S&P Global Terms of Use

This web page, together with the legal pages, details the terms of a legal agreement (the "Terms of Use") between you and S&P Global Inc., also acting on behalf of its subsidiaries and affiliates (collectively "S&P Global"). By accessing or using this website, currently located at spglobal.com or any website or mobile application referring to these Terms of Use as its terms (the “Website”), or any Content (as defined below), you acknowledge and irrevocably represent that you have read and understood the Terms of Use, and you voluntarily and irrevocably accept and agree to be bound by the Terms of Use. You also agree to comply with all laws and regulations applicable to the use of this Website, the use of the internet, and the activities involved in using this Website.

If you do not agree with these Terms of Use, do not use this Website. If you, or the entity through which you were provided a log-in ID and password, subscribed to certain content or services found on this Website by way of executing a written agreement, in the form of an addendum, order form, or otherwise ("Agreement"), then these Terms of Use shall be supplemental to such Agreement, and use of this Website is subject to the terms of the Agreement in addition to these Terms of Use. By accessing this Website, you acknowledge that you have read and are bound by the Agreement (if you require a copy of the Agreement, please contact your company's contract administrator).

S&P Global reserves the right to vary, amend, remove or add to the Terms of Use at any time. Such modifications shall be effective immediately. Your continued access and use of this Website and Content following the posting of modifications to the Terms of Use shall constitute your acknowledgment and acceptance of such modifications. If, at any time, you do not wish to accept the Terms of Use, you must immediately cease to access or use this Website and all Content. Any additional terms, conditions, or modifications to these Terms of Use that are proposed by you shall be of no force or effect unless and until expressly agreed to by S&P Global in writing.

1. License

You acquire absolutely no rights or licenses in or to this Website and any text, graphics, user interfaces, visual interfaces, photographs, trademarks, logos, sounds, music, audio, video, artwork, computer code, information, data and material therein, including ratings or scores (collectively, the "Content") other than the limited right to utilize this Website and Content for your own personal, internal, non-commercial purposes in accordance with these Terms of Use.

2. General Restrictions on Use

You will not in connection with your use of this Website and all Content therein: (a) violate any applicable local, state, national or international law, statute, ordinance, rule or regulation, including without limitation those relating to competition or antitrust, economic sanctions, or export controls; (b) interfere with or disrupt the computer networks of S&P Global or attempt to do so; (c) forge headers or in any manner manipulate identifiers in order to disguise the origin of any information; (d) download, upload, post, transmit, publish, or distribute any material that infringes, violates, breaches or otherwise contravenes the rights of S&P Global or any third party, including any copyright, trademark, patent, rights of privacy or publicity or any other proprietary right; (e) interfere with or disrupt the use of this Website by any other customer or user or reverse look-up, trace or seek to trace any information on any other user of or visitor to this Website, or any other customer of S&P Global, including any S&P Global account not owned by you; (f) probe, scan or test the vulnerability of this Website or any network connected to this Website or attempt to gain unauthorized entry or access to the computer systems of any other person or entity; (g) take any action that imposes an unreasonable or disproportionately large load on the infrastructure of this Website or S&P Global's systems or networks, or any systems or networks connected to this Website or to S&P Global; or (h) download, upload, post, transmit, publish or distribute any material or information that constitutes or encourages conduct that would constitute a criminal offence, give rise to other liability, or otherwise violate applicable law.

You may not use any linking, deep-linking, framing or page-scraping technology, robots, spiders or other automatic devices, programs, algorithms or methodologies, or any similar or equivalent manual processes, to access, acquire, copy, distribute, display or monitor any portion of this Website or any Content, or in any way reproduce or circumvent the navigational structure or presentation of this Website or any Content, to obtain or attempt to obtain any materials, documents or information through any means not purposely made available through this Website.

Unless provided otherwise in an Agreement, you hereby agree and acknowledge that you are expressly prohibited from: (i) making available all or any portion of the Content to any other person or entity, except as expressly permitted in these Terms of Use or in an Agreement; (ii) creating derivative works from the Content; and (iii) using the Content in the provision of any services to third parties. In addition, you shall not distribute, transfer, sub-license, rent, lend, transmit, sell, re-circulate, repackage, assign, lease, resell, publish, copy, translate, convert, decompile, reverse engineer, alter, enhance, disassemble, modify, or change all or any portion of the Content.

You shall not use the Content to develop, support, create or provide pricing for: (i) any database or product that competes directly with the Content or any other S&P Global product or service offered in the marketplace or would create a functional substitute for any such S&P Global products or Content; or (ii) any index (e.g., any composite financial index).

You may download and use certain Content that is purposely and expressly made available by S&P Global for downloading from this Website (such as product sheets or articles), provided that you: (i) do not remove any proprietary notice or disclaimer language in any copies of such documents, (ii) use such information only for your personal, non-commercial informational purpose and do not copy or post such information on any networked computer or broadcast it in any media, (iii) make no modifications to any such information, and (iv) do not make any representations or warranties relating to same.

You grant to S&P Global a non-exclusive, perpetual, transferable, sublicensable, worldwide, royalty-free right and license to host, use, distribute, modify, enhance, run, copy, publicly perform and display, translate and create derivative works of and to all information, data, content and material submitted, uploaded, shared or otherwise made available on the Website by you and in any of S&P Global's and/or any of its affiliates' print or electronic publications, services or web sites ("Your Content").  S&P Global has the right to remove any part of Your Content if such data, information or content (i) violates any of the terms of these Terms of Use or any other policy of S&P Global, (ii) violates any applicable laws or regulations, (iii) is misleading, discriminatory, inaccurate, untrue, threatening, defamatory, harassing, libelous, deceptive, racist, or invasive of another person's privacy or contains untrue statements, unsubstantiated rumors or any misrepresentations, (iv) contains explicit or graphic descriptions or accounts of sexual or violent acts, (v) infringes, violates or misappropriates any third party's rights, including, without limitation, intellectual property or proprietary rights. If you violate any of the terms of these Terms of Use, S&P Global has the right to restrict or prohibit your use of the Website without providing any notice to you. In addition, S&P Global can remove any content or restrict or prohibit your access to the Website if S&P Global determines in its sole discretion that doing so is reasonably necessary to avoid or mitigate adverse legal or regulatory impacts on S&P Global. S&P Global retains the right, which it may exercise in its sole discretion, to review, edit, or delete any content posted or provided by you, or to delete the relevant account(s), that S&P Global deems to be (i) illegal, (ii) offensive, (iii) in violation of contractual obligations, or (iv) otherwise inappropriate.

Qualified and Institutional Investors. Portions of this Website were created in order to enable "qualified institutional buyers," as defined in Rule 144A under the Securities Act of 1933 ("QIBs"), to analyze data made available by issuers to QIBs in securities offerings and in the QIB secondary market. These data may or may not otherwise be publicly available. If you choose to access such QIB information on the Website ("QIB Information"), you hereby acknowledge and agree that (a) you must be a QIB to access the QIB Information, (b) the QIB Information contained on this Website may only be available to QIBs, (c) you will not transmit or use any such QIB Information in violation of the federal securities laws, and (d) you represent and warrant to S&P Global (on behalf of yourself or your organization) that you have such knowledge and experience in financial and business matters so that you are capable of evaluating the merits and risks of the securities for which QIB Information has been made available by the issuers, and utilize effectively the software, products and/or data provided by S&P Global as an analytical tool to assist in any such evaluation. You also confirm that you are solely responsible for performing your own evaluation of any such securities, and with respect to QIB Information made available by issuers to QIBs in securities offerings and in the QIB secondary market, S&P does not make any recommendations as to whether to buy, sell or hold any such securities or as to the usefulness of its software, products, and data to you for purposes of making any such evaluation.

Events. You hereby represent and warrant that by registering, accessing, or otherwise engaging in any S&P Global event through this website or which otherwise incorporate these Terms of Use: (i) you, your employer, directors or corporate officers of either your employer or your employer’s affiliates, are not the subject of any economic sanctions or export control measures administered by any applicable sanctions or export control authority (including, but not limited to, (a) the Government of the United States, including those administered by the Office of Foreign Assets Control of the U.S. Department of the Treasury or the Bureau of Industry and Security of the U.S. Department of Commerce, (b) the European Union, and (c) the Government of the United Kingdom) which would prohibit your registration, access, or participation in the event; and (ii) you are not located in, an agency or instrumentality of, owned or controlled by, acting for or on behalf of, or otherwise organized under the laws of or resident in a country or territory that is, or whose government is, the subject of economic sanctions that broadly prohibit dealings with that country or territory which would prohibit your registration, access, or participation in the event.  You acknowledge and agree that S&P Global has the right to immediately terminate all applicable services or remove you from any event, if S&P Global determines, in its sole discretion, that S&P Global is required to do so in order to comply with applicable law, or you have breached any of the representations or warranties in this paragraph.

3. Additional Product Specific Restrictions on Use

3.1 S&P Global Ratings.

Historical Ratings pursuant to SEC Rule 17g-7(b)

Historical S&P Global Ratings credit ratings in each class of credit rating for which S&P Global Ratings is registered as a Nationally Recognized Statistical Rating Organization ("NRSRO") is available at the Regulatory Tab (collectively, the "Ratings History") at www.spglobal.com/ratings. The Ratings History is made available free of charge subject to applicable time delays. It is intended that the availability of Ratings History on this Website will advance the Securities and Exchange Commission ("SEC") goal of fostering accountability and comparability among NRSROs with respect to issuer-paid credit ratings. As such, the Ratings History may be used to, inter alia, perform analysis comparing how different NRSROs perform in the class of credit ratings for which they are registered.

Ratings History may not be used or disseminated in a manner that would serve as a substitute for any S&P Global Ratings product or service for which a fee is charged. This restriction is not intended to prevent the use of the Ratings History in accordance with the SEC’s stated objectives for SEC Rule 17g-7(b).

Non-Historical Ratings

All ratings on this Website, excluding only the Ratings History, are referred to as "Non-Historical Ratings," regardless of their currency or date of issuance.

