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We have one operating segment, investment management and related services.
−Removed: We offer our services and products under our various distinct brand names, including, but not limited to, Alcentra ® , Benefit Street Partners ® , Brandywine Global Investment Management ® , Canvas ® , Clarion Partners ® , ClearBridge Investments ® , Fiduciary Trust International™, Franklin ® , Franklin Mutual Series ® , K2 ® , Legg Mason ® , Lexington Partners ® , Martin Currie ® , O’Shaughnessy ® , Putnam ® , Royce ® , Templeton ® and Western Asset Management Company ® .
−Removed: Unless otherwise indicated, our “funds” means the funds offered under our various brand names.
+Added: We offer our services and products under our various distinct brand names, including, but not limited to, Alcentra ® , Apera ® , Benefit Street Partners ® , Brandywine Global Investment Management ® , Canvas ® , Clarion Partners ® , ClearBridge Investments ® , Fiduciary Trust International™, Franklin ® , Franklin Mutual Series ® , K2 ® , Legg Mason ® , Lexington Partners ® , O’Shaughnessy ® , Putnam ® , Royce ® , Templeton ® and Western Asset Management Company ® .
+Added: Unless otherwise indicated, our “funds” means the funds offered under our various brand names, which may include co-branded funds.
We are a global investment management organization with over $1.6 trillion in assets under management (“AUM”) as of September 30, 2025.
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Our funds include registered funds (including exchange-traded funds, or “ETFs”) and unregistered funds.
−Removed: Related services include fund administration, sales and distribution, and shareholder servicing.
−Removed: We may perform services directly or through third parties.
+Added: Related services include applicable fund administration, sales and distribution, and shareholder servicing, which we may perform directly or outsource to third parties.
We also provide sub-advisory services to certain investment products sponsored by other companies that may be sold to investors under the brand names of those other companies or on a co-branded basis.
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We have added, among others:
−Removed: (i) the Templeton global investment firm in 1992, (ii) the Franklin Mutual Series investment firm in 1996, (iii) the Franklin Bissett Canadian investment firm in 2000, (iv) the Fiduciary Trust International investment and trust services firm in 2001, (v) the Benefit Street Partners alternative credit management firm in 2019, (vi) the Athena Capital Advisors investment and wealth management firm in March 2020, (vii) The Pennsylvania Trust Company investment and trust services firm in May 2020, (viii) the Legg Mason global investment firm in July 2020, (ix) the O’Shaughnessy Asset Management quantitative asset management firm in December 2021, (x) the Lexington Partners global alternatives investment firm in April 2022, (xi) the Alcentra alternative credit investment firm in November 2022, and (xii) the Putnam global investment firm in January 2024.
+Added: (i) the Templeton global investment firm in 1992, (ii) the Franklin Mutual Series investment firm in 1996, (iii) the Franklin Bissett Canadian investment firm in 2000, (iv) the Fiduciary Trust International investment and trust services firm in 2001, (v) the Benefit Street Partners alternative credit management firm in 2019, (vi) the Athena Capital Advisors investment and wealth management firm in March 2020, (vii) The Pennsylvania Trust Company investment and trust services firm in May 2020, (viii) the Legg Mason global investment firm in July 2020, (ix) the O’Shaughnessy Asset Management quantitative asset management firm in December 2021, (x) the Lexington Partners global alternatives investment firm in April 2022, (xi) the Alcentra alternative credit investment firm in November 2022, (xii) the Putnam global investment firm in January 2024, and (xiii) the Apera asset management firm in October 2025.
OUR BUSINESS STRUCTURE
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Our business is conducted through our subsidiaries, including our specialist investment managers.
−Removed: Our specialist investment managers include subsidiaries registered with the United States (“U.S.”) Securities and Exchange Commission (the “SEC”) as investment advisers under the Investment Advisers Act of 1940 (the “Advisers Act”), as well as subsidiaries registered as investment adviser equivalents in jurisdictions including Australia, Brazil, Canada, China, Commonwealth of The Bahamas, Hong Kong, Ireland, India, Japan, Luxembourg, Malaysia, Mexico, Saudi Arabia, Singapore, Switzerland, South Korea, the United Arab Emirates and the United Kingdom (“U.K.”).
