Vanguard® Managed Account Program Service Agreement

Vanguard? Managed Account Program

Service Agreement

I. Overview

The Vanguard Managed Account Program (the Program) is an advisory

service offered by Vanguard Advisers, Inc. (VAI), to participants in

employer-sponsored retirement plans (referred to in this document as

¡°Members¡±) for which The Vanguard Group, Inc. (Vanguard) provides

recordkeeping services. The Program is powered by software developed

by Financial Engines Advisors L.L.C. (Edelman Financial Engines), an

independent investment advisor unaffiliated with VAI or Vanguard.

Members who enroll in the Program authorize the Program to: (1) select

investments for their employer- sponsored retirement plan account

(Account) from the universe of investment alternatives authorized

by their plan sponsor for inclusion in the company¡¯s retirement plan;

and (2) manage the Account on an ongoing basis. References in this

document to ¡°we¡± and ¡°us¡± mean the Program, and references to ¡°you¡±

and ¡°your¡± mean Members enrolled in the Program. For additional

information, please see VAI¡¯s Form ADV Part II for the Program.

II. Description of services

The Program uses Edelman Financial Engines¡¯ software to determine

what percentage of your assets to invest in each of the investment

alternatives that have been selected by your plan sponsor for

inclusion in your employer¡¯s retirement plan. This is known as a ¡°target

allocation.¡± The Program determines your target allocation based on

your current age and an assumption about your age at retirement.

Using the Edelman Financial Engines software, the Program chooses a

default risk level for you based on the median risk level from your peer

group ¨C i.e., a set of investors with the same investment horizon. As you

near retirement, the Program will reduce your Account¡¯s risk level.

Through your participation in the Program, you are giving the Program

discretionary authority over your Account. This means that you are

granting the Program the ability to buy and sell investments on your

behalf and for your Account, and to generally transact on your Account,

without obtaining your approval for each individual transaction.

Note: If you enroll in the Program, you will be unable to control or

manage the investments in your own Account or access Personal Online

Advisor, powered by Edelman Financial Engines, unless you cancel your

participation in the Program.

After you enroll in the Program, you will receive introductory materials

that will include a preview of the changes the Program intends to make

to your Account. You will then have a two-week opportunity to review

this report and to provide the Program with any additional information

that could help us more closely tailor your target allocation to your

individual circumstances. You may wish to provide us with additional

information relating to: (1) a desired maximum allocation to company

stock investments (not to exceed 20% of your unrestricted Account

balance) if your Account is invested in, or eligible for investment in,

such assets; (2) savings and investments you hold outside your Account

(although we will not be responsible for providing investment advice or

management for your outside accounts, they can be considered when

advice is provided); (3) the age at which you plan to retire, if different

from the Program¡¯s assumption; and (4) your desire to take on more or

less risk than the target allocation suggested by the Program.

After the two weeks following the mailing of the introductory

materials, we will begin managing your Account according to the

target allocation generated by Edelman Financial Engines¡¯ software,

incorporating any additional information that you may have

submitted to us during the two-week review period. Initially, we will

sell securities in your Account and use those proceeds, as well as your

future contributions, to purchase investments according to the target

allocation determined by Edelman Financial Engines¡¯ software. The

initial transition period can last anywhere from a few weeks up to a

few months as the Program invests periodically to bring your Account

in line with the advice and target allocation outlined in your introductory

materials, as well as any personalization information you may

have provided.

After the initial transition period, we will send you a progress report

each quarter that details the investments you hold, your total Account

balance, and other useful information. The Program typically reviews

your Account at least quarterly, which may result in a change to your

target allocation or to the actual allocation of investments in

the Account.

III. Fees

The Program fees are based on a percentage of assets under

management (excluding loan balances) according to the following

schedule:

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40 basis points (0.40%) per year for the first $100,000.

30 basis points (0.30%) per year for the next $150,000.

20 basis points (0.20%) per year for the next $250,000.

10 basis points (0.10%) per year for the next $500,000.

If applicable, there is a minimum annual fee of $60 per Account.

The fee will be deducted on a monthly basis proportionally from the

balances invested in the Account for each full month that you are

enrolled in the Program. On a business day on or around the 22nd day

of the month, VAI will post sell orders to liquidate a portion of each of

the holdings in your Account in order to make up the amount of the

monthly charge to be deducted. The fee will then be deducted on the

business day immediately following the date of the sell orders (generally

the 23rd day of the month).