Except as expressly set forth below, you agree not to copy, reproduce, modify, create derivative works from, or store any Non-Historical Ratings, in whole or in part, from this Website or to display, perform, publish, distribute, transmit, broadcast or circulate any Non-Historical Ratings to anyone, or use any Non-Historical Ratings for any commercial purpose, without the express prior written consent of S&P Global Ratings. You may, (a) on an ad hoc basis, use individual Non-Historical Ratings in the ordinary course of securities disclosure activities and the drafting of transaction documents internally within your organization or publish, on a non-commercial basis, selected individual Non-Historical Ratings, and (b) only insofar as you are directly compelled by applicable law or regulation: (1) include credit ratings within a report required by that law or regulation and (2) deliver such report only to such regulator, or authority or government agency as is identified by that law or regulation and solely insofar as to meet your own obligations under that law or regulation and not for the benefit of another party.

Notwithstanding the foregoing, Non-Historical Ratings may not (i) be compiled into a database; (ii) be used or disseminated in a manner that would serve as a substitute for any S&P Global product or service for which a fee is charged; or (iii) be systematically distributed or shared.

Narrative and Other Content

You may also, on an occasional, ad hoc basis, reproduce, distribute, display or transmit an insubstantial portion of other narrative (non-ratings) content ("Narrative Content"), for a non-commercial purpose and without charge, to a limited number of individuals, provided you include all copyright and other proprietary rights notices and the S&P Global Ratings disclaimer with such portion of the Narrative Content in the same form in which the notices and disclaimer appear on the Website, the original source attribution, and the phrase "Used with permission from S&P Global Ratings." However, you may not post Narrative Content from this Website to forums, newsgroups, list serves, mailing lists, electronic bulletin boards, or other sites, without the prior written consent of S&P Global Ratings. To request consent for uses such as linking to Narrative Content or posting Narrative Content on your website, please contact S&P Global Ratings at ratings.request@spglobal.com.

Material that appears on this Website that is entered by you or other authorized users, or that is otherwise made accessible by other than S&P Global Ratings, is referred to as "Other Content." You may use Other Content in accordance with the terms set forth above relating to the use of Narrative Content.

Country Conditions and Qualified Institutional Investors

The terms and conditions set forth in this section (the “Country Conditions”) are the result of various regulatory and/or legal requirements relating to the usage of this Website including its Content.  Your use of this Website in the specified jurisdictions is subject to these Country Conditions.

Australia.  To the extent that S&P’s Global Ratings credit ratings (the “Ratings”) are included as part of any Content, S&P Global Ratings Australia Pty Limited (ABN 62 007 324 852), being the holder of Australian Financial Services License No. 337565 issued pursuant to the Corporations Act 2001 (Cth) (“SPA”), whose registered office is located at Level 45, 120 Collins Street, Melbourne Vic 3000 Australia, shall provide such portion of Content to you and SPA shall license you the right to use the intellectual property in such portion of the Content and, as owner of such intellectual property, shall receive any fees with respect thereto.  SPA expressly agrees to be bound by the terms and conditions of these Terms of Use to the extent it applies to the provision of the Ratings.  You accept and acknowledge that SPA’s provision of the Ratings to you through the Website is based on, and conditional on, the veracity and accuracy of your representation that you are a “Wholesale Client” (as such is defined in Chapter 7 of the Corporations Act of 2001 (Australia)).  In addition, you acknowledge that Ratings and/or related research licensed to you pursuant to these Terms of Use or an Agreement, as applicable, are not intended for, and should not be distributed to, any person other than a Wholesale Client (to the extent such distribution is permitted by an Agreement).  In furtherance of the foregoing, you undertake that (a) you will not pass on any Rating and/or related research to a party who is not a Wholesale Client and (b) that you will obtain the same undertaking from your own Wholesale Clients (to the extent such distribution is permitted by an Agreement).  S&P Global represents that it is authorized to bind SPA to the terms and conditions set forth in these Terms of Use to the extent such terms and conditions pertain to the provision of Ratings.

All countries located in Europe, the Middle East or Africa (“EMEA”).  In the event your use of the Ratings is in any country located in EMEA, you further acknowledge and agree to the following:  The Ratings shall not in any circumstances be used by you where, as part of an effort to sell securities to Retail Investors (as defined below), you use the Ratings: (a) to create a type of recommendation, (b) to create your own interpretation of the Ratings or (c) in some other form of “risk classification.”  For the purposes of these Terms of Use, “Retail Investor” shall mean an individual investor who buys and sells securities or other financial products for his/her personal account, and not for another company, individual or organization.

3.2 S&P Dow Jones Indices. Unless otherwise permitted, S&P Dow Jones Indices (“SPDJI”) data may be used solely for internal business purposes. You understand and agree that you shall not: (i) use the SPDJI data to create, issue, manage, sponsor or develop any financial products (including, without limitation, derivatives, funds, structured products or contracts for difference) or asset management where the price, return and/or performance of such product is based on or intended to track any index published by SPDJI including, without limitation, customized versions thereof, such as direct indexing; (ii) use the SPDJI data to create or develop indices, a classification system or historical databases; (iii) create any derived data based on the SPDJI data, except with SPDJI’s express written consent; (or) disclose, duplicate, display, redistribute, resell or otherwise convey the SPDJI data or any portion thereof internally within your organization except to other authorized end users of the relevant SPDJI services or externally to any third party.   

SPDJI licenses its indices for use with financial products and receives compensation in connection with such licensing.  SPDJI does not make any representation or warranty, express or implied, to the owners of such financial products or any member of the public regarding the advisability of investing in such financial products or the ability of SPDJI’s indices to track market performance.  SPDJI is not a fiduciary, investment advisor, commodity trading advisor, commodity pool operator or a broker dealer.  Inclusion of a security, commodity, cryptocurrency or other asset within an index is not a recommendation by SPDJI to buy, sell, or hold such security, commodity, cryptocurrency or other asset, nor is it considered to be investment advice or commodity trading advice.  The opinions, observations, and analysis of SPDJI included within this Website are statements of opinion as of the date they are expressed and not statements of fact or recommendations to purchase, hold, or sell any securities, other assets or make any investment decisions. SPDJI assumes no obligation to update any Content included within this Website following publication. Users of the Website should not rely on any of the Content in making any investment decision. SPDJI’s opinions, observations and analyses do not address the suitability of any security or other asset.  While SPDJI has obtained information from sources it believes to be reliable, SPDJI does not perform an audit and undertakes no duty of due diligence or independent verification of any information it receives. 

PERFORMANCE DISCLOSURE/BACK-TESTED DATA. All SPDJI Index information presented on the Website prior to an index’s Launch Date is hypothetical (back-tested), not actual performance. The back-test calculations are based on the same methodology that was in effect on the index Launch Date. However, when creating back-tested history for periods of market anomalies or other periods that do not reflect the general current market environment, index methodology rules may be relaxed to capture a large enough universe of securities to simulate the target market the index is designed to measure or strategy the index is designed to capture. For example, market capitalization and liquidity thresholds may be reduced. Complete index methodology details are available at www.spdji.com. Past performance of the Index is not an indication of future results. Back-tested performance reflects application of an index methodology and selection of index constituents with the benefit of hindsight and knowledge of factors that may have positively affected its performance, cannot account for all financial risk that may affect results and may be considered to reflect survivor/look ahead bias. Actual returns may differ significantly from, and be lower than, back-tested returns. Past performance is not an indication or guarantee of future results. Please refer to the methodology for the index for more details about the index, including the manner in which it is rebalanced, the timing of such rebalancing, criteria for additions and deletions, as well as all index calculations. Back-tested performance is for use with institutions only, not for use with retail investors.

SPDJI defines various dates to assist our clients in providing transparency. The First Value Date is the first day for which there is a calculated value (either live or back-tested) for a given index. The Base Date is the date at which the index is set to a fixed value for calculation purposes. The Launch Date designates the date when the values of an index are first considered live: index values provided for any date or time period prior to the index’s Launch Date are considered back-tested. SPDJI defines the Launch Date as the date by which the values of an index are known to have been released to the public, for example via the company’s public Website or its data feed to external parties. For Dow Jones-branded indices introduced prior to May 31, 2013, the “Launch Date” (which prior to May 31, 2013, was termed “Date of introduction”) is set at a date upon which no further changes were permitted to be made to the index methodology, but that may have been prior to the Index’s public release date.

Typically, when SPDJI creates back-tested index data, SPDJI uses actual historical constituent-level data (e.g., historical price, market capitalization, and corporate action data) in its calculations. As ESG investing is still in early stages of development, certain datapoints used to calculate S&P DJI’s ESG indices may not be available for the entire desired period of back-tested history. The same data availability issue could be true for other indices as well. In cases when actual data is not available for all relevant historical periods, SPDJI may employ a process of using “Backward Data Assumption” (or pulling back) of ESG data for the calculation of back-tested historical performance. “Backward Data Assumption” is a process that applies the earliest actual live data point available for an index constituent company to all prior historical instances in the index performance. For example, Backward Data Assumption inherently assumes that companies currently not involved in a specific business activity (also known as “product involvement”) were never involved historically and similarly also assumes that companies currently involved in a specific business activity were involved historically too. The Backward Data Assumption allows the hypothetical back-test to be extended over more historical years than would be feasible using only actual data. For more information on “Backward Data Assumption” please refer to the FAQ. The methodology and factsheets of any index that employs backward assumption in the back-tested history will explicitly state so. The methodology will include an Appendix with a table setting forth the specific data points and relevant time period for which backward projected data was used.

Index returns shown do not represent the results of actual trading of investable assets/securities. SPDJI maintains the index and calculates the index levels and performance shown or discussed but does not manage actual assets. Index returns do not reflect payment of any sales charges or fees an investor may pay to purchase the securities underlying the index or investment funds that are intended to track the performance of the index. The imposition of these fees and charges would cause actual and back-tested performance of the securities/fund to be lower than the Index performance shown. As a simple example, if an index returned 10% on a US $100,000 investment for a 12-month period (or US $10,000) and an actual asset-based fee of 1.5% was imposed at the end of the period on the investment plus accrued interest (or US $1,650), the net return would be 8.35% (or US $8,350) for the year. Over a three-year period, an annual 1.5% fee taken at year end with an assumed 10% return per year would result in a cumulative gross return of 33.10%, a total fee of US $5,375, and a cumulative net return of 27.2% (or US $27,200).

