RUSSELL INVESTMENT MANAGEMENT COMPANY

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1 RUSSELL INVESTMENT MANAGEMENT COMPANY Part of Russell Investments 1301 Second Avenue, 18 th Floor Seattle, WA March 19, 2015 The following Brochure Supplements provide information about the qualifications of Supervised Persons of Russell Investment Management Company ( RIMCo ). If you have any questions about the content of these Brochure Supplements, please contact or [email protected]. The information in these Brochure Supplements has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. RIMCo is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about RIMCo is also available on the SEC s website at

2 The following outlines the professional designations held by certain Supervised Persons of RIMCo and explains the minimum qualifications required for each designation. Chartered Financial Analyst (CFA) The Chartered Financial Analyst (CFA) designation is an international professional designation offered by CFA Institute (formerly AIMR) to financial analysts who complete a series of three examinations. To become a CFA Charterholder candidates must pass each of three six-hour exams, possess a bachelor's degree from an accredited institution (or have equivalent education or work experience) and have 48 months of qualified, professional work experience. CFA charter holders are also obligated to adhere to a strict code of ethics and standards governing their professional conduct. Chartered Alternative Investment Analyst (CAIA) Chartered Alternative Investment Analyst (CAIA) is a professional designation given out by the Chartered Alternative Investment Analyst Association to establish an educational standard for individuals that specialize in the area of alternative investments (such as hedge funds, venture capital, private equity and real estate investment). In order to receive the designation, individuals must have at least one year of professional experience, a U.S. bachelor's degree and must pass two levels of curriculum that include topics ranging from qualitative analysis, trading theories of alternative investments, to indexation and benchmarking. Chartered Accountant Chartered Accountants must be members of the Institute of Chartered Accountants in England and Wales (ICAEW). The Institute admits members, who become Chartered Accountants, only after passing examinations and undergoing a period of relevant work experience. The ICAEW requires that students complete 15 examinations as well as 450 days of relevant work experience. Once admitted, members are expected to comply with ethical guidelines and gain appropriate continuing professional development. Chartered Accountant is a UK recognized professional designation. Certified Public Accountant (CPA) In order to become a CPA in the United States, the candidate must sit for and pass the Uniform Certified Public Accountant Examination (Uniform CPA Exam), which is set by the American Institute of Certified Public Accountants (AICPA) and administered by the National Association of State Boards of Accountancy (NASBA). Eligibility to sit for the Uniform CPA Exam is determined by individual State Boards of Accountancy. Typically the requirement is a U.S. bachelor s degree which includes a minimum number of qualifying credit hours in accounting and business administration with an additional 1 year study. This requirement for 5 years study is known as the "150 hour rule" and has been adopted by the majority of state boards, although there are still some exceptions (e.g. California). This requirement mandating 150 hours of study has been adopted by 45 states.

3 Member Royal Institution of Chartered Surveyors (RICS) Member Royal Institution of Chartered Surveyors (RICS) is an international professional qualification in real estate encompassing at least 3 years of practical experience followed by an interview. Fellow of the Institute of Actuaries of Australia (F.I.A.A.) The FIAA qualification is recognized in many countries and is held in high esteem both within Australia and within the international actuarial community. Fellowship with the Institute is granted once a Member has either: been approved by Council for the qualification of Fellow of the Institute of Actuaries of Australia (FIAA) after having passed or been exempted from examinations of the Institute, satisfied twelve months practical experience in the field and completed a recognized professionalism course; or been approved by Council to transfer to the qualification of Fellow of the Institute of Actuaries of Australia (FIAA) after having completed the required experience of living and working in Australia (or, in certain cases, in either or both of Australia and New Zealand) as an Accredited Member. Society of Actuaries (SOA) The Society of Actuaries (SOA) is a professional organization for actuaries based in North America. It was founded in 1949 as the merger of two major actuarial organizations in the United States: the Actuarial Society of America and the American Institute of Actuaries. It is a full member organization of the International Actuarial Association. The Society's vision is for actuaries to be recognized as the leading professionals in the modeling and management of financial risk and contingent events. The SOA has three overall goals: providing primary and continuing education for students and practicing actuaries, maintaining high professional standards for actuaries, and conducting research on actuarial trends and public policy issues.