Fee example: Assume that, on the 22nd day of the month, your Account

has a balance of $15,000, invested $9,000 (60%) in Fund A and

$6,000 (40%) in Fund B. You would be charged at the rate of 40 basis

points, which, on a balance of $15,000, results in an annual fee of $60.

Your fee for the month would be $60 divided by 12 (since there are 12

months in a year), or $5. Of that $5, 60%, or $3, would be deducted

from your balance in Fund A and 40%, or $2, would be deducted from

your balance in Fund B.

The Program reserves the right to increase or decrease the amount

of the fees charged, but will notify Members of any change in the

fee structure. The fee will be charged monthly for each full month a

participant is enrolled in the Program except during times of a planinitiated event, such as a plan termination or conversion to an alternate

service provider, where the fees may be charged for a partial month.

Please note that during times of a plan-initiated event, such as a

plan termination or conversion to an alternate service provider, fee

handling will vary and will be communicated. The Program also reserves

the right to offer certain retirement plan sponsors and/or Members

discounted fees or other promotional pricing. In addition to the Program

fee, Account assets that are invested in mutual funds indirectly bear

the annual fund operating expenses charged by those mutual funds. A

fund¡¯s expenses are detailed in the fund¡¯s prospectus. Account assets

that are invested in other securities may indirectly bear other expenses

charged by those securities. Such expenses may be detailed in the

security¡¯s investment guidelines or fact sheets, as applicable.

If your Account balance is less than $15,000, please call a Managed

Account specialist at 800-310-9228 to determine whether the Program

is right for you. You may cancel your participation in the Program at any

time by calling a Managed Account specialist.

IV. Outbound calling program

Unless otherwise agreed upon by a sponsor and Vanguard, Edelman

Financial Engines¡¯ Series 65 licensed advisors will make outcalls to

program participants to have discussions about the services available

to them. These calls will allow program participants to implement

personalizations on their account, unenroll from VMAP, discuss VMAP

program details, and receive high level guidance and education on

retirement-related topics.

Outbound calls will be made to new members after enrollment. The

Advisor Center will also make annual outbound retirement check-up

calls to enrolled program participants over the age of 45 years old to

assist in determining retirement readiness and account optimization.

The Advisor Center will not call program participants who have an

aligned Vanguard advisor relationship under a different advice service.

The Advisor Center outcalls will be made by Financial Engines

employees and are not considered employees, investment advisor

representatives, or supervised persons of Vanguard. Their role will be

limited to providing information to program participants to enable

them to decide how to best utilize the services available to them.

Edelman Financial Engines employees may implement participantdirected account personalizations.

V. Methodology

The Program offers investment advice based on an investment

methodology developed by Edelman Financial Engines. For more

information about Edelman Financial Engines or its investment

methodology, please see ¡°V. Edelman Financial Engines.¡± The Program

uses Edelman Financial Engines¡¯ proprietary software, including

software for which patents have been obtained and other patents

are pending, to analyze historical and current returns, volatility,

cross-correlations, and other factors to develop individualized target

allocation recommendations for your Account.

Generally, the methodology used takes a long-term view of investment

management. However, it may recommend trading or short-term

purchases depending on market conditions, changes in individual

preferences, and other relevant criteria.

The Program will invest your Account assets only in investments

available through your employer retirement plan, which are primarily

mutual funds but also may include exchange-listed equity securities,

guaranteed investment contracts issued by insurance companies and

banks, or other securities. The Program will not invest your Account

assets in investments available through your plan¡¯s brokerage window

(if applicable). The Program will not invest your Account assets in

the following types of securities, but can consider them as part of

its portfolio analysis if you already hold them: securities traded overthe-counter; securities traded in foreign markets; warrants; corporate

debt securities; commercial paper; certificates of deposit; municipal

securities; variable life insurance products; variable annuities; U .S.

Government securities; options contracts on securities; and futures

contracts on intangibles. The Program is not responsible for voting

proxies for any securities that may be held in your Account.

To the extent that company stock investments are permitted in your

Account, such investments may not exceed 20% of your unrestricted

account balance (or such other maximum allocation applicable to the

Program for your Account). You acknowledge and agree that you are

directing the Program to effect transactions involving unrestricted

company stock investments in your Account at the Program¡¯s sole

discretion. You therefore further acknowledge and agree that we

may decrease the amount of company stock investments held in your

Account, if any, taking into consideration any preferred maximum

target stock investments held in your Account, if any, taking into

consideration any preferred maximum target allocation that you have

specified. For example, if your current company stock investment

allocation is 15%, we will generally not issue allocations beyond 15% for

your Account balance, notwithstanding that the Program can provide

for allocations up to 20% (or such other maximum allocation applicable

to the Program).

