Overview
- Headquarters
- Los Angeles, CA
- Total Firm Assets
- $4320.8 billion
- Average High-Net-Worth Client Portfolio Size
- $4.6 million
- Stated Minimum Account Size
- $250,000
Fee Disclosure
ADV BROCHURE CRMC
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $1,000,000 | 0.55% |
| $1,000,001 | $3,000,000 | 0.45% |
| $3,000,001 | $10,000,000 | 0.40% |
| $10,000,001 | and above | 0.38% |
Estimated Annual Advisory Fees
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $5,500 | 0.55% |
| $5 million | $22,500 | 0.45% |
| $10 million | $42,500 | 0.42% |
| $50 million | $194,500 | 0.39% |
| $100 million | $384,500 | 0.38% |
Actual fees may vary; other investment costs may apply.
Clients
- High-Net-Worth Share of Firm Assets
- 0.09%
- Number of High-Net-Worth Clients
- 830
- Total Client Accounts
- 23,578
- Discretionary Accounts
- 23,578
Services Offered
Services: Portfolio Management for Individuals, Portfolio Management for Companies, Portfolio Management for Pooled Investment Vehicles
Regulatory Filings
- SEC CRD Number
- 110885
Additional Brochure: ADV BROCHURE CRMC (2026-09-25)
View Document Text
CAPITAL RESEARCH AND MANAGEMENT COMPANY
333 South Hope Street, 55th Floor
Los Angeles, California 90071
Phone: (213) 486-9200
capitalgroup.com
Form ADV, Part 2A Date:
September 25, 2026
This brochure provides information about the qualification and business practices of Capital Research and
Management Company. Throughout this brochure and related materials, Capital Research and Management Company
refers to itself as a “registered investment adviser” or “being registered”. You should be aware that registration with the
United States Securities and Exchange Commission (“SEC”) or a state securities authority does not imply a certain level
of skill or training.
If you have any questions about the contents of this brochure, please contact us at ADVPart2@capgroup.com.
The information in this brochure has not been approved or verified by the SEC or by any state securities authority.
Additional information about Capital Research and Management Company also is available on the SEC’s website at
www.adviserinfo.sec.gov.
1
ITEM 2: MATERIAL CHANGES
There have been no other material changes since the last update of Capital Research and Management Company’s
Form ADV, Part 2A brochure dated March 2, 2026.
2
ITEM 3: TABLE OF CONTENTS
Item
Page
1. Cover Page… .......................................................................................................................................... 1
2. Material Changes… ............................................................................................................................... 2
3. Table of Contents… ............................................................................................................................... 3
4. Advisory Business… .............................................................................................................................. 4
Fees and Compensation… ................................................................................................................... 6
5.
6. Performance-Based Fees and Side-by-Side Management… ............................................................ 8
7. Types of Clients… ................................................................................................................................... 9
8. Methods of Analysis, Investment Strategies and Risk of Loss… ....................................................... 10
9. Disciplinary Information… ................................................................................................................... 22
10. Other Financial Industry Activities and Affiliations… ........................................................................... 23
11. Code of Ethics… .................................................................................................................................... 25
12. Brokerage Practices… ........................................................................................................................... 27
13. Review of Accounts… ................................................................................................................................ 35
14. Client Referrals and Other Compensation ............................................................................................ 36
15. Custody ................................................................................................................................................... 37
16. Investment Discretion… ....................................................................................................................... 38
17. Voting Client Securities ........................................................................................................................ 39
18. Financial Information… ......................................................................................................................... 42
19. Requirements for State-Registered Advisers…..................................................................................... 43
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ITEM 4: ADVISORY BUSINESS
Capital Research and Management Company, a wholly-owned subsidiary of The Capital Group Companies, Inc., is a
Delaware corporation that traces its roots to 1931. The Capital Group Companies form one of the most experienced
families of investment management firms in the world. Capital Research and Management Company and The Capital
Group Companies, Inc. have always been privately held.
Capital Research and Management Company is the investment adviser to the Capital Group exchange-traded funds
(ETFs), closed-end management investment companies that operate as interval funds, including Capital Group KKR
funds, and to the American Funds family of mutual funds, including American Funds Target Date Retirement Series,
American Funds Portfolio Series, American Funds Retirement Income Portfolio Series, American Funds College
Target Date Series, and American Funds Insurance Series. It is also the investment adviser to the Capital International
Fund and International Investment Portfolios, two Luxembourg investment companies; Capital Group Fund, a United
Kingdom Open-Ended Investment Company; and an investment adviser and/or sub-adviser to investment vehicles of
Capital International Asset Management (Canada), Inc., Capital Group Private Client Services, Inc., Capital
International Management Company Sarl, Capital International Sarl, Capital International K.K., Capital International
Limited, and Capital International, Inc., affiliates of Capital Research and Management Company. In addition, Capital
Research and Management Company serves as the investment adviser to Capital Bank and Trust Company in its
capacity as the trustee of certain collective investment trusts that are exempt from SEC registration. Capital Bank and
Trust Company is an affiliate of Capital Research and Management Company.
Capital Research and Management Company also provides investment management to individuals, foundations, trusts
and other investors through wrap fee programs or dual contract programs (“managed account programs”) sponsored
by broker-dealers or other financial institutions. In such programs, the sponsor provides a platform where investors
can choose a variety of service providers to invest and manage their account. In a wrap fee program, a participant
enters into an advisory agreement with the sponsor and the sponsor enters into an agreement with Capital Research
and Management Company. In a dual contract program, a participant enters into an investment advisory agreement
with Capital Research and Management Company and a separate agreement with the program sponsor. Dual contract
programs are generally managed in a manner similar to wrap programs including with respect to the commissions and
other charges on trades as discussed throughout this brochure.
In cases where Capital Research and Management Company is an investment adviser to a managed account
program, clients are typically not charged separate brokerage commissions for the execution of transactions in the
client’s account that are executed by or through the sponsor; these commissions are generally included in the wrap
fee charged by the sponsor. Depending on the equity strategy a client is invested in, a significant portion of equity
portfolio transactions could be executed by broker-dealers other than the sponsor firm. Fixed-income transactions
for wrap programs are generally executed by broker-dealers other than the sponsor selected by Capital Research
and Management Company or its affiliate. The practice of trading with a broker-dealer other than the wrap program
sponsor is frequently referred to as “trading away.”
Trading away from the sponsor will usually result in the imposition of a commission or equivalent fees on equity trades.
Such fees are paid by the client and are in addition to the wrap fee. Please also refer to the disclosure under the
heading “Managed Account Programs” under Item 12 (Brokerage Practices) in this brochure for further information.
For some wrap fee programs, Capital Research and Management Company provides model portfolios to the sponsor
and the sponsor will have ultimate decision-making responsibility and discretionary authority for those accounts.
Accordingly, end investors in non-discretionary model delivery programs are not considered advisory clients of Capital
Research and Management Company. Generally, Capital Research and Management Company is paid an investment
management fee based on the amount of assets it manages in the wrap program by the wrap program’s sponsor.
Clients who enroll in wrap fee programs should carefully review the fee structure and other program documents
provided by the sponsor.
In addition, Capital Research and Management Company recommends model portfolios to the sponsor for certain
wrap fee or advisory programs. Capital Research and Management Company acts as portfolio strategist to the
sponsor in recommending model portfolios. Capital Research and Management Company does not have an advisory
relationship with, or act as a fiduciary to, any end investor of a sponsor using model portfolios. The sponsor has
ultimate decision-making responsibility and discretionary authority for the accounts investing in the model portfolios
and is solely responsible for recommending such portfolios to end investors. If the end investor implements the model
portfolios, the end investor will pay the expenses of the funds as disclosed in each fund’s prospectus provided to
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the end investor during the enrollment process. Capital Research and Management Company does not recommend
a share class. The sponsor is responsible for share class selection. In some cases, the mutual fund may have a lower
cost share class available for purchase outside of the portfolios offered by the sponsor. An end investor who holds a
less-expensive share class of a fund will pay lower fees over time – and earn higher investment returns – than an end
investor who holds a more expensive share class of the same mutual fund.
Capital Research and Management Company will create certain portfolios entirely from proprietary mutual funds and
ETFs. Capital Research and Management Company does not consider other potential investments in constructing all-
proprietary portfolios. Other model portfolios are intended for sponsors of wrap fee or advisory programs that wish to
invest in a mix of actively- and passively-managed mutual funds and ETFs. In creating hybrid portfolios of active and
passive funds and ETFs, Capital Research and Management Company will ordinarily maintain a minimum allocation
of 25% or more to funds and ETFs in each of the active and passive components. Capital Research and Management
Company will only consider proprietary mutual funds and ETFs for the active component of a hybrid portfolio. Capital
Research and Management Company will ordinarily recommend ETFs managed by third-party asset managers for the
passive component. When selecting a third-party asset manager, Capital Research and Management Company will
consider factors such as liquidity, fees, style drift and reputation, among others. In this regard, Capital Research and
Management Company has discretion to select third-party asset managers based on a number of factors, including,
but not limited to, distribution considerations, and may select different asset managers for different sponsors. Capital
Research and Management Company receives compensation from the mutual funds and ETFs that make up the model
portfolios for the investment advisory and other services it provides to those mutual funds and ETFs but does not
charge a separate fee for its model portfolio construction services. This creates an incentive for Capital Research and
Management Company to select actively-managed proprietary mutual funds and ETFs over passively-managed third
party ETFs. It also creates an incentive for Capital Research and Management Company to select proprietary mutual
funds and ETFs with higher fees. This may create an incentive to select proprietary mutual funds and ETFs in certain
asset classes over other asset classes.
Capital Research and Management Company manages equity assets through three equity investment divisions, fixed-
income assets through its fixed-income division, and asset allocation portfolios through its solutions division. The
three equity divisions, Capital World Investors, Capital Research Global Investors and Capital International Investors
make investment decisions on an independent basis. The investment divisions also provide investment services
to institutional clients and other accounts advised by affiliates of Capital Research and Management Company.
Capital Research and Management Company’s only business is investment management and related services.
Capital Research and Management Company typically builds portfolios for funds and accounts (collectively referred
to as “funds” throughout the brochure) from the bottom-up using rigorous fundamental research to find attractive
investments and manage risks. Investment decisions are subject to a fund’s objective, policies and restrictions and the
oversight of the appropriate investment-related committees of Capital Research and Management Company and its
investment divisions. The objective, policies and restrictions of each of the funds managed by Capital Research and
Management Company are set forth in its prospectus and statement of additional information or other disclosure
documents. Depending on a fund’s objective, policies and restrictions, Capital Research and Management Company
generally invests in equity securities, fixed-income securities or a combination of both. When consistent with a fund’s
or account’s objectives, strategies and guidelines, Capital Research and Management may also invest in other types of
securities or investment instruments, including, but not limited to, futures, options on futures, currency options, forward
contracts, swaps and repurchase agreements. Please also refer to Item 8 (Methods of Analysis, Investment Strategies
and Risk of Loss) in this Brochure for further information.
As of June 30, 2026, Capital Research and Management Company managed approximately $4,320,750,232,546 in
discretionary assets under management.
5
ITEM 5: FEES AND COMPENSATION
Capital Research and Management Company’s fees are generally not negotiable. Capital Research and Management
Company’s management fees are paid pursuant to investment advisory agreements, or in the case of Capital Bank
and Trust Company, Capital International Assets Management (Canada), Inc. and Capital International Management
Company Sarl, advisory or sub-advisory agreements. Capital Research and Management Company’s management
fees are generally based on a percentage of assets under management and, for certain funds, a combination of assets
under management and gross investment income.
Management fees are paid monthly by the American Funds, Capital Group KKR funds and ETFs to Capital Research
and Management Company based on the previous month’s daily net asset levels. Management fees for each of
the American Funds, Capital Group KKR funds and ETFs are described in such fund’s prospectus and statement of
additional information.
The annual fees for advisory services provided by Capital Research and Management Company to Capital Bank and
Trust Company, in its capacity as trustee to certain collective investment trusts, are agreed upon from time to time in
writing. The fees that Capital Bank and Trust Company receives for such collective investment trusts are described in
the characteristic documents.
The annual fees for investment advisory or sub-advisory services for Capital International Assets Management
(Canada), Inc., Capital Group Fund, and Capital International Fund are agreed to from time to time in writing.
Management fees paid by investors in each of these funds are described in such fund’s governing documents.
The funds incur fees and expenses in addition to the management fees described above, including administrative
service fees, custodial fees and other fund expenses. With respect to the American Funds and Capital Group KKR
funds, Capital Research and Management Company provides certain transfer agent and administrative services
for shareholders of the funds pursuant to an administrative service agreement. Capital Research and Management
Company contracts with third parties and affiliates, including American Funds Service Company, the funds’ transfer
agent, and Capital Client Group, Inc., the funds’ principal underwriter, to provide some of these services. In addition,
the funds will incur brokerage and other transaction costs. Please refer to Item 12 (Brokerage Practices) below for a
discussion of Capital Research and Management Company’s brokerage practices.
Conflicts Related to Valuation of Investments
Capital Research and Management Company’s management fees are generally based on a percentage of assets under
management. As a result, Capital Research and Management Company faces an inherent conflict of interest to overstate
the fair valuation of portfolio securities, thereby increasing its fees. Capital Research and Management Company seeks to
mitigate this conflict through the adoption of valuation policies and procedures, and through the use of third-party pricing
services where available to fair value securities without readily available market quotations. Capital Research and
Management Company has established a Joint Fair Valuation Committee to oversee and approve these fair value
determinations. To mitigate potential conflicts of interest, investment professionals (such as portfolio managers or
investment analysts) are not permitted to serve on the Committee. Additionally, the Fund Board is responsible for
overseeing the valuation process for funds registered with the SEC and receives periodic reporting to evaluate the
operation of relevant fair value processes.
Managed Account Program Sponsor Fees:
Capital Research and Management Company investment advisory services are also available through various managed
account programs including, but not limited to, bundled “wrap fee” programs sponsored by certain unaffiliated broker-
dealers or other financial institutions where the sponsor offers bundled investment management, custody, brokerage
or other services. The fee paid by the client to the sponsor, which may include the fee for advisory services provided by
Capital Research and Management Company, is generally based on a percentage of assets. Clients should contact
their program sponsor for more information on fees in connection with such programs.
