather structuring proposals and pricing from one or more brokers, depending on their expertise and subject to BlackRock’s requirement to diversify its counterparty exposure. Typically, such transactions comprise different components and, to satisfy itself on the fairness of the price proposed by the counterparty, BlackRock may request quotes from more than one counterparty before entering into the transaction or, alternatively, may break the transactions down into their individual components and analyse the implied pricing of each component based on historical data.

Securities Finance Transactions

• Securities Lending
• Repurchase Agreements
• Physical & Synthetic Securities Financing

For securities finance transactions including securities lending, repurchase agreements and physical/synthetic financing, the execution factors and criteria that BlackRock considers include the supply and demand characteristics for the securities in question and additional considerations such as:

• current market pricing to lend or finance the specific security
• price discovery will follow a similar process to other OTC markets in that traders will prioritize Trading Venues that facilitate ‘requests for price and capacity’ from multiple market participants
• liquidity of the lending, financing and cash market for the relevant security
• current utilisation/availability of the security and the size of supply or demand relative to the lending or financing market will be considered when determining the likelihood of execution
• overall utilization of a broker’s balance sheet; and
• other factors that may include, but are not limited to:
  
  • collateral type proposed (e.g., cash or non-cash)
  • proposed duration of the securities finance transaction
  • transaction costs levied by providers such as custodians, triparty banks, or broker; and
  • specific or idiosyncratic factors (e.g., a pending corporate action, or expected stability of financing).

9. Broker/Counterparty & Execution Venue Selection

General Considerations

After prioritizing the execution factors based on the characteristics of the order and the financial instruments, if BlackRock has a choice of a number of brokers or Execution Venues that could equally fulfil a given order, it selects the individual broker or Execution Venue by considering further qualitative and quantitative factors. These further factors are often specific to individual financial instruments or classes of financial instruments as the applicable market structure determines the instrument’s liquidity. These additional factors include, but are not limited to:

• trade confirmation and settlement capabilities
• ability to avoid information leakage
• breadth of liquidity access across markets, currencies and products
• execution quality
• operational resilience and responsiveness to errors
• pre- and post-trade execution insights
• personnel coverage of the venue or broker
• product offering and customizations
• research provided, where permitted under applicable regulation
• liquidity sourcing capabilities (such as the ability to source natural liquidity)
• willingness to commit capital
• risk concentration

Further Considerations, by Instrument, in the Selection of Execution Venues

Listed Instruments

Listed financial instruments that trade on an exchange may also be traded electronically. Specific factors for consideration of Execution Venue selection may include:

• types, quality and breadth of brokers’ traded financial instruments and functionalities
• quality of execution measured against benchmark exchange prices
• availability of algorithms and ability to adapt products to BlackRock’s workflows
• access to liquidity

OTC Instruments

Venue considerations for OTC instruments vary depending upon overall liquidity and the manner in which they trade:

• for liquid OTC instruments that trade electronically, consideration is given to the type, quality and breadth of Execution Venues; and
• for instruments that do no trade electronically, consideration is given to venue liquidity, coverage of instruments and sectors and competitive quoting

Securities Finance Transactions

• BlackRock will transact only with approved counterparties, up to any applicable credit limit determined by Blackrock’s CRG.
• Securities lending does not involve the execution of orders to trade but rather the allocation of loan requests submitted by brokers, BlackRock agrees and settles a requested loan allocation provided the broker has been approved, the value of the proposed transaction does not exceed the aggregate value of loans permitted, and the other execution factor considerations have been met.

Money Market Instruments

Specific factors for consideration of venue selection may include:

• liquidity and availability of instruments offered by the counterparty
• willingness of counterparties to bid back on paper;
• product availability, as some issuers will limit the size of issuances available for certain maturities.

Availability of venues which may be limited by the issuer in certain instances, such as asset backed commercial paper. Where certain financial instruments are only available directly from the issuer or a small group of brokers, this informs the selection of the Execution Venue.

10. Prohibited Considerations in Selecting Broker/Counterparties & Execution Venues

BlackRock employees are prohibited from considering the following factors when selecting a broker or Execution Venue:

• a counterparty’s placement of, or purchase of, any BlackRock products or BlackRock managed funds;
• any personal relationships, including former employment relationships;
• any personal benefit for any person associated with the employee, including but not limited to members of the employee’s family or household in addition to close associates and significant others;
• any gifts or entertainment received;
• a broker-dealer’s historical initial public offering or new issue allocations to BlackRock;
• a broker-dealer’s willingness to accommodate BlackRock’s trading errors.

11. Services and Benefits Received from Execution Venues

BlackRock from time to time may receive the following services and/or benefits from brokers and Execution Venues:

• information or documentation relating to financial instruments or investment services that is generic in nature or personalized to reflect BlackRock’s circumstances;
• issuer commissioned research coverage;
• participation in conferences, seminars or trading events on the benefits and features of specific financial instruments or investment services;
• hospitality of de minimis value during meetings or those events specified in clause iii above;
• connected research on an issuer in the context of an issuer capital raising;
• research provided for a trial period; and
• such other services and/or benefits that can be considered minor non-monetary benefits under Applicable Law from time to time.

12. Receiving a Specific Client Instruction

In instances where a client has provided a specific order instruction, BlackRock will be deemed to have complied with its best execution obligation for the specific part of the trade to which the instruction relates. However, BlackRock will continue to apply this Policy to those aspects of the order not covered by the specific instruction.

13. Directed Brokerage

From time to time, a client may instruct BlackRock to execute its trades with a particular counterparty or venue or otherwise place limitations on BlackRock’s discretion to determine counterparty, venue or commission. Directed brokerage arrangements are typically documented in a client’s Investment Management Agreement with BlackRock, or a side letter. Subject to applicable regional regulations, such arrangements may involve the receipt of brokerage commissions from the client transactions in exchange for the provision of services directly to the client or the payment of certain expenses on behalf of the client. The execution timing, levels and/or trading costs may be compromised when entering into directed brokerage arrangements.

Alternatively, a client may direct BlackRock to execute a certain proportion of their overall trading to a broker that meets specific criteria set by the client (e.g., an emerging broker). BlackRock traders use their judgment to decide which trades to execute with such directed brokers and balance a client’s directed brokerage requirements with trying to obtain the best overall result for the client.

Implications on Commission Rates

In directed brokerage arrangements, BlackRock may not be able to freely negotiate commission rates or spreads, obtain volume discounts on aggregated orders or select counterparties on the basis of best price and execution. As a result, directed brokerage transactions may result in higher commissions, greater spreads, or less favourable execution, than would normally be the case if BlackRock were able to choose the broker.

In certain instances where BlackRock is instructed by a client to execute transactions with a specific broker or dealer, BlackRock may “step out” part of an aggregated order in order to have the directed broker or dealer clear and settle that portion of the trade.

14. Monitoring

BlackRock performs multiple types of monitoring to help ensure its order execution arrangements remain suitable for the purpose of seeking to deliver the best client outcomes. Some aspects of monitoring include transaction cost analysis (TCA), senior management oversight in governance committees (Trading Oversight Committees) and compliance and risk monitoring activities. The specific scope and content of monitoring may vary depending on the data that is available, for the relevant asset class, in the market. As new data sources and pricing models become available, they are assessed for potential inclusion in our monitoring.

Transaction Cost Analytics (TCA)

BlackRock utilizes in-house TCA systems, to assess whether trading costs are in line with BlackRock’s expectations.

BlackRock’s TCA platform quantifies the full cost of trading, which includes cost contributions from commissions, spreads, market impact, and the opportunity costs that arise from not executing a trade. The total impact from order handling and routing decisions is captured by these measures. Transactions are evaluated against a range of pre-trade, intra-day, and post-trade benchmarks to holistically assess trading performance against the market context. Trading results can be examined in a TCA tool taking into account a broad array of attributes, such as by counterparty, trader, benchmark, or market, allowing for a focused evaluation of each category.

Governance

BlackRock performs reviews of its trading activity in regular Trading Oversight Committees which review execution quality, the effectiveness of execution arrangements and the effectiveness of this Policy. The Trading Oversight committees are also charged with making enhancements to BlackRock’s execution arrangements and this Policy, where deemed appropriate. The oversight committees are global in nature and cover all asset classes. Trading, Investments, Risk, and Legal & Compliance are represented on each Committee.

Compliance Monitoring

The Global Trade Surveillance and Forensic Testing team, within Legal & Compliance, is responsible for post trade, second line monitoring. The team conducts ongoing, routine, sample based and risk-based tests for adherence to the Policy, currently with a focus on pricing, timeliness of execution and broker selection criteria. Any deficiencies identified are escalated to the relevant Trading Oversight Committee.

RQA Oversight

Where applicable, RQA meets regularly with the relevant business to review and examine execution outlier patterns. The key objectives are to evaluate that execution decisions made by the business over time appear consistent with policy requirements, and ensuring adequate records are kept when point-in-time analysis is undertaken on outlier trades.

15. Periodic Review of the Policy and Order Execution Arrangements

BlackRock is required, under applicable regulations, to review this Policy and its order execution arrangements at least on an annual basis for its adequacy and the effectiveness of implementation. It is also required to review this policy whenever a material change occurs that affects BlackRock’s ability to continue to obtain the best possible result for its clients.

A material change means a significant event of an internal or external nature, that could materially impact the relevant best execution factors listed in this Policy or the execution venues or entities to which BlackRock transmits client orders for execution, on which BlackRock places significant reliance in meeting its overarching best execution requirement. Any of the following events may, but will not necessarily in all circumstances, amount to such a material change: regulatory changes that materially alter the market structure for certain classes of financial instruments or that otherwise require changes to BlackRock’s arrangements and processes; BlackRock’s observation of a significant and consistent deterioration in the liquidity offered and in the quality of execution achieved on a trading venue or from a broker or dealer.

