Invesco Asset Management Ltd..

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
INVESCO FUND MANAGERS
LIMITED
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINANCIAL CONDUCT AUTHORITY (UK)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/28/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON APRIL 28, 2014, THE FINANCIAL CONDUCT AUTHORITY (FCA), THE UK FINANCIAL SERVICES REGULATOR, ANNOUNCED THE SETTLEMENT OF AN
INVESTIGATION OF INVESCO ASSET MANAGEMENT LIMITED AND INVESCO FUND MANAGERS LIMITED (TOGETHER INVESCO PERPETUAL) THAT INCLUDED
THE IMPOSITION OF A FINANCIAL PENALTY OF £18.6 MILLION. THE ISSUES IDENTIFIED BY THE FCA RELATED TO THE PERIOD MAY 2008 TO NOVEMBER
2012 AND INCLUDED THE FOLLOWING: (1)INVESTMENT RESTRICTION BREACHES IN UK-DOMICILED RETAIL FUNDS MANAGED BY INVESCO PERPETUAL.
SUCH BREACHES HAD BEEN IDENTIFIED BY INVESCO PERPETUAL AND REPORTED TO FCA, AND THE FUNDS WERE PROMPTLY REIMBURSED WHERE
NECESSARY. (2)DISCLOSURES REGARDING THE USE OF, AND RISKS ASSOCIATED WITH, DERIVATIVES WERE NOT MADE OR INADEQUATELY MADE IN
DISCLOSURE DOCUMENTS FOR TWO UK-DOMICILED RETAIL FUNDS MANAGED BY INVESCO PERPETUAL. THESE DISCLOSURE FAILINGS WERE
CORRECTED IN AUGUST 2012. (3)INVESCO PERPETUAL FAILED TO ADEQUATELY DOCUMENT ALLOCATIONS OF FIXED INCOME SECURITIES WHEN
AGGREGATING CLIENT ORDERS. A REVIEW BY INVESCO PERPETUAL DETERMINED THERE WAS NO EVIDENCE THAT THIS IMPACTED INVESTORS. (4)
CERTAIN FIXED INCOME TRANSACTIONS WERE NOT POSTED ON A TIMELY BASIS. THIS DID NOT RESULT IN ANY NEED TO REPRICE FUNDS.
8.
Current Status?      
 Pending
 On Appeal
 Final

9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
04/28/2014
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 31,100,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FINANCIAL CONDUCT AUTHORITY IMPOSED A FINANCIAL PENALTY OF APPROXIMATELY $31.1 MILLION.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON APRIL 28, 2014, THE FINANCIAL CONDUCT AUTHORITY (FCA), THE UK FINANCIAL SERVICES REGULATOR, ANNOUNCED THE SETTLEMENT OF AN
INVESTIGATION OF INVESCO ASSET MANAGEMENT LIMITED AND INVESCO FUND MANAGERS LIMITED (TOGETHER INVESCO PERPETUAL) THAT INCLUDED
THE IMPOSITION OF A FINANCIAL PENALTY OF £18.6 MILLION. THE ISSUES IDENTIFIED BY THE FCA RELATED TO THE PERIOD MAY 2008 TO NOVEMBER
2012 AND INCLUDED THE FOLLOWING: (1)INVESTMENT RESTRICTION BREACHES IN UK-DOMICILED RETAIL FUNDS MANAGED BY INVESCO PERPETUAL.
SUCH BREACHES HAD BEEN IDENTIFIED BY INVESCO PERPETUAL AND REPORTED TO FCA, AND THE FUNDS WERE PROMPTLY REIMBURSED WHERE
NECESSARY. (2)DISCLOSURES REGARDING THE USE OF, AND RISKS ASSOCIATED WITH, DERIVATIVES WERE NOT MADE OR INADEQUATELY MADE IN
DISCLOSURE DOCUMENTS FOR TWO UK-DOMICILED RETAIL FUNDS MANAGED BY INVESCO PERPETUAL. THESE DISCLOSURE FAILINGS WERE
CORRECTED IN AUGUST 2012. (3)INVESCO PERPETUAL FAILED TO ADEQUATELY DOCUMENT ALLOCATIONS OF FIXED INCOME SECURITIES WHEN
AGGREGATING CLIENT ORDERS. A REVIEW BY INVESCO PERPETUAL DETERMINED THERE WAS NO EVIDENCE THAT THIS IMPACTED INVESTORS. (4)
CERTAIN FIXED INCOME TRANSACTIONS WERE NOT POSTED ON A TIMELY BASIS. THIS DID NOT RESULT IN ANY NEED TO REPRICE FUNDS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINANSTILSYNET, THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/19/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MARCH 19, 2015, FINANSTILSYNET, THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY, ISSUED A VIOLATION PENALTY ON INVESCO ASSET
MANAGEMENT LIMITED, PURSUANT TO SECTION 4-3, REF. SECTION 17-4, OF THE SECURITIES TRADING ACT (STA). THE ISSUE RELATED TO THE LATE
NOTIFICATION OF A SALE OF STOCK THAT TOOK THE RELEVANT HOLDING BELOW 5% REPORTING THRESHOLD. THE PENALTY TO BE PAID TO THE
NORWEGIAN TREASURY WAS 100,000 NORWEGIAN KRONE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
03/19/2015
 Exact
 Explanation

