Quarter 3 – 2009

ATLAS QUARTERLY DIGEST A Publication Relating to Northern Trust’s Global Network of Markets Quarter 1, 2012 Edition

TABLE OF CONTENTS Subcustodian updates

Subcustodian relocation .............................................................................3

Depository and settlement updates

Depository developments ...........................................................................4 Regulatory updates .....................................................................................6 Settlement cycle changes ...........................................................................7

Global markets at a glance

Exchange updates .......................................................................................9 Cash payment updates ..............................................................................10 Trading updates ........................................................................................10 Corporate action updates ..........................................................................12 Tax updates ..............................................................................................13

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Subcustodian Updates

SUBCUSTODIAN RELOCATION Hong Kong Effective April 16, 2012, our subcustodian in Hong Kong, the Hongkong and Shanghai Banking Corporation Limited relocated to the following location: The Hongkong and Shanghai Banking Corporation Limited Sub-Custody and Clearing Hong Kong, HSBC Securities Services 2F, Tower 1, HSBC Centre 1 Sham Mong Road Kowloon Hong Kong

Please note that no further changes took place across Northern Trust's sub-custody network during quarter 1, 2012.

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Depository and Settlement Updates

DEPOSITORY DEVELOPMENTS Botswana Effective March 15, 2012, the Central Securities Depository Company of Botswana Ltd (CSDB) implemented a 15% prefunding requirement for trade settlement of equities. Northern Trust's subcustodian, Standard Chartered Bank Botswana Limited, negotiated an agreement with the CSDB to establish a limit based on historical trading activity and as a result there is no prefunding requirement for Northern Trust and our clients. The limit will be reviewed after the three month period has expired; Northern Trust will continue to monitor the situation and will issue an update as necessary.

Kuwait Effective March 1, 2012, the Kuwait Clearing Company (KCC) introduced a new account opening form for all investors to satisfy the prevailing anti-money laundering framework within Kuwait. All new investors are required to complete and sign part of the form, existing investors should be made aware of and be compliant with, the obligations stated in the form. Investors are also required to submit an update form whenever there is a change in information submitted to the KCC. Existing Northern Trust clients do not have to complete the form, but should be aware of and be compliant with the obligations contained in the form. All new clients should note the following when completing the form:

    

The investor will be required to complete the 'Investor Information' section in the relevant Custody and Trading account application form except for the name (in Arabic), which HSBC Bank Middle East Ltd Kuwait branch will complete on behalf of the client The investor's authorised signatory/signatories are required to sign the form The signatures have to be verified by Northern Trust The completed application form will have to be forwarded by the investor/global custodian to HSBC along with the relevant supporting documents The duly signed form will subsequently be completed by HSBC in its capacity as the local subcustodian and submitted to KCC along with the other account opening documents

Due to the introduction of the new form, Northern Trust has amended the existing account opening requirements for the market, however Northern Trust's subcustodian, HSBC Middle East, does not envisage additional delays in the account opening process.

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Kuwait continued…. The KCC has also introduced the following additional forms:

 

An ‘update’ form, which clients must complete whenever there is a change in information submitted to the KCC A form specifically for any investor who is, or is related to a Politically Exposed Person (PEP)

Please contact your Northern Trust representative if you have any questions concerning the above, or require a copy of the KCC's Custody and Trading Account Application Form. Republic of Korea Effective February 20, 2012, the Korea Securities Depository (KSD) introduced changes to the settlement process for equities and government bonds listed on the Korea Exchange (KRX). Under the new process, a buy-in will be initiated against the selling broker that fails to deliver the listed equities. The changes have no operational impact and all existing operating procedures remain unchanged. Please contact your Northern Trust representative for a complete summary of the changes. Russia Announced on March 22, 2012, the National Settlement Depository (NSD) applied for recognition as a Central Securities Depository (CSD). Once the CSD is established under law, it will no longer be possible for transfers involving a change of beneficial ownership (CBO) in “CSD-only shares” (shares eligible at the CSD) other than internally on the books of the CSD or another nominee holder. At this time, the list of “CSD-only shares” is not available, nor is there an indication as to when it may be available. Other key points to note include:    

The procedure for the interaction between the CSD and registrars has yet to be finalised and is currently under discussion between market participants There are several different versions of the procedure on assignment circulating in the market, so it is unclear at this time which version will be ratified by the regulators It is possible that the status of CSD may be awarded to NSD as early as May 2012 It is also remains unclear as to how the merger between NSD and the Depository Clearing Company (DCC) will be completed structurally

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Russia continued…. In the case of “CSD-only shares”, the law does not make it mandatory for such shares to be held at the CSD although, as indicated, CBO transfers on the register will not be permitted once the CSD becomes operational. Northern Trust, through its subcustodian, ING Bank (Eurasia) ZAO, continues to lobby the market for clarification and for certain amendments to be considered to the proposed procedures.

