UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

FORM N-CSR

 

CERTIFIED SHAREHOLDER REPORT

OF

REGISTERED MANAGEMENT INVESTMENT COMPANIES

 

Investment Company Act file number: 811-02968-99

 

Name of Registrant: Vanguard Trustees’ Equity Fund
Address of Registrant: P.O. Box 2600
  Valley Forge, PA 19482

 

Name and address of agent for service: Anne E. Robinson, Esquire
  P.O. Box 876
  Valley Forge, PA 19482

 

Registrant’s telephone number, including area code: (610) 669-1000

 

Date of fiscal year end: October 31

 

Date of reporting period: November 1, 2021—October 31, 2022

 

 

 

 

Item 1: Reports to Shareholders

 

 

Annual Report  |  October 31, 2022
Vanguard International Value Fund

Contents

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7

9

11
Please note: The opinions expressed in this report are just that—informed opinions. They should not be considered promises or advice. Also, please keep in mind that the information and opinions cover the period through the date on the front of this report. Of course, the risks of investing in your fund are spelled out in the prospectus.

Table of Contents
Your Fund’s Performance at a Glance
The 12 months ended October 31, 2022, were a volatile, challenging period for financial markets. Vanguard International Value Fund returned –21.28%, which, was ahead of the –24.73% return of its benchmark.
The global economic backdrop deteriorated as inflation reached multidecade highs, notably in energy and food prices after Russia invaded Ukraine. Price increases then broadened to other goods and services, adding to concerns that inflation would remain stubbornly high. Many central banks tightened aggressively to try to rein in inflation, which increased fears of a recession.
All sectors except energy declined for both the fund and its benchmark. The advisors’ selections in energy and financial stocks helped performance relative to the benchmark, as did an underweight to information technology. The health care, utilities, and consumer staples sectors all detracted slightly.
Declines prevailed in most regions, but emerging markets aided relative performance primarily through an underweight to China, an overweight to Brazil, and security selection in Indonesia. European stocks were strong contributors, notably through stock selection in France and the Netherlands. Pacific markets, particularly Japan, Australia, and Hong Kong, hurt relative performance the most.
For the decade ended October 31, 2022, the fund’s average annualized return was 3.93%, outpacing the 3.27% return of its benchmark.
Market Barometer
  Average Annual Total Returns
Periods Ended October 31, 2022
  One Year Three Years Five Years
Stocks      
Russell 1000 Index (Large-caps) -16.38% 9.99% 10.19%
Russell 2000 Index (Small-caps) -18.54 7.05 5.56
Russell 3000 Index (Broad U.S. market) -16.52 9.79 9.87
FTSE All-World ex US Index (International) -24.20 -1.16 -0.18
Bonds      
Bloomberg U.S. Aggregate Float Adjusted Index
(Broad taxable market)
-15.69% -3.73% -0.50%
Bloomberg Municipal Bond Index
(Broad tax-exempt market)
-11.98 -2.18 0.37
FTSE Three-Month U.S. Treasury Bill Index 0.88 0.59 1.15
CPI      
Consumer Price Index 7.75% 5.01% 3.85%
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Advisors’ Report
For the 12 months ended October 31, 2022, Vanguard International Value Fund returned –21.28%. It outpaced its benchmark, the MSCI ACWI ex USA Index, which returned –24.73%.
Your fund is managed by three independent advisors, a strategy that enhances its diversification by providing exposure to distinct yet complementary investment approaches. It’s not uncommon for different advisors to have different views about individual securities or the broader investment environment.
The accompanying table lists the advisors, the amount and percentage of fund assets each manages, and brief descriptions of their investment strategies.
The advisors have provided the following assessment of the investment environment during the past 12 months and the notable successes and shortfalls in their portfolios. These comments were prepared on November 15, 2022.
Lazard Asset Management LLC
Portfolio Managers:
Michael G. Fry, Managing Director
Michael A. Bennett, CPA,
Managing Director
International markets fell sharply as the level and sustainability of inflation continued to surprise investors. The resulting higher interest rate environment, along with some rolling COVID
lockdowns, drove very weak equity markets for international investors. The U.S. dollar appreciated on interest rate differentials and its perceived safe-haven status. The deeply discounted valuations of international benchmarks relative to the U.S. have supported outperformance versus the U.S. in local terms. Weaker currencies contributed to a nearly 12-percentage-point headwind for international equities, a level that now represents the largest headwind to local performance over the past 20 years.
Stock selection in the financial sector was a large driver of strong relative performance during the period, where our preference for high-quality, strong deposit franchise banks was rewarded amid rising rates. Key outperformers were Mexico’s Grupo Banorte, Indonesia’s Bank Mandiri, and India’s ICICI Bank. Stock selection in the energy sector was also beneficial, as shares of U.K.-based integrated oil and gas company BP rose after the company announced a 10% dividend increase and a $3.5 billion share buyback. These results support our investment thesis of strong cash-flow production and should enable shareholder returns in the low-to-mid teens (through buyback and dividends) as well as debt paydown.
In contrast, stock selection in the utilities sector hurt relative returns. China Longyuan, the Chinese wind farm company, underperformed as investors gauged the impact of COVID restrictions in China, which prompted a general sell-off in Hong Kong stocks. Additionally, slightly weaker wind speeds in China
 