+Added: Our specialist investment managers include subsidiaries registered with the United States (“U.S.”) Securities and Exchange Commission (the “SEC”) as investment advisers under the Investment Advisers Act of 1940 (the “Advisers Act”), as well as subsidiaries registered as investment adviser equivalents in jurisdictions including Australia, Brazil, Canada, China, Commonwealth of The Bahamas, Hong Kong, Ireland, India, Japan, Luxembourg, Malaysia, Mexico, Saudi Arabia, Singapore, Switzerland, South Korea, the United Arab Emirates, the United Kingdom (“U.K.”) and Uzbekistan.
Our AUM by Asset Class and Product Type
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funds include U.S.
−Removed: mutual funds, closed-end funds, ETFs, private funds, sub-advised funds and other products.
+Added: mutual funds, closed-end funds, ETFs, private funds, sub-advised funds and other products (including products we sub-advise and those sub-advised by third parties).
funds include a variety of cross-border funds principally domiciled in Luxembourg or Ireland, registered for sale to non-U.S.
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Our specialist investment managers offer diverse perspectives and specialized expertise across asset classes and strategies.
−Removed: Across our business, our specialist investment managers generally focus on a portion of the asset management industry in terms of the types of assets managed and each may differ in the types of products and services offered, the investment styles utilized, and the types and geographic locations of its clients.
−Removed: Each typically markets its products and services under its own brand name, with certain distribution functions provided by our corporate distribution subsidiaries where applicable.
+Added: Across our business, our specialist investment managers generally focus on a portion of the investment management industry in terms of the types of assets managed and each may differ in the types of products and services offered, the investment styles utilized, and the types and geographic locations of its clients.
+Added: Each typically markets its products and services under its own brand name, with certain distribution functions provided by our corporate distribution
+Added: subsidiaries where applicable.
We have in place revenue sharing arrangements with certain of our specialist investment managers.
Our specialist investment managers include:
−Removed: Benefit Street Partners, Brandywine Global, Clarion Partners, ClearBridge Investments, Fiduciary Trust International, Franklin Equity Group, Franklin Income Investors, Franklin Mutual Series, Franklin Templeton Fixed Income, Franklin Templeton Investment Solutions, Lexington Partners, Martin Currie, O’Shaughnessy Asset Management, Putnam Investments, Royce Investment Partners, Templeton Global Investments, Templeton Global Macro and Western Asset Management.
+Added: Benefit Street Partners, Brandywine Global, Clarion Partners, ClearBridge Investments, Fiduciary Trust International, Franklin Equity Group, Franklin Income Investors, Franklin Mutual Series, Franklin Templeton Fixed Income, Franklin Templeton Investment Solutions, Lexington Partners, O’Shaughnessy Asset Management, Putnam Investments, Royce Investment Partners, Templeton Global Investments, Templeton Global Macro and Western Asset Management.
Through our specialist investment managers, our investment products are offered globally to retail, institutional and high-net-worth clients, which may include, among others, individual investors, institutional investors, sovereign wealth funds, defined benefit and contribution plans, endowments and charitable foundations, healthcare systems and insurance companies.
Our investment products include mutual funds, closed-end funds, collective investment trusts, interval funds, private funds, institutional separate accounts, retail separately managed accounts, and other products.
−Removed: Our products and capabilities are designed to accommodate a variety of investment goals and preferences, from capital appreciation to capital preservation, as well as other investor preferences, which may include sustainable investing and other environmental, social and governance (“ESG”) preferences.
+Added: Our products and capabilities are designed to accommodate a variety of investment goals and preferences, from capital appreciation to capital preservation, as well as other investor preferences.
We are committed to partnering closely with our clients to understand their challenges and aspirations, and drawing on our investment capabilities and resources to offer and/or design the right investment solutions for them.
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We also market and distribute our products through various subsidiaries to institutional investors with separate accounts.