As part of Global Trading and RQA’s continuous framework for evaluating execution quality and governance, along with oversight processes related to monitoring best execution, on an ongoing basis, BlackRock will consider whether it could consistently obtain better execution results if it were to:

• include additional or different Execution Venues or entities;
• remove any existing Execution Venues or entities;
• assign a different relative importance to the best execution factors;
• or modify any other aspects of this Policy and/or execution arrangements.

The effectiveness of BlackRock’s order execution arrangements is tested and monitored by Global Trading and any identified deficiencies are escalated to the relevant Oversight Committees. As new data sources and pricing models become available, they are assessed for potential inclusion in our monitoring. BlackRock tests both the effectiveness of the execution venues that it selects when executing client orders and the execution quality of the entities where it places orders for clients.

16. Conflicts of Interest

BlackRock’s Global Conflicts of Interest Policy (the “Conflicts Policy”) governs BlackRock’s responsibility to place its clients’ interests first and identify and manage any conflicts of interest inherent to BlackRock’s business. The Conflicts Policy requires that BlackRock employees report any actual or potential conflicts of interest to their supervisor and to Legal & Compliance. Amongst other things the Conflicts Policy also requires employees to act solely in the best interests of clients and avoid or otherwise mitigate conflicts of interest, which may involve curtailing or terminating an activity or seeking client consent.

17. Information Provided to Clients

In accordance with relevant regulatory requirements, BlackRock is required to disclose certain information to clients regarding this Policy, including appropriate information about BlackRock and its services, and in some jurisdictions, additional information about the consequences of executing outside a trading venue and the entities chosen for execution.

Appendix 1 – Glossary of Terms

Bid/Ask Spread	The difference between the market price quotations, for buying and for selling particular securities.
Directed Brokerage	The process whereby a client directs a manager to place trades for his account through a specific broker, in exchange for which the client will receive a rebate of a portion of the total commission in addition to execution services. The arrangement can be managed by a third party, such as an investment consultant, or managed by the client’s investment manager.
Crossing Network	An electronic execution venue that enables the matching of orders directly between buyers and sellers. Commissions are typically lower while market impact and bid/ask spreads are removed altogether. Liquidity is often a constraint to order completion.
Direct Market Access (“DMA”)	Direct access to the market floor by managers who wish to deal anonymously in the market, without the use of execution services provided by a broker.
Electronic Communication Network (“ECNs”)	An electronic system that connects major brokerages and individual traders so that they can trade financial products outside of stock exchanges, directly between themselves. The primary products that are traded on ECNs are stocks and currencies.
Execution Services	Those services related to trade execution that meet the criteria laid down by the FCA for payment out of commission.
Execution Venue	A Regulated Market, a Multilateral Trading Facility (MTF), an organized Trading Facility (OTF), a Systematic Internaliser, or a Market Maker or other Liquidity Provider or an entity that performs a similar function in a third country to the functions performed by any of the foregoing.
Liquidity	The degree to which an asset or security can be bought or sold in the market without affecting the asset's price. Liquidity is characterized by a high level of trading activity. 2) The ability to convert an asset to cash quickly. Investing in illiquid assets is riskier because there might not be a way for you to get your money out of the investment. Examples of assets with good liquidity include blue chip common stock and those assets in the money market. A fund with good liquidity would be characterized by having enough units outstanding to allow large transactions without a substantial change in price.
Market Impact	The effect a market participant has when it buys or sells an asset and the extent to which the buy or sell moves the price against the buyer or seller.
Market Maker	A person who holds himself out on the financial markets on continuous basis as being willing to deal on own account by buying and selling financial instruments against the person’s proprietary capital at prices defined by that person.
Multilateral System	Any system or facility in which multiple third-party buying and selling trading interests in financial instruments are able to interact in the system.
Multilateral Trading Facility (MTF)	A multilateral system, operated by an investment firm or a market operator, which brings together multiple third-party buying and selling interests in financial instruments – in the system and in accordance with non-discretionary rules – in a way that results in a contract in accordance with Title II of MIFID II.
Organized Trading Facility	A multilateral system which is not a regulated market or an MTF and in which multiple third-party buying and selling interests in bonds, structured finance products, emission allowances or derivatives are able to interact in the system in a way that results in a contract in accordance with Title II of MIFID II.
Other Liquidity Provider	A firm that holds themselves out as being willing to deal on own account, and which provides liquidity as part of their normal business activity, whether or not they have formal agreements in place or commit to providing liquidity on a continuous basis
Onshoring of MiFID II	Statutory Instrument No 2018/1403 The Markets in Financial Instruments (Amendment) (EU Exit) Regulations 2018 makes amendments to MiFIR, the tertiary legislation made under MiFID II and the UK legislation which implemented MiFID.
Programme Trades	Trades for a basket of securities placed through a single broker and priced as a portfolio and not by reference to the individual constituents of the basked.
Professional Client	A client who possesses the experience, knowledge and expertise to make its own investment decisions and properly assess the risks that it incurs. A client meeting the criteria laid out in Annex II of MIFID II is considered to be a Professional Client.
Regulated Market	A multilateral system operated and/or managed by a market operator, which brings together or facilitates the bringing together of multiple third-party buying and selling interests in financial instruments – in the system and in accordance with its non-discretionary rules – in a way that results in a contract, in respect of the financial instruments admitted to trading under its rules and/or systems, and which is authorised and functions regularly and in accordance with Title III of MIFID II.
Securities Lending	The process by which securities are transferred to a counterparty, subject to an obligation for return of the equivalent securities at a future date. The lender is remunerated by way of a fee.
Systematic Internaliser	An investment firm which, on an organized, frequent systematic and substantial basis, deals on own account when executing client orders outside a regulated market, an MTF or an OTF without operating a multilateral system.
Trading Venue	A regulated market, an MTF or an OTF. After the Transition Period ends, UK trading venues will become third-country trading venues. Similarly, EEA venues will become third-country venues under UK law.
Volatility	The relative rate at which the price of a security or fund moves up and down. Volatility is found by calculating the annualised standard deviation of daily change in price. If the price of a stock moves up and down rapidly over short time periods, it has high volatility. If the price almost never changes, it has low volatility.

ANNEX 1 – Execution Venues and Brokers (as of 30th June 2025)

This list is subject to change and may vary from time to time. Arrangements may vary depending on contractual arrangements with clients.

EQUITIES - Shares & Depositary Receipts

ABG SUNDAL COLLIER ASA

ABSA BANK LTD

ACADEMY SECURITIES INC

BAIRD FINANCIAL GROUP INC

BANCO SANTANDER SA

BANCROFT CAPITAL LLC

BANK OF AMERICA CORP

BANK OF MONTREAL

BARCLAYS CAPITAL INC.

BARCLAYS CAPITAL SECURITIES LTD

BARCLAYS PLC

BARRENJOEY MARKETS PTY LIMITED

BERNSTEIN AUTONOMOUS LLP

BLOOMBERG TRADEBOOK LLC

BMO CAPITAL MARKETS CORP.

BNP PARIBAS

BNP PARIBAS SECURITIES CORPORATION

BOFA SECURITIES INC.

BRADESCO SECURITIES INC

BTG PACTUAL US CAPITAL, LLC

BTIG LIMITED

BTIG SINGAPORE PTE LTD

BTIG, LLC

CABRERA CAPITAL MARKETS LLC

CANACCORD GENUITY (AUSTRALIA) LTD

CANACCORD GENUITY CORP.

CANACCORD GENUITY GROUP INC

CANACCORD GENUITY LIMITED

CANACCORD GENUITY LLC

CANTOR FITZGERALD & COMPANY

CANTOR FITZGERALD EUROPE

CARNEGIE INVESTMENT BANK AB

CASA DE BOLSA FINAMEX SAB DE CV

CASA DE BOLSA SANTANDER SA

CASTLEOAK SECURITIES, L.P.

CAVENDISH SECURITIES PLC

CGS INTL SECS SINGAPORE PTE. LTD

CHINA INTL CAPITAL CORPORATION

CIBC WORLD MARKETS CORP.

CITADEL SECURITIES LLC

CITIBANAMEX CASA DE BOLSA SA DE CV

CITIC SECURITIES COMPANY LIMITED

CITIGROUP GLOBAL MARKETS INC.

CITIGROUP GLOBAL MARKETS LIMITED

CITIGROUP GLOBAL MARKETS TAIWAN SECURITIES CO LTD

CITIGROUP INC

CLSA LIMITED

CL SECURITIES TAIWAN COMPANY LIMITED

CORMARK SECURITIES

TD SECURITIES (USA) LLC

CRAIGS INVESTMENT PARTNERS LTD

DAIWA CAPITAL MARKETS EUROPE LTD

DAIWA SECURITIES GROUP INC

DANSKE BANK A/S

DBS GROUP HOLDINGS LTD

DNB BANK ASA

DREXEL HAMILTON LLC

EFG HOLDING

EVANS AND PARTNERS PTY LTD

EFG HERMES IFA FINANCIAL BROKERAGE COMPANY KSCC

FUBON SECURITIES CO., LTD

FLEXTRADER

GOLDMAN SACHS & CO. LLC

GOLDMAN SACHS (ASIA) L.L.C.