4 Item 1 Cover Page Janine Baldridge Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Janine Baldridge that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Janine Baldridge is available on the SEC s website at

5 Item 2- Educational Background and Business Experience Janine Baldridge Year of birth: 1957 B.A., Finance, University of Puget Sound 1979; CFA Charterholder, 1999, CAIA Charterholder, CAIA Association, to Present - Russell Investments Janine Baldridge is Managing Director, Alternatives Investment Practice for Russell Investments. She leads Russell s alternative investment strategy research and investment policy development for North American institutional clients. In addition, Janine advises large institutional funds on all aspects of their investment programs, including governance, investment policy, asset allocation, asset class strategy, manager selection, and risk management. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

6 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

7 Item 1 Cover Page James Barber Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about James Barber that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about James Barber is available on the SEC s website at

8 Item 2- Educational Background and Business Experience James Barber Year of birth: 1971 B.Sc., Economics and Statistics, University of Cape Town, MBA, University of Witwatersrand, CFA Charterholder, CFA Institute 2009 to Present - Russell Investments; 1999 to 2009 SEI Investments James Barber is Chief Investment Officer of equities for Russell Investments where he is accountable for the performance of the equity funds, the quality of the investment content, direct investment strategies, quantitative research, and investment manager recommendations within his asset class globally. James is located in Russell s head office in Seattle. He is a member of Russell s investment strategy committee. James was named to this role in September Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

9 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

10 Item 1 Cover Page Harold Bradford Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Harold Bradford that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Harold Bradford is available on the SEC s website at

11 Item 2- Educational Background and Business Experience Harold Bradford Year of birth: 1962 B.S., Applied Mathematics / Engineering, Auburn University 2012 to Present - Russell Investments; 2008 to Celanese Corporation Hal Bradford is a senior consultant for Russell Investments Americas institutional business. In his senior consultant role, Hal is responsible for providing advice to large institutional fund clients on investment policy and strategy, asset allocation, asset class structure, manager selection and performance measurement and analytics. His professional background includes over twenty years of consulting and plan sponsor experience in the areas of investments, actuarial and employee benefits. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

12 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

13 Item 1 Cover Page Ron Bundy Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Ron Bundy that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Ron Bundy is available on the SEC s website at

14 Item 2- Educational Background and Business Experience Ron Bundy Year of birth: 1964 B.A., Business & Economics, Western Washington University 1999 to Present - Russell Investments Ron Bundy is the CEO of the Russell Indexes division of Russell Investments. Ron serves on Russell s Executive Committee, and is a member of the Russell Global Council. He is responsible for all business activities related to Russell Indexes as well as Russell Investments data licensing business globally. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

15 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

16 Item 1 Cover Page Rachel Carroll Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Rachel Carroll that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Rachel Carroll is available on the SEC s website at

17 Item 2- Educational Background and Business Experience Rachel Carroll Year of birth: 1971 B.A., Economics, University of Washington; CFA Charterholder, CFA Institute 1993 to Present - Russell Investments Rachel Carroll is a Senior Consultant in Russell Investments Americas Institutional business. Rachel is a member of the consulting team that provides advice to endowments, foundations and corporate clients on all aspects of their investment programs, including governance, asset allocation, investment structure, manager selection, performance monitoring and implementation strategies. Rachel also serves as a media spokesperson for Russell. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

18 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

19 Item 1 Cover Page Christophe Caspar Rex House 10 Regent Street London SW1Y4PE Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Christophe Caspar that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Christophe Caspar is available on the SEC s website at

20 Item 2- Educational Background and Business Experience Christophe Caspar Year of birth: 1971 M. Sc., Management, École Supérieure de Commerce de Reims, France; Post-graduate Diploma, European Management, University of London; CFA Charterholder, CFA Institute 1999 to Present - Russell Investments Christophe Caspar is Chief Investment Officer, Multi-Asset Solutions and Chief Investment Officer Europe, Middle East, Africa for Russell Investments. Based in London, Christophe has primary responsibility for the oversight of all multi-asset and balanced funds managed by Russell Investments globally. Prior to taking this role in April 2009, he had primary responsibility for all investment management and research activities in the Asia-Pacific region, including Japan. He relocated to Japan in January 2006 as Chief Investment Officer, Japan, before his role expanded to the Asia-Pacific region in March Christophe also serves as a member of Russell's Investment Strategy Committee and is a member of Russell s Europe, Middle East and Africa executive committee. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The

21 Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

22 Item 1 Cover Page Sandra Cavanaugh Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Sandra Cavanaugh that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Sandra Cavanaugh is available on the SEC s website at

23 Item 2- Educational Background and Business Experience Sandra Cavanaugh Year of birth: 1954 B.A., History, Minor Finance, California State University, Fresno; California State Polytechnic University 2010 to Present - Russell Investments; 2009 to SunTrust Bank; 1997 to JPMorgan Chase / Washington Mutual Sandra Cavanaugh is a Director for RIMCo. She is also Chief Executive Officer of Russell Investments U.S. Private Client Services business. In this role Sandy serves as a member of Russell s Executive Committee and Global Leadership Forum. She is the senior-most executive with regard to setting Russell s strategic direction affecting all intermediary relationships, including the bank, brokerage, insurance and other advisory channels. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