−Removed: Our services also include management of our ETF platforms.
Our specialist investment managers provide investment management services pursuant to agreements with each of our investment products and/or clients, including products for which we provide sub-advisory services.
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Certain of our specialist investment managers manage alternative products and investment strategies which provide our clients with alternatives to traditional equity and fixed income products and services.
−Removed: Our alternative products include private credit funds and structured products, business development companies, hedge funds (such as funds of funds and custom advisory solutions), private equity funds, secondary funds, venture capital funds and real estate funds.
+Added: Our alternative products include private credit funds and structured products, business development companies, hedge funds (such as funds of funds and custom advisory solutions), private equity funds, secondary private equity funds, venture capital funds and real estate funds.
These products employ various investment strategies and approaches, including loan origination, collateralized loan obligations, high-yield credit, hedge fund advisory, private equity and infrastructure transactions in emerging markets, global macro, consumer loans, direct real estate investments, and custom-tailored investment programs.
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Substantially all shareholder servicing fees are earned from our funds for providing transfer agency services, which include providing shareholder statements, transaction processing, client service and tax reporting.
−Removed: Shareholder servicing fees are primarily determined based on a contractual margin, or a percentage of AUM and either the number of transactions in shareholder accounts or the number of shareholder accounts.
+Added: Shareholder servicing fees are determined based on a contractual margin, or a percentage of AUM and either the number of transactions in shareholder accounts or the number of shareholder accounts.
We outsource various transfer agency and other services for our funds to third-party providers who serve as a sub-agent or delegate, depending on the jurisdiction.
Our fees and expenses are routinely benchmarked against applicable industry standards.
−Removed: The financial services industry is a highly competitive global industry.
+Added: The financial services industry is a highly competitive global environment.
Competition is based on various factors, including, among others, business reputation, investment performance, product mix and offerings, service quality and innovation, distribution relationships, and fees charged.
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and/or non-U.S.
−Removed: In particular, we are subject to various securities, compliance, corporate governance, disclosure, privacy, anti-bribery and anti-corruption, anti-money laundering, anti-terrorist financing, and economic, trade and sanctions laws and regulations, both domestically and internationally, as well as to various cross-border rules and regulations, such as the anti-bribery and anti-corruption rules under the Foreign Corrupt Practices Act of 1977 (“FCPA”) and the data protection rules under the General Data Protection Regulation (“GDPR”) of the European Union (“EU”).
+Added: In particular, we are subject to various securities, compliance, corporate governance, disclosure, privacy, anti-bribery and anti-corruption, anti-money laundering, anti-terrorist financing, and economic, trade and sanctions laws and regulations, both domestically and internationally, as well as to various cross-border rules and regulations, such as the anti-bribery and anti-corruption rules under the Foreign Corrupt Practices Act of 1977 and the data protection rules under the General Data Protection Regulation (“GDPR”) of the European Union (“EU”).
We are subject to sanctions programs administered by the Office of Foreign Assets Control of the U.S.
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operations also may be subject to regulation by U.S.
−Removed: regulators, including the SEC, the CFTC and the DOJ (for example with respect to the FCPA).
+Added: regulators, including the SEC, the CFTC and the DOJ.
Certain of our subsidiaries are registered with the SEC under the Advisers Act and/or with the CFTC, and many of our funds are registered with the SEC under the Investment Company Act.
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Antitrust Rules and Disclosure.
−Removed: In October 2024, the Federal Trade Commission (“FTC”) approved various rule changes under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (“HSR Act”) that amend certain premerger reporting and notification rules.
+Added: The Federal Trade Commission (“FTC”) has approved various rule changes under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (“HSR Act”) that amend certain premerger reporting and notification rules.
The HSR Act and its implementing rules require parties to certain mergers and acquisitions to submit premerger notifications to the FTC and DOJ and observe a waiting period before consummating such transactions.
−Removed: The new rule changes, scheduled to take effect in January 2025, significantly expand the premerger information and documentation required to be submitted in connection with an HSR filing, which could substantially increase our required disclosure and notification expenses and delay transactions.