GOLDMAN SACHS GROUP INC/THE

GOLDMAN SACHS INTERNATIONAL

GOLDMAN SACHS MEXICO CASA DE BOLSA SA DE CV

GOODBODY STOCKBROKERS

GREAT PACIFIC SECURITIES

GRUPO BURSATIL MEXICANO CASA BOLSA

GUZMAN & COMPANY

HAITONG INTERNATIONAL SECURITIES CO

HONGKONG AND SHANGHAI BANKING CORPORATION LTD

HSBC BANK PLC

HSBC HOLDINGS PLC

HSBC SECURITIES (TAIWAN) CO., LTD.

HSBC SECURITIES (USA) INC

TP ICAP MARKETS LIMITED

ICICI BANK LIMITED

ICICI SECURITIES LIMITED

IIFL CAPITAL SERVICES LTDINSTINET EUROPE LIMITED

INSTINET LLC

INVESTEC BANK PLC

INVESTEC PLC

ITAU BBA USA SECURITIES, INC.

JANE STREET CAPITAL, LLC

JANE STREET EXECUTION SERVICES, LLC

JARDEN SECURITIES LTD

J & E DAVY

JEFFERIES FINANCIAL GROUP INC

JEFFERIES INTERNATIONAL LIMITED

JEFFERIES LLC

JOH. BERENBERG, GOSSLER & CO. KG

JONESTRADING INSTITUTIONAL SERVICES LLC

J.P. MORGAN CASA DE BOLSA, S.A. DE

J.P. MORGAN CHASE & CO

J.P. MORGAN SECURITIES LLC

J.P. MORGAN SECURITIES (TAIWAN) LTD.

J.P. MORGAN SECURITIES PLC

KBC SECURITIES NV

KEPLER CHEUVREUX S.A.

KEYBANC CAPITAL MARKETS INC.

KEZAR TRADING, LLC

KOTAK MAH BK

KOTAK SECURITIES LIMITED

LEERINK PARTNERS LLC

LIBERUM CAPITAL LIMITED

LIQUIDNET ASIA LTD

LIQUIDNET EUROPE LIMITED

LIQUIDNET INC

LOOP CAPITAL MARKETS, LLC

MACQUARIE CAPITAL (EUROPE) LIMITED

MACQUARIE CAPITAL (USA) INC.

MACQUARIE GROUP LTD

MALAYAN BANKING BHD

MERRILL LYNCH INTERNATIONAL

MERRILL LYNCH MEXICO SA DE CV CASA DE BOLSA

MERRILL LYNCH SECURITIES (TAIWAN) LTD

MIB SECURITIES (HONG KONG) LIMITED

MIRAE ASSET SECURITIES CO LTD

MISCHLER FINANCIAL GROUP, INC.

MISCHLER FINANCIAL GROUP, INC.

MIZUHO FINANCIAL GROUP INC

MIZUHO INTERNATIONAL PLC

MIZUHO SECURITIES USA LLC

MOELIS AUSTRALIA SECURITIES P/L

MORGAN STANLEY

MORGAN STANLEY & CO LLC

MORGAN STANLEY & CO. INTERNATIONAL

MORGAN STANLEY MEXICO CASA DE BOLSA SA DE CV

MORGAN STANLEY SAUDI ARABIA

MORGAN STANLEY TAIWAN LIMITED

NATIONAL BANK FINANCIAL INC.

NOMURA HOLDINGS INC

NOMURA INT HK LTD (TAIPEI BRANCH)

NOMURA SECURITIES INTERNATIONAL INC

NORDEA BANK ABP

NORTHERN TRUST SECURITIES LLP

NUMIS SECURITIES LTD

NATIONAL BANK OF CANADA

ODDO BHF SCA

OPPENHEIMER & CO. INC.

OPTIVER V.O.F.

PANMURE LIBERUM LIMITEDPEEL HUNT LLP

PENSERRA SECURITIES LLC

PIPER SANDLER & CO.

RAYMOND JAMES & ASSOCIATES INC

RAYMOND JAMES LTD.

RBC CAPITAL MARKETS, LLC.

RBC EUROPE LTD

REDBURN (EUROPE) LIMITED

ROBERT W BAIRD & CO INC

ROTH CAPITAL PARTNERS, LLC

SAMSUNG SECURITIES CO., LTD

SAMUEL A. RAMIREZ & CO., INC

SANTANDER US CAPITAL MARKETS LLC

SCOTIA CAPITAL (USA), INC

SHORE CAPITAL STOCKBROKERS LIMITED

SIEBERT WILLIAMS SHANK & CO. LLC

SKANDINAVISKA ENSKILDA BANKEN AB

SMBC NIKKO SECURITIES INC.

SOCIETE GENERALE

STERN BROTHERS & CO.

STIFEL FINL CORP

STIFEL NICOLAUS EUROPE LIMITED

STUART FRANKEL & CO. INC.

SUMITOMO MITSUI FIN GRP INC

SUSQUEHANNA FINANCIAL GROUP LLLP

TD EXECUTION SERVICES LIMITED

TD SECURITIES INC

TOURMALINE PARTNERS, LLC

TRADEWEB MARKETS LLC

UBS AG

UBS GROUP AG

UBS SECURITIES LLC

UBS SECURITIES PTE LTD, TAIPEI BRAN

VAN LANSCHOT KEMPEN N.V.

VIRTU AMERICAS LLC

VIRTU EUROPE TRADING LIMITED

VIRTU ITG HONG KONG LIMITED

WELLS FARGO SECURITIES LLC

WINTERFLOOD SECURITIES LIMITED

XP INVESTMENTS US, LLC

YUANTA SECURITIES CO., LTD.

ZKB SECURITIES UK LTD

DEBT INSTRUMENTS – Bonds

ABN AMRO BANK NV

ABSA BANK LTD

ACADEMY SECURITIES INC

ADVISORS ASSET MANAGEMENT, INC.

AGRICULTURAL BANK OF CHINA LIMITED

AMERICAN VETERANS GROUP PBC

ANZ GROUP HOLDINGS LTD

ANZ SECURITIES INC.

ASL CAPITAL MARKETS INC

AUREL BGC

AUSTRALIA AND NEW ZEALAND

BAIRD FINANCIAL GROUP INCBANCO BILBAO VIZCAYA ARGENTARIA S.A

BANCO BRADESCO S.A.

BANCO CITI MEXICO, S.A.

BANCO HSBC S.A.

BANCO JP MORGAN SA INSTITUCION DE BANCA MULTIPLE JP MORGAN GRUPO FINANCIERO

BANCO NACIONAL DE MEXICO SA

BANCO SANTANDER (MEXICO), S.A., INS

BANCO SANTANDER SA

BANK OF AMERICA CORP

BANK OF AMERICA MEXICO SA INSTITUCION DE BANCA MULTIPLE

BANK OF AMERICA NA

BANK OF CHINA (HONG KONG) LIMITED

BANK OF COMMUNICATIONS CO., LTD

BANK OF MONTREAL

BARCLAYS BANK MEXICO SA

BARCLAYS BANK PLC

BARCLAYS CAPITAL INC.

BARCLAYS CAPITAL SECURITIES LTD

BARCLAYS PLC

BARCLAYS SECURITIES JAPAN LIMITED

BARRENJOEY MARKETS PTY LIMITED

BAYERISCHE LANDESBANKEN

BBVA MEXICO, S.A.

BBVA SECURITIES INC.

BC ZIEGLER & CO.

BCP SECURITIES, INC

BLAYLOCK VAN, LLC

BLOOMBERG TRADEBOOK LLC

BMO CAPITAL MARKETS CORP.

BMO NESBITT BURNS INC

BNP PARIBAS

BNP PARIBAS FINANCIAL MARKETS SNC

BNP PARIBAS (CHINA) LIMITED

BNP PARIBAS SECURITIES CORPORATION

BNP PARIBAS SECURITIES JAPAN LTD

BNY MELLON CAPITAL MARKETS LLC

BOFA SECURITIES INC.

BOFA SECURITIES JAPAN CO., LTD

BOK FINANCIAL CORPORATION

BOKF, NA

BPCE SA

BRADESCO SECURITIES INC

BREAN CAPITAL, LLC

BROWNSTONE INVESTMENT GROUP, LLC

BTG PACTUAL US CAPITAL, LLC

BTIG LIMITED

BTIG, LLC

C.L. KING & ASSOCIATES, INC

CABRERA CAPITAL MARKETS LLC

CAIXABANK, SACANADIAN IMPERIAL BANK OF COMMERCE

CANTOR FITZGERALD & COMPANY

CANTOR FITZGERALD EUROPE

CANTOR FITZGERALD LP

CASA DE BOLSA FINAMEX SAB DE CV

CASGRAIN & COMPANY (USA) LIMITED

CASTLEOAK SECURITIES, L.P.

CHINA CITIC BANK INTERNATIONAL LTD

CHINA CONSTRUCTION BANK CORPORATION

CHINA INTERNATIONAL CAPITAL CORP HONG KONG SECURITIES LTD

CHINA INTL CAPITAL CORPORATION

CHINA SECURITIES LTD

CIBC WORLD MARKETS CORP.

CIBC WORLD MARKETS INC

CIMB BANK BERHAD

CITADEL SECURITIES (EUROPE) LIMITED

CITADEL SECURITIES INSTITUTIONAL LLC

CITIBANK (CHINA) COMPANY LIMITED

CITIBANK NA

CITIC SEC INTL GLOBAL MARKETS LTD

CITIC SECURITIES COMPANY LIMITED

CITIGROUP GLOBAL MARKETS INC.