Fees charged to sponsors generally fall within the following ranges:
U.S. Equity
0.28% - 0.39%
International Equity/Global Equity
0.32% - 0.38%
6
Core Bond
0.22%
Core Plus Bond
0.26%
Municipal Bond
0.12%
Municipal Income Bond
0.22%
Fees charged by Capital Research and Management Company to the wrap program’s sponsor will vary based on the
relationship, services provided, level of discretion, and other factors. In addition to the above rates, fees for certain
overlay, administrative, platform, or other maintenance fees charged by select sponsor firms may apply, and they
generally range from 0.02% to 0.05% as applicable. Further, the above rates will differ for services provided by affiliates.
As such, please also refer to our affiliates’ and any of their sub-advisers’ respective ADVs for further details about their
services and fees. Sponsor firms should refer to their agreements with Capital Research and Management Company for
details on the fee schedule that applies for their relationship.
Dual Contract Client Fees:
In managed account programs that have a dual contract arrangement, Capital Research and Management
Company’s fee is typically paid directly by the client pursuant to a separate agreement. Fee rates for investment
management services for dual contract arrangements are determined based on assets invested in the applicable
strategy and may exceed the rates disclosed in the Managed Account Program Sponsor Fees schedule above by
up to 18 basis points, depending on account size and other relevant factors.
Different fee schedules apply for certain long-standing clients, initial investors in a new strategy, and clients with
customized mandates or special service needs. A highest fee rate of 17 basis points on all assets, regardless of
account size, will apply to clients in the Morgan Stanley dual contract municipal bond wrap fee program.
Aggregation Policy:
Where requested by the client or the client’s financial advisor, the values of personal accounts across a relationship (a
“Relationship”) invested in the same investment strategy under the same sponsor program (the “Eligible Accounts”)
may be aggregated to determine the applicable fee rate in the Annual Fee Rate table above if the total assets of the
Eligible Accounts are at least $5 million. A “Relationship” includes client, client’s spouse, son/daughter, parent,
brother/sister, grandchild. For the avoidance of doubt, the Eligible Accounts do not include any account of an
employer-sponsored retirement plan subject to ERISA.
Calculation Methodology:
Fees will generally be prorated for partial periods and calculated quarterly in arrears based on the average daily
market value or appraised value of the account, as determined in good faith by Capital Research and Management
Company.
Third party sponsors of certain managed account programs choose to calculate the fees for clients in their program.
Each sponsor uses its own fee calculation methodology, which may result in different fee calculation methodologies
among sponsors. Refer to your Investment Management Agreement and the ADV of the sponsor of your managed
account program for further details.
Model Portfolios:
Capital Research and Management Company may agree to a relationship with a third party involving the provision of
model portfolios. Fees for such services will vary based on the relationship, services provided, and other factors.
7
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE
MANAGEMENT
Capital Research and Management Company charges asset-based fees for providing investment advisory services to
client accounts. However, in limited circumstances, Capital Research and Management Company or its affiliates receive
fees that are based on the performance of the account. Certain of Capital Research and Management Company’s
portfolio managers manage both types of accounts. Managing both types of accounts simultaneously creates a
risk of conflicts for the portfolio manager to (i) allocate more attractive investment opportunities to accounts with
performance-based fees and/or (ii) make investments for those accounts that are more speculative than for accounts
that do not have performance-based fees.
Capital Research and Management Company and its affiliates have adopted allocation policies that are designed
in part to address these potential conflicts of interest. See Item 12 (Brokerage Practices) of this Brochure for Capital
Research and Management Company’s policy on allocating trades fairly, which is designed to allocate trades to clients
in a fair and equitable manner over time, taking into consideration the interests of each client. Non-investment factors,
such as fee arrangements, are not considered when allocating trades among clients.
In addition, while Capital Research and Management Company and its affiliates provide individual investment advice
and treatment to each portfolio, portfolio managers focus on particular investment mandates, using similar investment
strategies in connection with the management of multiple portfolios, which helps minimize the potential for conflicts
of interest. Further, Capital Research and Management Company and its affiliates provide investment advice to client
portfolios that are managed using investment objectives and strategies that are similar to but not identical to one
another. The results of such portfolios may vary depending on a number of factors, including, but not limited to, fees
and expenses, portfolio size, transaction costs, cash flows, currencies, securities pricing time, timing of trade
executions, taxes and portfolio holdings and any applicable investment limitations.
Capital Research and Management Company reviews funds with similar objectives managed by Capital Research
and Management Company and its affiliates at least annually. These reviews generally include, among other things,
information related to investment results, including dispersion of results among funds and reasons for such dispersion,
if any, significant fund guidelines and the investment structure of the portfolio.
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ITEM 7: TYPES OF CLIENTS
Capital Research and Management Company provides investment management services to registered investment
companies and other pooled investment vehicles. It is also the investment adviser to the Capital International Fund
and International Investment Portfolios, two Luxembourg investment companies, Capital Group Fund, a United
Kingdom Open-Ended Investment Company, and an investment adviser and/or sub-adviser to investment vehicles of
Capital International Asset Management (Canada), Inc., Capital Group Private Client Services, Inc., Capital
International Management Company Sarl, Capital International Sarl, Capital International K.K., Capital International
Limited, and Capital International, Inc., affiliates of Capital Research and Management Company. In addition, Capital
Research and Management Company serves as the investment adviser to Capital Bank and Trust Company in its
capacity as the trustee of certain collective investment trusts that are exempt from SEC registration. Capital Research
and Management Company also provides investment management and related services to participants in managed
account programs.
Minimum account sizes for fund investments are disclosed in each fund’s prospectus, statement of additional
information, characteristics, annual information form or other disclosure documents.
Minimum account sizes vary by strategy and program. Please refer to Item 5 (Fees and Compensation) for information
on applicable minimum account sizes.
9
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK
OF LOSS
Capital Research and Management Company maintains an investment philosophy that is distinguished by four key
beliefs:
• Fundamental research underlies all investment decisions. Capital Research and Management Company and its
affiliates employ teams of experienced analysts who regularly gather in-depth, first-hand information on markets
and companies around the globe.
•
Investment decisions are not made lightly. In addition to providing extensive research, our investment
professionals go to great lengths to determine the difference between the fundamental value of a company and its
price in the marketplace.
• A long-term approach. It’s part of the big-picture view our investment professionals take of the companies in which
we invest. This is reflected by the typically low turnover of portfolio holdings in the funds and accounts we manage.
In addition, our investment professionals usually remain with us for many years and are compensated according to
their investment results over time.
• The Capital System. Capital Research and Management Company uses a system of multiple portfolio managers
in managing most account and fund assets. Under this approach, the portfolio of a fund or account is divided
into segments managed by individual managers who decide how their respective segments will be invested.
In addition, Capital Research and Management Company’s investment research analysts may make investment
decisions with respect to a portion of a fund’s or client’s portfolio. Over time, this method has contributed to
consistency of results and continuity of management.
Capital Research and Management Company manages portfolios that seek to capture the risk and return
characteristics of other investment vehicles with the same investment strategy. In certain other instances, Capital
Research and Management Company manages net new strategies that seek to reflect certain investment
characteristics and underlying convictions of an existing similar investment strategy, while incorporating specific client
requirements. In each case, to manage these types of portfolios, we implement a proprietary solution that utilizes a
commercially available third-party risk model to help identify the characteristics of the underlying holdings of the
strategy. Capital Research and Management Company considers certain constraints on the resulting portfolio
including but not limited to turnover, market impact, number of holdings, trading cost, trading footprint and holding
period. The results of such portfolios may vary depending on a number of factors, including, but not limited to, fees
and expenses, portfolio size, transaction costs, cash flows, currencies, securities pricing time, timing of trade
executions, taxes and portfolio holdings and any applicable investment limitations. These risks may be heightened for
vehicles that have a limitation on the number of holdings in the resulting portfolio, such as the portfolios created for
managed account programs.
Investment decisions are subject to a fund’s or account’s objectives, policies and restrictions and the oversight of
the appropriate investment-related committees of Capital Research and Management Company and its investment
divisions. The objectives, policies and restrictions of each of the funds managed by Capital Research and Management
Company are set forth in the governing documents of the fund or guidelines of the account. Depending on a fund’s or
account’s objective, policies and restrictions, Capital Research and Management Company generally invests in equity
securities, fixed-income securities or a combination of both. Capital Research and Management Company invests
in U.S. and international equity securities, including common stocks, preferred stocks and convertible securities, of
companies with varying market capitalizations. Capital Research and Management Company also invests in U.S. and
international fixed-income securities, including bonds, loan participations, mortgage-backed securities and municipal
bonds of varying quality and duration. When consistent with a fund’s or account’s objectives, strategies and guidelines,
Capital Research and Management Company may also invest in other types of securities or investment instruments,
including, but not limited to, futures, options on futures, currency options, forward contracts, swaps and repurchase
agreements. Capital Research and Management Company may consider environmental, social and governance (“ESG”)
factors that, depending on the facts and circumstances, are material to the value of an issuer or instrument. ESG
factors may include, but are not limited to, environmental issues (e.g., water use, emission levels, waste, environmental
remediation), social issues (e.g., human capital, health and safety, changing customer behavior) or governance issues
(e.g., board composition, executive compensation, shareholder dilution).
10
Clients in discretionary managed account programs may impose certain reasonable restrictions on Capital Research
and Management Company’s management of their account. For example, clients may request that Capital Research
and Management Company exclude certain categories of investment (e.g., “no tobacco”) from a strategy and/or
provide a list of specific issuers for exclusion. In implementing category restrictions, Capital Research and Management
Company relies on third-party data, including in the application of “screens,” to help determine whether certain issuers
should be included or excluded from a strategy or an individual portfolio. When applying screens that exclude certain
issuers or types of issuers, absent express instruction from a client to the contrary, Capital Research and Management
Company will generally exclude issuers that derive any form of income from an excluded category, even if such issuer
is not commonly associated with the excluded category. For example, if a client requests that Capital Research and
Management Company exclude “adult entertainment” investment, issuers including large media conglomerates
may be excluded from the strategy. Additionally, Capital Research and Management Company will rely on third-
party data with respect to some or all of these determinations, and different third-party data providers may identify
different issuers as associated with different industries and these determinations may change over time. As a result,
category restrictions may be more or less inclusive depending on the methodology used by the third parties to define
the categories. For example, if a client requests Capital Research and Management Company exclude “fossil fuel”
investments, issuers that are classified as utilities may not be restricted. In cases where third-party data is not available,
Capital Research and Management Company will rely on internal good faith determinations to assess which issuers
should be included or excluded from a strategy and to implement such strategy. In addition, with respect to certain
managed account programs, Capital Research and Management Company relies on program sponsors to monitor,
implement, and/or enforce client requested restrictions. This may result in different exclusions or other investment
considerations between these managed account program clients and other types of clients, and among different
managed account programs.
The implementation of client-requested restrictions may impact the relative performance of the associated
accounts—positively or negatively—depending on the relative performance of investments selected on the basis of such
considerations. There is no guarantee that Capital Research and Management Company’s efforts to select investments
based on the requested restrictions will be successful.
Investment Strategies
Investment strategies offered by Capital Research and Management Company for managed account programs
include:
Equity strategies
U.S. Equity — The strategy’s investment objective is to provide prudent growth of capital and conservation of principal.
The strategy invests primarily in equity and equity related securities of U.S. issuers with a focus on prudent growth.
Generally, may invest no more than 15% at the time of purchase in securities of non-U.S. issuers, such as American
Depositary Receipts (“ADRs”).
U.S. Growth — The strategy’s investment objective is to provide long-term growth of capital. Takes a disciplined
approach to growth investing, focusing primarily on well-managed U.S. companies with sound fundamentals. Invests
in companies of any size that have solid long-term growth records and attractive future growth potential. The strategy
may invest to a limited extent in securities of issuers outside the United States.
U.S. Income and Growth — The strategy’s investment objective is to produce income and to provide an opportunity for
growth of principal consistent with sound common stock investing. A disciplined approach to investing that uses strict
eligibility criteria to screen for companies across a broad array of industries with strong balance sheets and consistent
dividends. The strategy seeks to be fully invested. A portfolio may invest up to 10% of its assets in companies outside
the United States and not included in the S&P 500.
U.S. Flexible Growth and Income — The strategy’s investment objective is to achieve long-term growth of capital and
income. With an emphasis on growth over income, the strategy seeks undervalued and overlooked opportunities. It
invests in companies with high-quality products and leading market shares with the underappreciated potential for
growth in sales, earnings and dividends. It has the flexibility to invest a sizable portion of its assets outside of the U.S.
The strategy may invest up to 35% of assets in securities of issuers outside the United States.
U.S. Flexible Growth — The strategy’s investment objective is to provide growth of capital. This strategy takes a flexible
11
approach to growth investing, seeking opportunities in traditional growth stocks as well as cyclical companies and
turnarounds with significant potential for growth of capital. Geographic flexibility also allows portfolio managers to
pursue opportunities outside of the United States. The strategy may invest up to 25% of assets in securities of issuers
outside the United States.
U.S. Conservative Growth and Income — The strategy strives for the balanced accomplishment of three objectives:
current income, growth of capital and conservation of principal. Conservatively managed to reduce volatility and risk,
this strategy seeks to invest in common stocks of companies that are likely to participate in the growth of the American
economy and whose dividends appear to be sustainable. The strategy may invest up to 20% of its assets in securities
of issuers domiciled outside the United States and not included in the S&P 500 Index. May invest up to 5% of its assets
in securities of issuers domiciled outside the United States and Canada and not included in the S&P 500 Index.
U.S. Core — The strategy’s investment objective is to achieve long-term growth of capital and income. With an 80-plus-
year track record, this strategy invests primarily in larger, well-established companies that represent a wide cross
section of the U.S. economy. It seeks to provide long-term growth of capital and income with a focus on future income.
A portfolio may invest up to 15% of its assets in securities of issuers domiciled outside the United States.
International Equity — The strategy’s investment objective is to provide prudent growth of capital and conservation of
principal. This international strategy invests in companies that are predominantly based in developed markets. Seeks to
provide a smoother return profile over a full market cycle – with less volatility and lower downside capture than the
market – by focusing on companies with characteristics associated with long-term growth and resilience to market
declines, including strong balance sheets and dividend payments. The portfolio may invest in securities of non-U.S.
issuers that trade in the United States and may invest up to 10% at the time of purchase in securities of emerging
market issuers.