+Added: The rules significantly expand the premerger information and documentation required to be submitted in connection with an HSR filing, which could substantially increase our required disclosure and notification expenses and delay transactions.
Cybersecurity Disclosure.
−Removed: The SEC’s amended rules requiring disclosure regarding cybersecurity risk management, strategy, governance and incident reporting by public companies became effective in December 2023.
−Removed: The amendments require public companies to (i) disclose, on a current basis, any cybersecurity incident it deems to be material within four business days on a Form 8-K;
+Added: The SEC’s amended rules require disclosure regarding cybersecurity risk management, strategy, governance and incident reporting by public companies.
+Added: The rules require public companies to (i) disclose, on a current basis, any cybersecurity incident it deems to be material within four business days on a Form 8-K;
(ii) describe, on an annual basis, the company’s processes, if any, for the assessment, identification and management of material risks from cybersecurity threats, as well as whether any risks from cybersecurity threats have materially affected or are reasonably likely to materially affect their business strategy, results of operations or financial condition;
and (iii) describe, on an annual basis, the board’s oversight of risks from cybersecurity threats and management’s role in assessing and managing those risks.
−Removed: The amendments require ongoing evaluation and analysis of our applicable processes and procedures, including regarding cyber incident response plans and procedures, disclosure analysis framework, risk management processes, and board oversight structure.
−Removed: Sustainable Investing and ESG, and Climate-Related Disclosure .
−Removed: Sustainable investing and ESG continue to be the focus of increased regulatory and legal scrutiny across jurisdictions.
−Removed: In the U.S., the SEC adopted, but subsequently stayed implementation of, climate disclosure rules to require public issuers to include enhanced disclosure and financial metrics regarding corporate climate-related information in their periodic reports and registration statements, and these rules remain subject to applicable legal challenges.
−Removed: In addition, state laws and regulations regarding these topics continue to evolve and impose further requirements.
−Removed: For example, in October 2023, California enacted a new climate accountability package pursuant to its Climate Corporate Data Accountability Act that requires annual disclosure of certain greenhouse gas emissions and Climate-Related Financial Risk Act that requires biennial disclosure of certain climate-related financial risks and mitigation measures, each beginning in 2026, subject to applicable implementing regulations and rulemaking that may impact final scope and compliance timing.
−Removed: Also, the SEC has increased its focus on disclosure and compliance related to ESG strategies of investment advisers and funds.
−Removed: Globally, the International Sustainability Standards Board and applicable sustainability disclosure standards impact how national regulators and governance bodies approach these and related topics.
+Added: The rules require ongoing evaluation and analysis of our applicable processes and procedures, including regarding cyber incident response plans and procedures, disclosure analysis framework, risk management processes, and board oversight structure.
+Added: Sustainability .
+Added: Sustainable investing and related environmental, social and governance (“ESG”) topics continue to be the focus of increased regulatory and legal scrutiny across jurisdictions.
+Added: In the U.S., the SEC adopted, but subsequently stayed the implementation of, climate disclosure rules to require public issuers to include enhanced disclosure and financial metrics regarding corporate climate-related information in their periodic reports and registration statements.
+Added: These rules remain stayed and subject to ongoing legal challenges.
+Added: In addition, state laws and regulations regarding these topics continue to evolve.
+Added: For example, in October 2023, California enacted a new climate accountability package pursuant to its Climate Corporate Data Accountability Act that requires annual disclosure of certain greenhouse gas emissions and Climate-Related Financial Risk Act that requires biennial disclosure of certain climate-related financial risks and mitigation measures, each beginning in 2026, subject to applicable implementing regulations that the California Air Resources Board is expected to finalize in late 2025 that may impact final scope and compliance timing.
+Added: Globally, the independent International Sustainability Standards Board and other applicable sustainability disclosure standards continue to impact how national regulators and governance bodies approach these and related topics.
Privacy and Data Protection.
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A majority of the jurisdictions where we operate are covered, or we expect will be covered, by stringent privacy and data protection laws and regulations.
