CLEARBRIDGE MULTI CAP GROWTH ESG PORTFOLIOS

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1 4Q 2018 Separately Managed Accounts Product Commentary CLEARBRIDGE MULTI CAP GROWTH ESG PORTFOLIOS Richard Freeman, Evan Bauman and Mary Jane McQuillen Portfolio Managers Multi Cap Growth ESG Portfolios Annualized returns net and gross of fees - PRELIMINARY (%) as of December 31, mo QTR YTD 1-yr 3-yr 5-yr 7-yr 10-yr Net of fees "Pure" gross of fees Russell 3000 Growth Index The strategy returns are preliminary composite returns, subject to future revision (downward or upward). Please visit for the latest performance figures. YTD numbers are not annualized. Monthly, quarterly and YTD numbers are not annualized. Past performance is no guarantee of future results. Please see the GIPS endnotes for important additional information regarding the portfolio performance and for effects of fees. Management and performance of individual accounts may vary for reasons that include the existence of different implementation practices and model requirements in different investment programs. Fees: Gross performance shown does not reflect the deduction of investment management fees and certain transaction costs, which will reduce portfolio performance. Net performance includes the deduction of a 3.0% annual wrap fee, which is the maximum anticipated wrap fee for equity and balanced portfolios. Actual fees may vary. For fee schedules, contact your financial professional, or if you enter into an agreement directly with Legg Mason Private Portfolio Group, LLC (LMPPG), refer to LMPPG's Form ADV disclosure document. Returns reflect the reinvestment of dividends and other earnings. Investors cannot invest directly in an index, and unmanaged index returns do not reflect any fees, expenses or sales charges. Key takeaways During the recent equity drawdown, the market began to reward attractively priced companies with solid cash flow profiles and defensible business models. We are working with portfolio companies, both makers of electric vehicles (EVs) and those in the supply chain, to promote sustainable and fair production and consumption of EVs. Increasing merger and acquisition (M&A) activity, an innovation-friendly regulatory environment, and the resetting of valuations in depressed areas of the market are encouraging signs for the year ahead. Market overview As the recent equity correction helps the market start to normalize in terms of volatility and valuations, we believe attractively priced companies with attributes like free cash flow and durable business models with high barriers to entry will once again be rewarded. We have always sought to target businesses with these fundamental characteristics. We believe conditions are setting up for our Portfolio companies to monetize assets that have been depressed for some time, either through accretive M&A, increasing share buybacks or through the rerating higher of under-owned and undervalued stocks and sectors. INVESTMENT PRODUCTS: NOT FDIC INSURED NO BANK GUARANTEE MAY LOSE VALUE

2 We have been discussing the green shoots of leadership change in recent commentaries, a progression that gained strength late in the year and into 2019 as investors began to acknowledge the risks embedded in certain crowded areas of the market, including the FAANG stocks. Apple, for example, has started to see a slowdown in iphone sales, and it issued its first ever profit warning in early January. As high active share investors, we have constructed a portfolio that looks very different from our benchmark and the passive strategies that track it. That differentiation has been a headwind in the increasingly narrow, momentum-driven market of the last several years. But recent results are beginning to demonstrate the benefits of our contrarian approach to long-term growth investing. Communication services, for example, was a leading driver of relative performance during the quarter, led by Comcast an out-ofbenchmark holding trading at a single-digit multiple of cash flow. Our information technology (IT) holdings have also showed greater resilience than many of the widely held tech stocks. Broadcom, which develops chips for Apple and software for a broad range of other industries (including networking infrastructure), and Cree, which has successfully expanded beyond its core LED business with its Wolfspeed division that develops custom chips for power applications that figure prominently in electric vehicle development (see ESG discussion below), both delivered gains in a quarter that saw 10 of the 11 sectors in the benchmark fall sharply. In addition, Broadcom followed through on a pledge to return cash to shareholders, raising its dividend 50%. Recent results have been in line with the market despite a significant performance headwind from our energy exposure. Crude oil prices plummeted more than 35% during the quarter due to oversupply