International Growth — The strategy’s primary investment objective is to provide long-term growth of capital. This
international strategy seeks growth of capital by employing a flexible approach to investing in attractively valued
companies in developed and emerging markets that are positioned to benefit from innovation, global economic
growth, increasing consumer demand or a turnaround in business conditions. Normally, at least 80% of assets must be
invested in securities of issuers in Europe or the Pacific Basin.
Global Equity — The strategy’s investment objective is to provide prudent growth of capital and conservation of
principal. This global strategy pursues prudent growth of capital and conservation of principal by investing in
companies that are predominantly based in developed markets. The strategy seeks to provide a smoother return
profile over a full market cycle — with less volatility and lower downside capture than the market — by focusing on
companies with characteristics associated with long-term growth and resilience to market declines, including strong
balance sheets and dividend payments. A portfolio may invest in securities of non-U.S. issuers that trade in the United
States and may invest up to 10% at the time of purchase in securities of emerging market issuers.
Global Growth — The strategy’s primary investment objective is to provide long-term growth of capital. Seeks to take
advantage of evolving global trade patterns by predominantly investing in companies that have potential for growth
in capital. Invests primarily in multinational companies with a meaningful share of their sales and operations outside
of their home countries. This approach provides the strategy’s portfolio managers with geographic flexibility and the
ability to navigate different markets. A portfolio may invest up to 100% of assets outside the United States, though
the strategy has typically invested in issuers throughout the world.
Fixed-Income strategies
U.S. Intermediate Bond (formerly Core Bond) — The strategy’s investment objective is to provide current income and
capital preservation. Invests primarily in debt securities rated BBB/Baa or better or unrated but determined to be of
equivalent quality by Capital Research and Management Company. May not invest in high-yield bonds. Under normal
circumstances, the dollar-weighted average effective maturity of the portfolio will be between three and five years and
will have a duration range of +/– one year of the benchmark duration.
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Core Bond — The strategy’s investment objective is to provide as high a level of current income as is consistent with
the preservation of capital. Has the ability to invest in every sector of the bond market and pursue multiple sources
of active return, with a limited percentage of below-investment-grade holdings. Typically, the portfolio will be
invested in intermediate- to long-term securities.
Short Municipal — The strategy’s investment objective is to provide current income exempt from federal tax, and capital
preservation. A short-term tax-exempt fixed income allocation with an emphasis on high-quality and liquid short maturity
credits. Invests in municipal bonds with quality ratings of BBB-/Baa3 or better while seeking to maintain a high level of
liquidity. Normally, the strategy has a duration range of +/–0.5 year of the benchmark duration. Will not invest in securities
that subject the investor to the federal alternative minimum tax (AMT).
Intermediate Municipal — The strategy’s investment objective is to provide current income exempt from federal tax,
and capital preservation. An intermediate-term tax-exempt fixed income allocation with an emphasis on investment
grade and intermediate maturity credits. Invests in municipal bonds with quality ratings of BBB-/Baa3 or better while
seeking to maintain a high level of liquidity. Normally, the strategy has a duration range of +/– one year of the
benchmark duration. Will not invest in securities that subject the investor to the federal alternative minimum tax (AMT).
Long Municipal — The strategy’s investment objective is to provide current income exempt from federal tax, and
capital preservation. A longer-term tax-exempt fixed income allocation with an emphasis on investment-grade and
long-maturity credits. Invests in municipal bonds with quality ratings of BBB-/Baa3 or better while seeking to
maintain a high level of liquidity. Normally, the strategy has a duration range of +/– one year of the benchmark
duration. Will not invest in securities that subject the investor to the AMT.
Core Plus — The strategy’s investment objective is to provide current income and seek maximum total return, consistent
with preservation of capital. Primarily invests in bonds and other debt securities, which may be represented by derivatives.
Has the ability to invest in every sector of the bond market and pursue multiple sources of active return.
Municipal Income — The strategy’s investment objective is to provide a high level of current income exempt from regular
federal income tax, consistent with the preservation of capital. Primarily invests in, or seeks to derive a majority of its
income from, securities that are exempt from regular federal income tax. Invests in municipal bonds with quality ratings
of BBB-/Baa3 or better. Normally, the strategy has a duration range of +/– one year of the benchmark duration.
Balanced and total opportunity strategies
World Dividend Growers — The strategy’s investment objective is to provide long-term total returns by investing in
companies globally that have the potential to provide combinations of current yield and dividend growth. The
strategy invests primarily in equity and equity-related securities we believe will increase dividends paid over a
multiyear period. Investments are limited to securities on the strategy’s eligible list, based on current yield and
anticipated dividend growth.
Completion Funds
Certain strategies for managed account programs invest in an affiliated mutual fund (“completion funds”) used to
enhance diversification and provide access to securities that are difficult, or not feasible, to include in a managed
account. These completion funds are available only to managed account clients in the applicable strategy and the
completion fund’s shares must be redeemed, which may occur by the completion fund’s investment adviser, if a client
exits the strategy. Additional information, including risks and investment restrictions, is described in the applicable
completion fund registration statement. Clients invested in the completion funds are not charged fees and expenses
at the completion fund level.
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INVESTMENT RISKS
Investing in securities involves risk of loss that funds and their shareholders or other clients should be prepared to
bear. Each fund or account is subject to certain risks associated with the investments made by Capital Research and
Management Company in accordance with that fund’s policies and restrictions. The risks associated with an investment
in each fund are set forth in that fund’s prospectus and statement of additional information or other disclosure
documents. These risks may include, but are not limited to, certain of the risks set forth below.
• Management — Capital Research and Management Company actively manages investments. Consequently,
the funds and accounts are subject to the risk that the methods and analyses including models, tools and data
employed by the investment adviser in this process may be flawed or incorrect and may not produce the desired
results. This could cause a fund or account to lose value or their investment results to lag relevant benchmarks or
other funds or accounts with similar objectives.
• Market conditions — The prices of, and income generated by, the common stocks and other securities held by the
funds or accounts may decline – sometimes rapidly or unpredictably –due to various factors, including events or
conditions affecting the general economy or particular industries or companies; overall market changes; local,
regional or global political, social or economic instability; governmental, governmental agency or central bank
responses to economic conditions; levels of public debt and deficits; changes in inflation rates; and currency
exchange rate, interest rate and commodity price fluctuations.
Economies and financial markets throughout the world are highly interconnected. Economic, financial or political
events, trading and tariff arrangements, wars, terrorism, cybersecurity events, natural disasters, public health
emergencies (such as the spread of infectious disease), bank failures and other circumstances in one country
or region, including actions taken by governmental or quasi-governmental authorities in response to any of the
foregoing, could have impacts on global economies or markets. As a result, whether or not the fund or account
invests in securities of issuers located in or with significant exposure to the countries affected, the value and
liquidity of the fund’s or account’s investments may be negatively affected by developments in other countries
and regions.
•
Investing in stocks — Investing in stocks may involve larger price swings and greater potential for loss than other
types of investments. As a result, the value of the underlying funds and accounts may be subject to sharp declines
in value. Income provided by an underlying fund or account may be reduced by changes in the dividend policies
of, and the capital resources available at, the companies in which the underlying fund or account invests. These risks
may be even greater in the case of smaller capitalization stocks.
•
Investing in growth-oriented stocks — Growth-oriented common stocks and other equity-type securities (such
as preferred stocks, convertible preferred stocks and convertible bonds) may involve larger price swings and
greater potential for loss than other types of investments. These risks may be even greater in the case of smaller
capitalization stocks.
•
Investing in income-oriented stocks — The value of the securities and income provided by the funds and accounts
may be reduced by changes in the dividend policies of, and the capital resources available for dividend payments
at, the companies in which a fund or account invests.
•
Issuer risks — The prices of, and the income generated by, securities held by the fund or account may decline in
response to various factors directly related to the issuers of such securities, including reduced demand for an
issuer’s goods or services, poor management performance, major litigation, investigations or other controversies
related to the issuer, changes in the issuer’s financial condition or credit rating, changes in government regulations
affecting the issuer or its competitive environment and strategic initiatives such as mergers, acquisitions or
dispositions and the market response to any such initiatives. An individual security may also be affected by factors
relating to the industry or sector of the issuer or the securities markets as a whole, and conversely an industry or
sector of the securities markets may be affected by a change in financial condition or other event affecting a single
issuer. To the extent that the market prices of securities of issuers in the same or related industries or sectors tend to
move in the same direction at the same time, and these issuers make up a sizeable portion of the market, events affecting
one issuer, industry or sector or the securities markets generally may have a larger impact. If such issuers represent a
substantial portion of major market indices, or the economy, a downturn in the prices of their securities may have a
disproportionate adverse effect on the overall market, even if other segments of the market perform well. The fund or
14
account invests in issuers based on their level of investment conviction. At times, the fund or account may invest
more significantly in a single issuer, which could increase the fund’s or account’s volatility and risk of loss arising from
the factors described above.
• Currency — The prices of, and the income generated by, most debt securities held by a fund or account may also be
affected by changes in relative currency values. If the U.S. dollar appreciates against foreign currencies, the value in
U.S. dollars of the fund’s or account’s securities denominated in such currencies would generally fall and vice versa.
• Currency transactions — In addition to the risks generally associated with investing in derivative instruments, the
use of forward currency contracts involves the risk that currency movements will not be accurately predicted by
the investment adviser, which could result in losses to the fund or account. While entering into forward currency
contracts could minimize the risk of loss due to a decline in the value of the hedged currency, it could also limit
any potential gain that may result from an increase in the value of the currency. Additionally, Capital Research and
Management Company may use forward currency contracts to increase exposure to a certain currency or to shift
exposure to currency fluctuations from one country to another. Forward currency contracts may expose the fund or
account to potential gains and losses in excess of the initial amount invested.
The fund or account may also enter into currency transactions to provide for the purchase or sale of a currency
needed to purchase a security denominated in such currency. In addition, the fund or account may enter into
forward currency contracts to protect against changes in currency exchange rates, to increase exposure to a
particular foreign currency, to shift exposure to currency fluctuations from one currency to another or to seek to
increase returns. A forward currency contract is an agreement to purchase or sell a specific currency at a future date
at a fixed price.
•
Investing in small companies — Investing in smaller companies may pose additional risks. For example, it is
often more difficult to value or dispose of small company stocks and more difficult to obtain information about
smaller companies than about larger companies. Furthermore, smaller companies often have limited product
lines, operating histories, markets and/or financial resources, may be dependent on one or a few key persons for
management, and can be more susceptible to losses. Moreover, the prices of their stocks may be more volatile than
stocks of larger, more established companies, particularly during times of market turmoil.
•
Investing outside the United States — Securities of issuers domiciled outside the United States or with significant
operations or revenues outside the United States, and securities tied economically to countries outside the United
States, may lose value because of adverse political, social, economic or market developments (including social
instability, regional conflicts, terrorism and war) in the countries or regions in which the issuers are domiciled,
operate or generate revenue or to which the securities are tied economically. These securities may also lose value
due to changes in foreign currency exchange rates against the U.S. dollar and/or currencies of other countries.
Issuers of these securities may be more susceptible to actions of foreign governments, such as nationalization,
currency blockage or the imposition of price controls, sanctions or punitive taxes, each of which could adversely
impact the value of these securities. Securities markets in certain countries may be more volatile and/or less liquid
than those in the United States. Investments outside the United States may also be subject to different regulatory,
legal, auditing, financial reporting, accounting and recordkeeping standards and practices, and may be more
difficult to value, than those in the United States. In addition, the value of investments outside the United States may
be reduced by foreign taxes, including foreign withholding taxes on interest and dividends. Further, there
may be increased risks of delayed settlement of securities purchased or sold by the fund or account,
which could impact the liquidity of the fund’s or account’s portfolio. These risks of investing outside the
United States may be heightened in connection with investments in emerging market.
•
Investing in emerging markets — Investing in emerging markets may involve risks in addition to and greater than
those generally associated with investing in the securities markets of developed countries. For instance, emerging
market countries tend to have less developed political, economic and legal systems than those in developed
countries. Accordingly, the governments of these countries may be less stable and more likely to intervene in
the market economy, for example, by imposing capital controls, nationalizing a company or industry, placing
restrictions on foreign ownership and on withdrawing sale proceeds of securities from the country, and/or imposing
punitive taxes that could adversely affect the prices of securities. Information regarding issuers in emerging markets
may be limited, incomplete or inaccurate, and such issuers may not be subject to regulatory, accounting, auditing,
and financial reporting and recordkeeping standards comparable to those to which issuers in more developed
markets are subject. The fund’s or account’s rights with respect to its investments in emerging markets, if any, will
generally be governed by local law, which may make it difficult or impossible for the fund or account to pursue
15
legal remedies or to obtain and enforce judgments in local courts. In addition, the economies of these countries
may be dependent on relatively few industries, may have limited access to capital and may be more susceptible
to changes in local and global trade conditions and downturns in the world economy. Securities markets in these
countries can also be relatively small and have substantially lower trading volumes. As a result, securities issued in
these countries may be more volatile and less liquid, more vulnerable to market manipulation, and more difficult
to value, than securities issued in countries with more developed economies and/or markets. Less certainty with
respect to security valuations may lead to additional challenges and risks in calculating the fund’s or account’s net
asset value. Additionally, emerging markets are more likely to experience problems with the clearing and settling
of trades and the holding of securities by banks, agents and depositories that are less established than those in
developed countries.
• Exposure to country, region, industry or sector — Subject to the investment limitations, the fund or account may
have significant exposure to a particular country, region, industry or sector. Such exposure may cause the fund
or account to be more impacted by risks relating to and developments affecting the country, region, industry
or sector, and thus its net asset value may be more volatile, than a fund or account without such levels of
exposure. For example, if the fund or account has significant exposure in a particular country, then social, economic,
regulatory or other issues that negatively affect that country may have a greater impact on the fund or account than
on a fund or account that is more geographically diversified.
•
Investing in private companies — The fund may invest in companies that have not publicly offered their securities.
