Vanguard FTSE Developed All Cap ex North America Index ETF

The Vanguard FTSE Developed All Cap ex North America Index ETF employs an indexing investment approach designed to track the performance of the FTSE Developed All Cap ex North America Index. This Vanguard ETF invests by sampling the applicable Index, meaning that it holds a broadly diversified subset of Constituent Securities and/or other securities selected by the Sub-advisor that, in the aggregate, approximates the applicable Index in terms of primary risk factors and other key index characteristics. The Sub-advisor matches this Vanguard ETF’s portfolio investments to the primary risk factors of the applicable Index and seeks to achieve returns that are similar to the applicable Index. This sampling technique is beneficial to this Vanguard ETF, as it is designed to reduce trading costs and avoid having to trade illiquid securities that may be included in the applicable Index. In the alternative, this Vanguard ETF may invest all, or substantially all, of its assets in the stocks that make up the applicable Index, holding each stock in approximately the same proportion as its weighting in the Index.