ERISA Plans Disclosures

Barclays Acting as Client's Agent in Securities Transactions ("Cash Equities")

BCI will provide services to clients as either a broker or clearing agent (or both) in connection with the purchase and sale (including short sales) of exchange listed or OTC securities or options executed on an agency basis, including, but not limited to, US equities (including “ADRs”), exchange-traded funds (“ETFs”) and foreign securities (“ORDs”). In some limited cases, BCI may directly or through others, including affiliates, also provide similar agency related execution services in connection with fixed income securities. Where applicable, BCI or an identified affiliate may also provide custody related services, and the provision of short-term “sweep” or other money market enhancements for available credit balances pending reinvestment or redistribution on behalf of a client account custodied or maintained at a Barclays Entity.

Barclays Acting as Client's Agent in Executing and/or Clearing Futures Transactions ("Futures")

Please refer to the relevant Futures and Options Customer Account Agreement and all amendments, annexes, addenda and schedules thereto ("Futures Agreement") as well as any International Uniform Brokerage Execution Services Agreement ("Give Up Agreement") for a description of the services provided and the terms and conditions which govern BCI and other parties involved with respect to such services.

Where applicable, BCI or another Barclays Entity may also provide custody related services, and the provision of short-term "sweep" or other money market enhancements for available credit balances pending reinvestment or redistribution on behalf of a client account custodied or maintained at BCI or another Barclays Entity.

To the extent BBPLC or other identified Barclays Entity provides financial intermediation, the terms and conditions of such service will be detailed in a separate agreement.

See also section entitled "OTC Derivatives Execution/Clearing/Settlement/Delivery" as applicable.

OTC Derivatives Execution/Clearing/Settlement/Delivery ("OTC Clearing")

Please refer to the relevant Cleared Derivatives Transactions Addendum ("Cleared Derivatives Addendum") of any Futures Agreement (or other applicable agreement relating to execution and clearing) for a description of the terms and conditions which govern BCI's or an affiliate’s clearing and other services on the client’s behalf of swaps, forwards, currency, commodities, options or similar transactions ("OTC Clearing") entered into by a client in the OTC market, and/or on an execution facility or on a designated contract market that are submitted for clearing at a derivatives clearing organization. The Cleared Derivatives Addendum supplements and forms a part of the Futures Agreement.

Prime Brokerage

The services a Barclays Entity may provide with respect to Prime Brokerage clients are detailed in the Prime Brokerage Services Agreement, including all attached terms, schedules, supplements and exhibits thereto (collectively "Prime Brokerage Agreement"). For further information, see the no-action letter dated January 25, 1994 issued by the Division of Market Regulation of the Securities and Exchange Commission. These services may include execution of securities and futures transactions, clearing, custody, and asset servicing, certain customized technology or research, provision of risk analytic technology, sometimes supplemented by consultations with senior risk professionals of a Barclays Entity, introductions to other financial market participants where there may be an interest in exploring mutually beneficial commercial opportunities, the maintenance of accounts for the purpose of carrying, custodying or financing positions in securities, futures, loans (including whole mortgage loans and bank debt), currencies, commodities or derivatives, and all transactions in which a Barclays Entity provides clearing, custody or settlement services to or for a client (including as prime broker in connection with prime broker transactions or fixed income clearing transactions, or in connection with any give-up, free delivery or unsettled transaction, or when acting as a clearance and/or settlement agent in any clearing system, market, or exchange, domestic or international) or transactions in, or the custody of, cash made in connection with, or in contemplation of, any of the foregoing. A Barclays Entity may further assist with account maintenance duties, including account set up and updating, client trading and processing journals, and other account maintenance-related services. A Barclays Entity may also provide transaction statements under the terms and conditions provided in the Prime Brokerage Agreement applicable to a client account. On a principal basis, a Barclays Entity may also assist clients by lending clients funds or securities or otherwise extending credit.

Also, please see the sections entitled "Barclays Acting as Client’s Agent in Securities Transactions" and "Barclays Acting as Client's Agent in Executing and/or Clearing Futures Transactions."

Cash Equities

With respect to securities related transactions, this section relates to only those arrangements where BCI has a direct relationship with a client, including a Plan that is not covered under a Prime Brokerage Agreement. For securities transactions executed in connection with any Prime Brokerage relationship, please see “Prime Brokerage” below.