Investing in private companies can involve greater risks than those associated with investing in publicly traded
companies. For example, the securities of a private company may be subject to the risk that market conditions,
developments within the company, investor perception, or regulatory decisions may delay or prevent the company
from ultimately offering its securities to the public. Furthermore, these investments are generally considered to be
illiquid until a company’s public offering and are often subject to additional contractual restrictions on resale that would
prevent the fund from selling its company shares for a period of time following the public offering.
Investments in private companies can offer the fund significant growth opportunities at attractive prices. However,
these investments can pose greater risk, and, consequently, there is no guarantee that positive results can be achieved
in the future.
•
Investing in debt instruments — The prices of, and the income generated by, bonds and other debt securities held
by the fund or account may be affected by factors such as the interest rates, maturities and credit quality of these
securities. Rising interest rates will generally cause the prices of bonds and other debt securities to fall. Also, when
interest rates rise, issuers of debt securities that may be prepaid at any time, such as mortgage- or other asset-
backed securities, are less likely to refinance existing debt securities, causing the average life of such securities to
extend. A general change in interest rates may cause investors to sell debt securities on a large scale, which could
also adversely affect the price and liquidity of debt securities and could also result in increased redemptions from
the fund. Falling interest rates may cause an issuer to redeem, call or refinance a debt security before its stated
maturity, which may result in the fund or account having to reinvest the proceeds in lower yielding securities.
Longer maturity debt securities generally have greater sensitivity to changes in interest rates and may be subject to
greater price fluctuations than shorter maturity debt securities.
Bonds and other debt securities are also subject to credit risk, which is the possibility that the credit strength of
an issuer or guarantor will weaken or be perceived to be weaker, and/or an issuer of a debt security will fail to
make timely payments of principal or interest and the security will go into default. Changes in actual or perceived
creditworthiness may occur quickly. A downgrade or default affecting any of the fund’s or account’s securities
could cause the value of the fund’s or account’s shares to decrease. Lower quality debt securities generally have
higher rates of interest and may be subject to greater price fluctuations than higher quality debt securities. Credit
risk is gauged, in part, by the credit ratings of the debt securities in which the fund or account invests. However,
ratings are only the opinions of the rating agencies issuing them and are not guarantees as to credit quality or an
evaluation of market risk. Capital Research and Management Company and its affiliates rely on their own credit
analysts to research issuers and issues in assessing various credit and default risks.
•
Investing in lower rated debt instruments — Lower rated debt securities or instruments, rated Ba1/BB+ or below
by Nationally Recognized Statistical Rating Organizations, generally have higher rates of interest and involve
greater risk of default or price declines due to changes in the issuer’s creditworthiness than those of higher quality
16
debt securities. The market prices of these securities may fluctuate more than the prices of higher quality debt
securities and may decline significantly in periods of general economic difficulty.
•
Investing in depository receipts — Depositary receipts are securities that evidence ownership interests in, and
represent the right to receive, a security or a pool of securities that have been deposited with a bank or trust
depository. Such securities may be less liquid or may trade at a lower price than the underlying securities of the
issuer. Additionally, receipt of corporate information about the underlying issuer and proxy disclosure may not
be timely and there may not be a correlation between such information and the market value of the depositary
receipts.
•
Investing in securities backed by the U.S. government — U.S. government securities are subject to market risk,
interest rate risk and credit risk. Securities backed by the U.S. Treasury or the full faith and credit of the U.S.
government are guaranteed only as to the timely payment of interest and principal when held to maturity.
Accordingly, the current market values for these securities will fluctuate with changes in interest rates and the credit
rating of the U.S. government. Notwithstanding that these securities are backed by the full faith and credit of the
U.S. government, circumstances could arise that would prevent or delay the payment of interest or principal on
these securities, which could adversely affect their value and cause the fund to suffer losses. Such an event could
lead to significant disruptions in U.S. and global markets. Securities issued by U.S. government-sponsored entities
and federal agencies and instrumentalities that are not backed by the full faith and credit of the U.S. government
are neither issued nor guaranteed by the U.S. government.
•
Interest rate risk — The values and liquidity of the securities held by a fund or account may be affected by changing
interest rates. For example, the values of these securities may decline when interest rates rise and increase when
interest rates fall. Longer maturity debt securities generally have greater sensitivity to changes in interest rates and
may be subject to greater price fluctuations than shorter maturity debt securities. The fund or account may invest in
variable and floating rate securities. When the fund or account holds variable or floating rate securities, a decrease
in market interest rates will adversely affect the income received from such securities and the net asset value of the
fund’s or account’s shares. Although the values of such securities are generally less sensitive to interest rate changes
than those of other debt securities, the value of variable and floating rate securities may decline if their interest
rates do not rise as quickly, or as much, as market interest rates. Conversely, floating rate securities will not generally
increase in value if interest rates decline. During periods of extremely low short-term interest rates, the fund or
account may not be able to maintain a positive yield or total return and, in relatively low interest rate environments,
there are heightened risks associated with rising interest rates.
• Tax-exempt securities — When seeking to purchase securities which bear interest that is exempt from federal income
taxes there are risks that such interest may be reclassified as taxable by the Internal Revenue Service, or a state tax
authority. Actions by the issuer or future legislative, administrative or court actions also could adversely affect the tax-
exempt status of interest paid by such securities. Such reclassifications or actions could cause interest from a security to
become includable in the gross income of the holder of the security, possibly retroactively, subjecting fund
shareholders or clients to increased tax liability. In addition, such reclassifications or actions could cause the value of
the affected security, and therefore the value of the fund’s shares, to decline.
•
Investments in future delivery contracts — A fund or account may enter into transactions involving future delivery
contracts, such as to-be-announced (TBA) contracts and mortgage dollar rolls. These contracts involve the
purchase or sale of mortgage backed securities for settlement at a future date and predetermined price. When the
fund enters into a TBA commitment for the sale of mortgage-backed securities (which may be referred to as having
a short position in such TBA securities), the fund may or may not hold the types of mortgage-backed
securities required to be delivered. The fund may choose to roll these transactions in lieu of settling
them. When the fund rolls the purchase of these types of future delivery transactions, the fund or account
simultaneously sells the mortgage backed securities for delivery in the current month and repurchase substantially
similar securities for delivery at a future date at a predetermined price. When the fund or account rolls the sale of
these transactions rather than settling them, the fund or account simultaneously purchases the mortgage backed
securities for delivery in the current month and sells substantially similar securities for delivery at a future date at a
predetermined price. Such roll transactions can increase the turnover rate of the fund or account and may increase
the risk that prices may move unfavorably between the original and new contracts, potentially resulting in losses or
reduced returns for the fund or account.
17
•
Investing in mortgage-related and other asset backed securities — Mortgage-related securities, such as
mortgage-backed securities, and other asset-backed securities, include debt obligations that represent interests in
pools of mortgages or other income-bearing assets, such as consumer loans or receivables. Such securities often
involve risks that are different from or more acute than the risks associated with investing in other types of debt
securities. Mortgage-backed and other asset-backed securities are subject to changes in the payment patterns
of borrowers of the underlying debt, potentially increasing the volatility of the securities and a fund’s or account’s
net asset value. When interest rates fall, borrowers are more likely to refinance or prepay their debt before its
stated maturity. This may result in the fund or account having to reinvest the proceeds in lower yielding securities,
effectively reducing the fund’s or account’s income. Conversely, if interest rates rise and borrowers repay their debt
more slowly than expected, the time in which the mortgage-backed and other asset-backed securities are paid off
could be extended, reducing the fund’s or account’s cash available for reinvestment in higher yielding securities.
Mortgage-backed securities are also subject to the risk that underlying borrowers will be unable to meet their
obligations and the value of property that secures the mortgages may decline in value and be insufficient, upon
foreclosure, to repay the associated loans. Investments in asset-backed securities are subject to similar risks.
•
Investing in derivatives — The use of derivatives involves a variety of risks, which may be different from, or greater
than, the risks associated with investing in traditional securities, such as stocks and bonds. Changes in the value
of a derivative may not correlate perfectly with, and may be more sensitive to market events than, the underlying
asset, rate or index, and a derivative instrument may cause a fund or account to lose significantly more than its initial
investment. Derivatives may be difficult to value, difficult for the fund or account to buy or sell at an opportune
time or price and difficult to terminate or otherwise offset. The fund’s or account’s use of derivatives may result in
losses to the fund, and investing in derivatives may reduce the fund’s or account’s returns and increase the fund’s
or account’s price volatility. The fund’s or account’s counterparty to a derivative transaction (including, if applicable,
the fund’s or account’s clearing broker, the derivatives exchange or the clearinghouse) may be unable or unwilling
to honor its financial obligations in respect of the transaction. In certain cases, the fund or account may be hindered
or delayed in exercising remedies against or closing out derivative instruments with a counterparty, which may result in
additional losses. Derivatives are also subject to operational risk (such as documentation issues, settlement issues and
systems failures) and legal risk (such as insufficient documentation, insufficient capacity or authority of a counterparty,
and issues with the legality or enforceability of a contract).
•
Investing in swaps — Swaps, including interest rate swaps and credit default swap indices, or CDSIs, are subject to
many of the risks generally associated with investing in derivative instruments. Additionally, although swaps require
no initial investment or only a small initial investment in the form of a deposit of initial margin, the amount of a
potential loss on a swap could greatly exceed the initial amount invested. The use of swaps involves the risk that
the investment adviser will not accurately predict anticipated changes in interest rates or other economic factors,
which may result in losses to a fund or account. If the fund or account enters into a bilaterally negotiated swap,
the counterparty may fail to perform in accordance with the terms of the swap. If a counterparty defaults on its
obligations under a swap, the fund or account may lose any amount it expected to receive from the counterparty,
potentially including amounts in excess of the fund’s or account’s initial investment. Certain swaps are subject to
mandatory central clearing or may be eligible for voluntary central clearing. Although clearing interposes a central
clearinghouse as the ultimate counterparty to each participant’s swap, central clearing will not eliminate (but may
decrease) counterparty risk relative to uncleared bilateral swaps. Some swaps, such as CDSIs, may be dependent
on both the individual credit of the fund’s or account’s counterparty and on the credit of one or more issuers of any
underlying assets. If the fund or account does not correctly evaluate the creditworthiness of its counterparty and,
where applicable, of issuers of any underlying reference assets, the fund’s or account’s investment in a swap may
result in losses to the fund.
•
Investing in futures contracts — In addition to the risks generally associated with investing in derivative instruments,
futures contracts are subject to the creditworthiness of the clearing organizations, exchanges and futures
commission merchants with which a fund or account transacts. Additionally, although futures require only a small
initial investment in the form of a deposit of initial margin, the amount of a potential loss on a futures contract could
greatly exceed the initial amount invested. While futures contracts are generally liquid instruments under certain
market conditions futures may be deemed to be illiquid. For example, the fund or account may be temporarily
prohibited from closing out its position in a futures contract if intraday price change limits or limits on trading
volume imposed by the applicable futures exchange are triggered. If the fund or account is unable to close out a
18
position on a futures contract, the fund or account would remain subject to the risk of adverse price movements
until the fund or account is able to close out the futures position. The ability of the fund or account to successfully
utilize futures contracts may depend in part upon the ability of the fund’s or account’s investment adviser to
accurately forecast market and economic factors (such as interest rates) and to assess and predict the impact of such
market and economic factors on the futures in which the fund or account invests. If the investment adviser
incorrectly forecasts economic developments or incorrectly predicts the impact of such developments on the
futures in which it invests, the fund or account could suffer losses.
•
Investing in options — Options on currencies, securities and other instruments (referred to as the “underlying
instruments”) are subject to additional risks aside from those generally associated with investing in derivatives
instruments. For example, there may be significant differences between the underlying instruments and options
markets that could result in an imperfect correlation between these markets, which could cause a given transaction
not to achieve its objectives. When a put or call option on a particular underlying instrument is purchased to hedge
against price movements in a related underlying instrument, for example, the price to close out the put or call
option may move more or less than the price of the related underlying instrument. Options prices can diverge from
the prices of their underlying instruments for a number of reasons. Options prices are affected by such factors as
current and anticipated short-term interest rates, changes in the volatility of the underlying instrument, and the
time remaining until expiration of the contract, which may not affect security prices in the same way. Imperfect
correlation may also result from differing levels of demand in the options markets and the markets for the underlying
instruments, from structural differences in how options and underlying instruments are traded, or from imposition
of daily price fluctuation limits or trading halts. The fund or account may purchase or sell options contracts with
a greater or lesser value than the underlying instruments it wishes to hedge or intends to purchase in order to
attempt to compensate for differences in volatility between the contract and the underlying instruments, although
this may not be successful. If price changes in the fund’s or account’s options positions are less correlated with its
other investments, the positions may fail to produce anticipated gains or result in losses that are not offset by gains
in other investments. There is no assurance that a liquid market will exist for any particular options contract at any
particular time.
• Hedging — There may be imperfect or even negative correlation between the prices of the options and futures
contracts in which a fund or account invests and the prices of the underlying securities or indexes which the fund or
account seeks to hedge. For example, options and futures contracts may not provide an effective hedge because
changes in options and futures contract prices may not track those of the underlying securities or indexes they
are intended to hedge. In addition, there are significant differences between the securities market, on the one
hand, and the options and futures markets, on the other, that could result in an imperfect correlation between the
markets, causing a given hedge not to achieve its objectives. The degree of imperfection of correlation depends
on circumstances such as variations in speculative market demand for options and futures, including technical
influences in options and futures trading, and differences between the financial instruments being hedged and
the instruments underlying the standard contracts available for trading. A decision as to whether, when and how
to hedge involves the exercise of skill and judgment, and even a well-conceived hedge may be unsuccessful to
some degree because of market behavior or unexpected interest rate trends. In addition, the fund’s or account’s
investment in exchange-traded options and futures and their resulting costs could limit the fund’s or account’s
gains in rising markets relative to those of the underlying fund, or to those of unhedged funds or accounts
in general.
• Lending of portfolio securities — Securities lending involves risks, including the risk that the loaned securities may
not be returned in a timely manner or at all, which would interfere with the fund’s or account’s ability to vote proxies
or settle transactions, and/or the risk of a counterparty default. Additionally, a fund or account may lose money
from the reinvestment of collateral received on loaned securities in investments that decline in value, default or do
not perform as expected.
