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        Managed Pension Funds Limited

        STATEMENT OF COMPLIANCE WITH S172(1) OF THE COMPANIES ACT 2006

        The directors have acted in a way that they considered, in good faith to be most likely to promote the success of the Company for the benefit of its members as a whole, and in doing so had regard, amongst other matters, to:

        • the likely consequences of any decision in the long term;
        • the need to foster the Company’s business relationships with suppliers, policyholders and others;
        • the impact of the Company’s operations on the community and the environment;
        • the desirability of the Company maintaining a reputation for high standards of business conduct; and
        • the need to act fairly as between members of the Company.

        In order to promote the success of the Company, the Board directs and supervises the Company’s affairs within a framework of effective controls which enable risk to be assessed and managed. The directors set the Company’s objectives and policies and standards ensuring that its obligations to the State Street Group, its policyholders and others are understood and complied with and that it operates high standards of business conduct. Management have an open and ongoing dialogue with the FCA and PRA to discuss regulatory priorities and strategic developments, the outcomes of which are regularly reported to the Board.

        The Company has minimal suppliers in the conventional sense as it has outsourced all client facing, investment management and back office services to SSGA. The directors perform regular oversight of these services through review of operational reports, routine meetings with SSGA management and attendance by SSGA representatives at board meetings.

        The directors monitor policyholder activity through regular review of financial and other reports on premiums and claims and the performance of the funds in which the policyholders are invested.
        During the year the directors have also overseen the implementation of the Consumer Duty regulations across the Group and have received regular reports on how customer outcomes are monitored.

        Streamlined Energy and Carbon Reporting (SECR)

        The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 have implemented the United Kingdoms (“UK”) Government’s policy on Streamlined Energy and Carbon Reporting (“SECR”). This new regulation, which came into effect for reporting periods beginning on or after 1 April 2019, require large unquoted companies that have consumed in the UK more than 40,000 kilowatt-hours (“kWh”) of energy in the reporting period to include energy and carbon information within their Directors’ Report.

        The Company does not fall into scope of this regulation (as per s465 and s466 of the Companies Act 2006) and has elected not to voluntarily disclose company specific energy and carbon information.
        The Financial Stability Board (FSB) created the Task Force on Climate-related Financial Disclosures (TCFD) in 2015 to improve and increase reporting of climate-related financial information. Following the release of the Task Force’s 2023 Status Report, upon request of the FSB, the TCFD has been disbanded.

        The Company has a single shareholder, no employees, and given the outsourced nature of its operations, it has no direct impact on the community. Through its emerging risk and material risks reviews, the Board has considered its specific climate risk and additionally the Board has considered the broader environmental impacts of its activity. The Company has engaged closely with SSGA to understand its environmental position. The Company does not consider its physical and transitional climate risks to be material. The Group publishes an annual ESG report: https://www.statestreet.com/us/en/asset-manager/about/our-impact/esg-report.

        By order of the Board

        04 April 2024

        MARKETING COMMUNICATION

                                           

        FOR PROFESSIONAL INVESTORS USE ONLY.

         

        SSGA SPDR ETFS MAY NOT BE AVAILABLE OR SUITABLE FOR ALL. SPDR ETFs may be offered and sold only in those jurisdictions where authorised, in compliance with applicable regulations.

         

        Investing involves risk including the risk of loss of principal.

         

        ETFs trade like stocks, are subject to investment risk, fluctuate in market value and may trade at prices above or below the ETFs net asset value. Brokerage commissions and ETF expenses will reduce returns.

         

        The S&P 500® Index is a product of S&P Dow Jones Indices LLC or its affiliates (“S&P DJI”) and have been licensed for use by State Street Global Advisors.  S&P®, SPDR®, S&P 500®,US 500 and the 500 are trademarks of Standard & Poor’s Financial Services LLC (“S&P”); Dow Jones® is a registered trademark of Dow Jones Trademark Holdings LLC (“Dow Jones”) and has been licensed for use by S&P Dow Jones Indices; and these trademarks have been licensed for use by S&P DJI and sublicensed for certain purposes by State Street Global Advisors. The fund is not sponsored, endorsed, sold or promoted by S&P DJI, Dow Jones, S&P, their respective affiliates, and none of such parties make any representation regarding the advisability of investing in such product(s) nor do they have any liability for any errors, omissions, or interruptions of these indices.