BCI will generally receive a commission from clients with respect to any trade executed on an agency basis for which BCI or another identified Barclays Entity acts as broker or clearing agent. The aggregate amount of the commission will be provided to the client at the time it (or the responsible Plan fiduciary) contacts BCI to place an order and will be confirmed in a written confirmation statement that will be received after the trade has been executed. Commissions may depend on a variety of factors, including market conditions, volume, quantities bought or sold, and exchange or other clearing and settlement considerations. Because many factors beyond the control of Barclays can affect the pricing of any securities executed by BCI (or another identified Barclays Entity) as agent on behalf of any client, it is difficult to predict with any sort of precision or certainty as to what a given client, including any Plan, may expect to pay BCI (or such other Barclays Entity) in the form of commissions for such services and Barclays believes it may not be possible to predict with certainty the jurisdictions in which any given client may execute any such transactions outside of the United States. In addition to dynamic market conditions, commission rates may often be affected by changes in trading strategies, trading volume, and/or trading frequency.

By way of illustration only, and looking at BCI’s prior one year ending December 31, 2011, BCI has typically charged no more than 5 cents per share for US and Canadian executions and 3 cents per contract for U.S. listed options, and typically received no more than 25 cents or basis points a share for equities transactions in developed markets, and 50 cents or basis points a share for equities transactions in developing markets. Please also note that BCI or an affiliate may act as principal (or act on a riskless principal basis) on certain transactions. In such cases, BCI or an affiliate receives compensation from clients by adding a mark-up to purchases, and deducting a mark-down from sales. This mark-up or mark-down will be reflected in the price when BCI or an affiliate acts as principal.

Futures

BCI or another identified Barclays Entity will generally receive a commission with respect to any trade for which such Barclays Entity acts as the client’s broker or clearing broker or agent. The terms governing commissions and other similar charges the client pays will be set forth in the client’s Futures Agreement (including any fee schedule related thereto that is provided to a client or its representative) or otherwise set forth in a writing (including e-mail) provided to the client or its representative. As provided in applicable agreements or arrangements, clients, including Plan clients, are required to pay brokerage and commission charges, give up fees, ticket charges, administrative charges, exchange fees, and service fees as Barclays may from time to time charge, all Transaction Facility (as defined in the Futures Agreement), clearing firm or National Futures Association (“NFA”) fees or charges, or any other transaction fees, regulatory fees and service charges incurred with respect to each contract executed thereunder, as well as other items specifically referred to in the Futures Agreement. Such fees are set forth in the relevant Futures Agreement and fee schedule or related addendum associated with the client’s Futures and OTC Clearing documentation. See also OTC Clearing to the extent applicable.

To the extent BBPLC or other identified Barclays Entity provides financial intermediation, the terms and conditions of such service will be detailed in a separate agreement.

OTC Clearing

When BCI or an identified Barclays affiliate acts as a client’s clearing agent or executes transactions as agent in connection with OTC derivatives and/or other transactions that are cleared or may be required to be cleared pursuant to applicable law, fees will be detailed in a client’s Futures Agreement, or supplemented by any Cleared Derivatives Addendum, or similar document, including any fee schedules or addenda related thereto, or otherwise as provided in writing.

Also please see the materials described with respect to Cash Equities and Futures where applicable to the Prime Brokerage relationship.

Prime Brokerage

Commissions or fees payable to BCI in connection with securities transactions executed on an agency basis with or through a Barclays Entity, along with ticket charges, administrative charges and certain fees for exercises of options, and fees for the clearing and custody of international assets (where applicable), as well as compensation received in connection with certain financing or other principal transactions are generally disclosed in a “Price Proposal” (or similar document or documents) in combination with the Prime Brokerage Agreement. Any changes to the Price Proposal are timely provided. Finally, all fees are posted to client accounts on a monthly basis, typically within the first several days of the new month. Commissions received in connection with BCI’s acting as broker or clearing agent for futures transactions will be disclosed in a client’s Futures Agreement and related documentation or schedule or in the Price Proposal. In addition, certain charges such as administrative fees, cancel and correct fees, wire fees, transfer fees and other fees may be charged as disclosed to a client in writing. Finally, certain debt fees for borrowed cash and securities lending fees (which could be paid in the form of rebates in cash) may be paid for borrowed securities, as detailed in the Price Proposal.

