Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Abrdn PLC
1 George Street
Edinburgh, EH2 2LL

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

BlackRock, Inc.
55 East 52nd Street
New York, NY 10055

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

BNP Paribas
16 Boulevard des Italiens
Paris, 75009

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Credit Suisse Group AG

Uetlibergstrasse 231
Zurich, 8070

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Danske Bank A/S

Holmens Kanal 2-12
Kobenhavn, 1092

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

HSBC Holdings PLC

8 Canada Square 42nd Floor
London, E14 5HQ

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Invesco Ltd.
Two Peachtree Pointe
1555 Peachtree St. N.E., Ste. 1800
Atlanta, GA 30309-2460

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

JPMorgan Chase & Co.

270 Park Avenue
New York, NY 10017

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Jupiter Fund Management PLC

The Zig Zag Building
70 Victoria Street
London, SW1E 6SQ

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Man Group PLC

Riverbank House
2 Swan Lane
London, EC4R 3AD

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

NatWest Group PLC

36 Saint Andrew Square
Edinburgh, EH2 2YB

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Nordea Bank Abp

Satamaradankatu 5
Helsinki, FI-00020

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Rathbones Group PLC

Belvedere
12 Booth Street
Manchester, M2 4AW

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Schroders PLC
1 London Wall Place
London, EC2Y 5AU

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Sumitomo Mitsui Trust Holdings, Inc.

1-4-1 Marunouchi Chiyoda-ku
Tokyo, 100-8233

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Svenska Handelsbanken AB
Kungstradgardsgatan 2
Stockholm, 106 70

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Swedbank AB
Landsvagen 40
Sundbyberg, 172 63

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

UBS Group AG
Bahnhofstrasse 45
Zurich, 8001

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Glenn Hegar Texas Comptroller of Public Accounts

March 16, 2022

Wells Fargo & Company

420 Montgomery Street
San Francisco, CA 94104

NOTICE

Your company may appear on the State of Texas’ list of financial companies that boycott
energy companies.

Such a listing will prohibit Texas governmental entities from investing in, and may
potentially require divestment from, your company; your company’s affiliates and
subsidiaries; or investment vehicles affiliated with your company, its affiliates or
subsidiaries.

Your Company may be presumed to be boycotting energy companies under Texas law if
you fail to timely respond to this request.

Re: Verification request regarding energy company boycott

To Whom It May Concern:

Pursuant to Texas Government Code Chapter 809, the Comptroller prepares and maintains a list
of financial companies that boycott energy companies. In maintaining the list, the Comptroller
may review and rely on publicly available information. Further, the Comptroller may request
written verification from a financial company that it does not boycott energy companies.

The Comptroller has determined you may be a financial company that boycotts energy
companies. Therefore, the Comptroller requests a written verification from your company. You
must complete and return answers to the questions enclosed with this letter.

A financial company that fails to provide a response to this request before the 61st day after
receipt is presumed to be boycotting energy companies. Texas law does not provide for
extension of this statutory deadline.

Send your company’s response to this verification request to the Texas Treasury Safekeeping
Trust Company, which prepares and maintains the listing on behalf of the Comptroller.

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 2 of 6

Texas Treasury Safekeeping Trust Company

Office of the General Counsel
Thomas Jefferson Rusk State Office Building
208 E. 10th St., 4th Floor
Austin, TX 78701
divestment@ttstc.texas.gov

If you have any questions, please contact the Trust Company at 512-463-4300 or
divestment@ttstc.texas.gov.

Sincerely,

Glenn Hegar
Comptroller of Public Accounts

Enclosure

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 3 of 6

TEXAS GOVERNMENT CODE

CHAPTER 809
VERIFICATION REQUEST

Introduction

The purpose of this verification request is to prepare and maintain a list of all financial
companies that boycott energy companies as set forth in Texas Government Code Chapter 809.
Pursuant to Texas Government Code Section 809.051, the Comptroller requests that your
company answer the following questions within 61 days of receipt. Your company’s failure to
respond to these questions will result in the presumption under Texas law that your company is
boycotting energy companies.

Your answers to the following questions must be complete and direct. If you cannot answer any
question in full, answer to the extent possible. Unless a term is defined, interpret a question
according to its common-sense meaning and in accordance with Texas Government Code
Chapter 809.

Your answers must be verified by an authorized representative of your company.

The Comptroller’s office is a governmental body subject to the Texas Public Information Act
(TPIA), Texas Government Code Chapter 552. The TPIA provides for disclosure of information
maintained by governmental bodies of the State of Texas unless an exception to disclosure is
available under the TPIA. Therefore, your answers to the following questions will be subject to
the TPIA and may be subject to public disclosure.