REGULATORY UPDATES Belgium Effective February 13, 2012, the Financial Services and Markets Authority (FSMA) modified the rules on short selling shares in Belgian financial institutions. The short selling of Belgian financials will be subject to local rules inspired directly by the European Regulation:  

Significant net short positions in Belgian financials (Dexia SA, Ageas NV/SA, KBC Groep NV and KBC Ancora CVA) are subject to a reporting obligation and are no longer prohibited For “naked” short selling, the restrictions in place prior to August 12, 2011, remain and now form part of the new European Regulation that contains a ‘locate rule’. The ‘locate rule’ states that anyone who sells shares without currently possessing or with a borrowing agreement in place must make arrangements to ensure that the shares sold can be delivered in a timely manner

If you have any questions regarding the above, please contact your Northern Trust representative. China Following the official launch of the Renminbi Qualified Foreign Institutional Investors (RQFII) scheme on December 16, 2011, relevant rules and guidelines regarding the RQFII scheme were published in January 2012, by the China Securities Regulatory Commission (CSRC), People’s Bank of China (PBOC) and State Administration of Foreign Exchange (SAFE). Under the pilot scheme, currently the RQFII scheme is only applicable to Hong Kong subsidiaries of qualified Chinese fund management and securities firms. Upon approval, the RQFIIs are allowed to use the Renminbi (RMB) funds raised in Hong Kong to invest in China’s securities market. As a risk control measure and to develop the China’s fixed income market for debt securities, RQFII must invest at least 80% of the RMB funds in fixed income securities such as bonds and fixed income funds and no more than 20% of the RMB funds in equities and equities funds. It is anticipated that the RQFII scheme will further facilitate the circulation of onshore and offshore RMB funds and thus, act as another important milestone towards the RMB's internationalization. If you have any questions regarding the above, please contact your Northern Trust representative.

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Egypt Further to our Atlas Bulletin's published August 19, 2011, and March 9, 2012, the Egyptian Financial Supervisory Authority (EFSA) announced on March 15, 2012, the approval of the listing and trading of rights subscriptions. The new rules confirmed that it became mandatory for rights to be listed on the stock exchange and trading will take place separately. Issuer companies that intend to increase their capital through rights subscriptions are now required to list the rights on the Egyptian Exchange (EGX) schedules at least three days prior to the subscription date. International Securities Identification Number (ISIN) codes for rights will be derived from the ISIN code of the original stock that will be identified in coordination with the Central Depository. The rules mandate the announcement of the rights trading dates, the period of the subscription and the rights last trading date. The calculation of the rights price has yet to be communicated by the EGX. The EGX will also have the right to identify price limits as required and these should not exceed the price limits in place for the original stock. All trading rules on ordinary shares shall apply to rights trading. Rights trading should aim to increase market liquidity and generally provide more trading options in the capital market. No effective date has been announced as yet, however Northern Trust will continue to monitor the situation and provide updates accordingly.

SETTLEMENT CYCLE CHANGES Botswana Further to our Atlas Bulletin published March 27, 2012, and effective April 1, 2012, the Botswana Stock Exchange (BSE) received regulatory approval to reduce the trade settlement cycle from T+4 to T+3, for all securities (equities and corporate bonds) listed on the exchange. As a consequence, clients of Northern Trust, Chicago should note the amendment to instruction deadlines as follows: London (GMT)

Chicago (CST)

Singapore (Singapore Time)

Current

09:00 SD-2

09:00 SD-4

12:00 noon SD-2

Proposed

No change

16.00 SD-3

No change

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France On March 7, 2012, and effective April 2, 2012, Agence France Trésor (AFT) advised of a change to the settlement cycle in the Secondary Market for Bons Taux Annuel Normalises (BTAN) and Bons Taux Fixe (BTF). Key points to note include:   

The settlement cycle for BTANs has been extended to T+3, replacing the previous T+1 The settlement cycle for BTFs has been extended to T+2, replacing the previous T+1 The settlement cycle for Obligation Assimilables du Tresor (OAT) remains T+3