−Removed: As the regulatory focus on privacy continues to intensify and laws and regulations concerning the management of personal data continue to expand, risks related to the handling of privacy obligations and personal data collection across our business will increase.
−Removed: For example, in addition to international data protection and privacy laws and regulations like the EU’s GDPR, we are, and expect to continue to be, subject to and affected by existing, new and evolving country, federal and state laws, regulations and guidance around the world impacting consumer and personnel privacy, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and various other U.S.
+Added: As the regulatory focus on privacy continues to intensify and laws and regulations concerning the management of personal
+Added: data continue to expand, risks related to the handling of privacy obligations and personal data collection across our business will increase.
+Added: For example, in addition to international data protection and privacy laws and regulations like the EU’s GDPR, we are, and expect to continue to be, subject to and affected by existing, new and evolving country, federal and state laws, regulations and guidance around the world impacting consumer and personnel privacy, including various U.S.
state consumer privacy laws that provide for enhanced consumer protections for their residents and impose requirements for the handling, disclosure and deletion of personal information of their residents.
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To the extent that we or any of our funds are designated as a SIFI or G-SIFI, such designations would add additional supervision, review, monitoring and/or regulation resulting in increased scrutiny and oversight that could impact our business.
−Removed: Derivatives and Other Financial Products.
−Removed: Regulators continue to review practices and regulations relating to the use of futures, swaps and other derivatives, which could result in further restrictions and limitations on the use of such products.
−Removed: In October 2020, the SEC adopted new rules governing the use of derivatives by certain registered investment companies, including certain mutual funds, designed to address investor protection concerns, which became effective in August 2022.
−Removed: Key aspects of the new framework include, among other things, value at risk limits on a fund entering into derivatives transactions, required risk management program, and further fund board oversight, reporting and compliance requirements.
−Removed: The EU and other countries have adopted and implemented, or are in the process of adopting or implementing, similar and additional requirements.
−Removed: There is the risk that full mutual recognition may not be achieved between the various regulators, which may cause us to incur duplicate regulation and transaction costs.
The DOL’s 2024 amended fiduciary rule broadening the definition of who is considered an “investment advice fiduciary” to a retirement investor, and adding significant restrictions and requirements for the use of prohibited transaction exemptions typically relied upon by investment firms such as ours, remains subject to applicable legal challenges.
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The QPAM amendment makes material changes and imposes additional conditions and affirmative requirements for the ongoing use of such exemption.
+Added: On August 7, 2025, President Trump issued an Executive Order to facilitate the ability of participants in 401(k) and other defined contribution plans to obtain exposure to alternative assets, including private equity, real estate, and digital assets.
Private Fund Adviser Reforms.
−Removed: In May 2023, the SEC adopted amendments to Form PF, which is the confidential reporting form that investment advisers to private funds file to provide confidential information to the SEC and the FSOC.
−Removed: The amendments require (i) current and quarterly reporting by large hedge fund advisers regarding certain events that may indicate stress at a fund or signal broader systemic risk;
−Removed: and (ii) enhanced reporting by large private equity advisers to allow the FSOC to monitor systemic risk.
−Removed: The amendments also require large private equity fund advisers to report information on general partner and limited partner clawbacks on an annual basis as well as additional information on their strategies and borrowings as a part of their annual filing.
−Removed: The current and quarterly event reporting requirements became effective in November 2023 and the remaining amendments became effective in May 2024.
−Removed: Money Market Fund Reforms .
−Removed: The regulatory structure governing U.S.
−Removed: money market funds was previously reformed to address perceived systemic risks of money market funds relating to fund stability and investor risks, including allowing certain funds to impose liquidity fees and redemption gates under certain circumstances.
−Removed: In July 2023, the SEC adopted additional rule and form amendments concerning money market funds registered under the Investment Company Act, intended to address problems experienced by certain money market funds in connection with the COVID-19 pandemic.