24 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

25 Item 1 Cover Page Peter Choi Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Peter Choi that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Peter Choi is available on the SEC s website at

26 Item 2- Educational Background and Business Experience Peter Choi Year of birth: 1982 B.A., Mathematics and Economics, State University of New York at Geneseo; M.A., Mathematics of Finance, Columbia University 2013 to Present - Russell Investments; 2011 to Swiss Re; 2009 to JPMorgan Chase; 2004 to Deloitte Peter Choi is an Implementation Portfolio Manager in the Investment Division at Russell Investments. He is responsible for trade implementation and cash management for Russell s Fixed Income Funds. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

27 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

28 Item 1 Cover Page Josh Cohen 71 South Wacker Drive Suite 2040 Chicago, IL Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Josh Cohen that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Josh Cohen is available on the SEC s website at

29 Item 2- Educational Background and Business Experience Josh Cohen Year of birth: 1974 B.A., University of Michigan, 1995; M.B.A., University of Chicago Graduate School of Business, 2003; CFA Charterholder, CFA Institute, to Present - Russell Investments Josh Cohen is Managing Director, Head of Institutional Defined Contribution for Russell Investments. Josh is responsible for the leadership, strategic direction, and growth of Russell s U.S. institutional defined contribution (DC) business. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

30 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

31 Item 1 Cover Page Jon E. Eggins Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Jon E. Eggins that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Jon E. Eggins is available on the SEC s website at

32 Item 2- Educational Background and Business Experience Jon E. Eggins Year of birth: 1981 B.Commerce (1st class honours), Economics and Finance, University of New South Wales, Sydney, Australia, CFA Charterholder, CFA Institute 2003 to Present - Russell Investments Jon Eggins is a senior portfolio manager for Russell Investments, with primary responsibility for Russell s global equity and small cap funds. Jon is responsible for all aspects of the portfolio management process including manager selection, portfolio construction and continuous monitoring. Jon assumed portfolio management responsibilities for the US small cap funds in 2011, and for the Global equity funds in Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

33 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

34 Item 1 Cover Page Gerard Fitzpatrick Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Gerard Fitzpatrick that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Gerard Fitzpatrick is available on the SEC s website at

35 Item 2- Educational Background and Business Experience Gerard Fitzpatrick Year of birth: 1972 B.B.S. & M.A., Finance, Trinity College Dublin B.Sc, Financial Services, University of Manchester; CFA Charterholder, CFA Institute; Chartered Alternative Investment Analyst, CAIA Association Certified Financial Risk Manager; Global Association of Risk Pr 2007 to Present - Russell Investments; 2004 to West End Capital (Bermuda) Advisors Ltd.; 1999 to Bank of Bermuda Gerard Fitzpatrick is Russell s chief investment officer, fixed-income portfolios. Prior to this, Gerard was a portfolio manager on the fixed income team, responsible for the portfolio management of Russell s flagship Russell Strategic bond fund along with a range of other short, intermediate and long bond funds invested by both retail and institutional clients. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

36 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

37 Item 1 Cover Page Kristin Gaerttner Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Kristin Gaerttner that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Kristin Gaerttner is available on the SEC s website at

38 Item 2- Educational Background and Business Experience Kristin Gaerttner Year of birth: 1967 Attended Western Washington University ; General Securities Principal, Municipal Securities Principal and Registered Representative 2000 to Present - Russell Investments Kristin Gaerttner is Director, Americas Compliance for Russell Investments. Kristin has held various compliance manager and CCO positions within Russell and has worked with Russell s retail and institutional advisers and broker dealers. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

39 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

40 Item 1 Cover Page Adam Goff Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Adam Goff that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Adam Goff is available on the SEC s website at

41 Item 2- Educational Background and Business Experience Adam Goff Year of birth: 1968 B.A., Geography, Vassar College; M.A., International Studies Japan; Jackson School of International Studies, University of Washington; CFA Charterholder, CFA Institute 1995 to Present - Russell Investments Adam Goff is Managing Director, Asset Allocation and Portfolio Strategy for Russell Investments, leading the broad set of teams responsible for strategic and tactical forecasting and asset allocation as well as other capital markets research relevant to Russell s investment process. The output of these teams provides investment recommendations essential to Russell s research and portfolio management process. Adam is also a member of Russell's Investment Strategy Committee. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

42 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

43 Item 1 Cover Page John Greves Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about John Greves that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about John Greves is available on the SEC s website at