3.3 S&P Global ESG Scores. All Content contained in this Website is the exclusive property of S&P Global, or their third party licensors and may not be copied or reproduced in any form except with the prior written permission of S&P Global. The Content, including the ESG Scores and related materials have been published here solely for informational purposes based upon information generally available to the public and from sources believed to be reliable. S&P Global reserves the right to change a company’s ESG score from time to time, in accordance with its methodologies, policies and procedures. 

Unless explicitly permitted by S&P Global in writing, the Content or any portion thereof may not be (i) modified, reverse engineered, reproduced, or distributed in any form or by any means, or stored in a database or retrieval system, (ii) used to create any derivative works; (iii) used as the input value or the constituent for the creation, structuring, development, calculation, maintenance, publication, distribution or any other means to derive or establish a financial index or investment strategy; or (iv) used as a component of or as the basis for corporate financing (including, without limitation, ESG-linked loans, credit facilities) or used for any investment product or financial instrument to be developed, issued, traded, sold, marketed and/or promoted, including, without limitation, a security whose capital and/or income value is calculated based on changes in value of any index or any indexed fund based on the Content in whole or in part or passively managed funds.

S&P Global is committed to providing transparency to the market through high-quality independent opinions on sustainability. Safeguarding the quality, independence and integrity of S&P Global’s ESG Scores, including by identifying and managing potential conflicts of interest, is embedded in its culture and at the core of everything S&P Global does. S&P Global keeps certain activities of its business units separate from each other in order to preserve the independence and objectivity of their respective activities. As a result, certain business units of S&P Global may have information that is not available to other S&P Global units. S&P Global has established policies and procedures to maintain the confidentiality of certain non-public information received in connection with each analytical process.

3.4 Platts LIVE.

Platts LIVE is a is a virtual hub, created to enable our clients and market participants to engage with us, and each other in relation to markets and commodity insights.  Platts LIVE also contains the My LIVE functionality which allows users to post information publicly which can be viewed by, and to communicate via message with, other users of Platts LIVE. Platts LIVE is hosted by S&P Global.

Your Platts LIVE account

In order to access Platts LIVE, you must register for a user account. As part of the registration process, you must create a user account by selecting a username and password and providing S&P Global with accurate, complete, and current information. You must keep your password safe and secure. If you know or suspect anyone other than you knows your password, please change your password immediately. If you are accessing Platts LIVE within the scope of your employment, you are required to register using an email address containing your employer's domain name. Failure to do so constitutes a breach of these Terms of Use, which may result in immediate termination of your access to Platts LIVE. S&P Global may suspend, invalidate or terminate any user account, at any time, where S&P Global has reason to believe that you have failed to comply with any of the provisions of these Terms of Use.

User-generated content is not approved by S&P

Platts LIVE may include information and materials uploaded by other users of Platts LIVE, including to social media pages, video-sharing sites, bulletin boards and chat rooms. This information and these materials have not been verified or approved by us. The views expressed by other users on our site do not represent S&P Global views or values. See also the section on Third Party Content below.

Your Content

Subject to these Terms of Use and applicable law, you acknowledge and agree that you are responsible for any content you post or distribute via Platts LIVE and any consequences that arise out of the posting or distribution of such content. TO THE EXTENT PERMITTED BY APPLICABLE LAW NEITHER S&P GLOBAL NOR ANY S&P GLOBAL AFFILIATE IS RESPONSIBLE FOR THE CONSEQUENCES OF POSTING OR DISTRIBUTING ANY PERSONAL OR OTHER INFORMATION VIA PLATTS LIVE. Your Content will be considered non-confidential and non-proprietary. As between you and S&P Global, you own the intellectual property rights in Your Content that you create and share on Platts LIVE, but you are required to grant us a limited licence to use, store and copy that content and to distribute and make it available to third parties. Subject to applicable laws, regulations and court orders, you have the right to remove any of Your Content from Platts LIVE. To do so, please Contact Us or, to the extent the functionality is available on Platts LIVE, by deleting your profile (go to the Profile tab in Platts LIVE and click on ‘Unsubscribe’), and/or by clicking on ’Delete’ next to your post on Platts LIVE to delete that specific post. Subject to applicable laws, regulations and court orders, your removal of Your Content from publicly displaying on Platts LIVE may not result in the deletion of all of Your Content from Platts LIVE’s systems or backup files. We also have the right to remove Your Content if, in our opinion, your post does not comply with the acceptable use standards set out in these Terms of Use, and to disclose Your Content to any legal or regulatory authority.

Acceptable use of Platts LIVE

You shall not utilize Platts LIVE to post or distribute any content that contains explicit or graphic descriptions or accounts of sexual acts or that is threatening, misleading, discriminatory, inaccurate, untrue, abusive, harassing, defamatory, libelous, deceptive, racist, fraudulent, invasive of another person's privacy, infringing, tortious or that contains unsubstantiated rumors or misrepresentations. You shall not post or distribute any content via Platts LIVE unless you own such content or otherwise have obtained the right to post or distribute such content. You shall not transmit junk mail, chain letters, spam or unsolicited mailings via Platts LIVE and shall not use Platts LIVE to transmit instructions regarding illegal activities. You may not input or distribute any material through Platts LIVE that is promotional in nature, including solicitations for funds or business.

We are not responsible for Third Party Content on Platts LIVE

Platts LIVE may contain Third Party Content (as defined below in section 16). S&P Global has no responsibility or liability with respect to the Third Party Content. You acknowledge that S&P Global has no responsibility for verifying the accuracy or timeliness of any Third Party Content.  You acknowledge and agree that whilst S&P Global or any S&P Global affiliate may monitor the content posted or distributed via Platts LIVE, you are solely responsible for verifying the accuracy of all Third Party Content posted or distributed via Platts LIVE.  If you become aware of any violation of these Terms of Use by a third party, you shall promptly notify S&P Global. You may also, through hypertext or other computer links, gain access to websites operated by persons other than S&P Global. Such hyperlinks are provided for your reference and convenience only, and are the exclusive responsibility of such websites' owners. You agree that S&P Global is not responsible for the content or operation of such websites, and that S&P Global shall have no liability to you or any other person or entity for the use of third party websites. Except as described below, a hyperlink from Platts LIVE to another website does not imply or mean that S&P Global endorses the content on that website or the operator or operations of that site. You solely are responsible for determining the extent to which you may use any content at any other websites to which you link from Platts LIVE.

How to complain about or report content

S&P Global encourages you to report any content (including any Third Party Content) that is illegal or violates any of the terms of these Terms of Use by email to SPGCIlegalnotices@spglobal.com .

Events on Platts LIVE

Where online events are accessed by you through Platts LIVE, such online events are hosted by a third party vendor, ON24. S&P Global retains no responsibility or liability to you or any third party for the availability of any online event, nor does it have any responsibility or liability to you or any third party for the security of any online event.  Where you register for an event that is being streamed through Platts LIVE, via ON24, you will additionally be required to register for a Platts LIVE account (if you have not already done so) in order to attend the event. During such an event, you understand that Platts LIVE may be used for networking among the event attendees and the fact of your attendance may be recorded, and the recording of the event may be published on Platts LIVE after the event. For the avoidance of doubt, all registered members of Platts LIVE, whether they attended the event or not, are able to similarly network after the event and you may be contacted by any member of Platts LIVE via Platts LIVE. You are able to delete your Platts LIVE account after the event. However, deletion of your Platts LIVE account will not remove any record of the fact of your attendance at the event.

Your personal data

We process your personal data in connection with Platts LIVE in accordance with our S&P Global Privacy Policy. Your attention is specifically drawn to the Platts LIVE Privacy Statement section.

3.5 CUSIP. The CUSIP information made available on this Website (the "CUSIP Database") consists of security identifiers and related descriptive information and is protected under copyright laws and is licensed with permission from CUSIP Global Services ("CGS"), on behalf of the American Bankers Association ("ABA").

User agrees and acknowledges that the CUSIP Database and the information contained therein is and shall remain valuable intellectual property owned by, or licensed to, CGS and the ABA, and that no proprietary rights are being transferred to User in such materials or in any of the information contained therein.

User agrees that User shall not publish or distribute in any medium the CUSIP Database or any information contained therein or summaries or subsets thereof to any person or entity except in connection with the normal clearing and settlement of security transactions. Any use by User outside of the clearing and settlement of transactions may require a license from CGS, and a possible fee. User agrees that misappropriation or misuse of such materials will cause serious damage to CGS and ABA, and that in such event money damages may not constitute sufficient compensation to CGS and ABA; consequently, User agrees that in the event of any misappropriation or misuse, CGS and ABA shall have the right to obtain injunctive relief in addition to any other legal or financial remedies to which CGS and ABA may be entitled.

User further agrees that the use of CUSIP numbers and descriptions is not intended to create or maintain, and does not serve the purpose of the creation or maintenance of, a master file or database of CUSIP descriptions or numbers for itself or any third party recipient of such service (even if in connection with the clearing and settlement of transactions) and is not intended to create and does not serve in any way as a substitute for the CUSIP MASTER FILE, DB, INTERNET, ELECTRONIC Services and/or any other future services developed by CGS .

4. Modification of Website and Content

This Website and Content are subject to modification by S&P Global to reflect statistical, technical, administrative, market based or similar changes that S&P Global determines in good faith are required or desirable. S&P Global also may make changes to any Content offered on this Website, or to the applicable prices for such Content, at any time, without notice.

5. No Advice

Any Content relating to financial information is intended only for professionals in the financial markets and is not, and should not be construed as financial, legal or other advice of any kind, nor should it be regarded as an offer or as a solicitation of an offer to buy, sell or otherwise deal in any investment. You may not use the Content in, or generate based on the Content, any advice, recommendations, guidance, publications or alerts made available to your clients or other third parties. Nothing in the Content constitutes a solicitation by S&P Global of the purchase or sale of loans, securities or any investment.