You represent and acknowledge that at the time of enrollment or at the

time you set or change your desired allocation for the company stock

investment, you are not aware of any material nonpublic information

regarding your employer or its securities. You acknowledge and agree

that we may be precluded from making allocation changes with respect

to company stock investments at any time that we may have material

nonpublic information about such employer or its securities. The

Program¡¯s analysis of equity securities generally assumes an efficient

market in which stock prices are fairly valued (as opposed to undervalued or overvalued). Thus, we do not change allocations with respect

to your company stock investment based on fundamental analysis of

the security value compared to current prices. Instead we determine

your allocation for your company stock investments after analyzing

the risk/return impact of concentrated holdings of such assets. The

Program will not take into consideration any favorable tax treatment

on your company stock investment when providing advice and does

not manage assets you may hold through a retirement plan brokerage

account, if applicable, or other restricted investments.

You should be aware that, on any particular day, the actual allocation

of your Account may differ from the target allocation and from any

preferred maximum target allocation to company stock investments

you may have indicated due to various factors including but not limited

to: (1) market movements; (2) changes to the Account; (3) availability

of investment alternatives; (4) results of transaction rounding in any

company stock investments; (5) contributions; (6) the duration of

the transition period; (7) the Program¡¯s capacity to execute directed

allocations and contributions to your Account; and (8) any legal,

regulatory, or other trading restrictions, including those imposed by

securities exchanges or parties other than VAI, Vanguard, and Edelman

Financial Engines.

VI. Edelman Financial Engines

Edelman Financial Engines¡¯ advisory tools are powerful enough to

analyze complex fund data, yet precise enough to make personalized

recommendations and provide expert advice and portfolio

management.

As an independent, third-party, federally registered investment advisor,

Edelman Financial Engines is able to provide its services free from

conflicts of interest. For more detailed information about Edelman

Financial Engines or its investment methodology, please write to Edelman

Financial Engines, Attn: Customer Support, 3315 Scott Blvd, 4th Floor,

Santa Clara, CA 95054 or go to for a copy

of its brochure.

VII. Other important disclosures

Standard of care. With respect to plans subject to the Employee

Retirement Income Security Act of 1974 (¡°ERISA¡±), VAI acknowledges

and agrees that it is a fiduciary under Section3(21) of ERISA and an

investment manager under Section 3(38) of ERISA with respect to the

investment of your plan account, other than restricted investments. In

addition, the Program and its representatives will perform the services

described in this Service Agreement in good faith and in accordance

with applicable federal and state securities laws. However, neither the

Program, VAI, nor any affiliate will be held liable for any losses arising

out of any action performed or omitted, or for errors of judgment

made, within the scope of the performance of such services except

for losses arising from its negligence, willful malfeasance, bad faith, or

breach of its fiduciary duty. Federal and state securities laws impose

liabilities under certain circumstances on persons even when they act

in good faith, and nothing contained herein shall constitute a waiver or

limitation of rights that you may have under federal or state securities

laws. In addition, participation in the Program does not waive your

rights under federal and state securities laws or ERISA which may

impose liability in some circumstances on persons acting in good faith.

The Program and its representatives are not liable for any losses caused

by circumstances beyond our reasonable control. The Program is not

responsible for voting proxies for any securities that may be held in

your Account.

Transaction and redemption fees. Some funds charge fees on the

purchase of shares. These fees, designed to offset the cost of buying

and selling securities, are paid directly to the fund and are not sales

charges. Additionally, some funds charge redemption fees in order to

discourage short-term trading. The Program may invest your assets

in investments with either or both of these types of fees. Should you

incur such fees as a result of the services provided under this Service

Agreement, you acknowledge that these fees will be assessed on your

purchase, or deducted from your redemption proceeds, in accordance

with the conditions set forth in the prospectus of the particular fund

bought or sold for your Account.

Investment results. There is no assurance that you will achieve positive

investment results by participating in the Program. The Program does

not and cannot guarantee the future performance of your Account,

nor can the Program ensure that the securities purchased on your

behalf will be profitable. Investment return and principal value will

fluctuate with market conditions and you may lose money. Although the

Program will implement investment strategies designed to be prudent

and diversified, all investments are subject to risks, including the risks

described in the prospectuses of the investments in which your Account

is invested.