from U.S. shale drillers, Saudi Arabia and Russia coupled with the perception of lower demand from slowing global growth. The energy sector (-31.05%) was by far the worst performer in the benchmark, with declines in the share prices of exploration & production and oil service companies exaggerated by year-end tax-loss selling and the liquidation of commodity-focused hedge funds. The Portfolio s overweight to energy plus generally negative sentiment toward the sector failed to spare even companies with strong balance sheet discipline. In these markets, price tends to cure price. The lower oil prices go, the more companies and countries will be forced to cut production. This dynamic could result in a quicker normalization of supply and demand and higher prices in a shorter period of time. Cash flow-producing enterprises and assets have a clearing price, and we expect to see both strategic and private equity purchases of high-quality assets trading at depressed valuations. Our largest exploration & production holdings own such assets, and they could be attractive targets for larger buyers. On the services side, while the decline in the spending cycle has been deeper and longer than we had forecast, equipment inventories remain incredibly low. We believe we are overdue for an equipment refresh cycle and that demand will pick up for next-generation technologies. Additionally, the industry may consolidate to leave stronger companies with better products and technologies. Innovation should also be a driver of improved performance in the biopharmaceutical industry saw a record number of first-cycle treatment approvals from the Food and Drug Administration (FDA), and regulators will continue to fast track therapeutics that serve unmet needs. These are the types of compounds in clinical development at Portfolio companies Biogen and Vertex Pharmaceuticals. The year also witnessed a record amount of capital markets activity, a trend that continued in early 2019 with Bristol-Myers Squibb s $74 billion offer for Celgene (the Portfolio does not hold either stock). We believe these clinical and consolidation trends could lead to a meaningful rerating of profitable health care stocks. Outlook Volatility remains at elevated levels compared with the recent past, and it should settle into a more normalized range going forward. This is the type of environment that separates quality, competitively advantaged companies from those lifted by easy financial conditions and broad market trends. We believe financial discipline and valuation will be key drivers of performance in the year ahead. Signs of a pickup in merger & acquisition activity, the outperformance of cash-rich companies across the market, and the resetting of prices in distressed areas like energy all point to what we expect to be a productive year. We are encouraged that the market climate has changed and risk has started to be priced into stocks. Investor pessimism has risen to extreme levels, and we feel the most optimistic about the broad market since making our call of a market bottom in early Market psychology tends to repeat, and the sentiment surveys that we follow, which are contrarian indicators, suggest the declines of the fourth quarter plus a pullback in interest rates could set up a meaningful leg up for equities in Importantly, as well, the Portfolio valuation vis-à-vis the market is close to its biggest discount in nearly two decades. 2

3 Portfolios highlights For the fourth quarter, the ClearBridge Multi Cap Growth ESG Portfolios declined 16.28% (gross of fees), while the benchmark Russell 3000 Growth Index declined 16.33% for the same period. Over the longer term, the Portfolios have outperformed the benchmark for the 10-year period ended December 31, 2018 (gross of fees). On an absolute basis, the Portfolios had losses across the seven sectors in which they were invested (out of 11 sectors total). The primary detractors from performance were the energy and health care sectors. Relative to the benchmark, overall stock selection contributed to performance. In particular, stock selection in the IT, communication services and health care sectors and an overweight to health care were the primary contributors to performance. On the negative side, an overweight to the energy sector and stock selection in the energy and industrials sectors were the primary detractors from relative returns. On an individual stock basis, positions in Broadcom, Cree and Ionis Pharmaceuticals were the leading contributors to absolute returns during the quarter. The largest detractors included Anadarko Petroleum, Fluor Corp., Weatherford International, Biogen and Autodesk. Top contributors 1 Contribution to equity return % Broadcom Inc Cree, Inc Ionis Pharmaceuticals, Inc LogMeIn, Inc GCI Liberty, Inc In terms of individual stocks, the positive contributors to the Portfolios performance for the quarter