A REFERENCE TO A PARTICULAR INVESTMENT, SECURITY, RATING OR ANY OBSERVATION CONCERNING A SECURITY OR INVESTMENT PROVIDED IN THE S&P GLOBAL INFORMATION IS NOT A RECOMMENDATION TO BUY, SELL OR HOLD SUCH INVESTMENT OR SECURITY OR MAKE ANY OTHER INVESTMENT DECISIONS AND DOES NOT ADDRESS THE SUITABILITY OF ANY INVESTMENT OR SECURITY.  NO USER OF THE S&P GLOBAL INFORMATION SHOULD RELY ON ANY INDEX, BENCHMARK, PRICE ASSESSMENT, OBSERVATION, OPINION OR OTHER INFORMATION CONTAINED IN THE S&P GLOBAL INFORMATION IN MAKING ANY INVESTMENT OR OTHER DECISION.  THE S&P GLOBAL INFORMATION IS NOT A SUBSTITUTE FOR THE SKILL, JUDGMENT AND EXPERIENCE OF SUBSCRIBER, ITS MANAGEMENT, EMPLOYEES, ADVISORS AND/OR CLIENTS IN MAKING INVESTMENT AND OTHER BUSINESS DECISIONS.

6. Delivery and Security

You shall solely be responsible for any and all necessary equipment and connections from your own computer systems to the S&P Global systems that will allow for access to this Website and delivery of the Content. S&P Global shall have no responsibility for any such equipment or connections. You shall ensure that you have implemented security systems and procedures to prevent the unauthorized access to or misuse or disruption of this Website or Content.

7. Intellectual Property

The ownership and intellectual property rights of this Website including all Content, models, software, information, data, documentation, computer programs, systems, customizations, enhancements thereto, and the design, structure, selection, coordination, expression "look and feel" and arrangement of the Content, and enhancements, modifications or additional Content thereto shall be the sole and exclusive property of S&P Global (or the relevant affiliate of S&P Global or Data Provider (as defined below), as the case may be) and you shall not: (i) copy such material for any purpose (including by reverse engineering) or disclose it to any third party for any purpose whatsoever; (ii) by act or omission infringe upon S&P Global's intellectual property rights in this Website or Content. You acknowledge that this Website, was developed, compiled, prepared, revised, selected and arranged by S&P Global and others (including certain third party information sources (each a "Data Provider")) through the application of methods and standards of judgment developed and applied through the expenditure of substantial time, effort and money, and constitute valuable intellectual property and trade secrets of S&P Global or such relevant Data Provider.

You hereby agree to use commercially reasonable efforts to protect the proprietary rights of S&P Global or the relevant Data Provider in this Website and Content. You irrevocably agree and acknowledge that, as between you and S&P Global, this Website and Content, as may be amended from time to time, is the sole and exclusive property of S&P Global, and shall not be considered works for hire. You shall honor and comply with all reasonable written requests made by S&P Global to protect its contractual, statutory and common law rights in this Website and Content. You agree to notify S&P Global in writing promptly upon becoming aware of any unauthorized use of this Website or Content or any claim that any or all of this Website or Content infringes upon or constitutes any unlawful use of any copyright, database right, trademark, or other proprietary, intellectual property, contractual, statutory or common law rights of a third party.

Trademarks. You shall not use any of S&P Global's trademarks, trade names or service marks in any manner, and in no event in a manner accessible by or available to any third party. You acknowledge that you have no ownership or license rights in or to any of these names or marks.

Copyright. This Website and Content is protected as a collective work or compilation under UK copyright, U.S. copyright and other laws and treaties. All data, information, articles, columns and other elements making up the Content are copyrighted works and S&P Global hereby reserves all rights.

Copyright Infringement Claims. We respect the intellectual property rights of others, and require that the people who use this Website do the same. If you believe that your work has been copied in a way that constitutes copyright infringement, please forward the following information to S&P Global's Copyright Agent, designated as such pursuant to the Digital Millennium Copyright Act, 17 U.S.C. § 512(c)(2) (the "DMCA"), named below:

• Your address, telephone number, and email address;
• A description of the copyrighted work that you claim has been infringed;
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Copyright Agent:
S&P Global
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Attention: Legal Department
legal@spglobal.com

8. Privacy Policy

For information related to how S&P Global processes personal information or uses cookies and similar technologies, please visit our Privacy Policy and Cookie Notice pages.

9. Links to Third Party Websites

This Website may contain links to websites of third parties. These links are provided to you as a convenience, and S&P Global is not responsible for the content of any linked website. In addition, a link to any non-S&P Global website does not imply that S&P Global endorses or accepts any responsibility for the content or use of such a website.

10. Other S&P Global Services

S&P Global may provide you with access to S&P Global services through links and/or dedicated frames (collectively, "Other S&P Global Services") from this Website. For example, you may have access to a Toolbar provided by our Markit Hub service that allows you, amongst other things, to navigate data and content on both S&P Global and third party Websites.

Your use of Other S&P Global Services shall be governed by any applicable terms of use and privacy policies. We recommend you review those before using Other S&P Global Services.

11. Log-in

You acknowledge that log-on access codes and passwords that are provided to you are for your use only and may not be shared. You shall ensure that your log-on access code and password is kept confidential. You agree to accept sole responsibility for the use and protection of the log-on access codes and passwords provided to you, including protecting the confidentiality of such passwords. You shall use commercially reasonable efforts to prohibit or cease any unauthorized access to this Website or Content.

12. Disclaimer of Warranties and Limitation of Liability

THIS WEBSITE AND CONTENT PROVIDED TO YOU BY S&P GLOBAL SHALL BE ON "AS IS" BASIS. NEITHER S&P GLOBAL, ITS AFFILIATES NOR ANY DATA PROVIDER MAKE ANY WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS OR COMPLETENESS OF THIS WEBSITE OR CONTENT OR AS TO THE RESULTS TO BE ATTAINED BY YOU OR OTHERS FROM THE USE OF THE CONTENT. YOU HEREBY ACKNOWLEDGE THAT THERE ARE NO EXPRESS OR IMPLIED WARRANTIES OF TITLE, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE, AND THAT IT HAS NOT RELIED UPON ANY WARRANTY, GUARANTY OR REPRESENTATION MADE BY S&P GLOBAL, ITS AFFILIATES OR ANY DATA PROVIDER, EXCEPT THE REPRESENTATIONS MADE BY S&P GLOBAL SPECIFICALLY SET FORTH IN THIS TERMS OF USE.

NO LIABILITY. NEITHER S&P GLOBAL, ITS AFFILIATES NOR ANY DATA PROVIDER SHALL IN ANY WAY BE LIABLE TO YOU OR ANY CLIENT OF YOU FOR ANY INACCURACIES, ERRORS OR OMISSIONS, REGARDLESS OF CAUSE, IN THE CONTENT PROVIDED HEREUNDER OR FOR ANY DAMAGES (WHETHER DIRECT OR INDIRECT) RESULTING THEREFROM. WITHOUT LIMITING THE FOREGOING, S&P GLOBAL SHALL HAVE NO LIABILITY WHATSOEVER TO YOU, WHETHER IN CONTRACT (INCLUDING UNDER AN INDEMNITY), IN TORT (INCLUDING NEGLIGENCE), UNDER A WARRANTY, UNDER STATUTE OR OTHERWISE, IN RESPECT OF ANY LOSS OR DAMAGE SUFFERED BY YOU AS A RESULT OF OR IN CONNECTION WITH ANY OPINIONS, RECOMMENDATIONS, FORECASTS, JUDGMENTS, OR ANY OTHER CONCLUSIONS, OR ANY COURSE OF ACTION DETERMINED, BY YOU OR ANY CLIENT OF YOU, WHETHER OR NOT BASED ON THIS WEBSITE OR CONTENT.

TO THE FULLEST EXTENT PERMITTED BY LAW, UNDER NO CIRCUMSTANCES WILL S&P GLOBAL, ITS AFFILIATES OR ANY DATA PROVIDER HAVE ANY LIABILITY TO YOU OR ANY THIRD PARTY ACCESSING THIS WEBSITE AND/ OR THE CONTENT THROUGH YOU, ARISING FROM CONTRACT (INCLUDING UNDER ANY INDEMNITY), IN TORT (INCLUDING NEGLIGENCE), UNDER ANY WARRANTY (EXPRESS OR IMPLIED) UNDER STATUTE OR OTHERWISE, IN EACH CASE FOR ANY DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, PUNITIVE, OR EXEMPLARY DAMAGES WITH RESPECT TO THE SUBJECT MATTER OF THE TERMS OF USE, THE CONTENT AND / OR THIS WEBSITE, INCLUDING, BUT NOT LIMITED TO, IN RESPECT OF ANY LOSS OF PROFITS, LOSS OF REVENUE, LOST BUSINESS, LOSS OF OPPORTUNITY REGARDLESS OF WHETHER SUCH DAMAGES COULD HAVE BEEN FORESEEN OR PREVENTED OR ADVISED TO S&P GLOBAL.  The Content contains certain statements, estimates and financial and operating information ("Estimates") that constitute forward-looking statements or information. Forward-looking statements or information may be identified by using the words "targets", "believes", "estimates", "expects", "aims", "intends", "will", "can", "may", "anticipates", "would", "should", "could" and similar expressions in such statements or the negative thereof. These forward-looking statements or information involve known and unknown risks and uncertainties that could cause actual outcomes and results to be materially different from the Estimates or results implied or expressed in such forward-looking statements. While in some cases presented with numerical specificity, the Estimates are based upon (i) certain assumptions that are inherently subject to significant business, economic, regulatory, environmental, seasonal, competitive uncertainties, contingencies and risks and (ii) assumptions with respect to future business decisions that are subject to change. For more information concerning the risks S&P Global faces, visitors to this website should refer to the "Risk Factors" contained in S&P Global’s filings with the United States Securities and Exchange Commission.

There can be no assurance that the Estimates or the underlying assumptions will be realized and that actual results of operations or future events will not be materially different from the Estimates. Under no circumstances should the inclusion of the Estimates be regarded as a representation, undertaking, warranty or prediction by S&P Global, or any other person with respect to the accuracy thereof or the accuracy of the underlying assumptions, or that S&P Global will achieve or is likely to achieve any particular results. S&P Global disclaims any intent or obligation to update publicly or to revise any of the Estimates, whether as a result of new information, future events or otherwise, except as required by law. Visitors to this website are cautioned that forward-looking statements or information are not guarantees of future performance and, accordingly, visitors are expressly cautioned not to put undue reliance on forward-looking statements or information due to the inherent uncertainty therein. Except as required by law, S&P Global undertakes no obligation to publicly release any update or revisions to these forward-looking statements to reflect events or circumstances after their time of publication.

