Vanguard S&P 500 UCITS ETF

The Fund employs a passive management – or indexing – investment approach, through physical acquisition of securities, and seeks to track the performance of the Standard and Poor’s 500 Index (the “Index”). The Index is comprised of large-sized company stocks in the US. The Fund attempts to: 1. Track the performance of the Index by investing through physical acquisition in all, or substantially all, of the constituent securities of the Index in the same proportion as the Index. Where not practicable to fully replicate, the Fund will use a sampling process. 2. Remain fully invested except in extraordinary market, political or similar conditions where the Fund may temporarily depart from this investment policy to avoid losses.