Also, please see the sections entitled Cash Equities and Futures.

Generally

In certain cases, BCI and other Barclays Entities may derive a benefit in connection with providing services to clients, including earnings on funds awaiting investment or reinvestment or funds pending distribution (i.e., float). In general, the amount of float earned is the difference between the rates stated in the governing documents and schedules or addenda for the appropriate product or service to be received by the client (e.g., for Prime Brokerage, the Price Proposal or related documentation) and the rate which a Barclays Entity earns at its own risk. Historically, such amounts earned by BCI or another Barclays Entity have typically tracked relatively short term interest rate benchmark, including but not limited to Fed Funds or LIBOR.

BCI and/or one or more of its affiliates may have ownership interests in one or more U.S. or foreign exchanges, execution facilities and clearing houses, consortium- owned alternative trading platforms (“ATS”) or similar venues that a client may trade on or that may clear the client’s trades (“Market Venues”). As a result, the client (including Plans and their responsible fiduciaries) should be aware that BCI and its affiliates might receive financial benefits related to its ownership interest in such Market Venues or revenue sharing arrangements amongst members when trades are executed on or cleared at such a Market Venue. Clients should contact an appropriate Barclays Entity representative directly if they would like to know whether any Barclays Entity has an ownership interest in a particular Market Venue. See also the discussion in Cash Equities and the information provided in Exhibit A.

Certain of these Market Venues offer BCI (and its affiliates) rebates, credits for orders that provide liquidity to their books and assess fees for orders that take liquidity from their books, provide discounts to a Barclays Entity for volume of trading, or pay a Barclays Entity for order flow. Additionally, there are some Market Venues that give credits for orders that take liquidity and assess fees for orders that provide liquidity. Whether any Market Venue offers Barclays a net credit or imposes net charges is dependent on a number of market and institution-wide factors, including the volume of trading a Barclays Entity sends to the Market Venue over a pre-established period. Accordingly, Barclays does not believe that the availability or amount of any such credit or rebate is based on the activity of any one account. Barclays believes that the discounts, rebates and other potential benefits derived from Market Venues have historically fluctuated often and are reasonably expected to change over time depending on market conditions and other factors. These operational facts, when combined with the multiple execution strategies Barclays typically employs across Market Venues over time for best execution make it difficult to predict the value (if any) Barclays expects it may receive from such Market Venues.

From time to time, employees of BCI, BBPLC or their affiliates may receive non-monetary compensation such as gifts and entertainment from vendors with whom they may engage in business dealings on behalf of clients. However, given the nature of Barclays’ businesses, Barclays reasonably believes that any gifts and entertainment received by employees of a Barclays Entity are typically received in the context of a general business relationship and should not be viewed as attributable or allocable to any transactions engaged in on behalf of their clients. BCI and BBPLC have historically maintained policies and procedures relating to gifts and entertainment activities in response to numerous laws and regulations with both local and global applicability.

Cash Equities

In connection with brokerage services, BCI may route orders to Market Venues (as defined above) such as national securities exchanges, alternative trading systems, electronic communications networks, as well as to broker-dealers.

Pursuant to SEC Rule 606, we disclose, on a quarterly basis, covered Market Venues to which we route customer orders for execution as required by Rule 606. Please follow the attached hyperlink to our latest report. http://www.barcap.com/site-footer/regulatory-disclosures.html. In addition, although BCI believes it is unable to predict with any meaningful degree of certainty what Market Venue, if any, may be used in connection with any client’s order or execution, the United States and Canada equities and listed options Market Venues contained in Exhibit A are listed by BCI for general consideration and may contain certain pricing and fee information that have been developed by the venue for a number of purposes. As Barclays does not typically control the content or timing of updates of information provided by any particular Market Venue, clients are advised to contact these Market Venues directly for information.