S&P GLOBAL RATINGS’ CREDIT RATINGS AND PUBLICATIONS ARE NOT INTENDED FOR USE BY RETAIL INVESTORS AND IT WOULD BE RECKLESS FOR RETAIL INVESTORS TO CONSIDER S&P GLOBAL RATINGS OR PUBLICATIONS IN MAKING ANY INVESTMENT DECISION. IF IN DOUBT YOU SHOULD CONTACT YOUR FINANCIAL OR OTHER PROFESSIONAL ADVISER.

The ratings and credit related analyses of S&P Global Ratings and its affiliates and the observations contained in reports and articles published on this Website are statements of opinion as of the date they are expressed and not statements of fact or recommendations to purchase, hold, or sell any securities or make any investment decisions. S&P Global Ratings assumes no obligation to update any information following publication. Users of the information provided through this Website should not rely on any of it in making any investment decision. S&P Global Ratings’ opinions and analyses do not address the suitability of any security. S&P Global Ratings does not act as a fiduciary or an investment advisor. While S&P Global Ratings has obtained information from sources it believes to be reliable, S&P Global Ratings does not perform an audit and undertakes no duty of due diligence or independent verification of any information it receives. S&P Global Ratings keeps certain activities of its business units separate from each other in order to preserve the independence and objectivity of each of these activities. As a result, certain business units of S&P Global Ratings may have information that is not available to other S&P Global business units. S&P Global Ratings has established policies and procedures to maintain the confidentiality of certain non-public information received in connection with each analytical process.

The S&P Global Ratings business may receive compensation for assigning credit ratings or engaging in other analytical activities normally from issuers of the securities or third parties participating in marketing the securities. S&P Global Ratings reserves the right to disseminate its opinions and analyses. S&P Global Ratings’ public ratings and analyses are made available on its sites, www.spglobal.com/ratings (free of charge) and www.capitaliq.com (subscription), and may be distributed through other means, including via S&P Global publications and third party redistributors.

13. Indemnification

You will indemnify, defend and hold harmless S&P Global and its affiliates, directors, officers, agents, employees, successors, assigns and all Data Providers, and each of their affiliates, directors, officers, agents, employees, members, partners, successors and assigns ("S&P Global Indemnitees") from and against any and all losses, liabilities, damages, costs (including reasonable attorneys' fees) and expenses arising as a result of any claims, suits or proceedings (collectively, "Claims") brought by any third party against any S&P Global Indemnitees arising from your use of this Website and/or Content.

14. Violation of these Terms of Use

You agree that S&P Global may, in its sole discretion and without prior notice, terminate your access to this Website or certain Content and/or block your future access to this Website or certain Content if S&P Global determines that you have violated these Terms of Use or other agreements or guidelines which may be associated with your use of this Website. You also agree that any violation by you of these Terms of Use will constitute an unlawful and unfair business practice, and will cause irreparable harm to S&P Global, for which monetary damages would be inadequate, and you consent to S&P Global obtaining any injunctive or equitable relief that S&P Global deems necessary or appropriate in such circumstances. These remedies are in addition to any other remedies S&P Global may have at law or in equity.

You agree that S&P Global may, in its sole discretion and without prior notice, terminate your access to this Website, for cause, which includes (but is not limited to): (i) requests by law enforcement or other government agencies, (ii) a request by you (self-initiated account deletions), (iii) discontinuance or material modification of this Website or any service offered on or through this Website, or (iv) unexpected technical issues or problems.

If S&P Global does take any legal action against you as a result of your violation of these Terms of Use, S&P Global will be entitled to recover from you, and you agree to pay, all reasonable legal costs of such action, in addition to any other relief granted to S&P Global. You agree that S&P Global will not be liable to you or to any third party for termination of your access to this Website as a result of any violation of these Terms of Use.

15. General

Relationship between the Parties. There is no joint venture, partnership, agency or fiduciary relationship existing between you and S&P Global, and the parties do not intend to create any such relationship by this Terms of Use.

Invalidity. If any provision in or any part of this Terms of Use shall be found to be illegal or unenforceable under any enactment or rule of law then that provision or part shall to that extent be deemed not to form part of this Terms of Use and the remaining provisions shall continue in full force and effect.

Governing Law. Your access to and use of this Website are governed by and will be construed in accordance with laws of England and Wales, without regard to the principles of conflicts of laws of other jurisdictions. Each party submits to the exclusive jurisdiction of the courts residing in London, England, United Kingdom, for the purposes of determining any dispute arising out of the Terms of Use, its construction or the transactions contemplated by it.

16. Third Party Restrictions

In addition to the rights and restrictions set forth in agreement(s) that you have entered into with S&P Global, use of S&P Global services is subject to the additional following terms: (i) you may be required to enter into, or to comply with the terms of, a third-party licensor agreement, and (ii) you may receive such terms within the service itself or directly by the third-party licensor.

To the extent that you redistribute any third-party services, you must obtain all required approvals for control and redistribution of such third-party services. You are responsible for any and all costs and fees associated with agreements entered into with any such third-party licensor. If a third-party licensor ceases to make one or more of its services available to S&P Global, or requires S&P Global to suspend or terminate the provision of all or any part of its services to you, or if S&P Global terminates its arrangements with the third-party licensor, then S&P Global may suspend or terminate that part of its services immediately without notice or further obligation to you.

Content provided by third-parties ("Third Party Content") may contain: (i) restrictions, including without limitation, as to disclosure and use of the Third Party Content; and (ii) specific disclaimers with regard to such Third Party Content, including without limitation disclaimer for liability for inaccuracies, errors or omissions; which may be displayed in and shall apply to the Third Party Content.

Such Third Party Content is provided by other, non-S&P Global information providers and therefore S&P Global has no responsibility and makes no representations or warranties as to the accuracy, timeliness or completeness of the Third Party Content. S&P Global shall not be held liable for any loss or damage caused by the inaccuracies, errors or omissions, incomplete or late Third Party Content.

In order to provide the Services, we may be required to share certain information regarding our agreement with you, your use of the S&P Global services or Third Party Content or details of the S&P Global services or Third Party Content provided to you with such third-party licensor.

Please click on any of the following hyperlinks to see the additional terms and conditions imposed by the following third-party data providers regarding use of their data:

1. Fitch Ratings Ltd.
2. FTSE International
3. FTSE – RussellTick
4. Moody's Investors Service
5. Morgan Stanley Capital International
6. CME
7. Deutsche Boerse
8. Morningstar
9. Euronext
10. MSRB
11. Australian Financial Markets Association (AFMA)
12. Australian Securities Exchange (ASX)
13. China Exchanges Services Company (CESC)
14. Citigroup
15. Hang Seng Indices
16. Hedge Fund Research
17. London Stock Exchange (SEDOL)
18. Robo Global LLC
19. Sustainalytics
20. FactSet Research Systems, Inc
21. National Association of Insurance Commissioners (NAIC)
22. Trepp UK Limited
23. Thomson Reuters Municipal Market Data (MMD)
24. Intercontinental Exchange Group (ICE)
25. Econoday, Inc.
26. SONIA and SONIA Compounded Index
27. NATIONAL ASSOCIATION OF REALTORS®
28. IBOR Fallback Rates Data - BLOOMBERG
29. Federal Reserve Bank of New York - SOFR Data
30. European Central Bank
31. Bank of Japan - TONAR

16.1 Fitch Ratings Ltd. Ownership. Fitch Information (including but not limited to the collection and presentation of the information contained in any Database) is owned by or licensed to Fitch, and contains the valuable copyrighted and proprietary material of Fitch or its affiliates and licensors, and all rights in or to Fitch Information not granted to client are expressly reserved by Fitch and its affiliates and licensors.

Disclaimer. Although the Fitch Information is based upon information obtained from sources Fitch believes in good faith to be reliable, client acknowledges that Fitch does not represent, warrant or guarantee the accuracy, correctness, integrity, completeness or timeliness of any part of Fitch Information and expressly acknowledges Fitch's disclaimer that Fitch does not audit or verify accuracy of the information provided to it by issuers, their representatives, accountants and legal advisors and others. Fitch also does not represent, warrant or guarantee: (i) the design or performance of any part of the Fitch Information or any Fitch website, or (ii) that the Fitch Information or any Fitch web site will fulfill any of the client's particular purposes or needs. Fitch does not recommend the purchase or sale of securities, does not give opinions as to the value of securities and does not give investment advice. Fitch is not responsible for any credit, loan or investment decisions, damages or other losses resulting from use of the Fitch Information. Fitch shall not be responsible for any discrepancies that may exist between the database from the Fitch Information sent to client and corresponding data contained in Fitch's database after the time such database was sent to client. FITCH INFORMATION AND ACCESS TO AND USE OF ANY FITCH WEB SITE, IF APPLICABLE, IS PROVIDED "AS IS" AND ALL FAULTS AND THE ENTIRE RISK AS TO SATISFACTORY QUALITY, PERFORMANCE, ACCURACY AND EFFORT IS WITH SUBSCRIBER. FITCH DISCLAIMS ALL OTHER WARRANTIES OR CONDITIONS, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES OR CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND ABSENCE OF VIRUSES AND DAMAGING OR DISABLING CODE. FITCH SPECIFICALLY DISCLAIMS ANY WARRANTY OR REPRESENTATION THAT FITCH PRODUCT WILL MEET SUBSCRIBERS' REQUIREMENTS, THAT THE OPERATION OF FITCH PRODUCT AND/OR ITS USE WILL BE UNINTERRUPTED OR ERROR-FREE, THAT DEFECTS IN FITCH PRODUCT, IF ANY, WILL BE CORRECTABLE OR CORRECTED, OR THAT FITCH PRODUCT IS COMPATIBLE WITH ANY PARTICULAR PLATFORM.

16.2 FTSE International S&P Global is licensed by FTSE International Limited to publish certain FTSE Products (“Products”) and make them available to you. FTSE shall not be responsible for any error or omission in these Products. All copyright and database rights in these Products belong to FTSE or its licensors. Redistribution of the data comprising these Products is not permitted. You agree to comply with any restrictions or conditions imposed upon the use, access, or storage of the data as may be notified to you by FTSE or S&P Global and you may be required to enter into a separate agreement with FTSE or S&P Global. "FTSETM", "FT-SETM" and "FootsieTM" are trademarks of London Stock Exchange PLC and The Financial Times Limited and are used by FTSE International Limited under license.

