In keeping with Voya Investment Management’s commitment to provide the highest quality of service to its customers, the Company has developed a comprehensive approach to planning for possible disruptions to its critical business operations. Voya Investment Management has developed a Continuity Management Program that includes the following five components:

• The Crisis Response Process/Incident Management Plan addresses various crisis situations (i.e. electrical power outage, fire, bomb threat, pandemics, inclement weather etc.). The plan includes crisis response teams to respond and implement an appropriate course of action in the event of a business disruption. The plan includes procedures for managing an incident, information for employees to follow related to building evacuations and shelter-in-place procedures, a dedicated off-site recovery location and employee updates via an Emergency Crisis Status Line.

• Departmental Business Continuity Plans address business unit actions to be undertaken in a disaster scenario. A risk assessment of each core business process is performed to identify failure scenarios with risk of occurrence in order to determine recovery tolerance for each core process. Documentation of how, by whom, and where critical processes will be resumed are included. Employees have a variety of options, as agreed with their management, for off-site work locations including other Voya Investment Management sites, a third party service recovery site and work from home strategies.

• The Disaster Recovery Plan addresses the recovery and availability of systems and data. Control measures are in place to help ensure the availability of systems and data (data replication, journaling, vaulting, mirroring and off-site media storage). Based on system criticality, applications and data are stored on Storage Area Networks (SAN) which is replicated between primary and secondary Voya Investment Management data centers. The Company maintains documented Disaster Recovery Plans for all critical systems and utilizes a third-party vendor for off-site document storage. Information Technology also provides robust work from home capability through Voya Investment Management provided laptops using Cisco’s Virtual Private Network (VPN) software and Quest Defender authenticated access to files and applications via Citrix.

• The Crisis Communication Plan addresses the communication roles across Voya business units and the types of messages communicated to Voya employees, customers and media in the event of a significant business disruption.

• The final component of Voya Investment Management's Continuity Management Program is the Test and Maintenance Plan. This strategy consists of scalable and incremental tests of the aforementioned Crisis Management Organization, Crisis Communication Plan, Business Continuity Plans and Disaster Recovery Plans. Annual and bi-annual tests include communication exercises, evacuation drills, desktop/walkthrough exercises and simulation exercises of critical system recovery capabilities.

Voya Investment Management is committed to providing seamless, high quality service to our clients at all times. To address pandemics, Voya Investment Management’s Crisis Management Organization has assembled a Crisis Response Team consistent with the firm’s standard operating procedure as part of our documented Crisis Management Plan. The Crisis Response Team consists of senior leaders representing key area of the firm that include: Human Resources, Communications, Compliance, Client Services, Information Technology, Facilities, Risk Management, Operations, Equity Investments, Fixed Income Investments and Proprietary Investments.

During the H1N1 2009/2010 pandemic, the team was convened regularly to update and adjust plans in accordance with breaking news, CDC guidelines and industry best practices. Standing topics discussed included social distances strategies, employee and client communications, business continuity strategies, employee safety and precautions, and business travel.

Voya Investment Management continues to refine its Continuity Management Program through ongoing risk assessments that considers: changing business conditions, local and regional events, the national security level and other factors that may influence the safety of employees and the ability to conduct business and meet customer obligations.

If you have any questions or concerns regarding our Continuity Management Program, please contact your Voya Investment Management Client Services Representative.