CITIGROUP GLOBAL MARKETS JAPAN INC

CITIGROUP GLOBAL MARKETS LIMITED

CITIGROUP INC

CLSA AMERICAS, LLC

CMB INTERNATIONAL GLOBAL MARKETS LTD

COMMERZ MARKETS LLC

COMMERZBANK AG

COMMONWEALTH BANK OF AUSTRALIA

COOPERATIEVE RABOBANK U.A.

CREDICORP CAPITAL, LLC

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK SA

CREDIT AGRICOLE SECURITIES (USA) IN

CREDIT INDUSTRIEL ET COMMERCIAL

DA DAVIDSON & COMPANY

DAIWA CAPITAL MARKETS AMERICA INC.

DAIWA CAPITAL MARKETS EUROPE LTD

DAIWA SECURITIES CAPITAL MARKETS KOREA CO LTD

DAIWA SECURITIES CO LTD

DAIWA SECURITIES GROUP INC

DANSKE BANK A/S

DAVENPORT & COMPANY LLC

DBS BANK LTD (SINGAPORE BRANCH)

DESJARDINS SECURITIES INC

DESJARDINS SECURITIES INTERNATIONAL

DEUTSCHE BANK (CHINA) CO., LTD

DEUTSCHE BANK AG

DEUTSCHE BANK SECURITIES INC.

DEUTSCHE SECURITIES INC.

DNB BANK ASA

DZ BANK AG DEUTSCHE ZENTRAL GENOSSENSCHAFTSBANK FRANKFURT AM MAIN

ERSTE GROUP BANK AG

EVERCORE INC

FHN FINANCIAL SECURITIES CORP.

FIDELITY CAPITAL MARKETS, DIV. OF NATIONAL FINANCIAL SERVICES LLCFIFTH THIRD SECURITIES, INC.FIRST ABU DHABI BANK PJSC

FIRST HORIZON BANK, N.A.

FIRST TRYON SECURITIES, LLC

FIRSTRAND BANK LIMITED

FLEXTRADER

FLOW TRADERS B.V.

FLOW TRADERS U.S. INSTITUTIONAL TRADING LLC

FMSBONDS, INC.

GOLDMAN SACHS & CO. LLC

GOLDMAN SACHS (INDIA) CAP MKTS PRVT LTD

GOLDMAN SACHS CHINA SEC CO LTD

GOLDMAN SACHS GROUP INC/THE

GOLDMAN SACHS INTERNATIONAL

GOLDMAN SACHS JAPAN CO. LTD.

GOLDMAN SACHS MEXICO CASA DE BOLSA SA DE CV

GOODBODY STOCKBROKERS

GREAT PACIFIC SECURITIES

GUOTAI JUNAN SECURITIES (HONG KONG)

GUOTAI JUNAN SECURITIES CO., LTD

HAITONG INTERNATIONAL SECURITIES CO

HAITONG SECURITIES CO LTD

HERBERT J SIMS & CO., INC

HILLTOP HOLDINGS INC

HILLTOP SECURITIES INC.

HONGKONG AND SHANGHAI BANKING CORPORATION LTD

HSBC BANK (CHINA) COMPANY LIMITED

HSBC BANK PLC

HSBC HOLDINGS PLC

HSBC MEXICO SA INSTITUCION DE BANCA MULTIPLE GRUPO FINANCIERO HSBC

HSBC SECURITIES (USA) INC

HUATAI FINANCIAL HOLDINGS (HONG KONG) LTDHUNTINGTON SECURITIES, INC.

ICBC STANDARD BANK PLC.

ICE BONDS SECURITIES CORPORATION

ICICI BANK LIMITED

ICICI SEC PRIMARY DEAL LTD

IMPERIAL CAPITAL (INTERNATIONAL) LLP

IMPERIAL CAPITAL LLC

INDUSTRIAL AND COMMERCIAL BANK OF CHINA LTD

ING BANK NV

ING FINANCIAL MARKETS LLC

INSPEREX LLC

INTESA SANPAOLO IMI SECURITIES CORP

INTESA SANPAOLO SPA

ITAU BBA USA SECURITIES, INC.

JANE STREET EXECUTION SERVICES, LLC

JANE STREET FINANCIAL LIMITED

JANNEY MONTGOMERY SCOTT LLC

J & E DAVY

JEFFERIES FINANCIAL GROUP INC

JEFFERIES INTERNATIONAL LIMITED

JEFFERIES LLC

J.P. MORGAN CHASE BANK (CHINA) COMPANY

J.P. MORGAN CHASE BANK N.A.

J.P. MORGAN CHASE & CO

J.P. MORGAN SECURITIES JAPAN CO LTD

J.P. MORGAN SECURITIES LLC

J.P. MORGAN SECURITIES PLC

KBC BANK N.V.

KEYBANC CAPITAL MARKETS INC.

LANDESBANK BADEN WUERTTENBERG

LANDESBANK HESSEN THUERINGEN GIROZENTRALE

LARRAIN VIAL SA CORREDORA DE BOLSA

LAURENTIAN BANK SECURITIES INC.

LIQUIDNET EUROPE LIMITED

LIQUIDNET INC

LLOYDS BANK CORPORATE MARKETS PLC

LLOYDS SECURITIES INC

LOOP CAPITAL MARKETS LLC

MALAYAN BANKING BERHAD

MARKETAXESS CAPITAL LIMITED

MARKETAXESS CORPORATION

MARKETAXESS EUROPE LTD

MEDIOBANCA

MERRILL LYNCH INTERNATIONAL

MESIROW FINANCIAL HOLDINGS INC

MESIROW FINANCIAL INC

MIDDLEGATE SECURITIES LTD.

MILLENNIUM ADVISORS, LLC

MILLENNIUM EUROPE LIMITED

MIRAE ASSET SECURITIES CO LTD.

MISCHLER FINANCIAL GROUP, INC.

MITSUBISHI UFJ FINANCIAL GROUP

MITSUBISHI UFJ MORGAN STANLEY

MIZUHO FINANCIAL GROUP INC

MIZUHO INTERNATIONAL PLC

MIZUHO SECURITIES ASIA LIMITED

MIZUHO SECURITIES CO.,LTD

MIZUHO SECURITIES USA LLC

MORGAN STANLEY

MORGAN STANLEY & CO LLC

MORGAN STANLEY & CO. INTERNATIONAL

MORGAN STANLEY MEXICO CASA DE

BOLSA SA DE CV

MORGAN STANLEY MUFG SECURITIES CO

MS INDIA PRIMARY DEALER PVT LTD

MUFG SECURITIES AMERICAS INC

MUFG SECURITIES EMEA PLC

MULTI-BANK SECURITIES, INC

NATIONAL AUSTRALIA BANK LIMITED

NATIONAL BANK FINANCIAL INC.

NATIONAL BANK OF CANADA

NATIXIS S.A.

NATIXIS SECURITIES AMERICAS LLC

NATWEST GROUP PLC

NATWEST MARKETS PLC

NATWEST MARKETS SECURITIES INC

NEDBANK LIMITED

NH INVESTMENT & SECURITIES CO., LTD

NOMURA FIXED INCOME SECURITIES LTD

NOMURA HOLDINGS INC

NOMURA INTERNATIONAL PLC

NOMURA SECURITIES COMPANY LIMITED

NOMURA SECURITIES INTERNATIONAL INC

NORDDEUTSCHE LANDESBANK

NORDEA BANK ABP

NYKREDIT BANK A/S

ODDO BHF SCA

OKASAN SECURITIES CO LTD

OLD MISSION MARKETS LLC

OP CORPORATE BANK PLC

OPPENHEIMER & CO. INC.

ORIENT SECURITIES COMPANY LIMITED

OVERSEA-CHINESE BANKING CORPORATION LTD

PENSERRA SECURITIES LLC

PERFORMANCE TRUST CAPITAL PARTNERS LLC

PING AN BANK CO LTD

PIPER SANDLER & CO.

PIPER SANDLER COMPANIES

PNC CAPITAL MARKETS INC

R. SEELAUS & CO., LLC.

RAYMOND JAMES & ASSOCIATES INC

RAYMOND JAMES FINANCIAL INC.

RAYMOND JAMES LTD.

RBC CAPITAL MARKETS, LLC.

RBC EUROPE LTD

ROBERT W BAIRD & CO INC

ROYAL BANK OF CANADA

RUE LA BOETIE SASSAMCO CAPITAL MARKETS, INC

SAMUEL A. RAMIREZ & CO., INC

SANTANDER US CAPITAL MARKETS LLC

SC LOWY FINANCIAL (HK) LIMITED

SCOTIA CAPITAL (USA), INC

SCOTIA CAPITAL INC

SCOTIABANK INVERLAT SA

SEAPORT GLOBAL SECURITIES LLC

SG AMERICAS SECURITIES LLC

SHANXI SECURITIES CO LTD

SHINKIN SECURITIES CO., LTD

SIEBERT WILLIAMS SHANK & CO. LLC

SKANDINAVISKA ENSKILDA BANKEN AB

SMBC BANK INTERNATIONAL PLC

SMBC NIKKO CAPITAL MARKETS LTD

SMBC NIKKO SECURITIES AMERICA, INC.

SMBC NIKKO SECURITIES INC.

SOCIETE GENERALE

STANDARD CHARTERED BANK

STANDARD CHARTERED BANK (CHINA) LTD

STATE STREET GLOBAL MARKETS, LLC

STEPHENS INC

STERN BROTHERS & CO.

