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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 26, 2025
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.
ITEM 2: MATERIAL CHANGES
There have been no material changes since the last update of Capital Research and Management
Company’s Form ADV, Part 2A brochure dated January 24, 2025.
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ITEM 3: TABLE OF CONTENTS
Item
Page
1 Cover Page………………………………………………………………………….……………….1
2 Material Changes ............................................................................................................................... 2
3 Table of Contents ............................................................................................................................... 3
4 Advisory Business ............................................................................................................................. 4
5 Fees and Compensation ..................................................................................................................... 7
6 Performance-Based Fees and Side-by-Side Management ............................................................... 11
7 Type of Clients ................................................................................................................................. 12
8 Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 13
9 Disciplinary Information .................................................................................................................. 29
10 Other Financial Industry Activities and Affiliations ........................................................................ 30
11 Code of Ethics .................................................................................................................................. 33
12 Brokerage Practices ......................................................................................................................... 35
13 Review of Accounts ......................................................................................................................... 46
14 Client Referrals and Other Compensation ....................................................................................... 47
15 Custody ............................................................................................................................................ 48
16 Investment Discretion ...................................................................................................................... 49
17 Voting Client Securities ................................................................................................................... 50
18 Financial Information ....................................................................................................................... 54
19 Requirements for State-Registered Advisers ................................................................................... 55
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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, 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".
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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 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
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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, 2025, Capital Research and Management Company managed approximately
$3,753,542,800,000 in discretionary assets under management.
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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., 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.
Managed Account Program Sponsor Fees:
Capital Research and Management Company investment advisory services are also available
through various 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
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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% - 0.32%
International Equity/ Global Equity: 0.32% - 0.38%
Intermediate/ 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 a dual contract arrangement, Capital Research and Management Company’s fee is typically
paid directly by the client pursuant to a separate agreement. The annual fee schedules for
investment management services for dual contract programs are expressed as a percentage of
total assets. All assets are stated in U.S. dollars. In addition to the fee schedules outlined below,
different fee schedules apply for certain long-standing clients, initial investors in a new strategy,
as well as 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 (Capital Group Short Municipal Bond SMA, Capital Group
Intermediate Municipal Bond SMA, and Capital Group Long Municipal Bond SMA) wrap fee
program.
Annual Fee Rate (flat rate on all assets, based on sub-account size):
Investment Mandate
$250,000 -
$1 million:
$1 million -
$3 million:
$3 million -
$10 million:
Greater than
$10 million:
0.550%
0.450%
0.400%
0.380%
Capital Group Global Equity SMA
Capital Group Global Growth SMA
Capital Group International Equity SMA
Capital Group International Growth SMA
Capital Group World Dividend Growers SMA
0.500%
0.390%
0.340%
0.320%
Capital Group U.S. Equity SMA
Capital Group U.S. Core SMA
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Capital Group U.S. Growth SMA
Capital Group U.S. Income & Growth SMA
Capital Group U.S. Conservative Growth & Income SMA
Capital Group U.S. Flexible Growth SMA
Capital Group U.S. Flexible Growth & Income SMA
0.440%
0.330%
0.280%
0.260%
Capital Group Core Plus Bond SMA*
*Anticipated launch November 18, 2025
0.400%
0.290%
0.240%
0.220%
Capital Group U.S. Intermediate Bond SMA
Capital Group Core Bond SMA
0.400%
0.290%
0.240%
0.220%
Capital Group Municipal Income SMA*
*Anticipated launch November 18, 2025
0.300%
0.190%
0.140%
0.120%
Capital Group Short Municipal Bond SMA
Capital Group Intermediate Municipal Bond SMA
Capital Group Long Municipal Bond SMA
Clients may be eligible for lower rates in the Capital Group Short Municipal Bond, Intermediate
Municipal Bond, Long Municipal Bond, and Municipal Income SMA strategies if their assets are
managed by an adviser with a large amount of overall advised assets in such strategies.
Sponsors of certain managed account programs require additional fees to cover administration
costs in addition to the fees noted above. Refer to your Investment Management Agreement for
complete applicable fees.
Minimum Account Size: $250,000*
Accounts funding below the minimum account size require prior approval.
*For all investment mandates other than the Capital Group Municipal Income SMA, for which the minimum account size is
$400,000.
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.
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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.
