WELLS FARGO ASSET MANAGEMENT (INTERNATIONAL) LLC

RTS 28 AND ARTICLE 65(6) DISCLOSURE

Wells Fargo Asset Management (International) LLC ("WFAM (International)"), as a discretionary portfolio manager authorised and regulated by the Financial Conduct Authority, has a duty to act and carry out activities in the best interests of clients when placing orders with venues or entities for execution that result from decisions by WFAM (International) to deal in financial instruments on behalf of its clients.

As part of WFAM (International)'s regulatory commitment and to increase transparency related to executing client orders, in accordance with MiFID II (Markets in Financial Instruments Directive 2014/65/EU) and Commission Delegated Regulation (2017/565) supplementing MiFID II, we are required to summarise and publish, on an annual basis, best execution information and data in order to enable our clients and the public to evaluate the quality of WFAM (International)'s execution practices.

In particular, WFAM (International) has identified and analysed the top 5 execution venues (as required under MiFID II Regulatory Technical Standard (RTS) 28) and the top 5 execution brokers (as required under MiFID Delegated Regulation Article 65(6)), in terms of trading volumes in the classes of financial instruments that WFAM (International) executes on behalf of clients, and provided information on the quality of execution obtained.

The analysis and reporting data in respect of ECM's RTS 28 and Article 65(6) disclosures can be found using the links on this page.

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© 2019 Wells Fargo Asset Management (WFAM) is the trade name for certain investment advisory/management firms owned by Wells Fargo & Company. These firms include but are not limited to Wells Capital Management Incorporated and Wells Fargo Funds Management, LLC. Certain products managed by WFAM entities are distributed by Wells Fargo Funds Distributor, LLC (a broker/dealer and Member FINRA). Associated with WFAM is Galliard Capital Management, Inc. (an investment advisor that is not part of the WFAM trade/GIPS firm).

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