STIFEL FINL CORP

STIFEL NICOLAUS AND CO INC

STIFEL NICOLAUS EUROPE LIMITED

STONEX FINANCIAL INC

STONEX FINANCIAL LTD

SUMITOMO MITSUI FIN GRP INC

SUMRIDGE PARTNERS, LLC

SUSQUEHANNA FINANCIAL GROUP LLLP

SUSQUEHANNA INTERNATIONAL SECURITIES LIMITED

SVENSKA HANDELSBANKEN AB

SWBC INVESTMENT SERVICES, LLC

SWEDBANK

TD SECURITIES (USA) LLC

TD SECURITIES AUTOMATED TRADING LLC

TD SECURITIES INC

THE SEAPORT GROUP EUROPE LLP

THE TORONTO DOMINION BANK

ICE BONDS SECURITIES CORPORATION

TRADEWEB DIRECT LLC

TRADEWEB EUROPE LIMITED

TRADEWEB EXECUTION SERVICES LTD

TRADEWEB MARKETS LLC

TRUIST FINANCIAL CORP

TRUIST SECURITIES, INC.U.S. BANCORP INVESTMENTS, INC.

UBS AG

UBS FINANCIAL SERVICES INC

UBS GROUP AG

UBS SECURITIES LLC

UMB BANK, N.A.

UNICREDIT BANK AG

UNITED OVERSEAS BANK LIMITED

VIRTU AMERICAS LLC

WEDBUSH SECURITIES INC.

WELLS FARGO & COMPANY

WELLS FARGO BANK NA

WELLS FARGO SECURITIES INTERNATIONAL LTD

WELLS FARGO SECURITIES LLC

WESTPAC BANKING CORP ABN

XP INVESTMENTS US, LLCZIONS BANCORPORATION N.A.

ZUERCHER KANTONALBANK

DEBT INSTRUMENTS – Money Market Instruments

ABN AMRO BANK NV

ACADEMY SECURITIES INC

ASL CAPITAL MARKETS INC

AUSTRALIA AND NEW ZEALAND BANKING GROUP LTD

BANCO BILBAO VIZCAYA ARGENTARIA S.A

BANCO CITI MEXICO, S.A.

BANCO JP MORGAN SA INSTITUCION DE BANCA MULTIPLE JP MORGAN GRUPO FINANCIERO

BANCO NACIONAL DE MEXICO SA

BANCO SANTANDER (MEXICO), S.A., INS

BANCO SANTANDER SA

BANK OF AMERICA MEXICO SA INSTITUCION DE BANCA MULTIPLE

BANK OF COMMUNICATIONS CO., LTD

BANK OF MONTREAL

BARCLAYS BANK PLC

BARCLAYS CAPITAL INC.

BBVA MEXICO, S.A.

BLOOMBERG TRADEBOOK LLC

BMO CAPITAL MARKETS CORP.

BMO NESBITT BURNS INC

BNP PARIBAS

BNP PARIBAS (CHINA) LIMITED

BNP PARIBAS SECURITIES JAPAN LTD

BNP PARIBAS SECURITIES CORPORATION

BNY MELLON CAPITAL MARKETS LLC

BOFA SECURITIES INC.

CABRERA CAPITAL MARKETS LLC

CASTLEOAK SECURITIES, L.P.

CHINA CONSTRUCTION BANK CORPORATION

CHINA INTL CAPITAL CORPORATION

CIBC WORLD MARKETS CORP.

CIMB BANK BERHAD

CITADEL SECURITIES INSTITUTIONAL LLC

CITIBANK (CHINA) COMPANY LIMITED

CITIC SECURITIES COMPANY LIMITED

CITIGROUP GLOBAL MARKETS INC.

CITIGROUP GLOBAL MARKETS JAPAN INC

CITIGROUP GLOBAL MARKETS LIMITED

COMMONWEALTH BANK OF AUSTRALIA

COOPERATIEVE RABOBANK U.A.

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK SA

DAIWA CAPITAL MARKETS AMERICA INC.

DAIWA CAPITAL MARKETS EUROPE LTD

DAIWA SECURITIES CO LTD

DANSKE BANK A/S

DBS BANK LTD (SINGAPORE BRANCH)

DESJARDINS SECURITIES INC

DESJARDINS SECURITIES INTERNATIONAL

DEUTSCHE BANK (CHINA) CO., LTD

DEUTSCHE BANK AG

DEUTSCHE BANK SECURITIES INC.

DEUTSCHE SECURITIES INC.

DZ BANK AG DEUTSCHE ZENTRAL GENOSSENSCHAFTSBANK FRANKFURT AM MAIN

GOLDMAN SACHS & CO. LLC

GOLDMAN SACHS INTERNATIONAL

GOLDMAN SACHS MEXICO CASA DE BOLSA SA DE CV

HSBC BANK (CHINA) COMPANY LIMITED

HSBC BANK PLC

HSBC MEXICO SA INSTITUCION DE BANCA MULTIPLE GRUPO FINANCIERO HSBC

HSBC SECURITIES (USA) INC

ICBC STANDARD BANK PLC.

INTESA SANPAOLO SPA

JEFFERIES INTERNATIONAL LIMITED

JEFFERIES LLC

J.P. MORGAN CHASE & CO

J.P. MORGAN SECURITIES JAPAN CO LTD

J.P. MORGAN SECURITIES LLC

J.P. MORGAN SECURITIES PLC

KBC BANK N.V.

LANDESBANK BADEN WUERTTENBERG

LOOP CAPITAL MARKETS, LLC

MALAYAN BANKING BERHAD

MARKETAXESS CORPORATION

MARKETAXESS EUROPE LTD

MERRILL LYNCH INTERNATIONAL

MISCHLER FINANCIAL GROUP, INC.

MITSUBISHI UFJ MORGAN STANLEY SECURITIES CO LTD

MIZUHO INTERNATIONAL PLC

MIZUHO SECURITIES ASIA LIMITED

MIZUHO SECURITIES CO.,LTD

MIZUHO SECURITIES USA LLC

MORGAN STANLEY

MORGAN STANLEY & CO LLC

MORGAN STANLEY & CO. INTERNATIONAL

MORGAN STANLEY MUFG SECURITIES CO LTD

MUFG SECURITIES AMERICAS INC

MUFG SECURITIES EMEA PLC

NATIONAL BANK FINANCIAL INC.

NATIXIS S.A.

NATWEST MARKETS PLC

NOMURA INTERNATIONAL PLC

NOMURA SECURITIES COMPANY LIMITED

NOMURA SECURITIES INTERNATIONAL INC

OKASAN SECURITIES CO LTD

ORIENT SECURITIES COMPANY LIMITED

OVERSEA-CHINESE BANKING CORPORATION LTD

RBC CAPITAL MARKETS, LLC.

RBC EUROPE LTD

SANTANDER US CAPITAL MARKETS LLC

SCOTIA CAPITAL (USA), INC

SCOTIA CAPITAL INC

SCOTIABANK INVERLAT SA

SHANXI SECURITIES CO LTD

SMBC BANK INTERNATIONAL PLC

SMBC NIKKO SECURITIES AMERICA, INC.

SMBC NIKKO SECURITIES INC.

SOCIETE GENERALE (NY BRANCH)

STANDARD CHARTERED BANK

STANDARD CHARTERED BANK (CHINA) LTD

SUMITOMO MITSUI BANKING CORP (SYDNEY BRANCH)

TD SECURITIES (USA) LLC

TD SECURITIES INC

BANK OF NOVA SCOTIA

THE TORONTO DOMINION BANK

TRADEWEB EUROPE LIMITED

TRADEWEB MARKETS LLC

TRUIST SECURITIES, INC.

U.S. BANCORP INVESTMENTS, INC.

UBS AG

UNICREDIT BANK AG

WELLS FARGO SECURITIES INTERNATIONAL LTD

WELLS FARGO SECURITIES LLCWESTPAC BANKING CORP ABN

INTEREST RATE DERIVATIVES – Futures & Options admitted to trading on a trading venue

BARCLAYS BANK PLC

BARCLAYS CAPITAL INC

BNP PARIBAS SECURITIES CORPORATION

BOFA SECURITIES INC.

CITIGROUP GLOBAL MARKETS INC

CITIGROUP GLOBAL MARKETS LIMITED

DEUTSCHE BANK AG

DEUTSCHE BANK SECURITIES INC

FLEXTRADER

GOLDMAN SACHS & CO. LLC

GOLDMAN SACHS INTERNATIONAL

HSBC BANK PLC

HSBC SECURITIES (USA) INC

J.P. MORGAN SECURITIES LLC

J.P. MORGAN SECURITIES PLC

MIZUHO SECURITIES USA LLC

MORGAN STANLEY & CO INTERNATIONAL PLC

MORGAN STANLEY & CO LLC

NOMURA SECURITIES INTERNATIONAL INC

RBC CAPITAL MARKETS, LLC.