included: Broadcom (AVGO), in the IT sector, develops semiconductors for a range of communications applications. Shares were hit hard over the summer after Broadcom announced its acquisition of CA. Shares rallied in the fourth quarter on better-than-expected operating results and guidance. Management s long-term strategy is unchanged, and a significant dividend increase has provided support for the stock. Cree (CREE), in the IT sector, is a developer of LED and related lighting and semiconductor technologies. The shares were lifted by quarterly results that topped forecasts on stabilization of the LED and lighting businesses and the announcement of several new deals for its Wolfspeed business, which is levered to high-growth opportunities in the areas of EVs and solar panels. Ionis Pharmaceuticals (IONS), in the health care sector, is a biotechnology company developing genetic-based treatments for rare diseases. Shares continued to rally off a recent bottom, as investors have expressed optimism for its ribonucleic acid (RNA) therapies, which include Spinraza for spinal muscular atrophy and Tegsedi for the genetic condition amyloidosis. 1 Portfolio characteristics are based on a model portfolio, not an actual client account. The model portfolio is a hypothetical portfolio whereby the portfolio characteristics are based on simulated trading and account activity of a client account invested in this strategy. The model portfolio assumes no withdrawals, contributions or client-imposed restrictions. Portfolio characteristics of individual client accounts may differ from those of the model portfolio as a result of account size, client-imposed restrictions, the timing of client investments, market conditions, contributions, withdrawals and other factors. Please see Endnotes for additional information. This information does not constitute, and should not be construed as, investment advice or recommendations with respect to the sectors and securities listed, and it should not be used as the sole basis for any investment decision. Past performance is no guarantee of future results. 3

4 Bottom contributors 2 Contribution to equity return % Anadarko Petroleum Corporation Fluor Corporation Weatherford International Plc Biogen Inc Autodesk, Inc The bottom contributors to the Portfolios performance for the quarter included: Anadarko Petroleum (APC), in the energy sector, is an oil and gas exploration and production company with major operations in North America and overseas. Despite positive capital allocation announcements, the stock was not spared in a broad energy sell-off tied to plummeting oil prices. The company s annual budget reflects a continued financial discipline with plans to deploy free cash flow to reduce debt and return capital to shareholders. Weatherford International (WFT), in the energy sector, is a provider of drilling equipment and services for oil and natural gas producers. The stock fell sharply on plummeting commodity prices, tax-loss selling and heightened concerns about its liquidity position and whether it has sufficient resources to meet debt obligations. We believe Weatherford has enough cash on hand to continue its deleveraging program. Biogen (BIIB), in the health care sector, is a biotechnology company that produces therapies in the areas of oncology, neurology and immunology. Shares were pressured as part of a broad sell-off across biopharmaceutical names. Investors grew concerned that the readout for a competitor s Alzheimer s treatment could be disappointing for the class of drugs. Environmental, social and governance (ESG) highlights Carbon emissions from vehicles contribute significantly to global warming, and the transportation sector is one of the larger contributors to greenhouse gas emissions (GHG) in the U.S. As institutional investors seek to offset and mitigate the rising levels of carbon and other GHGs, electric vehicles (EVs) are an increasingly viable solution. With sales of EVs growing faster than predicted a few short years ago, the outlook for EV production and adoption is becoming increasingly robust. We think greater consumer and commercial adoption of EVs will bring environmental benefits as well as financial opportunity for both manufacturers and users and throughout the EV supply chain. It will also involve environmental and social challenges, and we are working with the companies we own, both makers of EVs and those in the supply chain, to help make sustainable and fair production and consumption of EVs possible. Commercial Adoption of EVs Will Be a Watershed Much of the focus until now has been on consumer adoption of EVs. But there is reason to shift focus to commercial adoption, because as total cost of ownership for an EV falls, EVs are becoming more feasible for commercial use. Shareholders of both fleet buyers and manufacturers are poised to benefit from greater commercial adoption. ClearBridge holding United Parcel Service, for example, is currently buying a fleet of 1,000 electric vans from Workhorse, a U.S.