44 Item 2- Educational Background and Business Experience John Greves Year of birth: 1979 B.S., Computer Science and Business, University of Puget Sound; CFA Charterholder 2003 to Present - Russell Investments John Greves is a portfolio manager on the U.S. Multi-Asset Solutions team at Russell Investments. He is responsible for Russell s Target Date Funds and Adaptive Retirement Accounts. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

45 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

46 Item 1 Cover Page Scott Grimm Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Scott Grimm that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Scott Grimm is available on the SEC s website at

47 Item 2- Educational Background and Business Experience Scott Grimm Year of birth: 1966 B.A. University of Washington Concentration in Accounting (June 1989), CFA Charterholder, CFA Institute 1989 to present Russell Investments Scott Grimm is a consultant in Russell Investments Americas institutional business. Scott is a member of the team that provides advice to endowments, foundations, and corporate and public fund clients on all aspects of their investment programs including governance, asset allocation, investment structure, manager selection, performance monitoring, and implementation strategies. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

48 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

49 Item 1 Cover Page Marc Hewitt Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Marc Hewitt that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Marc Hewitt is available on the SEC s website at

50 Item 2- Educational Background and Business Experience Marc Hewitt Year of birth: 1977 Western Washington University; M.B.A., Finance, Katz Graduate Business School; University of Pittsburgh 2006 to Present - Russell Investments Marc Hewitt is a Portfolio Manager for Russell Investments, within the Portfolio Solutions team. Marc s primary responsibilities include performance and fund analytics, oversight of fund implementation with regards to daily rebalances, and developing the infrastructure capable of meeting the needs of clients internal and external to Russell. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

51 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

52 Item 1 Cover Page Catherine Higgins 1095 Avenue of the Americas 14th Floor New York, NY Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Catherine Higgins that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Catherine Higgins is available on the SEC s website at

53 Item 2- Educational Background and Business Experience Catherine Higgins Year of birth: 1942 B.A., Mathematics, University of Toronto; M.A., Mathematical Statistics, Columbia University; CFA Charterholder, CFA Institute 1997 to Present - Russell Investments Catherine Higgins is a Senior Consultant for Russell Investments Americas Institutional business. Catherine is responsible for providing advice to Russell s consulting clients on strategy, investment policy, asset class structure, manager selection and investment implementation. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

54 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

55 Item 1 Cover Page Jeff Hussey Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Jeff Hussey that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Jeff Hussey is available on the SEC s website at

56 Item 2- Educational Background and Business Experience Jeff Hussey Year of birth: 1969 B.S., Economics and Business (Finance emphasis), University of Puget Sound; M.S., Finance, Seattle University; CFA Charterholder, CFA Institute 1991 to Present - Russell Investments Jeff Hussey is Global Chief Investment Officer for Russell Investments, with responsibility for Russell's investment management, implementation and research activities worldwide. He has served in this role since August 2013 and is a member of Russell's Executive Committee. Prior to his current role, Jeff was Russell's chief investment officer of fixed income, where he was accountable for the performance of fixed-income funds, the quality of the investment content, and investment manager recommendations within this asset class globally. Jeff has had direct portfolio management responsibilities since 2001 for various Russell funds. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell

57 believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

58 Item 1 Cover Page James (Jim) Imhof Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about James (Jim) Imhof that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about James (Jim) Imhof is available on the SEC s website at

59 Item 2- Educational Background and Business Experience James (Jim) Imhof Year of birth: 1964 B.S., Finance, Central Washington University, CFA Charterholder, CFA Institute 1987 to Present - Russell Investments Jim Imhof is Managing Director of Global Trading for the Implementation Services Group for Russell Investments. Jim has managed the trading for Russell s investment division area since Jim is also a member of Russell's Investment Strategy Committee. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

60 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

61 Item 1 Cover Page Martin Jaugietis 1095 Avenue of the Americas, 14th Floor New York, NY Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Martin Jaugietis that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Martin Jaugietis is available on the SEC s website at

62 Item 2- Educational Background and Business Experience Martin Jaugietis Year of birth: 1974 B.Com. (honours), Finance, Australian National University; B.A., Political Science, Australian National University; CFA Charterholder, CFA Institute 2008 to Present - Russell Investments; 1998 to 2008 Towers Perrin Martin Jaugietis is Managing Director and Head of Liability Driven Investment (LDI) Solutions for Russell Investments Americas institutional business. In this position, Martin is responsible for shaping Russell s LDI offering across its institutional client base, providing business direction, thought leadership, and ensuring client satisfaction with Russell s results. Martin is chair of Russell s LDI steering committee which has accountability for its LDI research agenda, business plans, client investment portfolio positioning, and resourcing requirements. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