If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 12,686.73
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
FINANSTILSYNET, THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY IMPOSED A FINANCIAL PENALTY OF APPROXIMATELY $12,686.73.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON MARCH 19, 2015, FINANSTILSYNET, THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY, ISSUED A VIOLATION PENALTY ON INVESCO ASSET
MANAGEMENT LIMITED, PURSUANT TO SECTION 4-3, REF. SECTION 17-4, OF THE SECURITIES TRADING ACT (STA). THE ISSUE RELATED TO THE LATE
NOTIFICATION OF A SALE OF STOCK THAT TOOK THE RELEVANT HOLDING BELOW 5% REPORTING THRESHOLD. THE PENALTY TO BE PAID TO THE
NORWEGIAN TREASURY WAS 100,000 NORWEGIAN KRONE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
INVESCO LTD
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the

adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FEDERAL FINANCIAL SUPERVISORY AUTHORITY ("BAFIN")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/30/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
WA 17-WP 3120-2020/0003; WA 17-WP 3120-2020/0004
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
INVESCO LTD
6.
Principal Product Type:
Other
Other Product Types: 
THE MATTER RELATED TO OWNERSHIP FILINGS WITH THE GERMAN REGULATOR IN RELATION TO GERMAN LISTED COMPANIES.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
INVESCO LTD AND AIM INTERNATIONAL MUTUAL FUNDS FAILED TO SUBMIT VOTING RIGHTS NOTIFICATIONS TO BAFIN AND THE ISSUERS BY THE
REQUIRED DEADLINE. BAFIN ISSUED A NOTICE OF HEARING ON JULY 30, 2020 TO INVESCO LTD ALLEGING THAT VIOLATIONS OF THE VOTING RIGHTS
REQUIREMENTS OCCURED ON 26 OCCASSIONS RELATING TO THE VOTING RIGHTS NOTIFICATIONS OF INVESCO LTD AND ON 28 OCCASIONS RELATING
TO VOTING RIGHTS NOTIFICATIONS OF AIM INTERNATIONAL MUTUAL FUNDS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
05/31/2021
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 309,595.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution

 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
DECISION TO IMPOSE A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 USD AGAINST INVESCO LTD WILL BE PAID BY THE JULY 2, 2021
DEADLINE>
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
BAFIN IMPOSED A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 USD AGAINST INVESCO LTD FOR %$ INCORRECT THRESHOLD FILINGS
BETWEEN 05/2019 AND 10/2019. THE FINE WILL BE PAID BY THE JULY 2, 2021 DEADLINE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMISION FEDERAL DE COMPETENCIA ECONOMIC (COFECE)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/11/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
VCN-003-2022
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
INVESCO ASSET MANAGEMENT LIMITED
6.
Principal Product Type:
Debt - Corporate
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON 25 AUGUST 2022 COFECE, THE MEXICAN FEDERAL ECONOMIC COMPETITION COMMISSION, ANNOUNCED IT HAD FINED INVESCO ASSET
MANAGEMENT LTD ("IAML") $45,000 FOR CLERICAL ERRORS IN RELATION TO A PRE-MERGER CLEARANCE FILING MADE IN 2021 AND REQUESTED IAML
SUBMIT A NEW FILING IN RESPECT OF ALL INVESCO FUNDS AND ACCOUNTS INVOLVED IN THE TRANSACTION. THE OVERSIGHT OCCURRED BECAUSE
INVESCO USED AN INCORRECT DATA SOURCE FOR COMPLETION OF THE PAPERWORK. THE CORRECT DATA SOURCE TO USE IN ALL INSTANCES GOING
FORWARD HAS SINCE BEEN IDENTIFIED AND THIS HAS BEEN COMMUNICATED TO THE RELEVANT TEAM. NO CLIENTS WERE IMPACTED.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
09/09/2022
 Exact
 Explanation
If not exact, provide explanation:
RESOLUTION WILL OCCUR ON PAYMENT OF THE FINE
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 45,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
COFECE HAS FINED IAML $45,000 FOR CLERICAL ERRORS IN RELATION TO A PRE-MERGER CLEARANCE FILING MADE IN 2021 AND HAS
REQUESTED IAML SUBMIT A NEW FILING IN RESPECT TO ALL INVESCO FUNDS AND ACCOUNTS INVOLVED IN THE TRANSACTION. IAML WILL PAY
THE FINE IN FULL BY THE REQUIRED DEADLINE.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON 25 AUGUST 2022 COFECE, THE MEXICAN FEDERAL ECONOMIC COMPETITION COMMISSION, ANNOUNCED IT HAD FINED INVESCO ASSET
MANAGEMENT LTD ("IAML") $45,000 FOR CLERICAL ERRORS IN RELATION TO A PRE-MERGER CLEARANCE FILING MADE IN 2021 AND REQUESTED IAML
SUBMIT A NEW FILING IN RESPECT OF ALL INVESCO FUNDS AND ACCOUNTS INVOLVED IN THE TRANSACTION. THE OVERSIGHT OCCURRED BECAUSE
INVESCO USED AN INCORRECT DATA SOURCE FOR COMPLETION OF THE PAPERWORK. THE CORRECT DATA SOURCE TO USE IN ALL INSTANCES GOING
FORWARD HAS SINCE BEEN IDENTIFIED AND THIS HAS BEEN COMMUNICATED TO THE RELEVANT TEAM. NO CLIENTS WERE IMPACTED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMMISSIONE NAZIONALE PER LE SOCIETA E LA BORSA (CONSOB)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)