RBC EUROPE LTD

SOCIETE GENERALE INTERNATIONAL LTD

UBS AG

UBS SECURITIES LLC

INTEREST RATE DERIVATIVES – Swaps, forwards & other interest rates derivatives

ANZ GROUP HOLDINGS LTD

BANCO BILBAO VIZCAYA ARGENTARIA SA

BANCO SANTANDER SA

BANK OF AMERICA CORP

BANK OF MONTREAL

BANK OF NOVA SCOTIA

BARCLAYS PLC

BLOOMBERG TRADEBOOK LLC

BNP PARIBAS SA

BPCE SA

CANADIAN IMPERIAL BANK OF COMMERCE

CITADEL SECURITIES SWAP DEALER LLC

CITIGROUP GLOBAL MARKETS LIMITED

CITIGROUP INC

COMMONWEALTH BANK OF AUSTRALIA

DANSKE BANK A/S

DEUTSCHE BANK AG

GOLDMAN SACHS GROUP INC/THE

GOLDMAN SACHS INTERNATIONAL

HSBC HOLDINGS PLC

ING GROEP NV

JEFFERIES FINANCIAL GROUP INC

J.P. MORGAN SECURITIES PLC

JPMORGAN CHASE & CO

LLOYDS BANKING GROUP PLC

MERRILL LYNCH INTERNATIONAL

MIZUHO FINANCIAL GROUP INC

MORGAN STANLEY

MORGAN STANLEY & CO. INTERNATIONAL

NATWEST GROUP PLC

NOMURA HOLDINGS INC

NORDEA BANK ABP

ROYAL BANK OF CANADA

RUE LA BOETIE SAS

SKANDINAVISKA ENSKILDA BANKEN AB

SOCIETE GENERALE SA

STANDARD CHARTERED PLC

TRADEWEB EUROPE LIMITED

TRADEWEB MARKETS LLC

UBS GROUP AG

WELLS FARGO & COMPANY

WESTPAC BANKING CORP

COMMODITIES DERIVATIVES – Futures & Options admitted to trading on a trading venue

BARCLAYS CAPITAL INC

BARCLAYS CAPITAL INVESTMENT BANKING

BNP PARIBAS SECURITIES CORP

CITIGROUP GLOBAL MARKETS INC.

CITIGROUP GLOBAL MARKETS LIMITED

DEUTSCHE BANK SECURITIES INC

FLEXTRADER

GOLDMAN SACHS & CO. LLC

GOLDMAN SACHS INTERNATIONAL

HSBC SECURITIES (USA) INC

J.P. MORGAN SECURITIES LLC

J.P. MORGAN SECURITIES PLC

MORGAN STANLEY & CO LLC

MORGAN STANLEY & CO. INTL PLC

RBC CAPITAL MARKETS, LLC.

SG AMERICAS SECURITIES, LLC

SOCIETE GENERALE INTERNATIONAL LIMITED

UBS SECURITIES LLC

CREDIT DERIVATIVES – other credit derivatives

BANK OF AMERICA CORP

BANK OF AMERICA NA

BARCLAYS BANK PLC

BARCLAYS PLC

BLOOMBERG TRADEBOOK LLC

BNP PARIBAS SA

CITIBANK NA

CITIGROUP GLOBAL MARKETS LIMITED

CITIGROUP INC

DEUTSCHE BANK AG

GOLDMAN SACHS GROUP INC/THE

GOLDMAN SACHS INTERNATIONAL

HSBC HOLDINGS PLC

JEFFERIES FINANCIAL GROUP INC

J.P. MORGAN SECURITIES PLC

J.P. MORGAN CHASE BANK

J.P. MORGAN CHASE & CO

MERRILL LYNCH INTERNATIONAL

MORGAN STANLEY

MORGAN STANLEY & CO. INTERNATIONAL

ROYAL BANK OF CANADA

SOCIETE GENERALE

TRADEWEB EUROPE LIMITED

TRADEWEB MARKETS LLC

UBS GROUP AG

WELLS FARGO & COMPANY

CURRENCY DERIVATIVES – Futures & Options admitted to trading on a trading venue

BANK OF AMERICA NA

BARCLAYS CAPITAL INC.

BNP PARIBAS SA

BNP PARIBAS SECURITIES CORPORATION

BOFA SECURITIES INC.

CITIGROUP GLOBAL MARKETS INC.

DEUTSCHE BANK SECURITIES INC.

FLEXTRADERGOLDMAN SACHS & CO. LLC

GOLDMAN SACHS INTERNATIONALHSBC BANK PLC

HSBC BANK USA, NAJ.P. MORGAN SECURITIES LLC

JP MORGAN SECURITIES PLC

MERRILL LYNCH INTERNATIONAL

MORGAN STANLEY & CO LLC

MORGAN STANLEY & CO. INTERNATIONAL

ROYAL BANK OF CANADA

UBS SECURITIES LLC

CURRENCY DERIVATIVES – Swaps, forwards & other currency derivatives

360T

AUSTRALIA AND NEW ZEALAND

BANCO SANTANDER SABANK OF AMERICA NA

BANK OF AMERICA SECURITIES EUROPE SA

BANK OF MONTREAL

BANK OF NEW YORK MELLON

BANQUE PICTET ET CIE SA

BARCLAYS BANK IRELAND PLC

BARCLAYS BANK PLC

BNP PARIBAS

BROWN BROTHERS HARRIMAN & CO

CANADIAN IMPERIAL BANK OF COMMERCE

CITIBANK EUROPE PLC

CITIBANK NA

CITIGROUP GLOBAL MARKETS LIMITEDCOMMONWEALTH BANK OF AUSTRALIA

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK SA

JPMORGAN CHASE BANK NA

DEUTSCHE BANK AG

DEUTSCHE SECURITIES INC.

FLEXTRADERGOLDMAN SACHS BANK EUROPE, SE

GOLDMAN SACHS BANK USA

GOLDMAN SACHS INTERNATIONAL

GOLDMAN SACHS JAPAN CO. LTD.

HONGKONG AND SHANGHAI BANKING CORPORATION LTD

HSBC BANK PLC

HSBC BANK USA, NA

HSBC CONTINENTAL EUROPE SA

INTEGRAL

J.P. MORGAN AG

J.P. MORGAN SECURITIES PLC

LLOYDS BANK CORPORATE MARKETS

MERRILL LYNCH INTERNATIONAL

MITSUBISHI UFJ TRUST AND BANKING CO

MORGAN STANLEY & CO. INTERNATIONAL

MORGAN STANLEY CAPITAL SERVICES LLC

MORGAN STANLEY EUROPE SE

MORGAN STANLEY MUFG SECURITIES CO.

MUFG BANK, LTD

NATIONAL AUSTRALIA BANK LIMITED

NATWEST MARKETS NV

NATWEST MARKETS PLC

NOMURA INTERNATIONAL PLC

ROYAL BANK OF CANADA

SKANDINAVISKA ENSKILDA BANKEN AB

SOCIETE GENERALE

STANDARD CHARTERED BANK

STATE STREET BANK AND TRUST COMPANY

THE NORTHERN TRUST COMPANY

THE TORONTO-DOMINION BANK

UBS AG

UBS EUROPE SE

WELLS FARGO BANK NA

WESTPAC BANKING CORP

STRUCTURED FINANCE INSTRUMENTS

ACADEMY SECURITIES INC

BAIRD FINANCIAL GROUP INC

BANCO SANTANDER SA

BANK OF AMERICA CORP

BANK OF MONTREAL

BANK OF NOVA SCOTIA

BARCLAYS BANK PLC

BARCLAYS CAPITAL INC.

BARCLAYS PLC

BAY CREST PARTNERS, LLC

BLOOMBERG TRADEBOOK LLC

BMO CAPITAL MARKETS CORP.

BMO NESBITT BURNS INC

BNP PARIBAS

BNP PARIBAS SECURITIES CORPORATION

BNY MELLON CAPITAL MARKETS LLC

BOFA SECURITIES INC.

BOKF, NA

BPCE SA

BREAN CAPITAL, LLC

BRED BANQUE POPULAIRE

BROWNSTONE INVESTMENT GROUP, LLC

BTIG LIMITED

BTIG, LLC

CABRERA CAPITAL MARKETS LLC

CANADIAN IMPERIAL BANK OF COMMERCE

CANTOR FITZGERALD & COMPANY

CIBC WORLD MARKETS CORP.

CITIGROUP GLOBAL MARKETS INC.

CITIGROUP GLOBAL MARKETS LIMITED

CITIGROUP INC

COMMONWEALTH BANK OF AUSTRALIA

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK SA

CREDIT AGRICOLE SECURITIES (USA) INC.

DA DAVIDSON & COMPANY

DAIWA CAPITAL MARKETS AMERICA INC.

DEUTSCHE BANK AG

DEUTSCHE BANK SECURITIES INC.

DZ BANK AG DEUTSCHE ZENTRAL GENOSSENSCHAFTSBANK FRANKFURT AM MAIN

FHN FINANCIAL SECURITIES CORP

FIRST TRYON SECURITIES, LLC

GOLDMAN SACHS & CO. LLC

GOLDMAN SACHS GROUP INC/THE

GOLDMAN SACHS INTERNATIONAL

GUGGENHEIM SECURITIES, LLC

HILLTOP SECURITIES INC.

HSBC BANK PLC

HSBC SECURITIES (USA) INC

INTESA SANPAOLO IMI SECURITIES CORP

INTESA SANPAOLO SPA

JANE STREET EXECUTION SERVICES, LLC

JANE STREET FINANCIAL LIMITED

JANNEY MONTGOMERY SCOTT LLC

JEFFERIES FINANCIAL GROUP INC

JEFFERIES INTERNATIONAL LIMITED

JEFFERIES LLC

J.P. MORGAN CHASE & CO

J.P. MORGAN SECURITIES LLC

J.P. MORGAN SECURITIES PLC

KEYBANC CAPITAL MARKETS INC.

LLOYDS BANK CORPORATE MARKETS PLC

LLOYDS SECURITIES INC

LOOP CAPITAL MARKETS, LLC

MARKETAXESS CAPITAL LIMITED

MARKETAXESS CORPORATION

MARKETAXESS EUROPE LTD

MERRILL LYNCH INTERNATIONAL

MILLENNIUM ADVISORS, LLC

MISCHLER FINANCIAL GROUP, INC.

