Northern Trust Global Investments 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:
THE NORTHERN TRUST
COMPANY
(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) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CIVIL AND ADMINISTRATIVE PENALTIES/FINAES & REMEDIAL
3.
Date Initiated (MM/DD/YYYY): 
06/18/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-16628
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
THE NORTHERN TRUST COMPANY
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JUNE 18, 2015, THE SECURITIES AND EXCHANGE COMMISSION (SEC) BROUGHT ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS AGAINST
36 MUNICIPAL SECURITIES DEALERS, INCLUDING THE NORTHERN TRUST COMPANY (NORTHERN TRUST), IN WHICH THE SEC ALLEGED THAT THE
MUNICIPAL SECURITIES DEALERS CONDUCTED INADEQUATE DUE DILIGENCE EFFORTS IN THE ISSUANCE OF SECURITIES BY CERTAIN MUNICIPAL
ISSUERS, AND THEREFORE VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933. NORTHERN TRUST, WITHOUT ADMITTING OR DENYING ANY
FINDINGS, CONSENTED TO A $60,000 CIVIL PENALTY IN CONNECTION WITH THREE MUNICIPAL SECURITIES OFFERING THAT TOOK PLACE IN 2010. THE
SEC FURTHER ORDERED NORTHERN TRUST AND THE OTHER DEALERS TO RETAIN AN INDEPENDENT CONSULTANT TO REVIEW THEIR POLICIES AND
PROCEDURES RELATED TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE AND TO ADOPT RECOMMENDATIONS MADE BY THE INDEPENDENT
CONSULTANT WITHIN NINE MONTHS OF THE ISSUANCE OF THE ORDER.
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):
06/18/2015
 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: $ 60,000.00
 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 FINE WAS PAID IN FULL ON JUNE 19, 2015.
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 JUNE 18, 2015, THE SECURITIES AND EXCHANGE COMMISSION (SEC) BROUGHT ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS AGAINST
36 MUNICIPAL SECURITIES DEALERS, INCLUDING THE NORTHERN TRUST COMPANY (NORTHERN TRUST), IN WHICH THE SEC ALLEGED THAT THE
MUNICIPAL SECURITIES DEALERS CONDUCTED INADEQUATE DUE DILIGENCE EFFORTS IN THE ISSUANCE OF SECURITIES BY CERTAIN MUNICIPAL
ISSUERS, AND THEREFORE VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933. NORTHERN TRUST, WITHOUT ADMITTING OR DENYING ANY
FINDINGS, CONSENTED TO A $60,000 CIVIL PENALTY IN CONNECTION WITH THREE MUNICIPAL SECURITIES OFFERING THAT TOOK PLACE IN 2010. THE
SEC FURTHER ORDERED NORTHERN TRUST AND THE OTHER DEALERS TO RETAIN AN INDEPENDENT CONSULTANT TO REVIEW THEIR POLICIES AND
PROCEDURES RELATED TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE AND TO ADOPT RECOMMENDATIONS MADE BY THE INDEPENDENT
CONSULTANT WITHIN NINE MONTHS OF THE ISSUANCE OF THE ORDER.

