Investment in select Chinese companies:
Global economic sanctions
compliance statement – Executive Order 13959

BNY Mellon Investment Management and its investment firms intend to comply with a US government Executive Order (EO) prohibiting transactions in certain securities and derivatives of communist China military companies. BNY Mellon fund investors should be aware securities prohibited under the EO will be excluded for investment in the portfolios of all our funds as required.

Starting from 11th January, EO13959 prohibits US persons from transacting in select publicly traded securities (or any securities that are derivative of, or are designed to provide investment exposure to such securities). These are certain Chinese companies identified by the US Government as supporting China’s military. The EO also prohibits US persons from transacting in pooled vehicles that hold one or more prohibited securities, including exchange traded funds.

As a global company established and headquartered in the US, BNY Mellon regards the EO prohibitions as applicable on an enterprise-wide basis. This means it applies to BNY Mellon Investment Management and each of its investment firms, regardless of where they are domiciled or headquartered. Accordingly, portfolios of all of the sub-funds in our flagship UK and European fund umbrellas, BNY Mellon Investment Funds and BNY Mellon Global Funds, plc., that are managed by a BNY Mellon investment firm will adhere to these prohibitions.

BNY Mellon investment firms and BNY Mellon funds are currently taking appropriate steps to comply with the EO. An analysis across our fund ranges has been conducted to determine if any existing holdings might need to be divested under the EO. Where such securities are identified, the funds will divest those holdings within applicable compliance periods.

As of 8 January there were 39 sanctioned Chinese companies on the EO list, although it may be modified over time. To the extent the list of sanctioned Chinese companies is expanded, we will preclude investment (and divest) in associated prohibited securities as required. The sanctioned Chinese companies can be found on the US Department of the Treasury’s website: https://www.treasury.gov/ofac/downloads/ccmc/ns-ccmc_list.pdf