-based manufacturer of electric delivery and utility vehicles, as part of an electrification effort that includes converting up to 1,500 delivery trucks to battery electric and initiating the purchase of 125 Tesla Semi trucks and Daimler electric trucks. FedEx also recently ordered 1,000 electric vans from California-based Chanje for use in commercial and residential pickup and delivery in California. Commercial adoption should help the bottom lines not just of logistics companies but also of large consumer staples companies heavily dependent on transportation. Freight costs are one of the greatest areas of cost inflation among consumer staples companies such as ClearBridge holding Pepsico, which is ramping up its electrification efforts with 100 Tesla Semis on order. Other major consumer staples companies with Tesla Semis on order include Walmart and Sysco. As manufacturers continue to consolidate production in larger, more efficient plants, and retailers carry less inventory and demand delivery within ever more narrow time windows, transportation logistics become an increasingly important competitive advantage. 2 Portfolio characteristics are based on a model portfolio, not an actual client account. The model portfolio is a hypothetical portfolio whereby the portfolio characteristics are based on simulated trading and account activity of a client account invested in this strategy. The model portfolio assumes no withdrawals, contributions or client-imposed restrictions. Portfolio characteristics of individual client accounts may differ from those of the model portfolio as a result of account size, client-imposed restrictions, the timing of client investments, market conditions, contributions, withdrawals and other factors. Please see Endnotes for additional information. This information does not constitute, and should not be construed as, investment advice or recommendations with respect to the sectors and securities listed, and it should not be used as the sole basis for any investment decision. Past performance is no guarantee of future results. 4

5 Commercial vehicles remain an underappreciated source of net-environmental benefit and investment opportunity. We encourage a diversified fleet and view several portfolio companies taking advantage of the increased feasibility of EVs in their operations as significant progress in moving toward sustainable transport. Supply Chains Present Challenges While EV adoption has clear environmental and economic benefits, there are also challenges, such as eliminating or minimizing the environmental and social impacts of sourcing critical metals used in batteries. EV batteries contain lithium and cobalt, metals whose production can present several supply chain risks, including environmental damage, forced labor and poor health conditions. We are partnering with our Portfolio companies both to establish responsible and efficient sourcing practices and to reduce reliance on rare earth minerals through innovation. ClearBridge holding Umicore, for example, is a global materials technology and recycling company based in Belgium. During the year ClearBridge hosted several meetings with Umicore management, engaging the company on several ESGrelated topics. One key area of focus in 2018 was the company s approach to sustainable procurement and ethical sourcing of raw materials. Umicore has been a worldwide leader in the recycling, transformation and marketing of cobalt since 1912, and it s aware of the risks that are linked to the sourcing of cobalt. Umicore not only manufactures cathodes for batteries, it also has a large recycling operation that provides some of the materials needed for cathodes and reduces the impact of materials sourcing by getting some materials like cobalt from internal recycling operations. Umicore is investing in battery recycling technology, which has the potential to be a large business for the company in the future. Where recycling has not been firmly established, Umicore has established top sustainable policies for ethical sourcing of cobalt. These include supply chain traceability to track the origin of cobalt raw materials at the mine level, plant visits and red flag checks that eliminate suppliers engaged in any of several unacceptable practices. Innovation also provides a path to solving EV supply chain challenges. In a ClearBridge visit with Tesla management in 2018, for example, we noted how Tesla is reducing its reliance on cobalt through the adoption of batteries from Panasonic that use more nickel in the cathode and more silicone in the anode material. We also discussed the eventual need for endof-life battery recycling as part of the manufacturing facilities and observed Tesla Gigafactory s integrated recovery systems, which recover energy and save