MITSUBISHI UFJ FINANCIAL GROUP

MIZUHO INTERNATIONAL PLC

MIZUHO FINANCIAL GROUP INC

MIZUHO SECURITIES USA LLC

MORGAN STANLEY

MORGAN STANLEY & CO INTERNATIONAL PLC

MORGAN STANLEY & CO LLC

MUFG SECURITIES AMERICAS INC

NATIONAL AUSTRALIA BANK LIMITED

NATIONAL BANK FINANCIAL INC.

NATIXIS S.A.

NATIXIS SECURITIES AMERICAS LLC

NOMURA HOLDINGS INC

NOMURA SECURITIES INTERNATIONAL INC

OPPENHEIMER & CO. INC.

PERFORMANCE TRUST CAPITAL PARTNERS LLC

PIPER SANDLER & CO.

PIPER SANDLER COMPANIES

PNC CAPITAL MARKETS LLC

RAYMOND JAMES & ASSOCIATES INC

RBC CAPITAL MARKETS, LLC.

RBC EUROPE LTD

ROBERT W BAIRD & CO INC

ROYAL BANK OF CANADA

SAMUEL A. RAMIREZ & CO., INC

SANTANDER US CAPITAL MARKETS LLC

SCOTIA CAPITAL (USA), INC

SCOTIA CAPITAL INC

SEAPORT GLOBAL SECURITIES LLC

SIEBERT WILLIAMS SHANK & CO. LLC

SMBC BANK INTERNATIONAL PLC

SMBC NIKKO SECURITIES AMERICA, INC.

SOCIETE GENERALE (NY BRANCH)

STANDARD CHARTERED BANK

STEPHENS INC

STIFEL NICOLAUS AND CO INC

STONEX FINANCIAL INC

SUMITOMO MITSUI FIN GRP INC

TD SECURITIES (USA) LLC

TD SECURITIES INC

TRADEWEB DIRECT LLC

TRADEWEB EUROPE LIMITED

TRADEWEB EXECUTION SERVICES LTD

TRADEWEB MARKETS LLC

TRUIST SECURITIES, INC.

U.S. BANCORP INVESTMENTS, INC.

UBS AG

UMB BANK, N.A.

WELLS FARGO & COMPANY

WELLS FARGO SECURITIES INTERNATIONAL LTD

WELLS FARGO SECURITIES LLC

WESTPAC BANKING CORP ABN

EQUITY DERIVATIVES – Futures & Options admitted to trading on a trading venue

BANK OF AMERICA NA

BANK OF MONTREAL

BARCLAYS BANK PLC

BARCLAYS CAPITAL INC.

BLOOMBERG TRADEBOOK LLC

BMO CAPITAL MARKETS CORP.

BNP PARIBAS

BNP PARIBAS SECURITIES CORPORATION

BOFA SECURITIES INC.

CITADEL SECURITIES LLC

CITIBANK NA

CITIGROUP GLOBAL MARKETS INC.

CITIGROUP GLOBAL MARKETS LIMITED

FLEXTRADER

GOLDMAN SACHS & CO. LLC

GOLDMAN SACHS INTERNATIONAL

HSBC BANK PLC

JANE STREET EXECUTION SERVICES, LLC

JEFFERIES LLC

J.P. MORGAN CHASE BANK

J.P. MORGAN SECURITIES LLC

J.P. MORGAN SECURITIES PLC

MERRILL LYNCH INTERNATIONAL

MORGAN STANLEY & CO INTERNATIONAL PLC

MORGAN STANLEY & CO LLC

NOMURA INTERNATIONAL PLC

NOMURA SECURITIES INTERNATIONAL INC

OPPENHEIMER & CO. INC.

OPTIVER V.O.F.

RBC CAPITAL MARKETS, LLC.ROYAL BANK OF CANADA

SOCIETE GENERALE

SOCIETE GENERALE INTERNATIONAL LIMITED

SUSQUEHANNA FINANCIAL GROUP LLLP

TD SECURITIES (USA) LLC

TD SECURITIES INC

TRADEWEB MARKETS LLC

UBS AG

UBS SECURITIES LLC

WELLS FARGO SECURITIES LLC

EQUITY DERIVATIVES – Swap & other equity derivatives

ABG SUNDAL COLLIER ASA

BANK OF AMERICA CORP

BARCLAYS CAPITAL INC

BARCLAYS CAPITAL SECURITIES LTD

BARCLAYS PLC

BERNSTEIN AUTONOMOUS LLP

BNP PARIBAS

BNP PARIBAS SECURITIES CORP

BOFA SECURITIES INC.

BTIG LIMITED

CABRERA CAPITAL MARKETS LLC

CANACCORD GENUITY LIMITED

CANTOR FITZGERALD EUROPE

CARNEGIE INVESTMENT BANK AB

CAVENDISH SECURITIES PLC

CITIBANK NA

CITIGROUP GLOBAL MARKETS INC.

CITIGROUP GLOBAL MARKETS LIMITED

CITIGROUP INC

CLSA LIMITED

CHINA INTL CAPITAL CORPORATION LIMITED

DAIWA CAPITAL MARKETS AMERICA INC.

DAIWA CAPITAL MARKETS EUROPE LIMITED

DANSKE BANK A/S

DNB BANK ASA

EFG HERMES IFA FINANCIAL BROKERAGE COMPANY KSCC

FLEXTRADER

FLOW TRADERS B.V.

GOLDMAN SACHS & CO. LLC

GOLDMAN SACHS GROUP INC/THE

GOLDMAN SACHS INTERNATIONAL

GOODBODY STOCKBROKERS

HAITONG INTERNATIONAL SECURITIES CO

HONGKONG AND SHANGHAI BANKING CORPORATION LTD

HSBC BANK PLC

HSBC HOLDINGS PLC

HSBC SECURITIES (USA) INC

INSTINET EUROPE LIMITED

INSTINET LLC

INVESTEC PLC

INVESTEC BANK PLC

J & E DAVY

JANE STREET FINANCIAL LIMITED

JEFFERIES FINANCIAL GROUP INC

JEFFERIES INTERNATIONAL LIMITED

JOH. BERENBERG, GOSSLER & CO. KG

J.P. MORGAN CHASE BANK

J.P. MORGAN CHASE & CO

J.P. MORGAN SECURITIES PLC

J.P. MORGAN SECURITIES LLC

KEPLER CHEUVREUX S.A.

LIQUIDNET EUROPE LIMITED

MACQUARIE CAPITAL (EUROPE) LIMITED

MACQUARIE CAPITAL (USA) INC.

MERRILL LYNCH INTERNATIONAL

MIZUHO FINANCIAL GROUP INC

MIZUHO INTERNATIONAL PLC

MORGAN STANLEY

MORGAN STANLEY & CO INTERNATIONAL PLC

MORGAN STANLEY & CO LLC

NOMURA HOLDINGS INC

NOMURA INTERNATIONAL PLC

NORDEA BANK ABP

NORTHERN TRUST SECURITIES LLP

NUMIS SECURITIES LTD

ODDO BHF SCA

OPTIVER V.O.F.

PANMURE LIBERUM LIMITEDPEEL HUNT LLP

PENSERRA SECURITIES LLC

RBC EUROPE LTD

REDBURN (EUROPE) LIMITEDSG AMERICAS SECURITIES, LLC

SHORE CAPITAL STOCKBROKERS LIMITED

SKANDINAVISKA ENSKILDA BANKEN AB

SMBC BANK INTERNATIONAL PLC

SMBC NIKKO SECURITIES INC.

SOCIETE GENERALE

STIFEL FINL CORP

STIFEL NICOLAUS EUROPE LIMITED

TD EXECUTION SERVICES LIMITED

TRADEWEB EUROPE LIMITED

TRADEWEB MARKETS LLC

UBS AG

UBS GROUP AG

UBS SECURITIES LLC

VAN LANSCHOT KEMPEN N.V.

VIRTU EUROPE TRADING LIMITED

WELLS FARGO SECURITIES LLC

WINTERFLOOD SECURITIES LIMITED

ZKB SECURITIES UK LTD

SECURITIZED DERIVATIVES – Warrants & Certificate Derivatives

BARCLAYS CAPITAL SECURITIES LTD

BERNSTEIN AUTONOMOUS LLP

BNP PARIBAS

BNP PARIBAS SECURITIES

CORPORATION

BOFA SECURITIES INC.

BTG PACTUAL US CAPITAL, LLC

CITIGROUP GLOBAL MARKETS INC.

CITIGROUP GLOBAL MARKETS LIMITED

CLSA LIMITED

FLEXTRADER

GOLDMAN SACHS & CO. LLC

GOLDMAN SACHS INTERNATIONAL

HONGKONG AND SHANGHAI BANKING CORPORATION LTD

HSBC BANK PLC

HSBC SECURITIES (USA) INC

INSTINET LLC

JEFFERIES INTERNATIONAL LIMITEDJ.P. MORGAN SECURITIES LLC

J.P. MORGAN SECURITIES PLC

MACQUARIE CAPITAL (USA) INC.

MERRILL LYNCH INTERNATIONAL

MORGAN STANLEY & CO INTERNATIONAL PLC

MORGAN STANLEY & CO LLC

SANTANDER US CAPITAL MARKETS LLC

SOCIETE GENERALE PARIS

UBS AG

UBS SECURITIES LLC

SECURITIZED DERIVATIVES – Other Securitized Derivatives

N/A

CREDIT DERIVATIVES – Futures & Options admitted to trading on a trading venue

BARCLAYS CAPITAL INC

BARCLAYS CAPITAL SECURITIES LTD

BARCLAYS PLC

BLOOMBERG TRADEBOOK LLC

BNP PARIBAS

BNP PARIBAS SECURITIES CORP

BOFA SECURITIES INC.