• Liquidity risk — Certain fund or account holdings may be or may become difficult or impossible to sell, particularly
during times of market turmoil. Liquidity may be impacted by the lack of an active market for a holding, legal or
contractual restrictions on resale, or the reduced number and capacity of market participants to make a market in
such holding. Market prices for less liquid or illiquid holdings may be volatile or difficult to determine, and reduced
liquidity may have an adverse impact on the market price of such holdings. Additionally, the sale of less liquid or
illiquid holdings may involve substantial delays (including delays in settlement) and additional costs and the fund or
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account may be unable to sell such holdings when necessary to meet its liquidity needs or to try to limit losses, or
may be forced to sell at a loss.
• Asset allocation — The fund’s or account’s percentage allocation to equity securities, debt securities and money
market instruments could cause the fund or account to underperform relative to relevant benchmarks and other
funds with similar investment objectives.
The fund or account may also hold cash or cash equivalents, including commercial paper and short-term securities
issued by the U.S. government, its agencies and instrumentalities. The percentage of the fund or account
invested in such holdings varies and depends on various factors, including market conditions and purchases
and redemptions of fund or account shares. Capital Research and Management Company may determine that it
is appropriate to invest a substantial portion of the fund’s or account’s assets in such instruments in response to
certain circumstances, such as periods of market turmoil. For temporary defensive purposes, the fund or account
may invest without limitation in such instruments. A larger percentage of such holdings could moderate the
fund’s or account’s investment results in a period of rising market prices. Alternatively, a larger percentage of such
holdings could reduce the magnitude of the fund’s or account’s loss in a period of falling market prices and provide
liquidity to make additional investments or to meet redemptions.
• Cybersecurity risks — With the increased use of technologies such as the Internet to conduct business, the fund or
account has become potentially more susceptible to operational and information security risks through breaches in
cybersecurity. In general, a breach in cybersecurity can result from either a deliberate attack or an unintentional
event. Cybersecurity breaches may involve, among other things, “ransomware” attacks, injection of computer
viruses or malicious software code, or the use of vulnerabilities in code to gain unauthorized access to digital
information systems, networks or devices that are used directly or indirectly by the fund or account or its service
providers through “hacking” or other means. Cybersecurity risks also include the risk of losses of service resulting
from external attacks that do not require unauthorized access to the fund’s or account’s systems, networks or
devices. For example, denial-of-service attacks on the investment adviser’s or an affiliate’s website could effectively
render the fund’s or account’s network services unavailable to fund or account shareholders and other intended
end-users. Any such cybersecurity breaches or losses of service may, among other things, cause the fund or
account to lose proprietary information, suffer data corruption or lose operational capacity or may result in the
misappropriation, unauthorized release or other misuse of the fund’s or account’s assets or sensitive information
(including shareholder personal information or other confidential information), the inability of fund or account
shareholders to transact business, or the destruction of the fund’s or account’s physical infrastructure, equipment or
operating systems. These, in turn, could cause the fund or account to violate applicable privacy and other laws and
incur or suffer regulatory penalties, reputational damage, additional costs (including compliance costs) associated
with corrective measures and/or financial loss. While the fund or account and its investment adviser have
established business continuity plans and risk management systems designed to prevent or reduce the impact of
cybersecurity attacks, there are inherent limitations in such plans and systems due in part to the ever-changing
nature of technology and cybersecurity attack tactics, and there is a possibility that certain risks have not been
adequately identified or prepared for.
In addition, cybersecurity failures by or breaches of the fund’s or account’s third-party service providers (including,
but not limited to, the fund’s or account’s investment adviser, transfer agent, custodian, administrators and other
financial intermediaries) may disrupt the business operations of the service providers and of the fund, potentially
resulting in financial losses, the inability of fund or account shareholders to transact business with the fund or
account and of the fund or account to process transactions, the inability of the fund or account to calculate its
net asset value, violations of applicable privacy and other laws, rules and regulations, regulatory fines, penalties,
reputational damage, reimbursement or other compensatory costs and/or additional compliance costs associated
with implementation of any corrective measures. The fund or account and its shareholders could be negatively
impacted as a result of any such cybersecurity breaches, and there can be no assurance that the fund or account
will not suffer losses relating to cybersecurity attacks or other informational security breaches affecting the fund’s
or account’s third-party service providers in the future, particularly as the fund or account cannot control any
cybersecurity plans or systems implemented by such service providers.
Cybersecurity risks may also impact issuers of securities in which the fund or account invests, which may cause the
fund’s or account’s investments in such issuers to lose value.
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• Operational events — To the extent that a strategy relies on proprietary and third-party data analysis and systems to
support investment decision making, there is a risk of software or other technology malfunctions or programming
inaccuracies that may impair the performance of these systems. System impairment may negatively impact
performance.
• Loss of investment — An investor may lose money by investing in a fund. The likelihood of loss may be greater if the
investor invests for a shorter period of time.
•
Investments are not guaranteed — Investments in a fund or account are not bank deposits and are not insured or
guaranteed by the Federal Deposit Insurance Corporation or any other governmental agency, entity or person.
• Long-Term perspective — Investors in a fund or account should have a long-term perspective and be able to tolerate
potentially sharp declines in value.
• Past investment results are not predictive of future investment results.
Please see each fund’s prospectus and statement of additional information, account guidelines, or other disclosure
documents for further information on methods of analysis, investment strategies and risks specific to that fund or
account.
Capital Research and Management Company occasionally, as needed for account servicing, discloses nonpublic
personal information about your account such as name, account information, portfolio holdings or other relevant
details to unaffiliated third parties. If information is provided to a third party, such third party is required to protect the
confidentiality and security of this information and use it only for its intended purpose.
If a third party delivers client securities or funds to the investment adviser in connection with, among other things, a
securities law related lawsuit or regulatory order (e.g., proceeds from a class action settlement or Fair Fund account),
corporate action, tax refund or reclaim, such securities or funds will be forwarded to the client or the client’s custodian.
In certain circumstances, however, if the intended recipient cannot be readily identified, they may be returned to
sender, escheated or donated as deemed appropriate by the investment adviser.
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ITEM 9: DISCIPLINARY INFORMATION
Neither Capital Research and Management Company nor its management persons have been the subject of legal or
regulatory findings, or are the subject of any pending criminal proceedings that are material to a client’s or prospective
client’s evaluation of our advisory business or the integrity of our management. From time to time, Capital Research
and Management Company or its management persons may be subject to regulatory examinations, investigations,
litigation or inquiries that arise in the ordinary course of our business. In the event we become aware of any regulatory
matter or litigation that we believe would be material to an evaluation of our advisory business, we notify all clients or
prospects affected by those events, subject to applicable law and regulation.
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ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Capital Research and Management Company is registered as a commodity pool operator and a member of the
National Futures Association. Some of Capital Research and Management Company’s Associated Persons are also
management persons of Capital Research and Management Company and/or one or more of the affiliates listed
below. Capital Research and Management Company has the following arrangements that are material to clients or its
advisory business with certain affiliated entities. Some of Capital Research and Management Company’s directors and
executive officers and employees are also directors, officers or employees of one or more affiliates.
Broker–dealer
Capital Client Group, Inc., a wholly-owned subsidiary of Capital Research and Management Company, is a registered
broker-dealer and a member of the Financial Industry Regulatory Authority and Municipal Securities Rulemaking
Board. Capital Client Group, Inc. acts as the principal underwriter and distributor of mutual funds advised by Capital
Research and Management Company and its affiliates and provides related services. In addition, certain of Capital
Research and Management Company’s management persons or other employees are registered representatives
of Capital Client Group, Inc. Capital Client Group, Inc. is also registered as an insurance agency or producer in
certain states. Capital Client Group, Inc. is also an investment adviser which provides investment advisory services
in connection with various managed account programs sponsored by unaffiliated broker-dealers or other financial
institutions, where Capital Research and Management Company or its affiliates may be retained as an investment
manager. Capital Client Group, Inc. and Capital Research and Management Company share supervised persons.
Investment Companies
Capital Research and Management Company serves as investment adviser to investment companies registered under
the Investment Company Act of 1940 and other pooled investment vehicles. Capital Research and Management
Company will receive advisory and other fees and expenses from each such vehicle based upon the value of the
vehicle’s assets; those fees are described in each vehicle’s prospectus and statement of additional information or other
disclosure documents.
Other Investment Advisers
Because our funds and our personnel are located around the world, we share supervised persons and conduct
business through a number of affiliated entities licensed to offer services in various jurisdictions and to perform
particular business functions. Though legally distinct, our affiliates function as a unified, global business. We believe
that our globally integrated model helps us to serve our clients’ needs better. We often engage our affiliates and their
personnel to assist in managing client mandates. For example, our affiliated personnel provide research, portfolio
management or trading services to certain client accounts.
Certain portfolio managers employed by the following affiliated investment advisers, under the supervision and review
of Capital Research and Management Company, determine the securities to be purchased and sold for certain clients
of Capital Research and Management Company:
Capital Research Company, a wholly-owned subsidiary of Capital Research and Management Company, is an
investment adviser registered with the U.S. Securities and Exchange Commission and provides investment advisory
research, trading, and related services to Capital Research and Management Company. Capital Research Company
employees may also manage assets, under the supervision and control of Capital Research and Management Company.
Capital International, Inc. is an affiliated investment adviser registered with the U.S. Securities and Exchange
Commission as well as with the Hong Kong Securities and Futures Commission, the Financial Services Commission of
South Korea and the Australian Securities and Investment Commission as it conducts investment advisory and asset
management services in those regions.
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Capital Group Private Client Services, Inc is an affiliated investment adviser registered with the U.S. Securities and
Exchange Commission with which Capital Research and Management Company shares supervised persons.
Capital Group Investment Management Pte. Ltd. is based in Singapore and has been authorized by the Monetary
Authority of Singapore to provide investment advisory and asset management services.
Capital International K.K. is based in Japan and has been authorized by the Financial Services Agency to provide
investment advisory and asset management services. Capital International K.K. provides research information and
services to Capital Research and Management Company.
Capital International Limited is based in the U.K. and has been authorized by the U.K. Financial Conduct Authority to
provide investment advisory and asset management services.
Capital Group UK Management Company is authorized by the U.K. Financial Conduct Authority as a U.K. management
company. Capital Group UK Management Company serves as a management company only and does not undertake
other financially regulated activities, nor does it undertake any activities outside of the U.K.
Capital International Sarl is based in Switzerland and has been authorized by the Financial Markets Supervisory
Authority to provide investment advisory services.
Capital International Management Company Sarl is based in Luxembourg and has been authorized by the
Luxembourg financial regulator and other financial regulators in the European Union to provide investment advisory or
asset management services in Luxembourg and European Union countries.
Additionally, Capital International, Inc. and Capital International Limited provide portfolio control, administrative and
trading services to Capital Research and Management Company.
None of Capital Group Investment Management Pte. Ltd., Capital International K.K., Capital International Limited,
Capital International Sarl, nor Capital International Management Company Sarl are registered as an investment adviser
under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and each is deemed to be a “Participating
Affiliate” of Capital Research and Management Company, as this term has been used by the SEC’s Division of
Investment Management in various no-action letters granting relief from the Advisers Act’s registration requirements
for certain affiliates of registered investment advisers.
Trust Company
Capital Bank and Trust Company, a federal savings bank, is a wholly-owned subsidiary of The Capital Group
Companies, Inc. Capital Bank and Trust Company provides directed trustee services and custodial services to
employer-sponsored retirement plans and individual retirement accounts invested in the American Funds and other
outside assets. Capital Bank and Trust Company is an investment adviser registered with the U.S. Securities and
Exchange Commission and provides trust services to high net-worth individuals and trusts. Capital Bank and Trust
Company serves as discretionary trustee to certain collective investment trusts. Capital Bank and Trust Company and
Capital Research and Management Company share supervised persons.
Unregistered Collective Investment Trust
Capital Research and Management Company serves as the investment adviser to Capital Bank and Trust Company,
the trustee of collective investment funds that are exempt from SEC registration. Capital Research and Management
Company will receive advisory fees from Capital Bank and Trust as agreed upon in writing from time to time.
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ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Capital Research and Management Company and its affiliated companies have adopted a Code of Ethics for its
associates (Code of Ethics) that requires all associates to: (1) act with integrity, competence and in an ethical manner;
• comply with applicable U.S. federal securities laws, as well as all other applicable laws, rules and regulations; and
• promptly report violations of the Code of Ethics. All associates are required to certify at least annually that they
have read and understand the Code. A copy of the Code of Ethics is available to clients and prospective clients upon
request and on americanfunds.com.
The Code of Ethics includes:
• Protection of Non-Public Information: Policies and procedures designed to prevent and detect the misuse of
material non-public information (“MNPI”) by our associates. These procedures require all associates who believe
they may be in possession of MNPI regarding an issuer to notify the Legal Department, which will determine the
appropriate actions to be taken. Associates may come into possession of MNPI through various channels and
must comply with Capital Research and Management Company’s Insider Trading Policy.
• Personal Investing: Policies related to personal investing by our associates and their covered family members.
The policies ban excessive trading of any Capital-managed investment vehicles worldwide, including the
American Funds. Associates generally may not participate in the acquisitions of securities in initial public
offerings. Additional restrictions apply to associates with access to non-public information relating to current or
imminent fund/client transactions, investment recommendations or fund portfolio holdings (Covered
Associates). Covered Associates generally may not affect securities transactions for their own account when any
investment advisory account is transacting in the issuer in question. All such Covered Associates must report
their securities transactions on a quarterly basis and disclose their holdings annually. Covered Associates must
pre-clear certain personal security transactions and special review of private placements is required.
Additional restrictions and reporting apply to Investment Access Persons, including blackout periods
on personal investing and a ban on short-term trading.
• Gifts and Entertainment: Policy prohibiting associates from accepting and extending gifts or entertainment that
are excessive, repetitive or extravagant, if such gifts or entertainment involve a third party’s business relationship
(or prospective business relationship) with Capital. Procedures include quarterly reporting of gifts or entertainment
received or extended, a dollar limit on gifts that can be accepted from any one source during a calendar year, and
preclearance of entertainment beyond a certain dollar limit.