Communications. You agree to verify the accuracy and completeness

of your information on any communications to or from the Program

(including but not limited to your plan preview and Progress Reports)

and to inform the Program immediately of any inaccuracies so that we

may make any appropriate adjustments to your Account, if needed.

You agree to provide the Program with updated information if any

information provided by you changes at any time. You should be aware

that failure to update us could negatively impact our ability to select

a portfolio appropriate for your risk level and financial holdings. In

the event that the Program becomes aware that a security held in a

non-Program Account has been converted to cash or can no longer be

modeled, the Program will assume that the balance related to such

security has become zero.

You consent to the physical and electronic transmission and storage

of your personal and financial information by and among the Program

and you, VAI, the plan sponsor, their respective assignees and

successors, and other parties as necessary and permissible to continue

management of your Account under this Service Agreement.

? 2024 The Vanguard Group, Inc. All rights reserved.

BBBBRKXP 032024

Enforceability. If any part of this Service Agreement is found to be

invalid or unenforceable, it will not affect the validity or enforceability

of any other part of this Service Agreement, which will continue in full

force and effect.

Arbitration. All controversies arising out of or relating to any services

provided by the Program, VAI, Vanguard and their respective affiliates,

directors, or employees with respect to transactions of any kind

executed pursuant to this Service Agreement, with respect to any

Accounts serviced according to this Service Agreement, or which relate

in any way to this Service Agreement, will be resolved by arbitration

and, to the extent not governed by federal law, such as ERISA, governed

by the laws of the Commonwealth of Pennsylvania without reference

to its conflicts of law rules. Note that this arbitration clause does not

constitute a waiver of any right under federal or state securities laws,

or under ERISA, including the right to choose the forum in which to seek

resolution of disputes.

Arbitration shall be conducted in accordance with and subject to the

then-applicable Commercial Dispute Resolution Procedures of the

American Arbitration Association (the AAA Rules). Unless otherwise

mutually agreed upon by the parties, the arbitration hearings will be

held in Philadelphia, Pennsylvania. A panel of three arbitrators will be

selected in accordance with the AAA Rules. The arbitrators will allow

such discovery as is appropriate and consistent with the purposes of

arbitration in accomplishing a fair, speedy, and cost-effective resolution

of disputes. The arbitrators will reference the Federal Rules of Evidence

and the Federal Rules of Civil Procedure then in effect in setting the

scope of discovery. Judgment upon the award rendered in any such

arbitration may be entered in any court having jurisdiction thereof, or

application may be made to such court for a judicial acceptance of the

award and enforcement, as the law of such jurisdiction may require

or allow. You consent to service of process by first-class mail to your

addresses maintained on record at Vanguard.

You should know that: (1) arbitration awards will be final and binding

on all parties; (2) by electronically consenting to the Vanguard

Managed Account Program online enrollment agreement or by signing

the Vanguard Managed Account Program enrollment form, all parties

are waiving their right to seek remedies in court, including the right to

a jury trial; (3) pre-arbitration discovery is generally more limited than

and different from court proceedings; (4) the arbitrators¡¯ decision is

not required to include factual findings or legal reasoning; and (5) any

party¡¯s right to appeal or to seek modification of ruling by arbitrators

is strictly limited.

The arbitration clause may not apply to residents of all states.

VIII. Assignment and termination of services

You may terminate your participation in the Program at any time

by calling a Managed Account specialist at 800-310-9228. You may

terminate your membership in the Program within the first partial

month of enrollment at no cost.

If you terminate your participation, the Program will no longer manage

your Account. Your assets will remain invested in, and your contributions

will continue to be allocated to, the investments selected at the

time you terminate your participation in the Program until you take

further action.

The Program can terminate this Service Agreement at any time

by notifying you in writing. The Program reserves the right, at our

discretion and without prior notice, to change our investment planning

methodology and/or other Program components and/or to discontinue

the Program, in whole or in part, at any time. Changes may affect all

Program participants, individual Program participants, or only those in

certain classes or groups.

Vanguard

P.O. Box 2900

Valley Forge, PA 19482-2900

Vanguard Retirement Plan Participant

privacy policy

The following privacy policy is provided by The Vanguard Group, Inc., and Vanguard Fiduciary Trust Company

(together, Vanguard) and describes how we collect, use, share, and protect information of participants

(including prospective, current, and former participants, and their beneficiaries and/or alternate payees

(Participants)) in the employer-sponsored retirement plans for which Vanguard provides participant

recordkeeping, plan administrative services, and plan trust services.