The following table provides confirmation of the new deadlines: Security

Primary Market

BTF BTAN OAT

T+3 T+3 T+3

Secondary Market Prior April 2, 2012 After April 2, 2012 T+1 T+2 T+1 T+3 T+3 T+3

Israel Effective March 18, 2012, the Tel Aviv Stock Exchange (TASE) introduced a T+1 settlement regime for investors in equities. Local brokers still have the ability to extend the settlement cycle with counterparties (generally to T+2) and that this service is supported by Northern Trust's subcustodian, Bank Leumi, for foreign investors. As a consequence there has been no changes to Northern Trust’s settlement deadlines for the Israeli market. Vietnam Further to our Atlas Bulletin published September 28, 2011, the State Securities Commission's (SSC) approval to abolish the T+1 settlement cycle applicable for negotiation (put-through) trades in listed equities and fund certificates with a volume of 100,000 units or above became effective March 5, 2012. This is in line with the start date of the revised trading hours on the stock exchanges. From March 5, 2012, such large negotiation (put-through) trades will settle on T+3 cycle.

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Global Markets at a Glance

EXCHANGE UPDATES Greece On January 26, 2012, the Hellenic Capital Market Commission (HCMC) announced an extension to the prohibition of short selling of shares listed on the Athens Exchange to July 25, 2012. United Arab Emirates – NASDAQ Dubai Effective January 16, 2012, NASDAQ Dubai implemented the new Delivery versus Payment (DvP) model for listed equities which brings the exchange in line with the other exchanges in the UAE.

United Arab Emirates – NASDAQ Dubai (2) On February 15, 2012, NASDAQ Dubai revised the implementation date for late confirmation penalties to trade date February 20, 2012, from the original date of February 19, 2012. The exchange will continue to waive T+3 late confirmation penalties until further notice. The exchange will continue to waive T+3 late confirmation penalties until further notice. To recap, the penalty structure is as follows: Trade Processing Day

Penalty Structure

Late confirmation window on T+2

Nil

Late confirmation window on T+3

USD 150 or 0.05% of trade value (whichever is the higher) - waived until further notice)

Late confirmation window on T+4

USD 700 or 0.25% of trade value (whichever is the higher)

Late confirmation penalties will be invoiced on a monthly basis to Northern Trust’s subcustodian, HSBC Bank Middle East Limited, and must be paid within 14 business days to the exchange.

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CASH PAYMENT UPDATES Bahrain

Effective January 31, 2012, the use of the International Bank Account Numbers (IBAN) became mandatory for clients to quote on all payment instructions and transfer of funds to a third party bank located in Bahrain. Failure to do so will result in the payment or transfer not being effected. Clients are also required to advise their IBAN to the various parties from whom they expect to receive payments both domestically and internationally. The Northern Trust IBAN’s to be used are as follows: Entity * The Northern Trust Company Northern Trust Global Services Limited, London Northern Trust Global Services Limited, Luxembourg

Previous Account Number

New Account Number

001-072404-001

BH75BBME00001072404001

001-545557-001

BH32BBME00001545557001

001-039858-001

BH63BBME00001039858001

* Please note this change also impacts clients that are not contracted to the Northern Trust Company (NTC) but do utilise the NTC cash account to support their asset servicing and payment activities e.g. including clients of Northern Trust entities in Guernsey and Ireland.

TRADING UPDATES Brazil Effective March 1, 2012, the Brazilian government announced changes to the Imposto sobre Operacoes de Credito, Cambio e Seguro, ou relativas a Titulos ou Valores Mobiliarios (IOF) tax applicable to transactions associated with Brazilian Depository Receipts (BDRs). IOF tax imposed on investors when converting a local security to a BDR was reduced from 6.38% to 0 (zero) percent, and IOF tax imposed on investors when acquiring Brazilian real (BRL) for the purpose of purchasing a BDR was reduced from 6% to 0 (zero) percent. As a result of these changes, investors acquiring BRL for the purpose of purchasing a BDR must advise their local foreign exchange (FX) agent of their intent accordingly, and must also instruct the receipt of the BRL into their Equity Cash Account. If you have any questions regarding the above, please do not hesitate to contact your Northern Trust representative.

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Bulgaria On February 15, 2012, the Board of Directors of the Bulgarian Stock Exchange announced the following changes in trading hours, which will become effective July 2, 2012, Monday to Friday. Session Pre-trading Opening Auction Continuous Trading Closing Auction Post-trading

From 9:30 am 10.00 am 10:10 am 4:55 pm 5:00 pm

To 10:00 am 10:10 am 4:55 pm 5:00 pm 5:30 pm

The above may be adjusted at a later date by 15 minutes (+/-) to align itself with Deutsche Börse.