−Removed: The new and amended rules were phased in through October 2024 and, among other changes, impose increased minimum liquidity requirements, impose mandatory liquidity fees on institutional prime and institutional tax-exempt funds under certain circumstances, eliminate redemption gates, and permit share cancellation measures during periods of negative
−Removed: interest rates.
−Removed: In addition, the Form PF was further amended to require additional information regarding the private liquidity funds that an investment manager advises.
+Added: In February 2024, the SEC and CFTC jointly adopted amendments to Form PF, which is the confidential reporting form that certain investment advisers to private funds file to provide confidential information to the agencies and the FSOC.
+Added: The amendments require all private fund advisers to report additional information about themselves and the funds they advise, including assets under management, withdrawal and redemption rights, gross and net asset value, inflows and outflows, borrowings and types of creditors, beneficial ownership, and fund performance.
+Added: Hedge fund advisers are subject to additional reporting requirements with respect to the funds they advise, including information about investment strategies, counterparty exposures, and trading and clearing mechanisms.
+Added: Large hedge fund advisers that report on qualifying hedge fund assets are required to report more detailed information about investment exposures, borrowing and counterparty exposure, market factor effects, currency exposure, turnover, country and industry exposure, central clearing counterparty reporting, risk metrics, investment performance, portfolio liquidity, and financing and investor liquidity.
+Added: The compliance date for the amended reporting requirements has been extended, most recently until October 2026.
+Added: The SEC has indicated that, during the further extension period, it will continue its substantive review of the amendments and Form PF more generally.
Fund Names Rule Reforms.
4 unchanged sentences
The SEC did not clearly define these terms and instead is allowing fund managers the flexibility to create their own reasonable definitions.
−Removed: Compliance with the rules is required effective in December 2025.
+Added: As extended in April 2025, compliance with the rules is required for larger fund complexes by June 2026.
+Added: Digital Assets.
+Added: Regulatory attention to digital assets—including cryptocurrencies, stablecoins, tokenized securities and other distributed ledger instruments—has continued to intensify across jurisdictions.
+Added: leadership has
+Added: shown greater support for financial technology innovation and activity.
+Added: In July 2025, the U.S.
+Added: enacted legislation governing the issuance and regulatory oversight of payment stablecoins.
+Added: Congress is considering legislation that would allocate primary oversight of most other digital asset activities between the SEC and CFTC.
+Added: Also in July 2025, the President’s Working Group on Digital Asset Markets issued a report that includes numerous legislative and regulatory recommendations.
+Added: The SEC, CFTC, and other agencies have begun implementing these recommendations.
+Added: Internationally, the EU’s Markets in Crypto-Assets Regulation became fully applicable in late 2024, and the United Kingdom, Singapore, Hong Kong and Japan have introduced or strengthened licensing, prudential and consumer-protection rules for crypto-asset service providers.
+Added: Although the expanding regulatory framework raises legal, compliance and operational challenges for firms, the anticipated clarity and predictability around permissible digital asset activities is broadly positive for the market and its participants.
and Global Tax Compliance.
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The CSSF’s rules include capital resource, governance and risk management requirements, business conduct rules, remuneration rules and oversight of systems and controls.
−Removed: Our international funds include two broad ranges of cross-border UCITS that are domiciled in Luxembourg and Ireland, as applicable, and thereby subject to regulation by the CSSF and the Central Bank of Ireland.
+Added: Our international funds include two broad ranges of cross-border UCITS that are domiciled in Luxembourg and Ireland, and thereby subject to regulation by the CSSF and the Central Bank of Ireland.
Both UCITS are also registered for public sale in many countries around the world, both in the EU and beyond, and thus are also subject to the laws of, and certain supervision by, the governmental authorities of those countries.
3 unchanged sentences
The FCA’s rules under that act govern a firm’s capital resources requirements, senior management arrangements, business conduct, interaction with clients, and systems and controls.
−Removed: The FCA recently established Sustainability Disclosure Requirements and we are reviewing the applicable product, marketing and other disclosure requirements for compliance with the December 2024 deadline.
+Added: In 2024, we updated the applicable product, marketing and other materials of our U.K.