63 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

64 Item 1 Cover Page James (Jim) Jornlin Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about James (Jim) Jornlin that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about James (Jim) Jornlin is available on the SEC s website at

65 Item 2- Educational Background and Business Experience James (Jim) Jornlin Year of birth: 1961 B.A., Business and Finance, Washington State University, 1983; M.B.A., Finance and Investment, University of Chicago, 1990; CFA Charterholder, CFA Institute, to Present - Russell Investments Jim Jornlin is a Portfolio Manager for Russell Investments. He has worked in this capacity for Russell Investments since Since 2000, he has been specifically responsible for managing several of Russell s global equity strategies. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

66 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

67 Item 1 Cover Page Mark M. Klein Rex House 10 Regent Street London SW1Y4PE Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Mark M. Klein that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Mark M. Klein is available on the SEC s website at

68 Item 2- Educational Background and Business Experience Mark M. Klein Year of birth: 1965 No Advanced Degree present Russell Investments; , ; 1991 to 2008, Portfolio Manager BNY Mellon & Standish Mellon Mark Klein is a fixed income portfolio manager for Russell Investments, based in London. Mark has specialized in fixed income since 1994, with his expertise focused in Global fixed income portfolio management. During this period he has been responsible for the analysis, trading and management of several multi-currency fixed income investment portfolios and strategies. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

69 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

70 Item 1 Cover Page H. Victor (Vic) Leverett Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about H. Victor (Vic) Leverett that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about H. Victor (Vic) Leverett is available on the SEC s website at

71 Item 2- Educational Background and Business Experience H. Victor (Vic) Leverett Year of birth: 1965 B.A., Accounting, Washington State University 1988 to Present - Russell Investments Vic Leverett is Managing Director of Alternative Investments for Russell Investments. Vic manages Russell s hedge fund, listed real assets and private markets teams to ensure the investment integrity of portfolios. In addition he oversees portfolio management, manager research and risk management, he also coordinates the product strategy of alternative investments globally. Vic is a member of Russell s Investment Division s Investment Leadership Team, as well as Russell s Global Council. Vic also serves as a member of Russell's Investment Strategy Committee, as well as director of Russell s Cayman-domiciled fund and fund management companies. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

72 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

73 Item 1 Cover Page William (Bill) Madden 71 South Wacker Drive Suite 2040 Chicago, IL Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about William (Bill) Madden that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about William (Bill) Madden is available on the SEC s website at

74 Item 2- Educational Background and Business Experience William (Bill) Madden Year of birth: 1943 B.S. Physics, University of Portland, 1965; Ph.D. Physics, University of Notre Dame, to Present - Russell Investments Bill Madden is a Senior Investment Strategist for Russell Investments Americas Institutional business. Bill works in the Investment Strategies Group where he is focused on bringing new portfolio diversification practices and interest-rate hedging concepts to clients and researching alternative asset classes such as collateralized commodity futures. Bill joined Russell in 2002 as a Senior Consultant in Chicago. He has over thirty years of asset consulting and related investment experience. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

75 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

76 Item 1 Cover Page Kelly Mainelli Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Kelly Mainelli that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Kelly Mainelli is available on the SEC s website at

77 Item 2- Educational Background and Business Experience Kelly Mainelli Year of birth: 1967 M.B.A., Finance, University of Colorado, 1997; B.S., Finance, Merrimack College, North Andover, Massachusetts, to Present - Russell Investments; 2002 to Columbia Funds Kelly Mainelli is Director, Direct Investments, Cash and Fixed Income for Russell Investments. Kelly manages and trades fixed income portfolios, deciding on security selection, portfolio construction, and duration. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

78 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

79 Item 1 Cover Page John McMurray Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about John McMurray that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about John McMurray is available on the SEC s website at

80 Item 2- Educational Background and Business Experience John McMurray Year of birth: 1958 B.S.B.A., Trinity University; M.B.A., University of Texas at S.A.; M.S., Massachusetts Institute of Technology (MIT); CFA Charterholder, CFA Institute; C.P.A., State of Texas (not currently practicing public accountancy) 2010 to Present - Russell Investments; 2008 to Federal Home Loan Bank of Seattle; 2007 to JPMorgan Chase s Washington Mutual Division John McMurray is Chief Risk Officer for Russell Investments. He leads Russell s global risk management function which provides strategic direction on and assessment of Russell s risk exposures including investment, credit and operational risks. John is also a member of Russell's Investment Strategy Committee. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

81 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

82 Item 1 Cover Page Natalie Miller Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Natalie Miller that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Natalie Miller is available on the SEC s website at