Please click here to view our Privacy notice for California residents.

Our commitment to you

How we handle your personal information

As the recordkeeper and/or trustee of the employer-sponsored or other

retirement plan in which you participate, Vanguard understands the

importance of safeguarding your financial assets and protecting your

personal and financial information. As a retirement plan Participant,

you trust Vanguard to protect your assets and your information. When

we share Participant information, we do so under the circumstances

described in this policy.

We do not share personally identifying information about Participants

with unaffiliated third parties for use in marketing their own products

and services. We may share personal information when needed to

complete transactions that you request or to raise your awareness

about the financial products and services that we offer. Here are

the details:

? To respond to inquiries, complete transactions, make account changes,

and provide requested services, it may be necessary to provide

identifying information about you to Vanguard¡¯s affiliates or service

suppliers, or to other authorized third parties that are not affiliated

with Vanguard. For example, if you ask to transfer assets from another

financial institution to Vanguard, we will need to provide certain

information about you to that institution to complete the transaction.

? To provide retirement plan education that may increase your chances

of meeting your financial goals, or the goals of the plan, and to educate

you about financial products and services that Vanguard offers or

sponsors, to better understand your needs, and to improve our product

and service offerings, we may share your information within the

Vanguard family of affiliated companies, to the extent permitted

by law.

? At the direction of your plan sponsor, we will provide your information to

third parties, such as service providers of the plan or the plan sponsor.

? To comply with regulatory or legal requirements, we may provide your

information to regulatory bodies, taxing agencies, and law enforcement.

? In certain instances, we contract with service suppliers to perform

services for us. Where necessary, we will disclose information, including

personally identifying information, that we have about you to these

service suppliers. In all such cases, we provide the service supplier with

personal information only as necessary to carry out its responsibilities

as provided in its agreement with us, and only for that purpose. And we

require these service suppliers to treat your personal information with

the same high degree of confidentiality that we do.

? To engage in research collaborations designed to enhance public

understanding of workplace retirement plans and to encourage

supportive public policies, we may share information with leading

academic researchers or industry trade associations. Our research

collaborations have included projects with The Wharton School of the

University of Pennsylvania, Columbia University, and UCLA, among

others. In all cases, the information we provide does not include any

identifying information about you, such as your name, address, or Social

Security number.

? Finally, we will release information about you if we are directed or

authorized to do so, if we are compelled by law or legal process to do so,

or in other legally limited circumstances (for example, to prevent fraud).

We use the personal and other information provided to us primarily

to respond to your inquiries or requests; to maintain and protect your

accounts; to process transactions you request; to provide education

related to retirement plans and financial goals; to fulfill our legal

obligations; for research and analytical purposes; and to develop and

provide the financial products and services that we offer or sponsor.

The personal information we collect about you

Vanguard may collect Participant information from you or from your

plan sponsor, its representatives, and third-party service suppliers

not affiliated with Vanguard (service suppliers). For example, we

may collect information about you when you request information or

materials from Vanguard and when you enter information into an online

application or enrollment process.

To provide participant recordkeeping and plan administration services,

information we may collect or receive about you includes, among other

things, your name, address, Social Security or taxpayer identification

number, employee identification number, phone number, email address,

date of birth, account balances, investment activity, and accounts at

other institutions.

We may combine the information collected on our websites with

information collected from or about you in other contexts. This may

include information collected online, such as on our websites or through

our email exchanges with you, or from offline sources, such as when you

enroll in your plan or call Vanguard Participant Services. We will treat

such combined information in accordance with this policy. If you do not

wish to provide information to Vanguard, we may be unable to provide

certain products or services to you.

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Cookies and web beacons

Our websites offer customized features that require our use of cookies

and web beacons. Certain sections of our websites require cookies

to be enabled to support site performance and provide enhanced

authentication. For example, cookies enable us to personalize and

improve the user experience and help enhance site navigation. Cookies

also help us to understand how people use our online services so that

we can improve their structure,

Our websites use some of the most secure forms of online

communication available, including data encryption, transmission

encryption, user names and passwords, adaptive authentication

techniques, and back-end fraud and account monitoring. These

technologies provide a high level of security and privacy when you

access your account information, initiate online transactions, or send

secure messages.

functionality, and content. Web beacons allow us, directly or through

our service suppliers, to collect information used for website analytics,

such as how many users have visited particular pages or downloaded

documents, or how frequently users search for a particular term.