Futures

In connection with its execution and clearing services in futures and/or OTC Clearing to its clients, a Barclays Entity may direct orders to persons or organizations unaffiliated with it, such as floor brokers and other futures executing institutions or market makers as brokers or agents for the client or with respect to execution facilities for OTC cleared derivatives. BCI or other Barclays Entities may have certain agreements with some of these institutions or persons, and, where permitted, BCI or other Barclays Entities may receive volume discounts or similar concessions or rebates as a function of the volume of transactions directed to such persons or organizations. However, BCI believes that given its execution activities, it is not possible to meaningfully determine in advance the existence of, or amount of any such compensation with respect to any given client.

As described in the applicable Futures Agreement, a client generally grants BCI the right to borrow, pledge, re-pledge, transfer hypothecate, re-hypothecate, engage in repurchase or reverse repurchase transactions with respect to, invest or loan, either separately or with the property of other clients, to either BCI or to others, any securities or other property held by BCI on margin for a client account or as margin or collateral therefor. As the Cleared Derivatives Addendum supplements and forms part of the relevant Futures Agreement, a client generally grants BCI the same rights described in the immediately preceding sentence for purposes of OTC Clearing. CFTC regulations limit the instruments in which BCI can invest a client’s collateral. Accordingly, the return that BCI earns by investing that collateral will be limited to the returns on such instruments and market conditions. Pursuant to CFTC Rule 1.25, a registered futures commission merchant (“FCM”), such as BCI, may invest margin in U.S. government securities, municipal securities, U.S. agency obligations, certificates of deposits of certain banks, commercial paper fully guaranteed as to principal and interest by the United States under the Temporary Liquidity Guarantee Program as administered by the Federal Deposit Insurance Corporation, corporate notes or bonds fully guaranteed as to principal and interest by the United States under the Temporary Liquidity Guarantee Program as administered by the Federal Deposit Insurance Corporation (corporate notes or bonds), and interests in money market mutual funds, or, in certain cases, agreements for resale or repurchase of certain instruments as well as obligations issued by the Federal National Mortgage Association or the Federal Home Loan Mortgage Association while such entities operate under the conservatorship or receivership of the Federal Housing Finance Authority with capital support from the United States. CFTC Rule 1.25 contains additional details and requirements and may be updated from time to time.

Finally, BCI may earn amounts from a client’s financing of its margin obligations. BCI may derive income in the form of the spread between the interest paid to a client on equity balances in excess of required margin and the interest BCI earns from any short-term financing, at its own risk and return. BCI may also earn float on a client’s account balance deficits. The relevant interest rates are set forth on the interest or fee schedule associated with the client’s Futures Agreement.

OTC Clearing

See the section entitled Futures

Prime Brokerage

In connection with Prime Brokerage relationships, clients, including Plan clients having a direct Prime Brokerage relationship with BCI, or such other Barclays Entity identified in its applicable agreement, may grant BCI (and its affiliated entities) the right, to the extent permissible under applicable law, to hold and re-register collateral posted by or on behalf of the client, pledge, repledge, hypothecate, rehypothecate, sell, lend, or otherwise transfer or use any amount of the collateral, separately or together with other assets or other amounts of the collateral, with all attendant rights of ownership (including the right to vote securities), and to use or invest cash collateral at BCI’s (or its affiliate’s) own reward (which may be without limitation) and risk. The amounts which may be rehypothecated under a Prime Brokerage relationship with BCI are generally limited to 140% of, or other applicable regulatory limits on, outstanding liability (i.e., the debit balance) to the Prime Broker. Please see Appendix A for selected information concerning Market Venues. For the purposes of the return of any collateral to customer, the Prime Brokerage Agreement provides for the return of collateral by delivering securities or other financial assets of the same issuer, class and quantity as the collateral initially transferred. Additional terms and conditions applicable to Plan accounts may be found in the Prime Brokerage Agreement.

Also, please see the sections entitled Cash Equities and Futures.

Cash Equities; Futures; OTC Derivatives

To the extent a client executes trades on a foreign exchange, BCI, BBPLC, or an affiliate of BCI or BBPLC may act as broker or clearing agent or both with respect to securities transactions. In connection with any such transaction, BCI or BBPLC may allocate a portion of the amount received from the client to such affiliate for the execution or clearing services such affiliate performs. Applicable tax laws require that the fees retained by such Barclays Entities reflect the fees that would be paid in arm’s length negotiations. In most instances, Barclays believes such allocations do not involve actual payments.

