may
be adversely affected, and the value of the Fund’s assets may go down. A public
health crisis and the ensuing policies enacted
by governments and central banks may cause significant volatility and
uncertainty in global financial markets, negatively impacting
global growth prospects. As the COVID-19 global pandemic illustrated, such
events may affect certain geographic regions, countries,
sectors and industries more significantly than others.
Advancements
in technology may also adversely impact markets and the overall performance of
the Fund. For instance, the economy
may be significantly impacted by the advanced development and increased
regulation of artificial intelligence. As the
use of technology grows, liquidity and market movements may be affected. As
artificial intelligence is used more widely, the
profitability and growth of Fund holdings may be impacted, which could
significantly impact the overall performance of the
Fund. Additionally, cyber security breaches of both government and
non-government entities could have negative impacts on infrastructure and
the ability of such entities, including the Fund, to operate
properly.
These
events, and any other future events, may adversely affect the prices and
liquidity of the Fund’s portfolio investments and could result in
disruptions in the trading markets.
CYBER
SECURITY RISK. The Fund is
susceptible to operational, information security and related risks through
breaches in cyber
security. A breach in cyber security refers to both intentional and
unintentional events that may cause the Fund to lose proprietary
information, suffer data corruption or lose operational capacity. Such events
could cause the Fund to incur regulatory penalties,
reputational damage, additional compliance costs associated with corrective
measures and/or financial loss. These risks
may not be fully covered by insurance. In general, cyber incidents can result
from deliberate attacks or unintentional events.
Cyber incidents include, but are not limited to, gaining unauthorized access to
digital systems (e.g., through “hacking”
or
malicious software coding) for purposes of misappropriating assets or sensitive
information, corrupting or destroying data, or
causing operational disruption (e.g., through
denial-of-service attacks to make network services unavailable to intended
users).
Cyber attacks may also be carried out in a manner that does not require gaining
unauthorized access, such as causing denial-of-service
attacks on websites (i.e., efforts to make
network services unavailable to intended users). Emerging threats like
ransomware or zero-day exploits could also cause disruptions to Fund operations.
The use of cloud-based software or data
storage by the Fund, the Advisor, or any of the Fund’s service providers may
exacerbate these risks. Additionally, geopolitical tension
may increase the scale and sophistication of deliberate attacks, particularly
those from nation states or from entities with
nation state backing. Unintentional events, such as power outages, natural
disasters, equipment malfunctions, processing errors
or market events that occur at a pace that overloads the information and
technology systems relied upon by the Fund or
its service providers, may also disrupt the Fund’s business operations or impact
critical data. Cyber security incidents may also trigger Fund
obligations under data privacy laws, potentially increasing notification and
compliance burdens.
Cyber
security failures by or breaches of the systems of the Advisor, distributor and
other service providers (including, but not
limited to, sub-advisors, index providers, fund accountants, custodians,
transfer agents and administrators), market makers, authorized
participants or the issuers of securities in which the Fund invests,
governmental and other regulatory authorities, exchanges
and other financial market operators, banks, brokers, dealers, insurance
companies, other financial institutions or other
parties, have the ability to cause disruptions and impact business operations,
potentially resulting in: financial losses; interference
with the Fund’s ability to calculate its net asset value; disclosure of
confidential trading information; impediments to
trading; submission of erroneous trades or erroneous creation or redemption
orders; the inability of the Fund or its service providers
to transact business; violations of applicable privacy and other laws;
regulatory fines penalties, reputational damage, reimbursement
or other compensation costs; or additional compliance costs. Further, errors,
misconduct, or compromise of accounts
of employees of the Fund or its third-party service providers can also create
material cybersecurity risks. Cyber incidents
may render records of the Fund, including records relating to its assets and
transactions, shareholder ownership of Fund
shares, and other data integral to the Fund’s functioning, inaccessible,
inaccurate or incomplete. Artificial intelligence (“AI”) and machine
learning technologies used by the Fund, the Advisor or third-party service
providers may allow the unintended
introduction of vulnerabilities into infrastructures and applications, which
could exacerbate these risks or result in
cyber incidents that implicate personal data. The Fund and its shareholders
could be negatively impacted as a result of these
cyber risks associated with AI technologies. Substantial costs may be incurred
by the Fund in order to resolve or prevent cyber incidents in
the future.
The
regulatory climate governing cyber security and data protection is developing
quickly and may vary considerably across jurisdictions.
Regulators continue to develop new rules and standards related to cyber security
and data protection. Compliance with
evolving regulations can be demanding and costly, requiring substantial
resources to monitor and implement required changes.
While
the Fund has established business continuity plans in the event of, and risk
management systems to prevent, such cyber incidents,
there are inherent limitations in such plans and systems, including the
possibility that certain risks have not been