83 Item 2- Educational Background and Business Experience Natalie Miller Year of birth: 1969 B.A., Mathematics, Statistics minor, Pacific Lutheran University, 1991; CFA Charterholder, CFA Institute, to Present - Russell Investments Natalie Miller is Director, Portfolio Strategies for Russell Investments U.S. Private Client Consulting Services business. Natalie is responsible for delivering market and economic insights and portfolio strategy advice to financial advisors and individual investors. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

84 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

85 Item 1 Cover Page Brian Mock Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Brian Mock that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Brian Mock is available on the SEC s website at

86 Item 2- Educational Background and Business Experience Brian Mock Year of birth: 1971 B.A., Political Economics, University of Washington, to Present - Russell Investments Brian Mock is the Managing Director for Direct Investments at Russell Investments. In this role, Brian is globally responsible for the leadership, portfolio management, implementation, research & development and growth for Russell s directly managed investment strategies. Brian leads a team of investment professionals consisting of portfolio managers, quantitative research analysts and portfolio analysts who are dedicated to Russell s global direct investments program. Brian s leadership led to the development of a new team and investment product offering at Russell. Brian is a member of the Russell Implementation Services, executive committee; serves as a member of Russell s Investment Strategy Committee (ISC), is a member of the Direct Investment Sounding Board; and is a member of Russell s Global Council. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s

87 associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

88 Item 1 Cover Page Matt Moss Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Matt Moss that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Matt Moss is available on the SEC s website at

89 Item 2- Educational Background and Business Experience Matt Moss Year of birth: 1956 BA, Law and Economics, Keele University (Staffordshire, England); Chartered Accountant, Institute of Chartered Accountants 2010 to Present - Russell Investments; 2004 to Evergreen Investments Matt Moss is the Chief Financial Officer for Russell Investments. In this role, Matt is responsible for the company s global financial and control functions including accounting, tax, treasury, management reporting and planning. He is also responsible for Russell s, global sourcing and procurement. Matt serves on Russell s Executive Committee and is a member of Russell s Global Council. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

90 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

91 Item 1 Cover Page Marcus Muetze Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Marcus Muetze that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Marcus Muetze is available on the SEC s website at

92 Item 2- Educational Background and Business Experience Marcus Muetze Year of birth: 1978 B.Sc., Systems and Computer Engineering, University of Guelph, Fellow of the Society of Actuaries, CFA Charterholder 2008 to Present - Russell Investments Marcus Muetze is a consultant in Russell Investments Americas institutional business. Marcus provides advice to large institutional consulting clients on investment policy and strategy, asset allocation, asset class structure, manager selection, and performance measurement. Marcus also leads the strategic review process and asset/liability studies for his clients, leveraging off his actuarial background and knowledge of pension and insurance liabilities. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

93 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

94 Item 1 Cover Page Heather Myers 1095 Avenue of the Americas 14th Floor New York, NY Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Heather Myers that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Heather Myers is available on the SEC s website at

95 Item 2- Educational Background and Business Experience Heather Myers Year of birth: 1965 B.A., Political Science, minor in Japanese Studies, Whitman College, 1987; Whitman College Associated Kyoto Program attendee, Doshisha University, 1986 to to Present - Russell Investments Heather Myers is managing director, non-profits for Russell Investments; in this capacity, she is responsible for providing leadership on strategy development and advice to clients and prospects. Additionally, Heather serves as a senior consultant for several key non-profit clients, providing strategic advice on all aspects of clients investment programs, including governance, investment policy, asset allocation, manager selection and risk management. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

96 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

97 Item 1 Cover Page Erik Ristuben Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Erik Ristuben that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Erik Ristuben is available on the SEC s website at

98 Item 2- Educational Background and Business Experience Erik Ristuben Year of birth: 1964 B.B.A., Finance, Pacific Lutheran University 1985 to Present - Russell Investments Erik Ristuben is Global Chief Investment Strategist for Russell Investments. His team s responsibilities include the creation and management of integrated client investment strategies for Russell institutional and retail clients globally, as well as the creation of Russell s global economic and market outlooks. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

99 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

100 Item 1 Cover Page Megan Roach Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Megan Roach that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Megan Roach is available on the SEC s website at

101 Item 2- Educational Background and Business Experience Megan Roach Year of birth: 1980 B.A., Finance, Washington State University; M.B.A>, Investment Management, Washington State University; CFA Chartholder, CFA Institute. June 2004 to Present - Russell Investments. Megan Roach is a portfolio manager for Russell Investments, with primary responsibility for Russell s small and mid cap funds. Megan is responsible for all aspects of the portfolio management process including manager selection, portfolio construction, and continuous monitoring. Prior to assuming portfolio management responsibilities, Megan served on Russell s small cap manager research team from 2005 to 2015, including acting as head of research for the asset class since Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