costs through regeneration braking in drivetrain testing and wastewater recovery. Well-to-Wheel, EV Benefits Add Up Another challenge is the concern that the total carbon profile of EVs is potentially still significant, given the energy and resources required to build and power EVs. Often, however, these concerns are grounded on incomplete information. Examples of EV energy and resource use, for example, often focus on the energy and resources required to make batteries, but they ignore a comparison to the energy and resources required to make traditional powertrains. A complete vehicle fuel-cycle analysis, or well-to-wheels analysis, however, shows numerous clear benefits of EVs, such as the elimination of tailpipe emissions from population centers. While the life-cycle impact of EVs compared with internal combustion engines (ICEs) on climate should consider the nature of the electricity charging EVs (electricity may be generated by coal, for example, counteracting environmental gains of EVs), this impact is positive under any electric grid scenario. There are many academic studies comparing the EV versus ICE impact on the environment throughout the life cycle of a vehicle: from materials extraction to end-of-life recycling. One study concludes that even in the dirtiest grid (coal power), a fully electric fleet would result in 25% GHG emission reductions versus a diesel fleet. EVs represent a compelling business opportunity for Portfolio companies that can also have significant environmental benefits, and institutional investors are playing a growing role in pushing EVs forward. ClearBridge is a long-standing member of the Investor Network on Climate Risk (INCR), which has organized biennial summits on climate change at the United Nations for institutional investors to convene on how to apply private capital solutions to global warming. Both business opportunities and environmental benefits look poised to increase as EVs are adopted for commercial use. Commercial adoption should also reinforce the need for innovation in battery technology, reducing the need for rare materials and increasing the effectiveness of battery recycling. We will continue to engage with our Portfolio companies to foster greater consumer and commercial EV adoption and address the challenges that the EV supply chain presents. 5

6 Market capitalization 3 Market cap breakdown ($) Portfolio weight Benchmark weight Above 50 billion billion billion billion billion Weighted average market cap ($bil) Top 10 equity holdings 3 Percent of equity UnitedHealth Group Inc 9.34 Comcast Corp 7.52 Biogen Inc 7.38 Twitter Inc 6.71 Broadcom Inc 6.70 Autodesk Inc 6.10 Anadarko Petroleum Corp 4.70 Vertex Pharmaceuticals Inc 4.64 TE Connectivity Ltd 4.38 Nucor Corp 3.88 Total number of holdings 38 Sector highlights 3 Average sector weightings and performance (%) Gross of fees from 09/30/18 to 12/31/18 Sector Port. weight Port. return Benchmark* weight Benchmark* return Weight diff. Active contrib. Information Technology Health Care Communication Services Energy Industrials Materials Consumer Discretionary Real Estate Utilities Consumer Staples Financials Cash *Benchmark: Russell 3000 Growth Index. 3 Portfolio characteristics are based on a model portfolio, not an actual client account. The model portfolio is a hypothetical portfolio whereby the portfolio characteristics are based on simulated trading and account activity of a client account invested in this strategy. The model portfolio assumes no withdrawals, contributions or client-imposed restrictions. Portfolio characteristics of individual client accounts may differ from those of the model portfolio as a result of account size, client-imposed restrictions, the timing of client investments, market conditions, contributions, withdrawals and other factors. Please see Endnotes for additional information. This information does not constitute, and should not be construed as, investment advice or recommendations with respect to the sectors and securities listed, and it should not be used as the sole basis for any investment decision. Past performance is no guarantee of future results. 6

7 Important information Any information, statement or opinion set forth herein is general in nature, is not directed to or based on the financial situation or needs of any particular investor, and does not constitute, and should not be construed as, investment advice, a forecast of future events, a guarantee of future results, or a recommendation with respect to any particular security or investment strategy or type of retirement account. Investors seeking financial advice regarding the appropriateness of investing in any securities or investment strategies should consult their financial professional. Please refer to for more information about the Portfolio, including objective, risks and investment process. The information presented does not constitute