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:
THE NORTHERN TRUST
COMPANY
(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) 
NATIONAL FUTURES ASSOCIATION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/30/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NFA CASE NO. 21-BCC-009
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
SWAPS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
THE NORTHERN TRUST COMPANY ("NORTHERN TRUST"), ACTING IN ITS CAPACITY AS A SWAP DEALER, WAS ORDERED TO PAY A $999,000 FINE BYTHE
NATIONAL FUTURES ASSOCIATION ("NFA"). THE DECISION BY THE NFA'S BUSINESS CONDUCT COMMITTEE ("BCC") WAS BASED ON ACOMPLAINT AND A
SETTLEMENT OFFER SUBMITTED BY NORTHERN TRUST, IN WHICH IT NEITHER ADMITTED NOR DENIED THE ALLEGATIONS. THEBCC FOUND THAT
NORTHERN TRUST COMMITTED THE ALLEGED RULE VIOLATIONS AND CONSIDERED RECENT NORTHERN TRUST REMEDIATIONEFFORTS IN ACCEPTING
THE SETTLEMENT OFFER. GENERALLY, IT WAS ALLEGED THAT NORTHERN TRUST DID NOT ESTABLISH AND IMPLEMENTADEQUATE WRITTEN PROCEDURES
REASONABLY DESIGNED TO ENSURE THAT NORTHERN TRUST PROVIDED COUNTERPARTIES WITH APPROPRIATEDOCUMENTATION AND DISCLOSURES
PRIOR TO OR CONTEMPORANEOUSLY WITH ENTERING INTO SWAP TRANSACTIONS AND DID NOT ESTABLISH ASYSTEM TO DILIGENTLY SUPERVISE ITS
SWAP DEALER ACTIVITIES, INCLUDING THE REMEDIATION, RETESTING AND RESOLUTION OF NON-COMPLIANCE ISSUES.
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):
06/29/2021
 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: $ 999,000.00
 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 FINE WAS PAID IN FULL ON JULY 7, 2021.
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).
THE NORTHERN TRUST COMPANY ("NORTHERN TRUST"), ACTING IN ITS CAPACITY AS A SWAP DEALER, WAS ORDERED TO PAY A $999,000 FINE BYTHE
NATIONAL FUTURES ASSOCIATION ("NFA"). THE DECISION BY THE NFA'S BUSINESS CONDUCT COMMITTEE ("BCC") WAS BASED ON ACOMPLAINT AND A
SETTLEMENT OFFER SUBMITTED BY NORTHERN TRUST, IN WHICH IT NEITHER ADMITTED NOR DENIED THE ALLEGATIONS. THEBCC FOUND THAT
NORTHERN TRUST COMMITTED THE ALLEGED RULE VIOLATIONS AND CONSIDERED RECENT NORTHERN TRUST REMEDIATIONEFFORTS IN ACCEPTING
THE SETTLEMENT OFFER. GENERALLY, IT WAS ALLEGED THAT NORTHERN TRUST DID NOT ESTABLISH AND IMPLEMENTADEQUATE WRITTEN PROCEDURES
REASONABLY DESIGNED TO ENSURE THAT NORTHERN TRUST PROVIDED COUNTERPARTIES WITH APPROPRIATEDOCUMENTATION AND DISCLOSURES
PRIOR TO OR CONTEMPORANEOUSLY WITH ENTERING INTO SWAP TRANSACTIONS AND DID NOT ESTABLISH ASYSTEM TO DILIGENTLY SUPERVISE ITS
SWAP DEALER ACTIVITIES, INCLUDING THE REMEDIATION, RETESTING AND RESOLUTION OF NON-COMPLIANCE ISSUES.

