Investment Options

Additional Rules and Information on the Investment Options

Additional Information on the S&P Global Stock Fund

The Plan provides for the S&P Global Stock Fund to be offered as an investment option.

The Plan has established procedures designed to ensure the confidentiality of your investment, voting, and tendering decisions concerning the S&P Global Stock Fund. Your confidentiality is maintained by the following procedures:

• Investment elections are received and processed by the Plan recordkeeper. All information relating to your investment in the S&P Global Stock Fund is held by the Plan record keeper in strict confidence.
• When you exercise your voting or tendering rights with respect to the portion of your Plan Account invested in the S&P Global Stock Fund, the Plan recordkeeper and the vendor selected by the Plan Sponsor for proxy and tender solicitation and tabulation services keep all information related to your tendering and voting in strict confidence.

The Plan Administrator is responsible for monitoring compliance with these procedures.

The Plan does not limit the number of shares of S&P Global stock available for purchase under the Plan through the S&P Global Stock Fund.

The Pension Investment Committee has appointed Newport Trust Company (“Newport Trust”) to serve as the independent fiduciary for the S&P Global Stock Fund (the “Stock Fund Fiduciary”), in order to provide independent third-party oversight of the S&P Global Stock Fund. In its role, Newport Trust will assess the prudence of the S&P Global Stock Fund on an ongoing basis and take action only if and to the extent it deems appropriate. They will have sole authority to impose changes to the S&P Global Stock Fund in the best interest of all Plan participants. For example, they may limit or restrict future investments in the S&P Global Stock Fund, or even liquidate the S&P Global Stock Fund.

The S&P Global Stock Fund is a “unitized fund” that invests exclusively in S&P Global common stock and a small amount of cash (and cash equivalents) to fund participant transactions into and out of the S&P Global Stock Fund and to pay certain plan expenses. As such, the value of the S&P Global Stock Fund will depend almost entirely upon the financial performance of S&P Global and its affiliates. Because the S&P Global Stock Fund is unitized, the price of a single unit in the S&P Global Stock Fund held in your account will not be the same as the price of a single share of S&P Global common stock. Moreover, the performance of the S&P Global Stock Fund will differ from that of S&P Global common stock due to, among other things, the amount of cash or cash equivalents in the S&P Global Stock Fund and the transaction costs associated with purchases and/or sales of S&P Global common stock that are paid from the S&P Global Stock Fund.

Because the S&P Global Stock Fund is not diversified – it invests in only one company, S&P Global – it has the highest risk of all of the investment funds under the Plan. The decision of how to invest your Plan account is yours to make, but the best way to reduce market risk is to diversify your investments. The Plan offers participants numerous investment choices, in addition to the S&P Global Stock Fund, with a wide range of risk and return characteristics that allow you to construct a diversified portfolio tailored to your own investment goals. You are able at any time to transfer the portion of your Plan account that is invested in the S&P Global Stock Fund into other investment funds under the Plan. You should therefore review from time to time your investment portfolio, your investment objectives, and the investment options under the Plan and consider whether the level of your investment in the S&P Global Stock Fund is appropriate in light of your own financial situation and your personal retirement goals.

As the independent fiduciary and investment manager for the S&P Global Stock Fund under ERISA, Newport Trust has the sole fiduciary responsibility under the Plan and ERISA for deciding, among other things, whether the S&P Global Stock Fund should continue to be offered as an investment option under the Plan, including deciding whether to restrict new investment in the S&P Global Stock Fund or to sell or otherwise dispose of all or any portion of the S&P Global common stock held in the S&P Global Stock Fund (subject to any practical or legal restrictions). Under the terms of its engagement, Newport Trust will continue to maintain the S&P Global Stock Fund as a Plan investment option consistent with the terms of the Plan unless otherwise prohibited by ERISA.

In fulfilling its responsibilities set forth above, Newport Trust continually monitors S&P Global and the market for S&P Global’s common stock. Newport Trust will not be in possession of any inside information concerning S&P Global or its financial condition, and will make any decisions regarding the S&P Global Stock Fund solely on the basis of publicly available information. Newport Trust currently has no intention to eliminate the S&P Global Stock Fund or to sell any portion of the S&P Global common stock held in the Stock Fund. Additionally, Newport Trust does not expect to take any action with respect to the S&P Global Stock Fund simply because of fluctuations in the market price of S&P Global common stock. In the event of a sale or other disposition, Newport Trust would designate an alternate investment fund under the Plan for the temporary investment of any proceeds pending your further investment instructions. While Newport Trust intends to communicate to participants any significant action it takes with respect to the S&P Global Stock Fund, circumstances may require Newport Trust to act prior to doing so.

Newport Trust has no responsibility for managing or investing the portion of the S&P Global Stock Fund that is held in cash or cash equivalents.

S&P Global stock is traded on the New York Stock Exchange.

Special Rules for Section 16 Officers and Others You will be subject to rules with respect to the timing and effect of withdrawals from the S&P Global Stock Fund if you are an officer of the Company subject to the provisions of Section 16 of the Securities Exchange Act of 1934 or are designated by the Company as a certain other employee subject to these rules (each, a “Windows Person”). The Company’s Securities Disclosure Policy and Securities Trading Policy, as amended from time to time, imposes blackout periods as described under Blackout Periods. If you are a Windows Person, preclearance from the Company’s Corporate Secretary is required to process some transactions in your Plan account. Please contact the Company’s Corporate Secretary to obtain preclearance to perform any transactions impacting your Plan account balance in the S&P Global Stock Fund prior to contacting Fidelity.