S&P Global Inc. 401(k) Summary Plan Description

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Investment Options

Additional Rules and Information on the Investment Options

Derivatives

Certain of the Plan’s investment options invest in derivatives, including commodities futures and options. A “derivative” product refers to an asset or security whose value is related in a contractual way to stock or commodity prices. The value of the asset at a particular time in the future establishes the payoff for the derivative product.

S&P Global is relying on Commodity Futures Trading Commission Rule 4.5 with respect to the operation of the Plan and, accordingly, is not subject to registration or regulation as a commodity pool operator with respect to the operation of the Plan.