However, our use of these cookies and web beacons is limited. We do

not use them to view or collect data in cookies or similar data files

created by other websites. We will not share the information in these

data files or give others access to it¡ª except to help us better serve

your investment needs and as described in this privacy policy.

We use a variety of technologies, such as cookies, web beacons, and

similar mechanisms, as described further below, to collect information

that helps us understand how our websites are used. Specifically, when

you visit our websites, we or our service suppliers may automatically

collect a variety of technical and navigational information via these

technologies, including, as applicable: your computer or device type;

operating system version; browser type and version; user agent string;

internet connection type; mobile network provider; date and time

of your visit; time since your last visit; pages you view; links you click;

searches you conduct; the internet protocol (IP) address used to access

our websites; your general geographic location (e.g., your city, state,

or zip code); and the website visited before our sites. We also may use

similar tracking technologies in emails that we or our service suppliers

send to you, as further described below. This information may be used,

for example, to alert you of software compatibility issues, to resolve

technical or service problems, and for security purposes. We also

analyze this information, with the assistance of our service suppliers, to

improve our website design and functionality, to enhance our ability to

serve you and your accounts, and to tailor our communications to you

regarding our products and services.

We and our service suppliers use web beacons and cookies to determine

whether and when you receive and open our emails; these beacons

and cookies may also capture information such as the type of device,

operating system, email program, and web browser used to view the

email, the IP address from which you opened the email, and whether

you clicked any links in the email. These technologies enable us to gauge

the effectiveness, relevance, and value of our email communications.

If you have registered for secure online access to your employer plan

account, we are able to combine the information we collect about

your website usage during a secure (logged-on) session with other

information we know about you, such as any account transactions you

conducted during the web session. We can also identify your computer

or device on each online visit to Vanguard, even if you do not log on,

and link information about that visit to you. We may use this combined

information to assess the appeal and usefulness of the information and

tools offered on our websites.

Cookies

A cookie is a small file of letters and numbers that is stored on your

computer or other device when you visit a website. Cookies contain

information that is transferred to or read on your device and allow

websites to recognize devices and store certain information, such

as user preferences. Cookies are used to distinguish you from other

users of our online services. This helps us to provide you with a useful

experience when you browse and also allows us to improve our online

services. We and our service suppliers use session cookies, which link

your actions during a particular online session and expire at the end of

that session, as well as persistent cookies, which remain on your device

and allow us to remember your actions or preferences across multiple

browser sessions.

Our websites include links to third-party sites or information that we

think may be of interest to you. When you click these links and leave

our websites, our sites¡¯ terms and conditions of use and privacy policy

no longer apply. You are responsible for complying with the third-party

site¡¯s terms of use and understanding its privacy policy, both of which

you should review carefully.

Our websites may enable you to share information directly with

websites or online services operated by third parties. For example,

our sites contain features that allow you to share articles or content

through Facebook, Twitter, LinkedIn, and other services, and to view

content through video players and other services (such as the YouTube

video player). If you choose to use these features, you may disclose

information to those websites or services and their users, and to the

public more generally. Even if you do not click these plug-in features,

these third parties may collect information about you, such as your IP

address and the pages that you view, and they may also set and/or

access a cookie on your device. Because these third-party websites and

services are not operated by Vanguard, we are not responsible for their

content or practices. The collection, use, and disclosure of information

through these websites and services are subject to the privacy policies

of the third-party websites or services, and not this privacy policy.

If you are concerned about having cookies on your computer or other

device, you can set your web browser to refuse all cookies or to indicate

when a cookie is being set, allowing you to decide whether to accept it.

You can also delete cookies from your device. The help feature on most

web browsers will tell you how to prevent your browser from accepting

new cookies, how to receive notice when a new cookie is set, and how

to disable cookies altogether. However, if you choose to block or delete

cookies, certain features of our websites may not operate correctly.

For further information about deleting or blocking cookies, please visit

here. Information about how to opt out of the use of cookies for certain

purposes is discussed below in the section titled ¡°Website analytics.¡±

Web beacons

Our websites and the emails that you receive from Vanguard use an

application known as a web beacon (also known as a pixel tag or clear

gif). A web beacon is an electronic file that usually consists of a singlepixel image, embedded in a web or mobile application page or an email

to measure usage and activity. In some cases, a web beacon triggers

the placement of a persistent cookie on your device.

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