Hong Kong On January 10, 2012, the Hong Kong Stock Exchange (SEHK) announced an extension in trading hours, which became effective March 5, 2012. The changes are noted as follows: Trading Period Effective March 5, 2012

Previous Trading Hours 9:30 am – 12:00 pm 1:30 pm - 4:00 pm

Revised Trading Hours 9:30 am – 12:00 pm 1:00 pm - 4:00 pm

Russia Effective March 5, 2012, trading in government bonds transferred from the government bonds section at MICEX to the Main Section of MICEX-RTS; from this date, trading in government bonds is only possible in the Main Section. Auctions will continue in the government bonds section but this is expected to be transferred to the Main Section by July 1, 2012. In addition to the above, OTC trading in government bonds is also permitted. Due to the infrastructure at MICEX and the National Settlement Depository (NSD), separate accounts are required to support trading in each section, although it is possible to transfer securities between each. Northern Trust will continue to monitor developments and will provide additional updates as necessary.

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Vietnam Effective March 5, 2012, the State Securities Commission (SSC) confirmed the extension to the trading hours on the Ho Chi Minh Stock Exchange (HOSE) and the Hanoi Stock Exchange (HNX) for a period of three months. The SSC will further review the effectiveness of the revised trading hours after the three month period has expired. During the trial period, the trading hours have been revised as follows: Previous Trading Hours Monday to Friday Ho Chi Minh Stock Exchange (HOSE) Hanoi Stock Exchange (HNX)

8.30 am – 11:00 am

Revised Trading Hours Monday to Friday (March 5 to June 1, 2012) 9:00 am - 11.30 am and 1:00 pm - 2.15 pm

CORPORATE ACTION UPDATES Canada In March 2012, TELUS Corporation (TELUS) announced that the total non-Canadian resident holdings of their outstanding shares with voting rights was close to the maximum 33 1/3% ownership limit permitted under local regulations. Consequently, non-Canadian resident investors intending to purchase TELUS shares with voting rights may be unable to obtain a “Reservation” from TELUS’s transfer agent, Computershare Trust Company of Canada (Computershare). A Reservation is used to reserve non-Canadian resident voting rights shares of TELUS (ISIN: CA87971M9969) for a non-Canadian resident investor. Non-Canadian residents found to hold Canadian resident shares of TELUS with voting rights (ISIN: CA87971M1032) may be subject to various penalties including but not limited to the loss of voting rights and / or a requirement to dispose of shares. If you have any questions regarding the above, please contact your Northern Trust representative.

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TAX UPDATES France On January 30, 2012, the French President announced that the French Government had issued a proposal to introduce a 0.1% Financial Transaction Tax (FTT) that will become applicable to any transactions on French listed shares and other instruments such as Credit Default Swaps. The French Financial Amendment Bill for 2012, which introduced the (FTT), was published in the Official Gazette through Law No 2012-354 dated March 14, 2012. The FTT is due to become effective from August 1, 2012. Northern Trust continues to work with our subcustodian BNP Paribas and the market, to establish the process for the collection and payment of any FTT due and will issue further communication once further details become available. Please contact your Northern Trust representative if you require full details of the draft article published by the French Government, which summarises the key points of the Bill.

Italy Effective January 1, 2012, the Italian Government approved a new Law Decree which reintroduced the 11% withholding tax (WHT) for EU/EEA resident pension funds. The 11% rate was previously removed by Law Decree 138/2011, as confirmed in our Atlas Bulletin published September 19, 2011. Clients impacted by the change that had the necessary documentation in place for 2011 received the benefit of the 11% rate until March 31, 2012. Northern Trust will be contacting clients for renewal documentation once the market clarifies the new requirements. Northern Trust will continue to monitor the situation and will advise accordingly as further information becomes available.

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FOR MORE INFORMATION The Northern Trust Atlas Quarterly Digest is compiled by our Subcustodian Network Management Team. This group is charged with monitoring and managing our global network of foreign subcustodians. If you would like additional information regarding any of the topics covered in the Atlas Quarterly Digest, or have suggestions for future topics, please contact:

Tom Brock Head of Information Products Network Management +44 (0)1481 745537 [email protected]

The information contained herein has been obtained from sources, which we believe to be reliable, but its accuracy cannot be guaranteed. Such information is subject to change, is intended for informational purposes only, and is not to be construed as investment or legal advice or guidance. Northern Trust assumes no responsibility for any reliance by recipients on the information contained herein. Authorised and regulated in the United Kingdom by the Financial Services Authority.

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