16.3 FTSE - RussellTick You are required to enter into a separate license agreement (which may be subject to additional charges) with The Frank Russell Company (“Russell”) in order to access and/or use indices, index values, data or other information relating to or derived from any Russell index (“Data”) via the S&P Global services. Unless expressly permitted otherwise under your own written agreement with Russell, you may use the Data solely for your own internal business purposes (if you are a business) or individual purposes (if you are an individual), and you shall not, and shall not permit any third party to, do any of the following. To the extent there is a conflict between the Data usage rights and restrictions as set forth in your agreement with S&P Global and those set forth in your agreement with Russell, the terms of your agreement with Russell shall control:(a) copy, sell, license, distribute, transmit or duplicate the Data (or any part thereof) to any third party or to any person or other entity in your organization (unless such entity is expressly licensed under your agreement with S&P Global to receive such Data) in any form or by any means;(b) derive or create derivative works of, recalculate, combine with other data, or otherwise modify, the Data (except that you may reprocess Data and perform calculations using the Data for your own internal business use subject to the other restrictions herein), and/or distribute such derived, recalculated, combined or modified Data to any third party;(c) remove any copyright or other proprietary notice accompanying or incorporated into the Data;(d) use the Data for the purpose of:(i) creating and/or operating (whether for your own purposes or on behalf of any third party) any financial product, index, or service which seeks to match the performance of or whose capital and/or income value is related to other Data or any part thereof;(ii) creating and/or operating (whether for your own purposes or on behalf of any third party) any financial product, index, service the performance of which is linked to the performance of a third party's product, index or service which, in turn, seeks to match the performance of or whose capital and/or income value is related to the Data or any part thereof (and whether or not such third party is licensed by Russell to do so); or(iii) generally exploit the Data in a manner designed to benefit you or any third party (including the creating of any additional service).(e) make the Data available on any website or in an application, or to the public via the internet;(f) use the index trademarks in a generic way or as part of your name or the name of any associated company;(g) use the Data or index trademarks:(i) in a way that might cause confusion as to the person responsible for preparing or disseminating the Data;(ii) for any unlawful or illegal purpose in any jurisdiction; or (iii) for or in connection with any contracts for difference service, spread betting service or any other purpose related to betting or gaming;(h) use the Data on behalf of, or for the benefit of, anyone else; or(i) use the Data in any way or for any purpose that would require a separate license from Russell or a third party information provider.

You acknowledge that Russell and/or any relevant third party information providers are the owners of the intellectual property rights in the Data, and that the Data is provided subject to the terms of your agreement with S&P Global.

16.4 Moody's Investors Service Moody's© Copyright 2021, Moody's Investors Service, Inc. ("Moody's"). Moody's ratings ("Ratings") are proprietary to Moody's or its affiliates and are protected by copyright and other intellectual property laws. Ratings are licensed to Licensee by Moody's. RATINGS MAY NOT BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT MOODY'S PRIOR WRITTEN CONSENT.

Moody's® is a registered trademark.

All Data furnished by Moody's are proprietary to Moody's (or its licensors) and are so furnished at Moody's' request and for your exclusive use. No Data so furnished may be copied or otherwise reproduced, repackaged, further transmitted, transferred, disseminated, distributed, redistributed, sold, resold, leased, rented, licensed, sublicensed, altered, modified, adapted, or stored for subsequent use for any such purpose, in whole or in part, in any form or manner or by any means whatsoever, by you or any other person or entity, without Moody's' prior written consent.

All Data is provided "AS IS" without warranty of any kind, and MOODY'S (AND MOODY'S' LICENSORS AND SERVICE PROVIDERS), IN PARTICULAR, MAKE NO REPRESENTATION OR WARRANTY, EXPRESS OR IMPLIED, TO YOU OR ANY OTHER PERSON OR ENTITY AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY SUCH DATA. Under no circumstance shall Moody's, or its licensors or service providers, have any liability whatsoever to you or any other person or entity, or be liable for any indirect, special, consequential, incidental or compensatory damages resulting or relating to the use of, or inability to use, any of the Data.

16.5 Morgan Stanley Capital International, MSCI Inc. Copyright MSCI 2021. All Rights Reserved. Without prior written permission of MSCI, this information and any other MSCI intellectual property may only be used for your internal use, may not be reproduced or redisseminated in any form and may not be used to create any financial instruments or products or any indices. This information is provided on an "as is" basis, and the user of this information, assumes the entire risk of any use made of this information.

Neither MSCI nor any third party involved in or related to the computing or compiling of the data makes any express or implied warranties, representations or guarantees concerning the MSCI index-related data, and in no event will MSCI or any third party have any liability for any direct, indirect, special, punitive, consequential or any other damages (including lost profits) relating to any use of this information.

MSCI ESG Research LLC data (“MSCI Data”) was used by S&P Global in the selection process of companies included in the S&P Global MSCI ESG indices. MSCI does not in any way sponsor, support, promote or endorse the index. MSCI was not and is not involved in any way in the creation, calculation, maintenance or review of the index. For the avoidance of doubt, MSCI is not the benchmark “administrator” for, or a “contributor”, “submitter” or “supervised contributor” to, the index, and the MSCI Data is not considered a “contribution” or “submission” in relation to the index, as those terms may be defined in any rules, laws, regulations, legislation or international standards. MSCI Data is provided “AS IS” without warranty or liability and no copying or distribution is permitted. MSCI does not make any representation regarding the advisability of any investment or strategy and does not sponsor, promote, issue, sell or otherwise recommend or endorse any investment or strategy, including any financial products or strategies based on, tracking or otherwise utilizing any MSCI Data, models, analytics or other materials or information. Without limiting any of the foregoing, in no event shall MSCI have any liability for any direct, indirect, special, incidental, punitive, consequential (including, without limitation, lost profits) or any other damages in connection with the MSCI Data or the index.

16.6 CME OTC Information, including Real Time, Delayed and/or End of Day Information, may only be distributed to Subscribers that have executed a Subscriber Agreement. Subscribers accessing Information and/or OTC Information may not (i) distribute Information to third parties outside Subscriber's Group and (ii) OTC Information to any other entity including without limitation other entities within Subscriber's Group, except for: (i) Delayed Information (other than OTC Information), when available as a licensing option and subject to the conditions published by CME from time to time and provided also that Distributor reports to CME and pays the applicable delayed license, website, and user fees where applicable, and as outlined in the Schedule 4: Market Data Policies and the Schedule 5: Fee Schedule. This exception is solely for Information and is not applicable to OTC Information. (ii) Inclusion of Information (other than OTC Information) in Media Publications, subject to the conditions published by CME from time to time and provided also that the Distributor reports to CME and pays the applicable Media Redistribution Fee for Subscribers that redistribute Information. (iii) Communication of limited extracts of Information (other than OTC Information), subject to the conditions published by CME from time to time, and (iv) Public Internet Display, subject to Distributor meeting the applicable reporting and payment obligations specified in this Schedule, provided that all persons accessing Information (other than OTC Information) on web-hosted sites will be regarded as Subscribers of Distributor, except that they may not be allowed to redistribute Information (other than OTC Information) to third parties.

Inclusion of OTC Information in Media Publications or any other form of Media Redistribution is expressly prohibited. For the avoidance of doubt, please note that the foregoing subsections (i) through (iv) (the “Exceptions”) are applicable solely to Information, and the Exceptions are not applicable to OTC Information. Please reference Schedule 5: Fee Schedule for availability of any of the foregoing.

CME reserves all rights to determine whether any form of Information redistribution by Subscriber may be allowed, and reserves the right to change the foregoing policy at any time.

All uses of Information by Subscriber that are subject to reporting requirements as specified in this Schedule must be identified and measured with an approved Unit of Count and be subject to effective Internal Controls which record all authorized use and prevent (or identify and record) any unauthorized use.

Subscribers accessing Information, as defined below, may process Information with or without other data for the purpose of creating new original works, provided that:(i) Any works so created, which display, represent or recreate any item of Information (including any works from which Information may be reasonably be reverse-engineered) will be regarded as Information for the purposes of this Agreement and will be subject to applicable Fees.(ii) Subscriber must obtain prior permission from CME before using any element of Information to create or recalculate indices or any original work that does not include, display or recreate Information. These works will be considered derived works and will require licensing under separate agreement with CME. No use, creation or distribution of such works shall be permitted without CME's express approval which will include a separate license agreement (iii) CME may at its sole discretion deny permission or require Distributor to pay License Fees for each Subscriber granted the right to create or recalculate indices or any other work from Information, for use in derived works. (iv) CME hereby grants permission for the use of Information to create graphs and charts, where the underlying value of elements of Information cannot be identified or calculated (for example to compare percentage change in elements of Information with percentage change in other data.)Such use will not be considered derived works. No fees will apply to Subscribers where the Distributor provides this service.

Subscriber must not misrepresent Information or deface or remove any trademarks transmitted with Information.

Subscriber must not use Information for any illegal purpose. Subscriber must recognize all Intellectual Property Rights as acknowledged between Distributor and CME.

Subscriber must maintain all records and provide all information required by Distributor to meet Distributor's record-keeping, reporting and payment obligations to CME.

Subscriber must allow CME or any auditors acting on behalf of CME to audit Subscriber's records and use of Information.

Subject to applicable law, Subscriber shall obtain and provide any consent needed for CME or any auditors acting on behalf of CME to review and receive Personal Data, where necessary for the purposes of verifying or ensuring compliance with Distributor's obligations to CME.

In addition to any other remedy, Distributor may immediately suspend or terminate distribution of Information to Subscriber if Distributor has reason to suspect non-compliance with any of these terms of if Distributor is required to do so by CME for any reason.