and should not be construed as investment advice with respect to any investment discussed. There is no guarantee that investment objectives will be met. An investor cannot invest directly in an index. Investments are not FDIC insured or guaranteed by any government agency. Values may fluctuate due to market conditions and other factors. Past performance is no guarantee of future results. Separately managed accounts (SMAs) are investment services provided by Legg Mason Private Portfolio Group, LLC (LMPPG), a federally registered investment advisor. Client portfolios are managed based on investment instructions or advice provided by one or both of the following Legg Masonaffiliated subadvisors: ClearBridge Investments, LLC and Western Asset Management Company. Management is implemented by LMPPG, the designated subadvisor or, in the case of certain programs, the program sponsor or its designee. The investment strategies described herein are those of Legg Mason Private Portfolio Group, LLC (LMPPG). These materials are being provided for illustrative and informational purposes only. The information contained herein is obtained from multiple sources that are believed to be reliable. However, such information has not been verified, and it may be different from the information included in documents and materials created by the sponsor firm in whose investment program a client participates. Some sponsor firms may require that these LMPPG materials are preceded or accompanied by investment profiles or other documents or materials prepared by such sponsor firms, which will be provided upon a client s request. For additional information, documents and/or materials, please speak to your financial advisor. Risks All investments involve risk, including loss of principal, and there is no guarantee that investment objectives will be met. In addition to investments in large-capitalization companies, investments may be made in speculative and/or small-cap and mid-cap companies, which involve a higher degree of risk and volatility than investments in larger, more established companies. In addition, because the investments may be concentrated in a limited number of industries and companies, the Portfolios may involve heightened risk. While most investments are in U.S. companies, investments may also be made in ADRs and other securities of non-u.s. companies in developed and emerging markets, which involve risks in addition to those ordinarily associated with investing in domestic securities, including the potentially negative effects of currency fluctuation, political and economic developments, foreign taxation, and differences in auditing and other financial standards. These risks are magnified in emerging markets. Certain limits on the amount of investment in any one company may cause individual MCG investment portfolios to vary from each other and thus the performance results of such portfolios may also vary from each other, particularly when combined with the price volatility of stocks in such portfolios. Definitions and additional information An investor cannot invest directly in an index, and unmanaged index returns do not reflect any fees, expenses or sales charge. Active share is a measure of the percentage of stock holdings in a manager's portfolio that differs from the benchmark index. FAANG is an acronym for the five most popular and best-performing tech stocks in the market, namely Facebook, Apple, Amazon, Netflix and Alphabet s Google. Food and Drug Administration (FDA) is a government agency established in 1906 with the passage of the Federal Food and Drugs Act. Free cash flow (FCF) is a measure of financial performance calculated as operating cash flow minus capital expenditures. An internal combustion engine (ICE) is a heat engine. Russell 3000 Growth Index measures the performance of those Russell 3000 Index companies with higher price-to-book ratios and higher forecasted growth values. 7

8 ClearBridge Multi Cap Growth ESG SMA GIPS endnotes ($USD) Ending December 31 Inception date: July 2006; Composite creation date: June 2008 Period Total return (net) Total return (* pure gross) Russell 3000 Growth Index return Number of portfolios % of bundled fee portfolios in Composite the composite dispersion Composite 3 Yr. Standard Deviation Benchmark 3 Yr. Standard Deviation Total composite assets at end of period (USD million) % of firm assets Total firm assets at end of period (USD million) % 17.35% 29.59% % 13.85% 10.77% % 119, % 9.20% 7.39% % 14.64% 11.50% % 100, % -2.22% 5.09% % 13.16% 10.95% % 92, % 14.23% 12.44% n/m 12.50% 9.87% % 100, % 46.36% 34.23% <5 100 n/m 16.86% 12.66% % 85, % 22.33% 15.21% <5 100 n/m 20.47% 16.21% % 54, % -0.80% 2.18% <5 100 n/m 23.87% 18.43% % 50, % 34.84% 17.64% <5 100 n/m n/a n/a % 55, % 51.93% 37.01% <5 100 n/m n/a n/a % 53, % % % <5 100 n/m n/a n/a % 50,614.9 *Pure gross of fee returns do not reflect the deduction