Similarly, in connection with its execution and clearing services in futures to its clients, BCI may direct orders to affiliates of BCI, which will act as brokers and agents of the client. In connection with any such transaction, a portion of its commission that is actually received may be allocated to such affiliate, based on a fee schedule and based on the services such affiliate performs.

All or a portion of the execution, clearing and settlement fees may be passed on to introducing brokers, floor brokers, clearinghouses or settlement or execution facilities as set forth on the relevant fee schedule.

In the context of Futures and OTC Derivatives, clients should consult the fee schedules or other related addenda associated with the Futures Agreement or Cleared Derivatives Addendum for additional information or otherwise contact their BCI representative for more information.

See also Prime Brokerage, if applicable

Prime Brokerage

Portions of the domestic clearing and settlement fees may be passed on to clearinghouses or settlement facilities (such as DTC). These may include, for example, fees for exercises and assignments of options and ticket charges for settlement of trades in equities and fixed income products. Portions of international clearing and custody fees may also be passed on to affiliated or unaffiliated local sub-custodians, agents or clearinghouses to compensate for services in clearance of trades or custody of securities in certain markets.

BCI, or an affiliate, or as otherwise denoted in the Prime Brokerage Agreement, may also hire sub-custodians, including those listed below. A link to their schedule of fees is also included, where available. Clients should check these websites for periodic updates.

Depository Trust Company (acting together with its clearing affiliates, the National Securities Clearing Corporation and Fixed Income Clearing Corporation);

The Options Clearing Corporation; http://www.optionsclearing.com/membership/schedule-of-fees/

Euroclear Bank SA/NV; https://www.euroclear.com/en.html

These sub-custodians (“Primary Sub-custodians”) offer services themselves as well as through their significant networks of members and participants. It is Barclays’ belief that the Primary Sub-custodians occupy a position in the market, which, together with their networks, effectively makes them essential utilities for clearing, settlement, custody and other related services of the type provided through Prime Brokerage.

While it is Barclays’ belief that the above mentioned Primary Sub-custodians can be expected to occupy a substantial position in the marketplace, other sub-custodians in other jurisdictions may charge a variety of other custody, transaction and related fees. Some of these other sub-custodians perform special services, depending on the legal, regulatory and operational environment of the jurisdiction involved. Many of these other sub-custodians are banks which are retained to hold securities where the Primary Sub-custodians are either not permitted by law to do so or are otherwise ineligible. It is Barclays’ experience that these other sub-custodians are compensated on an arm’s length basis depending on the fees and other services as specified in the relevant sub-custodial (or other relevant) agreement.For a list of sub-custodians, including where any BCI affiliate is used, please contact a BCI representative. The amount of any such fees is typically provided in the Price Proposal.

Cash Equities

Manner of payment is not typically addressed contractually for these relationships. Unless otherwise agreed to by the parties, payments in the United States are typically made at the time of the transaction.

Futures/OTC Clearing

See Futures Agreement; Cleared Derivatives Addendum and any applicable fee schedules thereto.

Prime Brokerage

See Prime Brokerage Agreement and Price Proposal.

BATS

BATS Exchange

Cboe US Equities Exchanges Overview

BOX

Boston Options Exchange

Box Options Fee Schedule

C2

CBOE

Cboe Options Exchange

Chicago Board of Options

Cboe Fee Schedule

ISE

International Securities Exchange

OCC Schedule of Fees / March 2018

i-Swap

i-Swap

ICAP Our Swap Execution Facility (SEF)

NASDAQ NOM

NASDAQ Options Market

NASDAQ Stock Market NOM Price list

NASDAQ OMX BX

NASDAQ OMX BX Options

NASDAQ BX TotalView-ITCH ("BX TotalView")

NYSE AMEX

NYSE AMEX Options

OCC Schedule of Fees / March 2018

Intercontinental Exchange

NYSE ARCA

NYSE ARCA Options Exchange

OCC Schedule of Fees / March 2018

Intercontinental Exchange

PHLX

NASDAQ OMX PHLX

OCC Schedule of Fees / March 2018

TMX

Toronto Stock Exchange

TMX