+Added: funds in line with the FCA’s new Sustainability Disclosure Requirements and we are preparing the first annual disclosure for funds with sustainability characteristics for compliance with the December 2025 deadline.
We offer a significant number of EU UCITS to U.K.
−Removed: retail investors which will need to apply for registration under the U.K.’s new Offshore Funds Regime by mid-2025 in order to continue such offerings.
+Added: retail investors which have registered under the U.K.’s new Offshore Funds Regime to continue such offerings.
We await a further consultation from the U.K.
−Removed: Treasury as to how such funds may in the future also be covered by the Sustainability Disclosure Requirements.
+Added: Treasury as to how such funds may in the future also be covered by the FCA’s Sustainability Disclosure Requirements.
In addition, the EU Markets in Financial Instruments Directive, as revised and expanded in 2018 (“MiFID II”), regulates the provision of investment services and conduct of investment activities throughout the European Economic Area (“EEA”).
2 unchanged sentences
MiFID II also includes a ban on commission and other payments (“inducements”) to independent advisers and discretionary managers, which has changed the commercial relationships between fund providers and distributors.
−Removed: Arrangements with non-independent advisers have also been affected, as narrower rules around the requirement that any commission reflect an enhancement of the service to customers come into effect, along with a prescriptive list of permissible non-monetary benefits.
−Removed: The interpretation of the inducements rules has also resulted in major changes to how fund managers finance investment research with many firms, including ours.
+Added: Arrangements with non-independent advisers have also been affected, as narrower rules around the requirement that any commission reflect an enhancement of the service to customers came into effect, along with a prescriptive list of permissible non-monetary benefits.
+Added: The interpretation of the inducements rules has also resulted in major changes to how fund managers finance investment research with many firms, including ours, though changes to those rules are due to take effect in 2026 and the impact of such changes remains to be seen.
The European Market Infrastructure Regulation sets out rules in relation to the central clearing of specified derivatives.
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The availability of such sustainability disclosures may impact the investment decisions of European investors.
+Added: The European Commission is currently reviewing SFDR and expected to propose major changes before the end of 2025.
The EU’s Corporate Sustainability Due Diligence Directive (“CSDD”) will impose due diligence obligations requiring companies to identify, and to prevent or at least mitigate, adverse impacts on human rights and the environment across their value chain, including by their subsidiaries, supply chain partners and clients.
1 unchanged sentence
The CSDD remains subject to further secondary rulemaking and guidance around implementation.
−Removed: While CSDD does not currently apply to investment funds, the European Commission is required to consider the merits of potentially extending the requirements to funds within the next two years.
+Added: While CSDD does not currently apply to investment funds, the European Commission is required to consider the merits of potentially extending the requirements to funds.
As investors in the public markets do not have the contractual relationship with issuers to compel them to provide the information required by CSDD, the imposition of CSDD to funds could prove problematic for the industry.
+Added: With a fresh political focus on encouraging economic growth and regulatory simplification, a fundamental review of both CSDD and the EU’s Corporate Sustainability Reporting Directive (“CSRD”) began early in 2025 and continues, and the implementation deadlines for both CSDD and CSRD have been pushed back to allow for resolution of that process.
In Australia, our subsidiaries are subject to various Australian federal and state laws and are regulated by the Australian Securities and Investments Commission (“ASIC”).
4 unchanged sentences
to foster fair, efficient and competitive capital markets;
−Removed: to foster capital
+Added: to foster capital formation;
and to contribute to the stability of the financial system and the reduction of systemic risk.
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jurisdictions where our subsidiaries, branches and representative offices, as well as certain joint ventures or companies in which we own minority stakes, are authorized to conduct business.
−Removed: We are also subject to regulation and supervision by, among others, the Securities Commission of The Bahamas, the Central Bank of Brazil and the Comissão de Valores Mobiliários in Brazil, the China Securities Regulatory Commission in the People’s Republic of China, the Financial Services Commission and the Financial Supervisory Service in South Korea, the Securities Commission in Malaysia, the Comision Nacional Bancaria y de Valores in Mexico, the Polish Securities and Exchange Commission, the Romanian Financial Services Authority, the Swiss Federal Banking Commission, the Financial Supervisory Commission in the Republic of China, the Dubai Financial Services Authority in the United Arab Emirates, the Saudi Capital Market Authority, and the State Securities Commission of Vietnam.
