Business Continuity Plan

The State Street Global Advisor Funds Distributors, LLC (“SSGA FD”) Business Continuity Plan (the “Plan”) takes a risk-based, “all hazards” approach to contingency planning.  SSGA FD‘s Plan is designed to ensure business continuity through multiple recovery strategies, including State Street-owned and leading third-party recovery provider facilities, as well as work-from-home, split operations and work load swap capabilities.

This framework is designed to enable planning and recoverability for operations records based on scenarios in which access to the primary work facility is:

• possible, however systems are inoperable

• not possible, but all systems are in full operation

• not possible and all systems are inoperable

• possible, all systems are in full operation, however there is limited staffing available due to transportation issues, severe weather, and/or a pandemic outbreak

Testing is conducted every calendar year, incorporating critical processes and hosted applications. Also conducted regularly are processing sufficiency testing with limited staff and simulation exercises with Incident Management Team members and key business continuity personnel.