CME GROUP MARKET DATA IS USED UNDER LICENSE AS A SOURCE OF INFORMATION FOR CERTAIN S&P GLOBAL PRODUCTS. CME GROUP HAS NO OTHER CONNECTION TO S&P GLOBAL PRODUCTS AND SERVICES AND DOES NOT SPONSOR, ENDORSE, RECOMMEND OR PROMOTE ANY S&P GLOBAL PRODUCTS OR SERVICES. CME GROUP HAS NO OBLIGATION OR LIABILITY IN CONNECTION WITH THE S&P GLOBAL PRODUCTS AND SERVICES. CME GROUP DOES NOT GUARANTEE THE ACCURACY AND/OR THE COMPLETENESS OF ANY MARKET DATA LICENSED TO S&P GLOBAL AND SHALL NOT HAVE ANY LIABILITY FOR ANY ERRORS, OMISSIONS, OR INTERRUPTIONS THEREIN. THERE ARE NO THIRD-PARTY BENEFICIARIES OF ANY AGREEMENTS OR ARRANGEMENTS BETWEEN CME GROUP AND S&P GLOBAL.

16.7 Deutsche Boerse Subscribers are permitted to exclusively use the Licensed Information internally; onward dissemination of Licensed Information by Subscribers to third parties without the express prior written approval by Deutsche Boerse AG is prohibited. The prohibition of the onward dissemination in the prior sentence does not apply if the Subscriber is simultaneously a Vendor.

16.8 Morningstar © 2021 Morningstar. All Rights Reserved. The information contained herein: (1) is proprietary to Morningstar and/or its content providers; (2) may not be copied or distributed; and (3) is not warranted to be accurate, complete or timely. Neither Morningstar nor its content providers are responsible for any damages or losses arising from any use of this information. Past performance is no guarantee of future results.

Select Fundamentals Content and Ownership Content, and Select ETF Prices (NYSE CTA Tape A and AMEX CTA Tape B) Provided by Morningstar, Inc.

© 2021 Morningstar. All Rights Reserved. The information, data, analyses and opinions (“Information”) contained herein: (1) include the proprietary information of Morningstar and its content providers; (2) may not be copied or redistributed except as specifically authorized; (3) do not constitute investment advice; (4) are provided solely for informational purposes; (5) are not warranted to be complete, accurate or timely; and (6) may be drawn from fund data published on various dates. Morningstar is not responsible for any trading decisions, damages or other losses related to the Information or its use. Please verify all of the Information before using it and don’t make any investment decision except upon the advice of a professional financial adviser. Past performance is no guarantee of future results. The value and income derived from investments may go down as well as up.

16.9 Euronext Redistribution of Euronext Information is prohibited without an individual license between you and Euronext. Powered by Euronext ©.

16.10 MSRB We are providing certain data supplied to us by the Municipal Securities Rulemaking Board (“The Service”) without warranties or representations and on an “as is” basis. We hereby disclaim all representations and warranties (express or implied), including, but not limited to, warranties or merchantability and fitness for a particular purpose regarding the service. You shall bear all risk, related costs and liability and be responsible for your use of the service. We assume no responsibility for the consequences of any intentional or unintentional error, omission, inaccuracy, incompleteness or untimeliness in or with respect to the service. The MRSB, its officers, directors, employees, agents, consultants and licensors shall not be liable or responsible to you or anyone else for any losses, injuries, damages, costs, expenses or claims caused by, arising out of or relating to the following: (a) acts, omissions, occurrences or contingencies beyond their control; (b) service interruptions or performance failures, such as those that result from the use of telecommunications facilities that are outside their control, including the internet; (c) negligence, gross negligence or willful misconduct in procuring, compiling interpreting, editing, writing, reporting or delivering any of the content and material; (d) lost, stolen, late, corrupted, misdirected, failed, incomplete or delayed transmissions by anyone using the Service including but not limited to, any technical malfunctions, human error, computer viruses, lost data transmissions, omissions, interruptions, deletions, defects, hyperlink failures or line failures of any telephone network, computer equipment, software or any combination thereof; (e) damage to your computer systems, equipment software, data or other tangible or intangible property resulting from or sustained in connection with your use of the Service; and/or (f) any disruption of business, lost sales or lost profits or any punitive, exemplary, indirect, special, incidental, or consequential damages associated or in connection with, resulting from or arising out of any use of the Service or the content and material in the Service. The MSRB and its officers, directors, employees, agents, consultants and licensors shall have no liability in tort, contract or otherwise (and as permitted by law product liability) to you or anyone else for any reason associated or in connection with, resulting from or arising out of your use of the Service. The MSRB, its officers, directors, employees, agents, consultants and licensors make, and have made, no recommendations regarding any of the securities or other investment vehicles identified, referred to or described in the Service. The Service is reproduced by permission of the MSRB under a non-exclusive limited license. The MSRB accepts no responsibility or liability for the accuracy of the reproduction of the Service or that such Service is current.

16.11 Australian Financial Markets Association (AFMA) The information is proprietary to AFMA and third parties. All rights are reserved. Clients may only use this information in accordance with the Subscriber Agreement. To the fullest extent permitted by law, AFMA provides the information ‘as is' and clients may not rely on it as being accurate or comprehensive. You should independently verify the accuracy and comprehensiveness of the information.

16.12 Australian Securities Exchange (ASX) Client hereby agrees to comply with any terms and conditions governing the use of any third party website or content accessed through the Service. Note that all clients must abide by the rules and requirements as per the ASX Market Information Product and Services Guide which can be found in the following link https://asxonline.com/marketinfo/product.shtm

16.13 China Exchanges Services Company (CESC) China Exchanges Services Company Limited (CESC) endeavors to ensure the accuracy and reliability of the information provided, but does not guarantee its accuracy and reliability and accept no liability (whether in tor or contract or otherwise) for any loss or damage arising from, any inaccuracy or omission or from any decision, action or non-action based on or in reliance upon the information provided.

CESC is not an investment advisor. Appropriate independent professional advice should be sought where necessary. All of the information, materials and data provided do not constitute any offer or invitation to make any kind of investment. Past performance is also not a guide to future performance and does not guarantee future results.

16.14 Citigroup You may not authorize or license the use of the index data and/or any of its constituent indexes as components or benchmarks of financial instruments, contracts, or securities, whether publicly or privately issued, bought or sold.

16.15 Hang Seng Indices The Data File referred to in this section is provided by Hang Seng Indexes Company Limited. Neither Hang Seng Indexes Company Limited nor any of its holding companies and subsidiaries nor S&P Global provides any warranties of any kind in relation to such Data File (including, without limitation, that the Data File is fit for a particular purpose) or accepts any responsibilities for its accuracy, completeness and/or consistency, or for any loss or damage whatsoever and howsoever suffered or incurred by any party, With the use of or the access to the Data File referred to in this section, the subscriber or any party irrevocably and unconditionally accepts and agrees to be bound by this disclaimer.

16.16 Hedge Fund Research Client Restriction on Usage/Distribution. Client's use of the HFR Indices is solely limited to internal usage only. No redistribution by any means is permitted by the client or client's group. Clients are strictly prohibited from any form of onward distribution of Hedge Fund Research Indices, up to and including any and all derivative works.

Additional Restrictions. Client will not (i) copy or manufacture the Index Dataset or any portion thereof for any use prohibited under this Agreement, (ii) translate, modify, adapt, enhance, decompile, disassemble, or reverse engineer the Index Dataset, except as to render the Index Dataset in a format compatible with the Licensee's software and to the extent permitted under applicable law despite this restriction, (iii) use the Index Dataset to create an index or populate any other commercial Database or index dataset, (iv) use the Index Dataset in the operation of its own data or index business, or (v) use the Index Dataset, Resultant Data and/or HFR trademarks, including HFR Index names, ticker symbols, or graphically representative HFR Index performance in any manner in association with products which are created as investable index products.

16.17 London Stock Exchange Customers wishing to store, extract, download and/or reproduce Stock Exchange Daily Official List (SEDOL) codes are required to sign a license agreement with the London Stock Exchange. The following exceptions apply:

Where the customer has stored or archived off SEDOL codes for regulatory purposes, as long as the customer can demonstrate that there are controls in place to ensure SEDOL codes that only named individuals can access that data for regulatory or regulatory support purposes, then all SEDOL codes within this database can be discounted.

Where a vendor is unable to control or permission the level of codes provided to the customer, codes which are not being processed, as defined above, may be discounted. In such cases, the vendor is required to provide to the London Stock Exchange lists of all customers that have the ability to access SEDOL codes and the London Stock Exchange will contact such customers to ascertain whether they are processing SEDOL codes. However, the customer would be expected to technically demonstrate to the London Stock Exchange that these discounted codes are being discarded and/or archived for regulatory purposes. Where SEDOL codes are being held, but not being processed (as per the definition above) because trading has officially ceased (for example, delisting or maturity date expired) in the security to which they relate, they can be discounted.

For further information, please refer to the SEDOL Masterfile Pricing and Policy Guidelines, or contact the London Stock Exchange SEDOL team: info: sedol@londonstockexchange.com

16.18 Robo Global LLC Copyright Robo Global LLC (“RG") 2021. All Rights Reserved. Without prior written permission of RG, this information and any other RG intellectual property may only be used for your internal use, may not be reproduced or redisseminated in any form and may not be used to create any financial instruments or products or any indices. This information is provided on an “as is” basis, and the user of this information assumes the entire risk of any use made of this information. Neither RG nor any third party involved in or related to the computing or compiling of the data makes any express or implied warranties, representations or guarantees concerning the RG index-related data, and in no event will RG or any third party have any liability for any direct, indirect, special, punitive, consequential or any other damages (including lost profits) relating to any use of this information.

16.19 Sustainalytics Part of this publication may contain Sustainalytics proprietary information that may not be reproduced, used, disseminated, modified nor published in any manner without the express written consent of Sustainalytics. NOTHING CONTAINED IN THIS PUBLICATION SHALL BE CONSTRUED AS TO MAKE A REPRESENTATION OR WARRANTY, EXPRESS OR IMPLIED, REGARDING THE MERCHANTABILITY, COMPLETENESS, ACCURACY OR FITNESS FOR A PARTICULAR PURPOSE. THE INFORMATION HEREIN IS PROVIDED SOLELY FOR INFORMATIONAL PURPOSES AND THEREFORE IS NOT AN OFFER TO BUY OR SELL A SECURITY. NEITHER SUSTAINALYTICS NOR ALL ITS THIRD-PARTY SUPPLIERS PROVIDE INVESTMENT ADVICE (AS DEFINED IN THE APPLICABLE JURISDICTION) OR ANY OTHER FORM OF (FINANCIAL) ADVICE AND NOTHING WITHIN THIS PUBLICATION/REPORT CONSTITUTES SUCH ADVICE. The information is provided “as is” and, therefore Sustainalytics assumes no responsibility for errors or omissions. Sustainalytics cannot be held liable for damage arising from the use of this publication or information contained herein in any manner whatsoever. Copyright © Sustainalytics 2021. All rights reserved.