+Added: We are also subject to regulation and supervision by, among others, the Securities Commission of The Bahamas, the Comissão de Valores Mobiliários in Brazil, the China Securities Regulatory Commission and the Financial Supervisory Commission in the People’s Republic of China, the Securities Commission in Malaysia, the Comision Nacional Bancaria y de Valores in Mexico, the Romanian Financial Services Authority, the Saudi Capital Market Authority, the Financial Services Commission and the Financial Supervisory Service in South Korea, the Swiss Federal Banking Commission, the Dubai Financial Services Authority in the United Arab Emirates, the National Agency of Perspective Projects in Uzbekistan, and the State Securities Commission of Vietnam.
INTELLECTUAL PROPERTY
We have used, registered, and/or applied to register certain trademarks, service marks and trade names to distinguish our sponsored products and services from those of our competitors in the U.S.
−Removed: and in other countries and jurisdictions, including, but not limited to, Alcentra ® , Benefit Street Partners ® , Brandywine Global Investment Management ® , Canvas ® , Clarion Partners ® , ClearBridge Investments ® , Fiduciary Trust International™, Franklin ® , Franklin Mutual Series ® , K2 ® , Legg Mason ® , Lexington Partners ® , Martin Currie ® , O’Shaughnessy ® , Putnam ® , Royce ® , Templeton ® and Western Asset Management Company ® .
+Added: and in other countries and jurisdictions, including, but not limited to, Alcentra ® , Apera ® , Benefit Street Partners ® , Brandywine Global Investment Management ® , Canvas ® , Clarion Partners ® , ClearBridge Investments ® , Fiduciary Trust International™, Franklin ® , Franklin Mutual Series ® , K2 ® , Legg Mason ® , Lexington Partners ® , O’Shaughnessy ® , Putnam ® , Royce ® , Templeton ® and Western Asset Management Company ® .
Our trademarks, service marks and trade names are important to us and, accordingly, we enforce our trademark, service mark and trade name rights.
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The retention of our key investment personnel is material to the management of our business.
+Added: As a global asset manager, we are committed to building and maintaining an inclusive workplace that respects and values all employees, To support our efforts, we have established dedicated resources and a global governance structure.
+Added: We support our business resource groups, regional executive councils, partnerships, programs and other practices that align with this focus.
At an enterprise level, we use employee surveys to understand sentiment and engagement in the organization.
−Removed: At a team level, our performance management system supports ongoing, active discussion about goals and objectives.
We also host live forums for leaders to engage directly with employees to help reinforce our culture of open feedback.
Our employees have access to a valuable set of equitable and competitive total rewards, which consists of a mix of monetary and non-monetary rewards designed to recognize their time, talents and results.
−Removed: Recognizing the importance of diversity, equity, and inclusion (“DEI”) is a priority in our organization.
−Removed: We believe that our ability to attract, develop and retain a diverse and highly-skilled workforce is important to our long-term success.
−Removed: We have developed DEI strategies and initiatives anchored in our core values.
−Removed: To support our DEI efforts, we have allocated dedicated resources for DEI, established a global governance structure, and have established research-based DEI policies and procedures.
−Removed: We believe that our commitment to creating and maintaining a diverse workforce, including backgrounds and perspectives, makes us a better place to work and a more resilient business.
−Removed: We value an inclusive culture that leverages the expertise and perspectives of our diverse workforce as an important factor in our ability to deliver innovative and relevant client solutions in a dynamic marketplace.
+Added: We have developed strategies and initiatives anchored in our core values to prioritize attracting and retaining top talent, promoting an inclusive workplace, driving good decision-making and igniting innovation, all of which we believe are important to our long-term success.
AVAILABLE INFORMATION
4 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.