102 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

103 Item 1 Cover Page Clive Smith Level King Street Sydney, NSW 2000 Australia Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Clive Smith that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Clive Smith is available on the SEC s website at

104 Item 2- Educational Background and Business Experience Clive Smith Year of birth: 1966 Bachelor of Economics, Macquarie University, 1988; Master of Economics, Macquarie University, 1993; Graduate Program in Accounting, Macquarie University, 1994; Master of Applied Finance, Macquarie University, 1995; CFA Charterholder, CFA Institute, to Present - Russell Investments Clive Smith is a Senior Portfolio Manager for Russell Investments. Based in Russell s Sydney office, Clive is responsible for managing Russell s Australian fixed income portfolios. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

105 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

106 Item 1 Cover Page Mark Swanson Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Mark Swanson that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Mark Swanson is available on the SEC s website at

107 Item 2- Educational Background and Business Experience Mark Swanson Year of birth: 1963 B.S., Accounting, Central Washington University, 1985; Certified Public Accountant, 1987; M.B.A., University of Washington, to Present - Russell Investments Mark Swanson is a Director of RIMCo. Also, he is the Global Head of Fund Services for Russell Investments, supporting Russell s investment products. Mark s responsibilities include oversight of fund accounting and reporting, fund valuation, tax reporting, transfer agency and unit registry, and compliance for all of Russell s fund products. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

108 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

109 Item 1 Cover Page Mike Sylvanus Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Mike Sylvanus that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Mike Sylvanus is available on the SEC s website at

110 Item 2- Educational Background and Business Experience Mike Sylvanus Year of birth: 1955 B.A., Engineering, Harvard College; B.S., Environmental Engineering, Harvard College 1987 to Present - Russell Investments Mike Sylvanus is a Senior Consultant for Russell Investments Americas institutional business. Mike provides advice to large institutional fund clients on investment policy and strategy, asset allocation, asset class structure, manager selection and performance measurement and analytics. For more than seventeen years, Mike was a senior member of Russell s Research and Strategy Group where his primary responsibility was to develop and interpret asset/liability models to help institutional clients determine the appropriate allocation of assets. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

111 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

112 Item 1 Cover Page Michael (Mike) Thomas Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Michael (Mike) Thomas that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Michael (Mike) Thomas is available on the SEC s website at

113 Item 2- Educational Background and Business Experience Michael (Mike) Thomas Year of birth: 1968 M.B.A., Finance and Marketing, City University, 1991; CFA Chartholder to Present - Russell Investments As CIO, Americas Institutional, Michael Thomas, CFA is responsible for overall investment strategy for Russell s institutional clients. Mike s team includes asset allocation and risk management, investment practice for alternatives, liability driven investing and OCIO along with the US consulting team. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

114 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

115 Item 1 Cover Page Kevin Turner Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Kevin Turner that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Kevin Turner is available on the SEC s website at

116 Item 2- Educational Background and Business Experience Kevin Turner Year of birth: 1971 B.Com., Accounting and Finance, University of Auckland; B.Sc., Mathematics and Statistics, University of Auckland; CFA Charterholder, CFA Institute 1995 to Present - Russell Investments Kevin Turner is the Managing Director of Consulting for Russell Investments Americas Institutional business. Kevin assumed this leadership role in Kevin has primary responsibility for Russell s consulting client relationships in the U.S. and also continues to serve as a Senior Consultant on a number of significant relationships. Kevin is also a member of the Americas Institutional Executive Committee which is the governance body responsible for overseeing Russell s broad business initiatives in the U.S. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the

117 requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules. All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

118 Item 1 Cover Page Royce Weisenberger Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Royce Weisenberger that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Royce Weisenberger is available on the SEC s website at

119 Item 2- Educational Background and Business Experience Royce Weisenberger Year of birth: 1973 B.S. in Finance and Accounting. University of Arizona. CFA charter holder, CFA Institute to Present - Russell Investments; 2012 to Sand Dune Capital; 2001 to Inflective Asset Management Royce Weisenberger is a Senior Implementation Portfolio Manager in the Investment Division. He handles cash management for funds. Royce is responsible for transition events and direct trading implementation. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

120 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

121 Item 1 Cover Page Kenneth (Ken) Willman Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Kenneth (Ken) Willman that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Kenneth (Ken) Willman is available on the SEC s website at