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:
THE NORTHERN TRUST
COMPANY
(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) 
U.S. COMMODITY FUTURES TRADING COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CIVIL MONETARY PENALTY AND RELATED UNDERTAKINGS, INCLUDING REMEDIATION AND COOOPERATION.
3.
Date Initiated (MM/DD/YYYY): 
09/30/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
DOCKET 19-39
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
SWAPS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS OF THE COMMODITY FUTURES TRADING COMMISSION ("CFTC"), THE NORTHERN
TRUST COMPANY ("TNTC") CONSENTED TO ENTRY OF AN ORDER ISSUED ON SEPTEMBER 30, 2019 FINDING THAT FROM 2013 THROUGH AT LEAST 2018
TNTC FAILED TO REPORT CERTAIN SWAPS TO A SWAP DATA REPOSITORY CONSISTENT WITH THE REQUIREMENTS OF THE COMMODITY EXCHANGE ACT
AND CFTC REGULATIONS, AND THAT THOSE SWAP REPORTING FAILURES WERE A DIRECT RESULT OF TNTC'S FAILURE TO ADEQUATELY SUPERVISE ITS
SWAP DEALER, INCLUDING FAILING TO HIRE QUALIFIED SUBJECT MATTER EXPERTS TO ENSURE SWAP DEALER COMPLIANCE. THE CFTC'S ORDER
REQUIRES THAT TNTC PAY A CIVIL MONETARY PENALTY OF $1 MILLION, AND THAT IT ENHANCE ITS SUPERVISORY PROGRAM, POLICIES, PROCEDURES
AND CONTROLS, AND PROVIDE ADDITIONAL TRAINING TO RELEVANT PERSONNEL. TNTC WILL PROVIDE STATUS REPORTS TO THE CFTC CONCERNING
ITS REMEDIATION PROGRESS. ADDITIONALLY, TNTC HAS RETAINED OUTSIDE CONSULTANTS TO REVIEW ITS SWAP DEALER PROCESSES AND
PROCEDURES, HAS HIRED NEW PERSONNEL TO OVERSEE COMPLIANCE AT ITS SWAP DEALER AND HAS TAKEN SUBSTANTIAL STEPS TO IMPROVE ITS
PROCESSES FOR SWAP REPORTING GOING FORWARD.
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):
09/30/2019
 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: $ 1,000,000.00
 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 FINE WAS PAID IN FULL ON 10/7/2019.
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).
WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS OF THE COMMODITY FUTURES TRADING COMMISSION ("CFTC"), THE NORTHERN
TRUST COMPANY ("TNTC") CONSENTED TO ENTRY OF AN ORDER ISSUED ON SEPTEMBER 30, 2019 FINDING THAT FROM 2013 THROUGH AT LEAST 2018
TNTC FAILED TO REPORT CERTAIN SWAPS TO A SWAP DATA REPOSITORY CONSISTENT WITH THE REQUIREMENTS OF THE COMMODITY EXCHANGE ACT
AND CFTC REGULATIONS, AND THAT THOSE SWAP REPORTING FAILURES WERE A DIRECT RESULT OF TNTC'S FAILURE TO ADEQUATELY SUPERVISE ITS
SWAP DEALER, INCLUDING FAILING TO HIRE QUALIFIED SUBJECT MATTER EXPERTS TO ENSURE SWAP DEALER COMPLIANCE. THE CFTC'S ORDER
REQUIRES THAT TNTC PAY A CIVIL MONETARY PENALTY OF $1 MILLION, AND THAT IT ENHANCE ITS SUPERVISORY PROGRAM, POLICIES, PROCEDURES
AND CONTROLS, AND PROVIDE ADDITIONAL TRAINING TO RELEVANT PERSONNEL. TNTC WILL PROVIDE STATUS REPORTS TO THE CFTC CONCERNING
ITS REMEDIATION PROGRESS. ADDITIONALLY, TNTC HAS RETAINED OUTSIDE CONSULTANTS TO REVIEW ITS SWAP DEALER PROCESSES AND
PROCEDURES, HAS HIRED NEW PERSONNEL TO OVERSEE COMPLIANCE AT ITS SWAP DEALER AND HAS TAKEN SUBSTANTIAL STEPS TO IMPROVE ITS
PROCESSES FOR SWAP REPORTING GOING FORWARD.

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:
105780
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
NORTHERN TRUST
INVESTMENTS, INCORPORATED
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 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:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: $
 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: 
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).

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:
NORTHERN TRUST ASSET
MANAGEMENT AUSTRALIA PTY
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) 
AUSTRALIAN SECURITIES & INVESTMENTS COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
12/01/2022
 Exact
 Explanation
If not exact, provide explanation:
N/A
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6.
Principal Product Type:
Other
Other Product Types: 
THE NT WORLD GREEN TRANSITION INDEX FUND (THE "FUND") IS AN AUSTRALIAN REGISTERED MANAGED INVESTMENT SCHEME GOVERNED BY THE
FUND'S CONSTITUTION
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE AUSTRALIAN SECURITIES & INVESTMENTS COMMISSION ALLEGED THAT CERTAIN DISCLOSURES INCLUDED IN PRODUCT DISCLOSURE STATEMENTS
FOR THE NT WORLD GREEN INDEX FUND (THE "FUND") CONTAINED STATEMENTS THAT COULD MISLEAD THE PUBLIC AS TO THE NATURE OR
CHARACTERISTICS OF THE FUND.
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:
Order
11. Resolution Date (MM/DD/YYYY):
12/19/2023
 Exact
 Explanation
If not exact, provide explanation:
N/A
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 20,270.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction

 Bar
 Suspension
B.
Other Sanctions Ordered:
N/A
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: 
ON NOVEMBER 23, 2023 THE AUSTRALIAN SECURITIES & INVESTMENTS COMMISSION LEVIED A FINE OF $29,820 AUD (APPROX. $20,270 USD)
AGAINST NORTHERN TRUST ASET MANAGEMENT AUSTRALIA PTY LTD ("NTAMA"). NTAMA, AS INVESTMENT MANAGER FOR THE NT WORLD GREEN
INDEX FUND, PAID THE AMOUNT ON DECEMBER 19, 2023
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).
THE INFRINGEMENT NOTICES FROM THE THE AUSTRALIAN SECURITIES & INVESTMENTS COMMISSION ("ASIC") WERE RELATED TO THREE SECURITIES
WITHIN THE NT WORLD GREEN INDEX FUND (THE "FUND") PORTFOLIO (OF OVER 1,250 CONSTITUENTS) AND WITHIN THE INDEX TRACKED BY THE FUND
THAT WERE INCONSISTENT WITH ONE ASPECT OF A LOW CARBON INVESTMENT SCREEN. THE MAXIMUM EXPOSURE OF RTHE THREE SECURITIES IN
AGGREGATE WAS LESS THAN $75,000 AUD ($50,000 USD), AND AT NO POINT WAS ANY ONE SECURITY HOLDING GREATER THAN 0.05% OF THE FUND'S
NET ASSET VALUE. WITHOUT ADMITTING OR DENYING ANY VIOLATION, NORTHERN TRUST ASSET MANAGEMENT AUSTRALIA PTY LTD, AS INVESTMENT
MANAGER OF THE FUND, PAID $29,820 AUD (APPROX. $20,270 USD) ON DECEMBER 19, 2023 TO COMPLY WITH THE INFRINGEMENT NOTICES FROM
ASIC REGARDING ALLEGED FALSE AND MISLEADING STATEMENT WITHIN THE PRODUCT DISCLOSURE STATEMENT FOR THE FUND

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:
NORTHERN TRUST COMPANY
OF HONG KONG
(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) 
KOREA FINANCIAL SERVICES COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
04/02/2025
 Exact
 Explanation
If not exact, provide explanation:
N/A
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
N/A
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING ANY VIOLATION OF THE RELEVANT SHORT SALE RESTRICTIONS PROVISIONS OF THE KOREAN FINANCIAL
INVESTMENT SERVICES AND CAPITAL MARKETS ACT, THE NORTHERN TRUST COMPANY OF HONG KONG LIMITED ("TNTCHK") WAS ISSUED WITH A
PENALTY OF KRW 141,700,000 (APPROXIMATELY USD 100,000) ON OCTOBER 23, 2025 BY THE KOREA FINANCIAL SERVICES COMMISSION ("FSC") IN
CONNECTION WITH THE UNINTENTIONAL SHORT SALE OF 6,811 SHARES OF AN ISSUER THAT WAS NOT CONSIDERED BY THE FSC TO HAVE BEEN
OWNED BY TNTCHK'S CLIENT (TO WHOM TNTCHK PROVIDES DISCRETIONARY INVESTMENT MANAGEMENT SERVICES) AT THE TIME THE ORDER WAS
PLACED.
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:
N/A
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):
10/23/2025
 Exact
 Explanation
If not exact, provide explanation:
N/A
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?

 Monetary/Fine Amount: $ 100,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
N/A
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 FINE WAS PAID IN FULL ON OCTOBER 27, 2025
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).
WITHOUT ADMITTING OR DENYING ANY VIOLATION OF THE RELEVANT SHORT SALE RESTRICTIONS PROVISIONS OF THE KOREAN FINANCIAL
INVESTMENT SERVICES AND CAPITAL MARKETS ACT, TNTCHK WAS ISSUED WITH A PENALTY OF KRW 141,700,000 (APPROXIMATELY USD 100,000) ON
OCTOBER 23, 2025 BY THE KOREAN FSC IN CONNECTION WITH THE UNINTENTIONAL SHORT SALE OF 6,811 SHARES OF AN ISSUER THAT WAS NOT
CONSIDERED BY THE FSC TO HAVE BEEN OWNED BY TNTCHK'S CLIENT (TO WHOM TNTCHK PROVIDES DISCRETIONARY INVESTMENT MANAGEMENT
SERVICES) AT THE TIME THE ORDER WAS PLACED.