CITADEL SECURITIES LLC

CITIGROUP GLOBAL MARKETS INC

CITIGROUP GLOBAL MARKETS LIMITED

DEUTSCHE BANK AG

DEUTSCHE BANK SECURITIES INC.

FLEXTRADER

GOLDMAN SACHS & CO. LLC

GOLDMAN SACHS INTERNATIONAL

HONGKONG AND SHANGHAI BANKING CORPORATION LTD

HSBC BANK PLC

HSBC SECURITIES (USA) INC

J.P. MORGAN SECURITIES LLC

J.P. MORGAN SECURITIES PLC

JANE STREET EXECUTION SERVICES, LLC

JANE STREET FINANCIAL LIMITED

MERRILL LYNCH INTERNATIONAL

MIZUHO SECURITIES USA LLC

MORGAN STANLEY & CO LLC

MORGAN STANLEY & CO. INTERNATIONAL

MORGAN STANLEY MUFG SECURITIES CO.

NOMURA INTERNATIONAL PLC

NOMURA SECURITIES INTERNATIONAL INC

PRISM FINANCIAL PRODUCTS LP

RBC CAPITAL MARKETS, LLC.

RBC EUROPE LTDSG AMERICAS SECURITIES, LLC

SOCIETE GENERALE (NY BRANCH)

SOCIETE GENERALE CAPITAL CANADA INC

SOCIETE GENERALE INTERNATIONAL LTD

TRADEWEB EUROPE LIMITED

TRADEWEB MARKETS LLC

UBS AG

UBS SECURITIES LLC

WELLS FARGO SECURITIES LLC

COMMODITIES DERIVATIVES – Other commodities derivatives

BARCLAYS CAPITAL INC

BNP PARIBAS SA

BNP PARIBAS SECURITIES CORP

CITIBANK NA

CITIGROUP GLOBAL MARKETS INC.

DEUTSCHE BANK SECURITIES INC.

FLEXTRADER

GOLDMAN SACHS & CO. LLC

GOLDMAN SACHS INTERNATIONAL

HSBC BANK PLC

HSBC SECURITIES (USA) INC

J.P. MORGAN CHASE BANK

J.P. MORGAN SECURITIES LLC

J.P. MORGAN SECURITIES PLC

MACQUARIE BANK LIMITED

MERRILL LYNCH INTERNATIONAL

MORGAN STANLEY & CO LLC

MORGAN STANLEY & CO. INTL PLC

RBC CAPITAL MARKETS, LLC.

ROYAL BANK OF CANADA

SG AMERICAS SECURITIES, LLC

SOCIETE GENERALE

UBS SECURITIES LLC

EXCHANGE TRADED PRODUCTS

BARCLAYS CAPITAL INC.

BARCLAYS CAPITAL SECURITIES LTD

BLOOMBERG TRADEBOOK LLC

BMO CAPITAL MARKETS CORP.

BNP PARIBAS

BNP PARIBAS SECURITIES CORPORATION

BOFA SECURITIES INC.

BTIG, LLC

CABRERA CAPITAL MARKETS LLC

CANTOR FITZGERALD & COMPANY

CASA DE BOLSA FINAMEX SAB DE CV

CASA DE BOLSA SANTANDER SA

CASTLEOAK SECURITIES, L.P.

CIBC WORLD MARKETS CORP.

CITADEL SECURITIES LLC

CITIBANAMEX CASA DE BOLSA SA DE CV

CITIGROUP GLOBAL MARKETS INC.

CITIGROUP GLOBAL MARKETS LIMITED

CLSA LIMITED

TD SECURITIES (USA) LLC

DEUTSCHE BANK AG

DRW EUROPE B.V.

FLEXTRADER

FLOW TRADERS B.V.

FLOW TRADERS HONG KONG LTD

FLOW TRADERS U.S. INSTITUTIONAL TRADING LLC

GOLDMAN SACHS & CO. LLC

GOLDMAN SACHS INTERNATIONAL

GOLDMAN SACHS MEXICO CASA DE BOLSA SA DE CV

GREAT PACIFIC SECURITIES

GRUPO BURSATIL MEXICANO CASA BOLSA

GUZMAN & COMPANY

HONG KONG & SHANGHAI BANKING CORP LIMITED

HSBC BANK PLC

HSBC SECURITIES (USA) INC

INSTINET LLC

JANE STREET EXECUTION SERVICES, LLC

JANE STREET FINANCIAL LIMITED

JEFFERIES INTERNATIONAL LIMITED

JEFFERIES LLC

JONESTRADING INSTITUTIONAL SERVICES LLC

J.P. MORGAN CASA DE BOLSA, S.A. DE

J.P. MORGAN SECURITIES LLC

J.P. MORGAN SECURITIES PLC

KEPLER CHEUVREUX S.A.

LOOP CAPITAL MARKETS, LLC

MACQUARIE CAPITAL (USA) INC.

MERRILL LYNCH INTERNATIONAL

MERRILL LYNCH MEXICO SA DE CV CASA DE BOLSA

MISCHLER FINANCIAL GROUP, INC.

MIZUHO INTERNATIONAL PLC

MIZUHO SECURITIES USA LLC

MORGAN STANLEY & CO INTERNATIONAL PLC

MORGAN STANLEY & CO LLC

MORGAN STANLEY MEXICO CASA DE BOLSA SA DE CV

NATIONAL BANK FINANCIAL INC.

OLD MISSION EUROPE LLP

OLD MISSION MARKETS LLC

OPPENHEIMER & CO. INC.

OPTIVER V.O.F.

PENSERRA SECURITIES LLC

PIPER SANDLER & CO

RBC CAPITAL MARKETS, LLC.

RBC EUROPE LTD

ROTH CAPITAL PARTNERS, LLC

SAMUEL A. RAMIREZ & CO., INC

SCOTIA CAPITAL (USA), INC

SIEBERT WILLIAMS SHANK & CO. LLC

SMBC NIKKO SECURITIES INC.

SOCIETE GENERALE PARIS

STERN BROTHERS & CO

SUSQUEHANNA FINANCIAL GROUP LLLP

TD SECURITIES INC

TOURMALINE PARTNERS, LLC

TRADEWEB EUROPE LIMITED

TRADEWEB MARKETS LLC

UBS AG

UBS SECURITIES LLC

VIRTU AMERICAS LLC

VIRTU EUROPE TRADING LIMITED

WELLS FARGO SECURITIES LLC

EMISSION ALLOWANCES

N/A

OTHER INSTRUMENTS

BARCLAYS BANK PLC

BARCLAYS CAPITAL INC.

BARCLAYS CAPITAL SECURITIES LTD

BNP PARIBAS SA

BNP PARIBAS SECURITIES CORPORATION

BOFA SECURITIES INC.

CITIBANK NA

CITIGROUP GLOBAL MARKETS INC.

CITIGROUP GLOBAL MARKETS LIMITED

CITIZENS BANK, NATIONAL ASSOCIATION

DEUTSCHE BANK SECURITIES INC.

DEUTSCHE BANK TRUST COMPANY AMERICAS

GOLDMAN SACHS INTERNATIONAL

HSBC BANK PLC

HSBC BANK PLC

JEFFERIES LEVERAGED CREDIT PRODUCTS

JEFFERIES LLC

J.P. MORGAN SECURITIES LLC

J.P. MORGAN CHASE BANK

J.P. MORGAN SECURITIES PLC

MARKETAXESS CORPORATION

MERRILL LYNCH INTERNATIONAL

MORGAN STANLEY & CO INTERNATIONAL PLC

MORGAN STANLEY & CO LLC

NATIXIS S.A.

NATIXIS SECURITIES AMERICAS LLC

NOMURA SECURITIES INTERNATIONAL INC

RBC CAPITAL MARKETS, LLC.

ROYAL BANK OF CANADA

SANTANDER US CAPITAL MARKETS LLC

SOCIETE GENERALE

TD SECURITIES INC

TD SECURITIES (USA) LLC

TRUIST SECURITIES, INC.

UBS AG

UBS SECURITIES LLC

WELLS FARGO BANK NA

WELLS FARGO SECURITIES LLC

SECURITIES FINANCING TRANSACTIONS

BANK OF AMERICA SECURITIES EUROPE SA

BANK OF MONTREAL

BARCLAYS BANK PLC

BNP PARIBAS

BOFA SECURITIES INC.

CANADIAN IMPERIAL BANK OF COMMERCE

CITIGROUP GLOBAL MARKETS INC.

CITIGROUP GLOBAL MARKETS LIMITED

COMMONWEALTH BANK OF AUSTRALIA

CREDIT AGRICOLE CIB (NEW YORK)

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK SAGOLDMAN SACHS & CO. LLC

GOLDMAN SACHS INTERNATIONAL

HSBC BANK PLC

ING BANK NV

J.P. MORGAN SECURITIES LLC

J.P. MORGAN SECURITIES PLC

MIZUHO SECURITIES USA LLC

MUFG SECURITIES EMEA PLC

NATIONAL AUSTRALIA BANK LIMITED

NATIXIS S.A.

NATWEST MARKETS PLC

ROYAL BANK OF CANADA (NEW YORK BRANCH)

SANTANDER UK PLC

SOCIETE GENERALE

TD SECURITIES (USA) LLC

BANK OF NOVA SCOTIA

TRADEWEB EUROPE LIMITED

TRADEWEB MARKETS LLC

WELLS FARGO SECURITIES LLC