• Outside Business Activities: Policies governing avoidance of outside business interests or affiliations that may give rise
to conflicts of interest or that may create divided loyalties, divert substantial amounts of associates’ time, or
compromise their independent judgment. Associates must obtain prior approval to serve on the board of directors or
as an advisory board member of any public or private company and must disclose if they serve on the board of a non-
profit or charitable organization that has issued or has future plans to issue publicly held securities, including debt
obligations. Associates must also disclose if they or certain close family members serve as a board director or as an
advisory board member of, holds a senior officer position with, or owns 5% or more of any public company or any
private company that may be reasonably expected to go public.
• Political Contributions: Policy governing political contributions and/or other activities that directly support officials,
candidates, or organizations that may be in a position to influence decisions to award business to investment
management firms. Specific rules exist for political contributions and activities within the U.S. and restricted
associates are required to seek preclearance and approval for political contributions to state and local government
officials (or a candidate for those positions), federal candidate campaigns and affiliated committees, and political
organizations, such as Political Action Committees (PACs).
• Charitable Contributions: Associates must not allow Capital Research and Management Company’s present or
anticipated business to be a factor in soliciting charitable contributions. In addition, it is generally not appropriate to
solicit for donations to a charitable organization in which an associate or their family members are significantly involved.
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Participation or Interest in Client Transactions
Capital Research and Management Company and its affiliates recommend that certain clients invest in limited
partnerships, pooled investment vehicles or mutual funds managed by the Investment Adviser or its affiliates.
Additionally, an affiliate of Capital Research and Management Company, in its fiduciary capacity, may invest
client assets in certain of these funds. In all cases, the nature and scope of the financial interest (e.g., investment
management fees or economic interest in such partnerships or funds) is disclosed.
Capital Research and Management Company’s employees may also purchase shares in certain pooled investment
vehicles managed by Capital Research and Management Company or an affiliate of Capital Research and Management
Company. Such purchases take place either through their personal account or through retirement plans sponsored by
The Capital Group Companies, Inc., the ultimate parent company of Capital Research and Management Company. All
such transactions are conducted at net asset value and in accordance with the purchase and redemption provisions as
described in either the prospectus or offering memorandum of the fund.
Capital Research and Management Company manages investments made by it or an affiliate either in a separate
account or through investing in a pooled investment vehicle. In those instances in which Capital Research and
Management Company or an affiliate makes an investment in a pooled investment vehicle, they may be the first
participants in such vehicle and may be the only participant for one or more years. Capital Research and Management
Company treats these separate and pooled investment vehicle accounts the same as any client account.
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ITEM 12: BROKERAGE PRACTICES
As a U.S. registered investment adviser, Capital Research and Management Company is committed to identifying,
monitoring, disclosing, and mitigating actual and potential conflicts of interest that may arise in the course of providing its
services. Capital Research and Management Company has established policies and procedures designed to promote the
fair and equitable treatment of client accounts.
These policies include mechanisms designed to support the fair and equitable allocation of investment opportunities
among participating accounts, taking into account the relevant circumstances of the accounts and investment opportunity,
as well as best execution of transactions and the dissemination of investment ideas and recommendations.
Selecting Broker-Dealers
Capital Research and Management Company selects among a variety of broker-dealers, exchanges and other market
participants when executing client portfolio transactions. In selecting broker-dealers and execution venues, Capital
Research and Management Company considers a variety of factors, including but not limited to the size and type of
transaction, the nature and character of the markets for the security to be purchased or sold, the cost, quality, likely speed
and reliability of execution and settlement, the broker-dealer’s or execution venue’s ability to offer liquidity and anonymity,
applicable tax considerations, and the trade-off between market impact and opportunity costs. These activities are
governed by policies and procedures designed to support Capital Research and Management Company's best execution
obligations and address actual and potential conflicts that may arise in connection with brokerage and execution
decisions.
Portfolio Transactions
Capital Research and Management Company places orders with broker-dealers for its clients’ portfolio transactions.
Purchases and sales of equity securities on a securities exchange or an over-the-counter market are effected through
broker-dealers who receive commissions for their services. Purchases and sales of fixed-income securities and currency
foreign exchange transactions are generally made with an issuer or a primary market-maker acting as principal with
no stated brokerage commission. Prices for fixed-income securities in secondary trades usually include undisclosed
compensation to the market-maker reflecting the spread between the bid and ask prices for the securities. The prices
for equity and fixed-income securities purchased in primary market transactions, such as initial public offerings, new
fixed-income issues, secondary offerings and private placements, may include underwriting fees.
Best Execution
In selecting broker-dealers, Capital Research and Management Company strives to obtain “best execution” (the most
favorable total price reasonably attainable under the circumstances) for its clients’ portfolio transactions, taking into
account a variety of factors. These factors include the size and type of transaction, the nature and character of the
markets for the security to be purchased or sold, the cost, quality, likely speed and reliability of execution and
settlement, the broker-dealer’s or execution venue’s ability to offer liquidity and anonymity, applicable tax
considerations, and the trade-off between market impact and opportunity costs. Capital Research and Management
Company considers these factors, which involve qualitative judgment, when selecting broker-dealers and execution
venues for its clients’ portfolio transactions.
Capital Research and Management Company views best execution as a process that should be evaluated over time as
part of an overall relationship with particular broker-dealer firms. In this regard, Capital Research and Management
Company does not consider itself as having an obligation to obtain the lowest commission rate available for a portfolio
transaction to the exclusion of price, service and qualitative considerations. Brokerage commissions are only a small
part of total execution costs and other factors, such as market impact and speed of execution, contribute significantly
to overall transaction costs.
Oversight
The Capital Group Companies Equity Trading Oversight and Best Execution Committee and the Capital Group
Companies Fixed-Income Best Execution Committee provide oversight to Capital Research and Management
Company’s policies, procedures and practices relating to best execution. Capital Research and Management Company
obtains third-party analysis of trading execution quality. These analyses compare execution results with various
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benchmarks which provide quantitative data that is one of many data points that is evaluated to ensure that Capital
Research and Management Company is meeting its best execution obligation.
The Market and Transaction Research group performs in-depth analysis on equity trade execution data and reviews
the findings with the Global Equity Trading Manager to enhance the ability to measure and interpret trading costs and
their effects on portfolio performance. The Equity Trading Oversight and Best Execution Committee meets periodically
to review such trade execution analysis and evaluate the overall quality of execution and trades. The Equity Trading
Oversight and Best Execution Committee also reviews equity trading policies and approves changes as appropriate.
Fixed-income analysis of trade execution data and trading costs is performed in coordination with the traders and
reviewed by the Fixed Income Trading Management team to enhance the ability to measure and interpret trading costs
and their effects on portfolio performance. The Fixed-Income Best Execution Committee meets periodically to review
fixed-income trading practices and overall quality of execution for fixed-income and foreign exchange trades. The
Fixed-Income Best Execution Committee also reviews fixed-income trading policies and approves changes
as appropriate.
The Capital Group Companies Investment Group Oversight Committee provides oversight of Capital Group’s research
management program. It is responsible for (a) overseeing the quality of the research acquired by Capital Research and
Management Company and its affiliates to inform future procurement processes, decisions and payment levels and (b)
approving an annual research budget.
Commission Rates
Capital Research and Management Company and its affiliates negotiate commission rates with brokers based on what
they believe is reasonably necessary to obtain best execution. Capital Research and Management Company and its
affiliates do not consider the appropriate commission to necessarily be the lowest available commission, but attempt
to maximize the overall benefits received by their clients for their commissions. Commission rates vary based on the
nature of the transaction, the market in which the security is traded and the venue chosen for trading, among other
factors.
Capital Research and Management Company and its affiliates seek, on an ongoing basis, to determine what the
reasonable levels of commission rates for execution services are in the marketplace, taking various considerations into
account, including the extent to which a broker-dealer has put its own capital at risk, historical commission rates and
commission rates that other institutional investors are paying.
Brokerage and Investment Research Services
Capital Research and Management Company and its affiliates execute portfolio transactions with broker-dealers who
provide certain brokerage and/or investment research services to Capital Research and Management Company and its
affiliates, but only when in Capital Research and Management Company’s and its affiliates’ judgment the
broker-dealer is capable of providing best execution for that transaction. Capital Research and Management Company
and its affiliates make decisions for procurement of research separately and distinctly from decisions on the choice of
brokerage and execution services. The receipt of these research services permits Capital Research and Management
Company and each affiliate to supplement its own research and analysis and makes available the views of, and
information from, individuals and the research staffs of other firms. These services include, among other things, reports
and other communications with respect to individual companies, industries, countries and regions, economic, political
and legal developments, as well as scheduling meetings with corporate executives and seminars and conferences
related to relevant subject matters. This information may be provided in the form of written reports, telephone contacts
and meetings with securities analysts.
Capital Research and Management Company and its affiliates bear the cost of all third-party investment research
services for all client accounts they advise. However, in order to compensate certain U.S. broker-dealers for research
consumed, and valued, by their investment professionals, Capital Research and Management Company and its
affiliates operate a limited commission sharing arrangement with commissions on equity trades for certain registered
investment companies they advise. Capital Research and Management Company and its affiliates voluntarily reimburse
such registered investment companies for all amounts collected into the commission sharing arrangement. In order
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to operate the commission sharing arrangement, Capital Research and Management Company and its affiliates may
cause such registered investment companies to pay commissions in excess of what other broker-dealers might have
charged for certain portfolio transactions in recognition of brokerage and/or investment research services. In this
regard, Capital Research and Management Company and its affiliates have adopted a brokerage allocation procedure
consistent with the requirements of Section 28(e) of the U.S. Securities Exchange Act of 1934. Section 28(e) permits an
investment adviser to cause an account to pay a higher commission to a broker-dealer to compensate the
broker-dealer or another service provider for certain brokerage and/or investment research services provided to
Capital Research and Management Company and its affiliates, if Capital Research and Management Company and
each affiliate makes a good faith determination that such commissions are reasonable in relation to the value of
the services provided to Capital Research and Management Company and its affiliates in terms of that particular
transaction or Capital Research and Management Company’s or its affiliates’ overall responsibility to their clients.
Certain brokerage and/or investment research services may not necessarily benefit all accounts paying commissions
to a broker-dealer, therefore, Capital Research and Management Company and its affiliates assess the reasonableness
of commissions in light of the total brokerage and investment research services provided to Capital Research and
Management Company and its affiliates. Further, research services may be used by all investment associates of Capital
Research and Management Company and its affiliates, regardless of whether they advise accounts with trading activity
that generates eligible commissions. In accordance with its internal brokerage allocation procedure, Capital Research
and Management Company and its affiliates periodically assess the brokerage and investment research services
provided by each broker-dealer and each other service provider from whom they receive such services.
As part of ongoing relationships, Capital Research and Management Company and its affiliates routinely meet with
firms to discuss the level and quality of the brokerage and research services provided, as well as the value and cost
of such services. In valuing the brokerage and investment research services Capital Research and Management
Company and its affiliates receive from broker-dealers and other research providers in connection with their good faith
determinations of reasonableness, Capital Research and Management Company and its affiliates take various factors
into consideration, including the quantity, quality and usefulness of the services to Capital Research and Management
Company and its affiliates. Based on this information and applying their judgment, Capital Research and Management
Company and its affiliates set an annual research budget.
Research analysts and portfolio managers periodically participate in a research provider poll to determine the
usefulness and value of the research provided by individual broker-dealers and research providers. Based on the
results of this research provider poll, Capital Research and Management Company and its affiliates may, through
commission sharing arrangements with certain broker-dealers, direct a portion of commissions paid to a broker-
dealer by the funds and other registered investment companies managed by Capital Research and Management
Company or its affiliates to be used to compensate the broker-dealer and/or other research providers for research
services they provide.
While Capital Research and Management Company and its affiliates may negotiate commission rates and enter into
commission sharing arrangements with certain broker-dealers with the expectation that such broker-dealers will be
providing brokerage and research services, none of Capital Research and Management Company, any of its affiliates or
any of their clients incurs any obligation to any broker-dealer to pay for research by generating trading commissions.
Capital Research and Management Company and its affiliates negotiate prices for certain research that may be paid
through commission sharing arrangements or by themselves with cash.
Cross Trades
As part of its authority to invest client assets on a discretionary basis, Capital Research and Management Company
places cross-trades between client accounts managed by Capital Research and Management Company and its
affiliates from time to time. Capital Research and Management Company recognizes that a potential conflict of interest
may exist when placing trades between client accounts. To address such potential conflicts, Capital Research and
Management Company maintains cross-trade policies and procedures and places a cross-trade under those limited
circumstances when such a trade: (a) is in the best interest of all participating clients and (b) is not prohibited by the
participating clients’ investment management agreement or applicable law.
Sale of Fund Shares Not Considered
29
Capital Research and Management Company may place orders for a client’s portfolio transactions with broker-dealers
who have sold shares in the funds managed by Capital Research and Management Company or its affiliated companies;
however, it does not consider whether a broker-dealer has sold shares of the funds managed by Capital Research and
Management Company or its affiliated companies when placing any such orders for a client’s portfolio transactions.
Client Referrals
Capital Research and Management Company does not consider client referrals from a broker-dealer or third party in
selecting or recommending broker-dealers.
Directed Brokerage
Capital Research and Management Company does not direct any trading activity for its mutual fund clients to a
particular broker-dealer based on instructions from a fund. In some instances, an affiliate of Capital Research and
Management Company will accept a client’s instructions to direct a portion of the account’s brokerage commissions to
a particular broker or group of brokers so long as the direction is consistent with such affiliate’s policy of seeking best
execution. The affiliate’s ability to meet client direction requests will depend on the broker(s) selected by the client
and the securities and markets in which the account invests, among other factors. Furthermore, Capital Research and
Management Company accepts requests to direct brokerage from clients who are subject to ERISA only if the client’s
direction program complies with ERISA.
Certain managed account program clients may direct Capital Research and Management Company to place all trades
for equity accounts through the program sponsor, a third-party platform and/or their affiliates. These directed trades
will not be subject to Capital Research and Management Company’s policy of seeking best execution. In these cases,
Capital Research and Management Company will not negotiate commissions for such accounts or otherwise monitor
the execution of trades. These accounts may therefore pay higher commissions (to the extent that commissions are
charged) than those that do not direct brokerage in this way. Further, such trades are not aggregated with trades for
Capital Research and Management Company’s other clients and funds, and may be executed subsequent to trades
for other Capital Research and Management Company accounts. Please refer to the disclosure under the heading
“Managed Account Programs” in this Brokerage Practices Section for more information about the handling of securities
trading with respect to such programs. With directed brokerage arrangements of this type, Capital Research and
Management Company cannot assure clients that they will be able to obtain best execution and these clients should
confirm with their program sponsor or third-party platform and/or their affiliates that they are able to provide best
execution of transactions.