122 Item 2- Educational Background and Business Experience Kenneth (Ken) Willman Year of birth: 1960 B.S., Economics, University of Puget Sound, 1982; B.A., Politics & Government, University of Puget Sound, 1982; J.D., University of Pennsylvania, to Present - Russell Investments; 2004 to Goldman Sachs (Asia) Ken Willman is Chief Legal Officer and Secretary of Russell Investments, with responsibility for the global legal, compliance, internal audit, governance and corporate records, government and community relations and risk management functions at Russell. Ken is a member of Russell s Executive Committee. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

123 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

124 Item 1 Cover Page Lohika Gayaan (Guy) Wickramanayake Rex House 10 Regent Street London SW1Y4PE Russell Investment Management Company Part of Russell Investments 1301 Second Avenue Seattle, WA March 19, 2015 This Brochure Supplement provides information about Lohika Gayaan (Guy) Wickramanayake that supplements the Russell Investment Management Company Brochure. You should have received a copy of that Brochure. Please contact or [email protected] if you did not receive Russell Investment Management Company s Brochure or if you have any questions about the contents of this supplement. Additional information about Lohika Gayaan (Guy) Wickramanayake is available on the SEC s website at

125 Item 2- Educational Background and Business Experience Lohika Gayaan (Guy) Wickramanayake Year of birth: 1979 B.A. Economics, B.A. East Asian Studies, Bucknell University 2010-Present - Russell investments; 2001 to SEI. Guy is based in London and is an Implementation Portfolio Manager in the Fixed Income team. Where he is responsible for the implementation of fixed income strategies in the Russell s Irish, Australian and Japanese domiciled Fixed Income suite of funds, this includes day to day cash and exposure management, manager changes, transition management, and fund launches, closures and mergers. Item 3- Disciplinary Information No disciplinary information for RIMCo is applicable. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Item 4- Other Business Activities Russell s Supervised Persons are not engaged in any financial or advisory business other than in their capacities as employees and/or officers of Russell in any capacity that would pose any material conflicts of interest. All outside business activities must be approved by Russell s Compliance Department to ensure that such activities do not present a material conflict of interest for Russell with respect to its clients. Item 5- Additional Compensation Generally, Russell s Supervised Persons are compensated via salaries and bonuses (paid in cash); however, in addition to salaries and bonuses, Supervised Persons may be compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed annually and are driven by the market place. Compensation is not affected by an increase in Fund assets. Russell s Supervised Persons are also subject to Russell s gifts and entertainment policy which contains reporting obligations and a general restriction on the receipt of gifts and limitations on business entertainment. Item 6- Supervision Russell has developed a Global Code of Conduct (the Global Code ) to support our value statements, protect the interests of our clients and reinforce our reputation for non-negotiable integrity by avoiding even the appearance of impropriety in the conduct of our business. The Global Code is intended to promote awareness and serve as a guide for all of Russell s associates. The Global Code summarizes the values and standards of conduct which Russell believes are critical. It is each employee s responsibility to understand and adhere to the requirements of the Global Code and other company policies, as well as applicable laws, regulations and rules.

126 All associates are required to certify in writing upon hire and annually thereafter that they (i) received a copy of the Global Code, (ii) read and understand it and (iii) agree to comply with its terms. Russell maintains its conflicts of interest policies in Russell s Codes of Conduct and Ethics ( Codes ), which are distributed to all employees upon hire, then annually, and any time the Codes are amended. New employees are required to sign a certification that they have read the Codes, understand the policies, and that they will fully comply with such policies. On an annual basis, each employee must sign a similar certification that he/she has fully complied with the policies over the past year. Responsibility for investment decision-making is clearly delineated throughout the Russell organization. In general, approval for most specific investment actions and activities is the responsibility of Russell s Investment Strategy Committee (ISC) which reports to Russell s Executive Committee. All material changes to an existing fund, the proposed launch of a new fund or the introduction of a new strategy to a fund require prior ISC approval. The committee has a global remit; it meets regularly and maintains a full audit trail of all decisions. The asset class Chief Investment Officer is ultimately accountable for all investment decisions within a given asset class. It is their responsibility, in conjunction with the ISC, to establish and operate an appropriate review and control environment. The portfolio manager is responsible for the performance of a specific fund and/or client account. They will have the necessary regulatory permissions to make investment decisions and their activities will be overseen by the relevant Chief Investment Officer. The Investment Strategy Committee also regularly reviews and monitors products, funds, and/or client accounts to ensure that they remain consistent with stated goals and objectives. Russell s Consultants ultimately report to Gregory Gilbert, Chief Executive Officer, America s Institutional at Russell s Consulting Director, Private Client Services, ultimately reports to Sandra Cavanaugh, Chief Executive Officer of Russell Investments

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