         

        The information provided does not constitute investment advice as such term is defined under the Markets in Financial Instruments Directive (2014/65/EU) or applicable Swiss regulation and it should not be relied on as such. It should not be considered a solicitation to buy or an offer to sell any investment. It does not take into account any investor's or potential investor’s particular investment objectives, strategies, tax status, risk appetite or investment horizon. If you require investment advice you should consult your tax and financial or other professional advisor.

         

        The information contained in this communication is not a research recommendation or ‘investment research’ and is classified as a ‘Marketing Communication’ in accordance with the Markets in Financial Instruments Directive (2014/65/EU) or applicable Swiss regulation. This means that this marketing communication (a) has not been prepared in accordance with legal requirements designed to promote the independence of investment research (b) is not subject to any prohibition on dealing ahead of the dissemination of investment research.

         

        All information is from SSGA unless otherwise noted and has been obtained from sources believed to be reliable, but its accuracy is not guaranteed.  There is no representation or warranty as to the current accuracy, reliability or completeness of, nor liability for, decisions based on such information and it should not be relied on as such.

         

        This content has been issued by State Street Global Advisors Europe Limited is regulated by the Central Bank of Ireland. Registered office address 78 Sir John Rogerson’s Quay, Dublin 2. Registered Number: 49934. T: +353 (0)1 776 3000. F: +353 (0)1 776 3300.

         

        FOR EUROPEAN SPDR ETFs and MANAGED FUNDS:

         

        Please refer to the Fund’s latest Key Information Document (KID) and Prospectus before making any final investment decision. The latest English version of the prospectus and the KID can be found at www.ssga.com/ch/en_gb/institutional/ic/fund-finder. A summary of investor rights can be found here:

         

        Managed Funds: https://www.ssga.com/library-content/products/fund-docs/summary-of-investor-rights/ssga-investors-rights-summary-non-etf-ireland.pdf

         

        SPDR ETFs: https://www.ssga.com/library-content/products/fund-docs/summary-of-investor-rights/ssga-spdr-investors-rights-summary.pdf

         

        Note that the Management Company may decide to terminate the arrangements made for marketing and proceed with de-notification in compliance with Article 93a of Directive 2009/65/EC.

         

        SPDR ETFs is the exchange traded funds ("ETF") platform of State Street Global Advisors and is comprised of funds that have been authorised by Central Bank of Ireland as open-ended UCITS investment companies.

         

        SSGA SPDR ETFs Europe I & SPDR ETFs Europe II plc issue SPDR ETFs, and is an open-ended investment company with variable capital having segregated liability between its sub-funds. The Company is organized as an Undertaking for Collective Investments in Transferable Securities (UCITS) under the laws of Ireland and authorized as a UCITS by the Central Bank of Ireland.


        For Ireland Unit Trust:

        The State Street Ireland Unit Trust was authorised by the Central Bank of Ireland as unit trust pursuant to the Unit Trusts Act, 1990 and the European Communities (Alternative Investment Fund Managers Directive) Regulations 2013 (as amended) as a Retail Investor Alternative Investment Fund on 30 June 2015. This document should be read in conjunction with its Prospectus and Supplement. All transactions should be based on the latest available Prospectus and Supplement which contain more information regarding the charges, expenses and risks involved in your investment. Prospective investors may obtain these reports free of charge from State Street Global Advisors Europe Limited which is regulated by the Central Bank of Ireland.

         

        FOR STRATEGIES:

         

        This document provides summary information regarding the Strategy. This document should be read in conjunction with the Strategy's Disclosure Document, which is available from SSGA. The Strategy Disclosure Document contains important information about the Strategy, including a description of a number of risks.

         

        The whole or any part of this work may not be reproduced, copied or transmitted or any of its contents disclosed to third parties without SSGA’s express written consent.

        4978691.4.1.EMEA.INST

        Exp: 30.06.2025

        © [[]] %%State Street Corporation%%. All rights reserved.