Certain funds managed by affiliates of Capital Research and Management Company may facilitate directed cash
subscriptions and redemptions. When an authorized participant of such funds seeks to have the underlying securities of a
cash subscription or redemption traded with a particular designated broker, Capital Research and Management
Company, on behalf of the adviser affiliate, may transact for the underlying securities with the designated broker. Directed
transaction orders are not aggregated with other orders for funds and accounts managed by Capital Research and
Management Company involving the same securities. Accordingly, they may receive different execution timing, prices,
transaction costs or market impact outcomes than would have resulted from aggregating such orders with orders for other
funds and accounts.
Aggregation and Allocation of Portfolio Transactions
Frequently, Capital Research and Management Company places orders to purchase or sell the same security for
a number of clients of Capital Research and Management Company and its affiliates that are advised by the same
investment division. Capital Research and Management Company has determined that it is fair and equitable to
participating funds and accounts to aggregate orders and allocate executions within each investment division in
accordance with Capital Research and Management Company’s allocation policy summarized below. Capital Research
and Management Company believes that placing aggregated or “block” trades is consistent with its duty to seek best
execution. Further, a client’s trades are aggregated with those of other clients only if it is consistent with the terms of the
client’s investment advisory agreement. Capital Research and Management Company may not aggregate certain trades
only when it believes that doing so will not have a material impact on the price or quality of other transactions.
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This policy is designed to allocate trades of the same security to clients in a fair and equitable manner over time, taking
into consideration the interests of each fund and account. Non-investment factors, such as fee arrangements, are not
considered in selecting clients or allocating trades.
Equity Securities
Within each equity investment division, if orders to purchase or sell the same security are open for more than one fund
or account, executed trades are generally allocated pro rata to the funds and accounts based on the authorized order
size for each fund and account at the time the trade is executed. Allocated amounts will be rounded to reflect the
Advisers’ and market practices for lot sizes. All funds and accounts receive shares at the average price and pay a pro
rata portion of all transaction costs.
In aggregating and allocating trades, Capital Research and Management Company seeks to allocate executions fairly
and equitably over time, taking into consideration relevant factors, including without limitation, applicable account
investment restrictions or guidelines, regulatory restrictions, relevant market practices, tax considerations, amounts of
available cash, the need to rebalance an account portfolio (e.g., due to investor contributions and redemptions) and
whether the allocation would result in an account receiving an amount below the established minimum quantity. See
additional information regarding these factors in the paragraphs below.
Restrictions in client accounts, such as broker selection requirements, may require that a client’s order be traded
separately. Client accounts that are traded separately from the aggregate order may receive a less favorable execution
price than the accounts that are part of the aggregate order.
Certain clients may have requested Capital Research and Management Company to direct a portion of their trades to a
particular broker-dealer, subject to the Capital Research and Management Company duty to seek best execution. If the
trader believes that best execution would not be harmed by directing the client’s trade to the requested broker-dealer,
then the trade for that client may be removed from the block to place the trade with the requested broker-dealer.
Additional equity authorizations: If an additional order to purchase or sell a security is placed after the trader has
begun to work the initial orders, the equity trading platform allocates executed trades to participating funds and
accounts based on the initial orders and then begins a new allocation process based on the remaining open orders
and the new orders. Under certain circumstances, traders are given discretion to include orders they receive after the
trader has started to work an initial order with the initial aggregated order for allocation purposes. This may occur for
example, when an analyst has issued a recommendation in the morning and not all managers have had the
opportunity to hear the recommendation before the start of trading or an order for the same security is subject to
additional compliance approvals. The traders have discretion to allocate on this basis when to do so will be fair and
equitable to all participating funds and accounts.
Special instructions: In certain circumstances, parts of an aggregated order may be subject to special portfolio
manager instructions, such as a price limit, or other factors that do not apply to the entire aggregated order. This may
result in an allocation other than pro rata to all accounts in the aggregated order. For example, trades executed above
a price limit (in the case of purchases) or below the limit (in the case of sales) would be allocated on a pro rata basis
only to orders that were not subject to the price limit. Occasionally when there is a relatively small remaining open
order and a very large new order is placed, trading may complete the small order before proceeding with the larger
new order, rather than aggregating the orders.
Program and list trades: Capital Research and Management Company and its affiliates serve as investment adviser
for certain accounts that are designed to be substantially similar to another account. This type of account will often
generate a large number of relatively small trades when it is rebalanced to its reference fund due to differing cash
flows or when the account is initially started up. Capital Research and Management Company may not aggregate
program trades or electronic list trades executed as part of this process. Non-aggregated trades performed for
these accounts will be allocated entirely to that account. This is done only when Capital Research and Management
Company believes doing so will not have a material impact on the price or quality of other transactions.
Minimum allocation size: Often, a single aggregated order may be executed in a series of smaller transactions over a
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period of time. In those circumstances, some clients, particularly those that represent a small portion of an aggregated
order, may incur significant trade ticket, custody and related fees due to multiple allocations. Capital Research and
Management Company may observe a minimum transaction size per client account and allocate trades in a manner that
seeks to reduce the transaction costs that clients may incur as a result of small allocations. These minimums may vary by
client account in an effort to treat all clients fairly and equitably.
In-kind transactions: From time to time, Capital Research and Management Company may facilitate in-kind creation or
redemption basket transactions for certain pooled investment vehicles, including exchange-traded funds and other
investment vehicles. Because these transactions may involve unique operational, liquidity, tax-management or
counterparty considerations, they may be executed separately from other client orders involving the same securities. As a
result, transactions associated with an in-kind basket will not be aggregated with other orders and may receive different
execution timing, prices, transaction costs or market impact outcomes than would have resulted from aggregating such
orders with orders for other funds and accounts.
Initial Public Offerings
Orders for initial public offerings of equity securities (“IPOs”) are allocated in the same manner as described above.
The trading department aggregates authorized orders it receives for IPOs and places a block trade with the
underwriting syndicate.
If the resulting allocation we receive from the underwriting syndicate is not sufficient to fill all orders, each equity
investment division generally allocates the transaction on a pro rata basis based on each account’s authorized order
size, unless the relevant investment committee approves another allocation. In certain circumstances, orders are
placed based on approximate fund or account asset size; however, no fund or account will be allocated more than its
indication. Allocations may be subject to Capital Research and Management Company’s and market practices for lot
sizes. If the allocation places some client accounts below the minimum lot size, then the trading department will
exclude those accounts in the allocation process and allocate the remaining shares to other clients on a pro rata basis.
Fixed-Income Securities
In allocating trades to accounts, portfolio managers and analysts review client guidelines and consider a variety of
other factors including: the other securities held in the account’s portfolio; the appropriateness of the security for the
fund’s objective; the industry/sector, issue/issuer holdings, portfolio analytic data; the size of the account; the size of
the confirmed, executed transaction; the invested position of the account; and the marketability of the security.
Once a fixed-income trade has been executed and participating client accounts are identified, all accounts receive the
same purchase price when participating in a block trade. All fixed-income trades are reviewed a final time after
allocation and execution by the Fixed Income Compliance team against the compliance guidelines of the accounts.
New Fixed-Income Issues
Funds and accounts are selected to participate in new issuance of fixed-income securities in the same manner as
described above. Orders are aggregated for new issues and a block order is placed with the lead arrangers or
bookrunners.
If the resulting allocation received from the arrangers is not sufficient to fill all orders, the trade is generally allocated
on a pro rata basis based on each account’s authorized order size, unless the relevant investment committee approves
another allocation methodology. Consideration may be given to the factors listed above.
Allocations may be subject to Capital Research and Management Company’s and market practices for lot sizes. If the
allocation places some client accounts below the minimum lot size, those accounts may not receive an allocation.
Managed Account Programs
When Capital Research and Management Company serves as a discretionary investment adviser for discretionary
managed account programs, equity portfolio transactions are either executed by the sponsor firm or traded away (see
more on this below). As a result, equity transactions for managed account program accounts are generally not
aggregated with orders for other accounts for which Capital Research and Management Company or an affiliate
serves as investment manager. Such trades are generally executed subsequent to trades for other Capital Research
and Management Company accounts. Managed account program accounts therefore may not receive the same
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quality of execution that Capital Research and Management Company and its affiliates are able to obtain for other
advisory clients.
Managed account program accounts that are charged a single “wrap fee” typically are not charged separate
brokerage commissions for the execution of transactions when Capital Research and Management Company executes
trades through the sponsor, or an affiliated broker-dealer designated by the sponsor. However, as noted above,
Capital Research and Management Company considers brokerage commissions to be only one part of total execution
costs, and if we determine that other factors, such as market impact and speed of execution, are likely to contribute
more to overall costs and quality of execution for a given transaction, we will execute trades for managed account
program accounts with broker-dealers other than the sponsor. The practice of trading with a broker-dealer other than
the wrap program sponsor is frequently referred to as “trading away”. If Capital Research and Management Company
selects a broker-dealer other than the sponsor or its designated affiliate to effect a trade for a managed account
program account, the managed account program account typically will incur expenses in the form of commissions on
equity trades, spreads on fixed income trades, ADR conversion fees and other applicable expenses in addition to the
wrap fee paid by the managed account program client.
The amount of transactions that we determine to “trade away” from the sponsor or its designated affiliate will vary by
strategy. For U.S. equity strategies, a majority of trades are typically placed through the sponsor or its designated
affiliate. For strategies with significant exposure to international equities or fixed income securities, a majority, and in
some cases substantially all, trades will typically be executed with a broker-dealer other than the sponsor or its
designated affiliate. For global equity strategies and other strategies that invest in U.S. equity securities as well as
other types of securities, the amount of transactions that we “trade away” from the sponsor or its designated affiliate
will vary depending on the relative exposures of the account and other factors, but may represent more than half of
the trades for the account. The amount of brokerage that we “trade away” from the sponsor or its designated affiliate
may change over time as security trading markets and practices evolve. We do not trade away for model delivery
managed account programs. Upon request, Capital Research and Management Company will provide additional
information related to its trading away practices to managed account program sponsors.
Capital Research and Management Company provides similar investment management services to multiple managed
account program clients, including model delivery and discretionary management account programs. This may result
in investment recommendations for the same security being provided to multiple program sponsors at a similar time.
In such cases, Capital Research and Management Company may rotate the order in which it places equity transactions
among the relevant sponsors or other trading entities under model delivery and discretionary programs. Capital
Research and Management Company uses a rotation methodology designed to avoid systematically favoring one
entity over another and to treat similarly situated groups of accounts equitably over time.
Capital Research and Management Company and its affiliates manage investment companies, institutional and other
accounts with similar or identical investment objectives, as well as accounts with different objectives that may trade in
the same securities as the managed account program accounts managed by Capital Research and Management
Company. Because investment decisions for managed accounts are based on, and occur after, investment decisions
for certain of these other accounts, the other accounts are not rotated with managed account program accounts, and
therefore, trade prior to managed account program. As a result, the market price of securities may rise or fall before a
managed account program transaction is executed (and, in certain circumstances, as a direct result of other portfolio
transactions placed by, or on the advice of, Capital Research and Management Company or its affiliates), causing
managed account program accounts to purchase the same securities at a higher price (or sell the same securities at a
lower price) than Capital Research and Management Company and its affiliates. Institutional and other accounts of
Capital Research and Management Company and its affiliates may therefore over time obtain more favorable prices
for their transactions than managed account program accounts purchasing or selling the same securities. See above
under the heading “Directed Brokerage” for more information about the handling of equity security trading with
respect to such programs. Capital Research and Management Company provides changes to the model portfolio
allocations to all clients simultaneously prior to the implementation date. This policy reflects that each model portfolio
consists solely of mutual funds and ETFs, so all sponsor firms have the ability to obtain the same end of day net asset
value price for the mutual funds and a similar market price for the ETFs.
Fixed-Income portfolio transactions for managed account program accounts are generally executed by broker-dealers
other than the sponsor selected by Capital Research and Management Company or its affiliate. Transactions in the
same fixed income security for managed account program accounts will generally be aggregated with transactions for
funds, accounts and other clients over which Capital Research and Management Company or one of its affiliated
companies has investment discretion, as described above under the heading “Fixed-Income Securities.”
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Forward Currency Exchange Transactions
Capital Research and Management Company generally executes foreign currency transactions for funds over which it
has investment discretion directly through broker-dealers; however, a fund’s custodian may be used to execute certain
foreign exchange transactions. These include transactions in markets with legal restrictions or operational risks that
make executing directly in those markets impractical.
Identification and Resolution of Trade Errors
Capital Research and Management Company maintains policies and procedures that address the identification and
remediation of trade errors. These policies and procedures are designed to address the resolution of errors and to
provide appropriate oversight and review of such errors. To the extent a trade error occurs, Capital Research and
Management Company seeks to identify and resolve such error in a manner that is fair to its clients as promptly as
possible. When determining the loss associated with an error, Capital Research and Management Company will
typically net gains and losses arising from a single error or a series, unless prohibited by applicable law or a specific
agreement with the client. Capital Research and Management Company will address and resolve errors on a case-by-
case basis, in its discretion, based on each error’s facts and circumstances. Capital Research and Management
Company attempts to resolve similar trade errors in a consistent manner, although we may elect to compensate a
client for a loss in certain circumstances where we believe it is not a compensable trade error.
The sponsor firm of a managed account program is generally responsible for the resolution of trade errors in
connection with trades placed through such sponsor firm. When an error is identified in a model portfolio provided by
Capital Research and Management Company to a sponsor, Capital Research and Management Company will seek to
resolve such error with the sponsor in accordance with Capital Research and Management Company’s policies and
procedures.
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ITEM 13: REVIEW OF ACCOUNTS
Capital Research and Management Company compliance teams monitor funds and accounts on an on-going basis and
perform periodic reviews. This monitoring and review is conducted to verify that funds and accounts are in compliance
with their objectives and guidelines. In addition, certain portfolio data for funds and accounts is periodically reviewed
by investment professionals, including portfolio managers.
The boards of directors/trustees of each of the registered investment companies are furnished the following
information: audited semiannual and annual financial statements, registration statements and proxy material.