Note, Customers hereby agree to comply with any terms and conditions governing the use of any third party Website or content accessed through the Service. Third party terms of use are available at: https://www.sustainalytics.com/third-party-terms-of-use.

16.20 FactSet Research Systems, Inc. Select Equity Ownership Content Provided by FactSet Research Systems, Inc. Underlying ownership data, Copyright © 2021 FactSet Research Systems Inc. All rights reserved.

16.21 National Association of Insurance Commissioners (NAIC). Certain Loan Ownership Data Provided by National Association of Insurance Commissioners (NAIC). Data Source: National Association of Insurance Commissioners, by permission. The NAIC does not endorse any analysis or conclusions based upon the use of its data.

16.22 Trepp UK Limited. Certain Collateralized Loan Obligation Data Provided by Trepp UK Limited. All rights reserved. Trepp provided data is “as is” without warranty of any kind and Trepp expressly disclaims the implied warranty of merchantability and fitness for any particular purpose.

16.23 Thomson Reuters Municipal Market Data (MMD). Select Municipal Market Data information provided by Thomson Reuters Municipal Market Data (MMD) Municipal Yield Curve and Early Read data provided by MMD. S&P Global reserves the right to remove MMD content for non-subscribers. Email clientservice@tm3.com or call 1-800-367-8251 for full MMD access. For more information see www.tm3.com.

16.24 Intercontinental Exchange Group (ICE). Select Treasuries information provided by Interactive Data Corporation, a wholly owned subsidiary of Intercontinental Exchange Group (ICE)

16.25 Econoday, Inc. Certain Basic U.S. and U.S. Treasuries Data provided by Econoday, Inc. Important legal notice: Econoday has attempted to verify the information contained in this calendar. However, any aspect of such info may change without notice. Econoday does not provide investment advice, and does not represent that any of the information or related analysis is accurate or complete at any time. © 2021 Econoday Inc. All rights reserved.

16.26 SONIA and SONIA Compounded Index are copyright the Bank of England. The trademarks “Bank of England” and “SONIA” are registered trademarks of the Bank of England. All Rights Reserved. The SONIA benchmark and SONIA Compounded Index include the proprietary information of the Bank of England and the data comprising the SONIA benchmark and SONIA Compounded Index may not be copied or distributed except as specifically authorized. The SONIA benchmark and SONIA Compounded Index are not intended to be relied upon as authoritative or taken in substitution for the exercise of judgment and do not constitute investment advice. The SONIA benchmark and SONIA Compounded Index are not, and should not be construed as, an offer, bid or solicitation in relation to any financial instrument. The Bank of England does not guarantee, and expressly disclaims any liability for, and makes no representations or warranties whether express or implied, as to the currency, accuracy, timeliness, completeness or fitness for any particular purpose of the SONIA benchmark or the SONIA Compounded Index. The Bank of England accepts no liability whatsoever for any loss (including, but not limited to any direct, indirect or consequential loss, whether or not such loss is foreseeable and whether or not the Bank of England has been appraised of the use to which the SONIA benchmark or SONIA Compounded Index will be put) howsoever arising from the use, the timeliness of delivery or the failure of delivery of the SONIA benchmark or SONIA Compounded Index.

16.27 NATIONAL ASSOCIATION OF REALTORS® Data used with the permission of the NATIONAL ASSOCIATION OF REALTORS®. Copyright 2021 NATIONAL ASSOCIATION OF REALTORS®. Such data shall not be redistributed in any way without permission of the NATIONAL ASSOCIATION OF REALTORS®. Information has been obtained by the NATIONAL ASSOCIATION OF REALTORS® from sources believed to be reliable. However, because of the possibility of human or mechanical error by the NATIONAL ASSOCIATION OF REALTORS® or others, NATIONAL ASSOCIATION OF REALTORS® does not guarantee the accuracy, adequacy, or completeness of any information and is not responsible for any errors or omissions or the results obtained from the use of such information and EXPRESSLY DISCLAIMS ALL WARRANTIES WITH REGARD TO THE DATA PROVIDED.

16.28 IBOR Fallback Rates Data - BLOOMBERG is a trademark and service mark of Bloomberg Finance L.P. ("BFLP"). ISDA is a trademark and service mark of the International Swaps and Derivatives Association, Inc. ("ISDA"). LIBOR® and ICE LIBOR® are trademarks of ICE Benchmark Administration Limited and/or its affiliates (collectively, “ICE”) and are used with permission under licence by ICE. Bloomberg Index Services Limited ("BISL" and, collectively with BFLP and their affiliates, "Bloomberg") maintains and calculates the ‘fallback’ data comprising the 'all in' fallback rates and their component parts, the adjusted ‘risk-free’ reference rates and the spread adjustment (collectively with any other data or information relating thereto or contained therein, the “Fallback Rates Data") under an engagement between BISL and ISDA. To the extent Bloomberg uses LIBOR in the determination of certain Fallback Rates Data, it does so under licence from ICE. None of Bloomberg, ISDA or, where applicable, ICE guarantees or makes any claim, prediction, warranty or representation whatsoever, express or implied, regarding the timeliness, accuracy, completeness of, or fitness for a particular purpose with respect to, the Fallback Rates Data and each shall have no liability in connection with the Fallback Rates Data. Without limiting the foregoing, to the fullest extent permitted by applicable law, none of Bloomberg, ISDA or, where applicable, ICE will be liable in contract or tort (including negligence), for breach of statutory duty or nuisance, or under antitrust laws, for misrepresentation or otherwise, in respect of any inaccuracies, errors, omissions, delays, failures, cessations or changes (material or otherwise) in the Fallback Rates Data, or for any damage, expense or other loss (whether direct or indirect) suffered by any person arising out of or in connection with the Fallback Rates Data or any reliance placed upon it by any person, and all implied terms, conditions and warranties, including, without limitation, as to quality, merchantability, fitness for purpose, title or non-infringement, in relation to the Fallback Rates Data, are hereby excluded. None of Bloomberg, ISDA or, where applicable, ICE makes any representations regarding whether the Fallback Rates Data would be appropriate for derivative or non-derivative financial instruments, including derivatives transacted outside of standard ISDA documentation and related protocols. Market participants are encouraged to consider and analyze the details of the Fallback Rates Data and determine independently whether they would be appropriate for any such use. Where Fallback Rates Data is used by IHS Markit as an input into: (i) a transaction, valuation, payment amount or settlement price and/or amount of an Approved Financial Product, or (ii) an index or benchmark, or constituents in any index or benchmark, and such Fallback Rates Data is disclosed by IHS Markit to you, you may only use it to identify how the Fallback Rates Data is used in connection with such use set out at (i) and (ii). “Approved Financial Product” means all financial products (created by any entity) incorporating or based upon ISDA Documentation for which the Fallback Rate(s) act as fallbacks as well as all other derivatives as well as cash security instruments, including, but not limited to, bonds, FRNs, loans and mortgages that have opted to use the Fallback Rate(s) as fallbacks in use cases not covered by ISDA Documentation. “ISDA Documentation” means standard documents produced and maintained by ISDA (such as the Supplement to the 2006 ISDA Definitions and related protocols) or instruments that incorporate such ISDA-maintained documents, including by exchange, clearing or other rule or reference.

Any other usage of any Fallback Rates Data (including pursuant to the usage terms referenced below) is prohibited without a separate agreement with Bloomberg in respect of such usage, unless otherwise agreed in writing.

For further information regarding the usage terms relating to the Fallback Rates Data, please refer to www.bloomberg.com/libor andhttps://assets.bbhub.io/professional/sites/27/ISDA-IBOR-Fallbacks-Web-Terms1.pdf (as may be updated from time to time).

16.29 Federal Reserve Bank of New York - SOFR Data Disclaimer: The Secured Overnight Financing Rate - SOFR, is subject to the Terms of Use posted at newyorkfed.org. The New York Fed is not responsible for publication of the SOFR rate by IHS Markit, does not sanction or endorse any particular republication, and has no liability for your use. For any republication of this data, you must include this Copyright notice: “SOFR © [year] Federal Reserve Bank of New York. Content from the New York Fed subject to the Terms of Use at newyorkfed.org.”

16.30 European Central Bank The euro short-term rate “€STR ©” is the copyright of the European Central Bank. Disclaimer: The euro short-term rate – €STR, and any re-publication thereof (the “rate”) and all other related data and information, including the compounded euro sort-term rate average rates and the compounded euro short-term rate index, (the “information”) are published by the European Central Bank (ECB) for public information purposes only. The ECB and the Eurosystem national central banks, in so far as they contribute to the euro short-term rate determination process, shall not be liable for any error or inaccuracy in the rate or the information, for any delay in updating the rate or the information, nor shall they be liable or responsible for any reliance on or use of or inability to use the rate on the information in any financial instrument, contract, trade or any other commercial activity or investment decision. The ECB makes no representations or warranties, express or implied as to the currency, accuracy, timeliness, completeness, merchantability, or fitness for purpose of the rate or the information. The ECB accepts no liability or responsibility for any loss, damage, expense or claim (including, but not limited to any direct, indirect or consequential loss, whether or not such loss is foreseeable and whether or not the ECB has been apprised of the use to which the rate or the information will be put), however arising, from reliance on, use of or inability to use the rate or the information.

This disclaimer is not intended to limit the ECB’s non-contractual liability in contravention of any requirement which accord with the general principles common to the laws of Member States or to exclude its liability for matters which cannot be excluded under such laws.

16.31 Bank of Japan - TONAR  The Tokyo Overnight Average Rate – TONAR, is the copyright of the Bank of Japan. Disclaimer: The Bank of Japan takes all reasonable measures to ensure the accuracy of the TONAR rate. However, the Bank of Japan assumes no responsibility for consequences arising in connection with the use of the TONAR rate.

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Last Updated: March 2022