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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, 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.
The minimum account size for dual contract managed account program clients is generally
$250,000. Please refer to Item 5 (Fees and Compensation) for information on minimum account
sizes.
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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 should not be 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. To manage
this type of portfolio, 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, 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
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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).
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.
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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 offered by Capital Research and Management Company for managed
account programs include:
Equity strategies
U.S. Equity — 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. For non-U.S. holdings, the strategy may
invest to a limited extent in securities of issuers outside the U.S.
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. For non-U.S. holdings, 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. 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. For non-U.S.
holdings, a portfolio may invest up to 15% of its assets in securities of issuers domiciled outside
the United States.
International Equity — The strategy seeks 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. For non-U.S. holdings, the
portfolio may invest in securities of non-U.S. issuers that trade in the U.S., 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
15
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. For non-U.S. holdings, normally, at least 80% of assets
must be invested in securities of issuers in Europe or the Pacific Basin.
Global Equity — The strategy seeks 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. For non-U.S. holdings, a portfolio may invest in securities of non-U.S.
issuers that trade in the U.S., 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. For non-U.S. holdings, a portfolio may invest up to 100% of assets
outside the United States, though the strategy has typically invested in issuers throughout the
world.
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. For
non-U.S. holdings, 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 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 U.S. For non-U.S. holdings, 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. For non-U.S. holdings, 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 U.S. and Canada and not included in the S&P 500 Index.
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Fixed-Income strategies
U.S. Intermediate Bond (formerly Core Bond) – Seeks 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.
Core Bond – Seeks 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 – Seeks 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 – Seeks 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 – Seeks 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 federal alternative minimum tax (AMT).
Core Plus – Seeks 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 – Seeks 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.
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Balanced and total opportunity strategies
World Dividend Growers – The strategy aims 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.
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
18
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.
The fund or 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 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.
19
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, accounting, auditing, financial reporting and
recordkeeping requirements, 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
20
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
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 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
21
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 bonds and other lower rated debt
securities, 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
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. These risks may be increased with respect to investments in junk bonds.
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
22
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.
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.
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.
23
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,
24
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 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 interest rates and other
economic factors and to assess and predict the impact of such 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
25
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 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.
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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 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.
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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.
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.
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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. This includes managing assets,
subject to 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.
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.
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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
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; (2) comply with applicable U.S. federal securities laws, as
well as all other applicable laws, rules and regulations; and (3) 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 by our associates. These procedures
require all associates who believe they may be in possession of material non-public
information regarding an issuer to notify the Legal Department, which will determine the
appropriate actions to be taken.
Personal Investing: Policies related to personal investing by our associates. 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.
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
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officials (or a candidate for those positions), federal candidate campaigns and affiliated
committees, and political organizations, such as Political Action Committees (PACs).
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
Selecting Broker-Dealers
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 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 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.
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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 and data 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
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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 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
37
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 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 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.
Exchange or alternative trading system ownership
Capital Research and Management Company currently maintains a minority ownership interest
in IEX Group and an indirect, minority ownership interest in alternative trading systems,
Luminex Trading and Analytics and LeveL ATS (through a non-controlling interest in their
common parent holding company). Capital Research and Management Company, or brokers
with whom it places orders, may place orders on these or other exchanges or alternative trading
systems in which it, or one of its affiliates, has an ownership interest, provided such ownership
interest is less than five percent of the total ownership interests in the entity. Capital Research
and Management Company is subject to the same best execution obligations when trading on any
such exchange or alternative trading systems.
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Sale of Fund Shares Not Considered
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.
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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.
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 addition, 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 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
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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 is executed in a series of smaller
transactions over a 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.
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
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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 quality of execution that Capital Research and Management Company and its affiliates
are able to obtain for other advisory clients.
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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
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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.”
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
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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.
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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:
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•
what securities are to be bought or sold;
the amount of securities 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.
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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 Policy and Procedures (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
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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,
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 company with a director of a U.S. mutual fund or ETF on its board that is
managed by the Adviser or its affiliates (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.
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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 toshareholder
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
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company’s long-term financial sustainability. Shareholder proposals, including those relating to
social and environmental issues, are evaluated in terms of their materiality to the company and
its ability to generate long-term value in light of the company’s business model specific
operating context. 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. mutual funds, ETFs and closed-end interval 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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