Additional information concerning portfolio activity and results are presented at meetings of the boards held at least
quarterly, and extensive additional information is furnished, generally annually, in connection with investment advisory
agreement renewals.
The boards of Capital International Fund, International Investment Portfolios, Capital International Assets Management
(Canada), Inc. and the trustees of the collective investment trusts are furnished audited annual financial statements, and
additional information concerning portfolio activity and results. Other information (e.g., foreign country registration and
service agreements) is furnished as needed.
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ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
Capital Research and Management Company and its affiliates compensate certain other affiliates for client relations
and marketing services.
Capital Research and Management Company’s affiliates from time to time compensate eligible third parties for client
referrals pursuant to a written solicitation agreement. At the time of solicitation, Capital Research and Management
Company’s affiliates provide – either directly or through the solicitor – written disclosure to referred clients regarding
the fee arrangement and any material conflicts of interest on the part of the solicitor with respect to their
recommendation of Capital Research Management Company’s affiliate resulting from the fee arrangement.
Some of Capital Research and Management Company’s clients and prospective clients retain investment consultants
to evaluate and recommend investment advisers and their services. Capital Research and Management Company and
its affiliates may provide investment management services to these consultants or their affiliates. Capital Research and
Management Company is not affiliated with an investment consultant business and has never paid to gain favor from
consultants in terms of future or continuing new business opportunities. Many consultants offer valuable services to
investment managers, and Capital Research and Management Company and its affiliates regularly subscribe to
various consultant services to gain access to their index and peer data and occasionally participate in their
conferences and training programs. In addition, from time to time, Capital Research and Management Company and
its affiliates co-sponsor with other managers or consultants, industry events such as conferences. Also, Capital
Research and Management Company and its affiliates purchase other products or services from certain consultants
such as data feed transmission, electronic services and related software.
Kohlberg Kravis Roberts & Co. L.P. (“KKR”) provides distribution payments to Capital Client Group, Inc., an affiliate of
Capital Research and Management Company, in connection with investments by certain funds and accounts managed
by Capital Research and Management Company or its affiliates in KKR-sponsored investments, including units offered
by KKR Private Equity Conglomerate LLC (“K-PEC”), other KKR Vehicles and KKR-sourced co-investments. These
payments are determined by the collective amount the fund or account invests in such KKR-sponsored investments
and are calculated as a revenue share of the fees and performance allocations received by KKR from such investments.
Any such compensation will apply regardless of how an investment is acquired and will not be contingent on the fund
or account realizing a gain on its investments in such KKR-sponsored investments. This may create an incentive for
Capital Research and Management Company to allocate a greater portion of the fund’s or account’s assets to K-PEC,
other KKR Vehicles and KKR sourced co-investments, even when it may conflict or appear to conflict with the fund’s
and shareholders’ interests and may create a disincentive for Capital Research and Management Company to attempt
to negotiate lower fees on such investments.
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ITEM 15: CUSTODY
Capital Research and Management Company does not have physical custody of client assets but is deemed to have
custody of certain client assets, as defined under rule 206(4)-2 of the Advisers Act. Clients for which Capital Research
and Management Company is deemed to have custody will receive account statements from a third-party custodian
bank at least on a quarterly basis and should carefully review those statements.
If a third party inadvertently delivers client securities or funds to Capital Research and Management Company, such
securities or funds generally will be forwarded to the client or the client’s custodian. In certain circumstances, however,
they may be returned to sender.
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ITEM 16: INVESTMENT DISCRETION
When Capital Research and Management Company is retained on a discretionary basis pursuant to an investment
management agreement, Capital Research and Management Company is generally authorized, without consultation
with the client (including a fund’s governing body as applicable) to determine, among other things:
the amount of securities to be bought or sold;
• what securities are to be bought or sold;
•
the prices at which securities are to be bought or sold;
the broker or dealer to be used; and
the commissions to be paid.
•
•
•
Capital Research and Management Company’s discretion is to be exercised in accordance with the fund’s, account
program’s or other client’s objectives, investment guidelines, policies, restrictions and limitations as outlined in the
applicable governing documents.
Investment discretion and authorization are described in the investment management agreement signed by Capital
Research and Management Company and the client. The agreement, including the investment guidelines, is typically
reviewed by administrative and legal personnel before being signed.
Capital Research and Management Company provides non-discretionary investment advisory services, in which it
provides a program sponsor with non-discretionary recommendations to assist the sponsor in the development of one
or more portfolios that the sponsor determines to be suitable for its end investors.
In certain limited arrangements where Capital Research and Management Company delivers a model portfolio, which
would typically be deemed a non-discretionary investment advisory service, Capital Research and Management Company
has contractually agreed to take discretion for ownership reporting purposes solely with respect to securities included in
its model portfolios. Discretion and ownership reporting for securities not included in the model portfolio remain the
responsibility of the applicable sponsor.
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ITEM 17: VOTING CLIENT SECURITIES
Capital Research and Management Company (the “Adviser”) accepts proxy voting authority from its advisory clients
and follows its Proxy Voting Procedures and Principles (the “Principles”), which are summarized below. If the Adviser
has voting authority for a client account, it generally does not provide the client the option to direct a proxy vote with
respect to a particular solicitation.
The Principles provide an important framework for analysis and decision-making by the Adviser. However, they are not
exhaustive and do not address all potential issues. The Principles provide a certain amount of flexibility so that all
relevant facts and circumstances can be considered in connection with every vote. As a result, each proxy received is
voted on a case-by-case basis considering the specific circumstances of each proposal. The voting process reflects the
Adviser’s understanding of the company’s business, its management and its relationship with shareholders over time.
In all cases, long-term value creation the investment objectives and policies of the funds and accounts managed by the
Adviser or its affiliates remain the focus.
Voting Procedures
The Adviser seeks to vote all U.S. proxies. Proxies for companies outside the U.S. also are voted where, there is
sufficient time and information available, taking into account distinct market practices, regulations and laws, and types
of proposals presented in each country. Where there is insufficient proxy and meeting agenda information available,
the Adviser will generally vote against such proposals in the interest of encouraging improved disclosure for investors.
The Adviser may not exercise its voting authority if voting would impose costs on clients, including opportunity costs.
For example, certain regulators have granted investment limit relief to the Adviser and its affiliates, conditioned upon
limiting voting power to specific voting ceilings. To comply with these voting ceilings, the Adviser will scale back its
votes across all funds and accounts it manages on a pro rata basis based on assets. In addition, certain countries
impose restrictions on the ability of shareholders to sell shares during the proxy solicitation period. The Adviser may
choose, due to liquidity issues, not to expose the funds and accounts it manages to such restrictions and may not vote
some (or all) shares. Finally, the Adviser may determine not to recall securities on loan to exercise its voting rights
when it determines that the cost of doing so would exceed the benefits to clients or that the vote would not have a
material impact on the investment. Proxies with respect to securities on loan through client-directed lending programs
are not available to vote and therefore are not voted.
After a proxy statement is received, the Adviser’s stewardship and engagement team prepares a summary of the
proposals contained in the proxy statement. Investment analysts are generally responsible for making voting
recommendations for their investment division on significant votes that relate to companies in their coverage areas.
Analysts also have the opportunity to review initial recommendations made by the Adviser’s stewardship and
engagement team. Depending on the vote recommendation, a second opinion may be made by a proxy coordinator
(an investment professional with experience in corporate governance and proxy voting matters) within the appropriate
investment division, based on knowledge of the Principles and familiarity with proxy-related issues. Each of the
Adviser’s equity investment divisions has its own proxy voting committee, which is made up of investment
professionals within each division. Each division’s proxy voting committee retains final authority for voting decisions
made by such division.
In cases where a fund or account is co-managed and a security is held by more than one of the Adviser’s equity
investment divisions, the divisions may develop different voting recommendations for individual ballot proposals. If
this occurs, and if permitted by local market conventions, the position will generally be voted proportionally by
divisional holding, according to their respective decisions. Otherwise, the outcome will be determined by the equity
investment division or divisions with the larger position in the security as of the record date for the shareholder
meeting.
In addition to its proprietary proxy voting, governance and executive compensation research, the Adviser may utilize
research provided by third-party advisory firms on a case-by-case basis. It does not, as a policy, follow the voting
recommendations provided by these firms. It periodically assesses the information provided by the advisory firms and
reports to the applicable governance committees that provide oversight of the application of the Principles.
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Conflicts of Interest
From time to time, the Adviser may vote proxies issued by, or on proposals sponsored or publicly supported by, (a) a
client with substantial assets managed by the Adviser or its affiliates, (b) an entity with a significant business
relationship with The Capital Group Companies, Inc. or its affiliates, or (c) a public company with a U.S. registered fund
director on its board or as a senior executive (each referred to as an “Interested Party”). Other persons or entities may
also be deemed an Interested Party if facts or circumstances appear to give rise to a potential conflict.
The Adviser has developed procedures to identify and address instances where a vote could appear to be influenced
by such a relationship. Each equity investment division of the Adviser has a Special Review Committee (“SRC”) of
senior investment professionals and legal and compliance professionals with oversight of potentially conflicted
matters.
If a potential conflict is identified according to the procedure above, the SRC will take appropriate steps to address the
conflict of interest. These steps may include, engaging an independent, third-party to review the proxy and using the
Principles to provide an independent voting recommendation to the Adviser for vote execution. The Adviser will
generally follow the third party’s recommendation, except when it believes the recommendation is inconsistent with
the Adviser’s fiduciary duty to its clients. Occasionally, it may not be feasible to engage the third party to review the
matter due to compressed timeframes or other operational issues. In this case, the SRC will take appropriate steps to
address the conflict of interest, including reviewing the proxy after being provided with a summary of any relevant
communications with the Interested Party, information on the organization’s relationship with the Interested Party and
any other pertinent information.
Proxy Voting Principles
The below sets forth at a high level the general positions of the Adviser on various types of proposals. A copy of the
full Principles is available upon request, free of charge, by visiting the Capital Group website (capitalgroup.com).
Director matters — The election of a company’s slate of nominees for director generally is supported. Votes may be
withheld for some or all of the nominees if this is determined to be in the best interest of shareholders or if, in the
opinion of the Adviser, such nominee has not fulfilled his or her fiduciary duty. In making this determination, the
Adviser considers, among other things, a nominee’s potential conflicts of interest, track record (whether in the current
board seat or in previous executive or director roles) with respect to shareholder protection and value creation as well
as their capacity for full engagement on board matters. The Adviser generally supports a breadth of experience and
perspectives among board members, and the separation of the chairman and CEO positions.
Governance provisions — Proposals to declassify a board (elect all directors annually) generally are typically supported
based on the belief that this increases the directors’ sense of accountability to shareholders. Proposals for cumulative
voting generally are supported in order to promote management and board accountability and an opportunity for
leadership change. Proposals designed to make director elections more meaningful, either by requiring a majority
vote or by requiring any director receiving more withhold votes than affirmative votes to tender his or her resignation,
generally are supported.
Shareholder rights — Proposals to repeal an existing poison pill generally are supported. (There may be certain
circumstances, however, when a proxy voting committee or an investment division of the Adviser believes that a
company needs to maintain anti-takeover protection). Proposals to eliminate the right of shareholders to act by written
consent or to take away a shareholder’s right to call a special meeting typically are not supported.
Compensation and benefit plans — Equity incentive plans are complicated, and many factors are considered in
evaluating a plan. Each plan is evaluated based on protecting shareholder interests and a knowledge of the company
and its management. Considerations include the pricing (or repricing) of options awarded under the plan and the
impact of dilution on existing shareholders from past and future equity awards. Compensation packages should be
structured to attract, motivate and retain existing employees and qualified directors; in addition, they should be
aligned with the long-term success of the company and the enhancement of shareholder value.
Routine matters — The ratification of auditors, procedural matters relating to the annual meeting and changes to
company name are examples of items considered routine. Such items generally are voted in favor of management’s
recommendations unless circumstances indicate otherwise.
Shareholder proposals on environmental and social issues — The Adviser believes environmental and social issues
present investment risks and opportunities that can shape a company’s long-term financial sustainability. Shareholder
proposals, including those relating to environmental and social issues, are evaluated in terms of their materiality to the
company, overall value of transparency and standardization of disclosure, the prescriptive and/or nonbinding nature
of the shareholder proposal, best-in-class practices by peer group companies and best practices in the applicable
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sector. The Adviser generally supports transparency and standardized disclosure, particularly that which leverages
existing regulatory reporting or industry best practices. With respect to environmental matters, this includes
disclosures aligned with industry standards and reporting on sustainability issues that are material to investment
analysis. With respect to social matters, the Adviser encourages companies to disclose the composition of the
workforce in a regionally appropriate manner. The Adviser supports relevant reporting and disclosure that is
consistent with broadly applicable standards.
Proxy Voting for Fund of Funds and Other Pooled Investment Vehicles
In cases where the underlying fund of an investing fund managed by the Adviser, including a fund of funds, holds a
proxy vote, such vote is reviewed based on the procedures described above for potentially conflicted matters.
Voting Information
Information regarding how the U.S. registered funds managed by the Adviser voted proxies relating to portfolio
securities during the 12- month period ended June 30 of each year will be available on or about September 1 of each
year (a) without charge, upon request by calling American Funds Service Company at 800/421-4225, (b) on the Capital
Group website at capitalgroup.com and (c) on the SEC’s website at sec.gov. With respect to client accounts advised by
the Adviser or its affiliate where the Adviser or its affiliate has accepted proxy voting authority, information regarding
how securities in such accounts were voted are provided upon request. Please contact your financial advisor or your
Capital Group representative for this information.
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ITEM 18: FINANCIAL INFORMATION
Capital Research and Management Company does not generally require or solicit pre-payment of fees; however,
certain sponsors of wrap fee programs pay Capital Research and Management Company fees in advance of its
provision of services related to such program, but in no case more than six months in advance. Investors who enroll
in wrap fee programs should refer to their disclosure documents from the sponsor for details on programs that may
require payment in advance and the treatment of fees upon termination of an account.
Capital Research and Management Company is not aware of any financial condition that is reasonably likely to impair
its ability to meet its contractual commitments to clients.
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ITEM 19: REQUIREMENTS FOR STATE-REGISTERED ADVISERS
Capital Research and Management Company is not registered with any state securities authority.
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