Legal and Operational Support | March 31, 2023

Statement of Proxy Voting Policy

0423-35H9

The information presented on this website is for institutional use only by plan sponsors, consultants, broker-dealers, and advisors. It is not intended for use by retirement plan participants.

The Schwab Managed Retirement Trust Funds™, Schwab Indexed Retirement Trust Funds™ and Schwab Institutional Trust Funds™ (each a “Trust”, collectively the “Trusts” or “Collective Investment Trusts (CITs)") are collective investment trusts maintained by Charles Schwab Trust Bank (CSTB), as trustee. They are available for investment only by eligible retirement plans and entities. Charles Schwab Trust Bank’s Collective Investment Trusts are not insured by FDIC or any other type of deposit insurance; are not deposits or other obligations of, and are not guaranteed by CSTB or any of its affiliates; and involve investment risks, including possible loss of principal invested. The Trusts are not mutual funds and are exempt from registration and regulation under the Investment Company Act of 1940 (the “1940 Act”), and their units are not registered under the Securities Act of 1933, or applicable securities laws of any state or other jurisdiction. Unit holders of the Trusts are not entitled to the protections of the 1940 Act. The decision to invest in the Trusts should be carefully considered. The Trusts’ unit values will fluctuate and may be worth more or less when redeemed, so unit holders may lose money. The Trusts are not sold by prospectus and are not available for investment by the public. The Trusts’ prices are not quoted in newspapers.

The Charles Schwab Corporation provides services to retirement and other employee benefit plans and participants through its separate but affiliated companies and subsidiaries: Charles Schwab Trust Bank (CSTB); Charles Schwab & Co., Inc.; Schwab Asset Management, the dba name for Charles Schwab Investment Management, Inc. (CSIM); and Schwab Retirement Plan Services, Inc. Trust, custody and deposit products and service are available through CSTB, Member FDIC. Brokerage products and services are offered by Charles Schwab & Co., Inc. (Member SIPC). Schwab Retirement Plan Services, Inc. is not a fiduciary to retirement plans or participants and only provides recordkeeping and related services to retirement plans. Schwab Asset Management provides investment research, advisory and administration services to CSTB and the Trusts. Schwab Asset Management is an investment advisers registered with the Securities and Exchange Commission.

The Charles Schwab Trust Bank CITs™ select investments based on advice received from, or products offered by, industry-recognized investment management firms ("sub-advisors"). The Trusts  access investment strategies through various investment vehicles including, but not limited to, collective investment trusts, mutual funds, and/or exchange-traded funds and may also access strategies through sub-advisors engaged by Charles Schwab Trust Bank to advise one or more separate accounts of a Trust. The Trusts may invest in securities directly managed by Schwab Asset Management, including Schwab ETFs, and from which Schwab Asset Management earns advisory fees. Exposure to some strategies may be indirect through investment in other Charles Schwab Trust Bank CITs. The Schwab Managed Retirement Trust™ invests in the Schwab Institutional Large Cap Value Trust™, Schwab Institutional Large Cap Growth Trust™, Schwab Institutional Small Cap Trust™, Schwab Institutional International Diversified Trust™, and Schwab Institutional Core Plus Fixed Income Trust™.

© 2023 Charles Schwab Trust Bank. All rights reserved. (0122-1FC4)