of any expenses, including transaction costs, and are presented as supplemental to the net of fee returns. n/m - Information is not statistically meaningful due to an insufficient number of portfolios in the composite for the entire year. COMPLIANCE STATEMENT: ClearBridge Investments, LLC claims compliance with the Global Investment Performance Standards (GIPS ) and has prepared and presented this report in compliance with the GIPS standards. ClearBridge Investments, LLC has been independently verified for the periods January 1, December 31, The verification reports are available upon request. Verification assesses whether (1) the firm has complied with all the composite construction requirements of the GIPS standards on a firm-wide basis and (2) the firm's policies and procedures are designed to calculate and present performance in compliance with the GIPS standards. Verification does not ensure the accuracy of any specific composite presentation. FIRM INFORMATION: ClearBridge Investments, LLC ("ClearBridge") is a wholly owned subsidiary of Legg Mason, Inc. ("Legg Mason"). The investment advisory business now known as ClearBridge was registered in September 2005 to facilitate Legg Mason's acquisition of substantially all the equity asset management businesses known as Citigroup Asset Management. These former businesses serve as the foundation of ClearBridge and its claim of GIPS compliance for institutional accounts through predecessor firms, effective as of January In June 2008, ClearBridge combined this business with its retail business to form a single GIPS firm. As of April 1, 2013 and January 1, 2016, ClearBridge's affiliates, Global Currents Investment Management, LLC, and ClearBridge, LLC, respectively, have become part of the ClearBridge GIPS firm. COMPOSITE INFORMATION: The ClearBridge Multi Cap Growth ESG SMA composite consists of discretionary wrap accounts with an account minimum of US $25,000. The managers actively integrate criteria inclusive of environmental, social and governance (ESG) issues into the portfolio construction of the strategy. Accounts within the composite seek long-term capital appreciation by investing in the stocks of small, mid, and large capitalization companies that the manager believes have the potential for above-average long-term earnings and/or cash flow growth. The strategy is implemented by Legg Mason Private Portfolio Group, LLC (LMPPG). LMPPG claims compliance with the Global Investment Performance Standards (GIPS ) and has been independently verified for the periods January 1, December 31, The verification reports are available upon request. Verification assesses whether (1) the firm has complied with all the composite construction requirements of the GIPS standards on a firm-wide basis and (2) the firm's policies and procedures are designed to calculate and present performance in compliance with the GIPS standards. Verification does not ensure the accuracy of any specific composite presentation. The main risks of this strategy are General Investment Risk, Industry and Issuer Concentration Risk, Small Cap Risk, Mid Cap Risk, High Volatility Risk, ESG Investing Risk, and Non-U.S. Investment Risk. Prior to June 2008, the minimum was $5,000. The composite consists of the following percentages of non-fee-paying seed capital: 12/2013-2%, 12/ %, 12/ %. INPUT AND CALCULATION DATA: The fee schedule currently in effect is 3.00% on all assets. Net of fee composite returns are calculated by reducing each monthly composite pure gross rate of return by the highest "bundled" fee charged (3.00%) annually, prorated to a monthly ratio. The "bundled" fee includes transaction costs, investment management, custodial, and other administrative fees. Effective January 1, 2013, the number of portfolios reflects a change from prior periods due to an aggregation of accounts as reported by one sponsor. As of January 2014, the internal dispersion of annual returns is measured by the asset-weighted standard deviation of portfolio returns included in the composite for the entire year. For prior years, the equal-weighted standard deviation was used. The composite employed a 10% significant cash flow policy which was discontinued in January A list of composite descriptions is available upon request. Policies for valuing portfolios, calculating performance, and preparing compliant presentations are available upon request. In September 2018, the composite inception date was revised to more accurately reflect the composite. Past performance is not necessarily indicative of future results. BENCHMARK INFORMATION: The Russell 3000 Growth Index measures the performance of those Russell 3000 Index companies with higher price-to-book ratios and higher forecasted growth values Legg Mason Investor Services, LLC, member FINRA, SIPC. Legg Mason Investor Services, LLC and ClearBridge Investments are subsidiaries of Legg Mason, Inc AMXX D