Definitions

Defined in Texas Government Code Section 809.001(1), “Boycott energy company” means,
without an ordinary business purpose, refusing to deal with, terminating business activities with
or otherwise taking any action that is intended to penalize, inflict economic harm on or limit
commercial relations with a company because the company:

(A) engages in the exploration, production, utilization, transportation, sale or manufacturing of

fossil fuel-based energy and does not commit or pledge to meet environmental standards
beyond applicable federal and state law; or

(B) does business with a company described by Paragraph (A).

For purposes of this verification request, note the statutory definition of “boycott energy
company” may apply even if your company maintains direct or indirect investments in fossil
fuel-based energy companies.

Defined in Texas Government Code Section 809.001(2), “Company” means a for-profit sole
proprietorship, organization, association, corporation, partnership, joint venture, limited
partnership, limited liability partnership or limited liability company, including a wholly owned

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 4 of 6

subsidiary, majority-owned subsidiary, parent company or affiliate of those entities or business

associations, that exists to make a profit.

Defined in Texas Government Code Section 809.001(4), “Financial company” means a

publicly traded financial services, banking or investment company.

As noted above, for purposes of all these questions, “company” includes subsidiaries, parent
companies and affiliates.

Questions – Annex 1

1. What is the name of your company? What is the ISIN for your company?

2. What is the name, title and mailing address for the person verifying the answers to these
questions on behalf of your company?

3. What is the name, title, mailing address, e-mail address and telephone number for the
person to whom the Comptroller may direct further communications regarding this
verification request?

4. Is your company publicly traded? On which securities exchange?

5. Does your company invest capital or loan capital to other people or entities? Does your
company invest capital or loan capital to other people or entities on behalf of
third parties?

6. Has your company committed or pledged to meet environmental standards beyond

applicable federal or state law? If so, to what environmental standards has your company
committed or pledged?

a. What is the name of the entity that established the environmental standards
beyond applicable federal or state law to which your company has committed or
pledged?

b. Are your company’s commitments or pledges to such environmental standards

mandatory for your company? If so, how are your company’s commitments or
pledges mandatory?

c. Who monitors your company’s commitments or pledges to such environmental

standards? How are your company’s commitments or pledges to such
environmental standards monitored?

d. What are the consequences for your company not fulfilling its commitments or
pledges to such environmental standards?

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 5 of 6

7. Does your company have a written policy, procedure or investment guideline restricting
or prohibiting investment in energy companies, including companies engaged in the
exploration, production, utilization, transportation, sale or manufacturing of fossil
fuel-based energy?

8. What is your company’s policy on banking, consumption, financing, investment,

underwriting or related activity pertaining to fossil fuel-based energy and fossil
fuel-based energy companies, including companies engaged in the exploration,
production, utilization, transportation, sale or manufacturing of fossil-fuel based energy?

9. How is your company’s chief executive officer, board of directors or other company
leadership involved in the development or monitoring of the company’s policies
pertaining to fossil fuel-based energy companies, including banking, consumption,
financing, investment, underwriting or related activity?

10. Applying Texas Government Code Chapter 809’s statutory definition of “boycott energy
company,” is your company boycotting energy companies as defined in Texas law?

Questions – Annex 2

Does your company offer for sale on an exchange securities of an investment company, mutual
fund, exchange-traded fund or other publicly traded security that has a written policy, procedure
or investment guideline restricting or prohibiting investment in energy companies, including
companies engaged in the exploration, production, utilization, transportation, sale or
manufacturing of fossil-fuel based energy?

If the answer is “yes,” please provide the following information in connection with each such
investment company, mutual fund, exchange-traded fund or other publicly traded security using
a format that can be viewed in Microsoft Excel. Append additional information as necessary.

Name of Issuer Name of Fund Ticker Name of

Symbol Exchange

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711

Verification request regarding energy company boycott
Page 6 of 6

Your company may provide further information to supplement answers to the foregoing
questions.

Please have an authorized representative of your company sign, date and return your company’s
response as soon as possible but not later than 61 days after receiving this verification request.

Failure to submit a timely response to this verification request may result in your company,
including its subsidiaries, parent companies and affiliates, appearing on the Texas list of
financial companies that boycott energy companies.

[End of document.]

Comptroller.Texas.Gov 512-463-4000

P.O. Box 13528 Toll Free: 1-800-531-5441, ext. 3-4000

Austin, Texas 78711-3528 Fax: 512-305-9711