Other Sanctions: 
PROFIT DISGORGEMENT
3.
Date Initiated (MM/DD/YYYY): 
04/19/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CONSOB RESOLUTION NUMBER 23237
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
EQUITY RIGHTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JANUARY 2, 2024, INVESCO ASSET MANAGEMENT LIMITED RECEIVED A NOTICE FROM THE COMMISSIONE NAZIONALE PER LE SOCIETÀ E LA BORSA
"CONSOB" THAT IT HAS COMMENCED A PROCEEDING IN CONNECTION WITH ALLEGED BREACHES OF CERTAIN PROVISIONS OF THE EU SHORT SELLING
REGULATION PERTAINING TO THE EXECUTION OF AN UNCOVERED SHORT SALE AND FAILING TO REPORT THAT NET SHORT POSITION IN JULY 2022.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
10/14/2024
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 272,750.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE SETTLEMENT REQUIRED INVESCO ASSET MANAGEMENT LIMITED ("IAML"), PAY A MONETARY PENALTY OF EUR 250,000 ($272,750) AND
PROFIT DISGORGEMENT OF EUR 94,680 ($103,296). IAML PAID THE MONETARY PENALTY AND PROFIT DISGORGEMENT ON OCTOBER 18, 2024.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON OCTOBER 14, 2024 THE CONSOB NOTIFIED IAML OF THE IMPOSITION OF A SANCTION REGARDING BREACHES OF THE EU SHORT SELLING
REGULATION IN CONNECTION WITH EQUITY SELL TRADES UNDERTAKEN BY IAML IN ITALIAN-LISTED ISSUER SAIPEM SPA AHEAD OF A CAPITAL
INCREASE THE COMPANY WAS UNDERTAKING. THE CONSOB FOUND THAT ON JULY 14, 2022 IAML EXECUTED AN UNCOVERED SHORT POSITION LASTING
1 DAY AMOUNTING TO 2.9% OF THE PRE-INCREASE SHARE-CAPITAL OF SAIPEM AND FAILED TO MAKE REQUIRED NOTIFICATIONS OF NET SHORT
HOLDINGS. IAML HELD SAIPEM OPTION RIGHTS BUT THESE COULD NOT BE USED TO COVER THE SELL TRADES AS THEY GAVE THE RIGHT TO RECEIVE
SHARES FUNGIBLE WITH OUTSTANDING SHARES ONLY ON JULY 19, 2022 AND THEREFORE NOT IN TIME FOR THE SETTLEMENT ON JULY 18, 2022 OF THE
SHORT SALES EXECUTED ON JULY 14, 2022. AS SUCH, IAML INCURRED A SETTLEMENT FAIL FOR FAILING TO DELIVER THE SHARES SOLD SHORT IN
ACCORDANCE WITH THE SETTLEMENT TERMS, WITH THE SHORT SALES OF SAIPEM SHARES BEING SETTLED 1 DAY LATE WITH THE NEW SHARES
RESULTING FROM THE EXERCISE OF THE OPTION RIGHTS. CONSOB IMPOSED A PENALTY OF EUR 250,000 ($272,750), EUR 220,000 ($240,020) FOR
BREACHING THE PROHIBITION ON NAKED SHORT SELLING AND EUR 30,000 ($32,730) FOR FAILING TO REPORT THE SHORT SELLS AS WELL AS EUR
94,680 ($103,296) DISGORGEMENT OF PROFITS FROM THE TRADES.