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during the first half led to some concerns over results, which proved to be fine.
In this environment, where the market, in our opinion, is expecting a contraction in earnings, we are finding an increasing number of relative value opportunities. Many are high-quality compounders whose valuations have fallen enough in our estimation because of higher interest rates. Others are very inexpensive but higher-quality cyclicals whose valuations, in our view, are already discounting pressure to earnings. We believe the portfolio is well balanced within relative value, between more defensive compounders and higher-quality cyclicals, and we continue to avoid the extremes of still-expensive growth and low quality.
Higher inflation and interest rates have changed the investment landscape, and we anticipate a much broader set of relative value ideas to materialize. This leadership, driven by the combination of higher financial productivity and less expensive valuations, should enable stock selection to drive performance once again.
Sprucegrove Investment Management Ltd.
Portfolio Managers:
Arjun Kumar, CFA,
Chief Executive Officer and Managing Director
Co-Lead of International Equities
Shirley Woo, CFA, Managing Director
Co-Lead of International Equities
The global economy was still facing several post-COVID challenges during the period, including inflation concerns, and the start of the conflict in Ukraine added another layer of uncertainty. International equities steadily declined to reach two-year lows.
The sharp rise in commodity prices, particularly in energy, further fueled inflationary pressures that forced central banks to raise rates quicker and by wider margins than anticipated. This, combined with the magnitude of the energy shock in Europe, makes a recession in the region highly likely in the coming months.
This environment was also marked by large currency extremes. The U.S. dollar has risen to its highest level in decades, supported by the Federal Reserve’s aggressive rate hikes and its safe-haven appeal during times of market volatility. This has weighed on currency-adjusted returns for U.S.-based investors.
Outperformance over the past year was led by stock selection in the information technology, communication services, and consumer discretionary sectors, which contain some of the most highly valued stocks in the index. Our discipline on valuations was an advantage this year, as higher interest rates hurt growth stocks the most.
From a regional perspective, emerging markets was a significant contributor due to an underweight position to China, no
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exposure to Russia, and strong performance from several of our Brazilian and Indonesian holdings, which provided rare positive returns.
Critical to understanding is how the portfolio is positioned today. Our bottom-up, fundamental approach has been consistently applied over the decades, as we continue to focus on constructing portfolios of quality companies at attractive valuations. Over the course of the past year, we have added new names to the portfolio and augmented several existing positions as opportunities presented themselves.
As compared to the benchmark at the end of the period, the fund represents higher quality and lower risk (as gauged by financial leverage) and was more attractively valued. These characteristics are critical to our quest to achieve superior investment returns through a full market cycle.
ARGA Investment Management, LP
Portfolio Managers:
A. Rama Krishna, CFA, Founder and
Chief Investment Officer
Steven Morrow, CFA, Director of Research
International equities plunged as world markets reacted to rate hikes, ongoing inflation, recessionary fears, supply chain disruptions, adverse regulation, and geopolitical tensions. Investor attention generally fixated on risks rather than opportunities.
In ARGA’s experience as a value manager, fear and uncertainty create opportunity. Accordingly, ARGA’s response to the year’s chaos was to identify new investment opportunities and control risk. The portfolio’s long-term orientation took advantage of significant near-term stress affecting many global businesses. Fundamental research showed many stressed businesses appear capable of surviving prolonged economic weakness and emerging competitively stronger when conditions normalize. Companies deemed most underpriced relative to their earning power were added to the portfolio.
This valuation discipline, coupled with rigorous risk management, led to a smaller decline in the ARGA portfolio than the broader market. ARGA believes that mandatory stress tests for every portfolio company helped mitigate the downside.
The current portfolio reflects a combination of older opportunities where full potential has yet to be realized and newer opportunities resulting from recent stress. While portfolio composition arises from company valuations rather than targeted industries or geographies, broad areas of opportunity include: (1) aerospace, airline, lodging, and other travel holdings positioned to benefit from travel recovery; (2) Chinese internet companies facing regulatory risk and slowing Chinese growth but with solid franchises generating strong cash flows; and (3) select opportunities in auto, steel, chemical, and other industries.
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Market risks and challenges of the past year may well persist. ARGA believes this creates meaningful opportunity for patient investors in general and value investors in particular.
5

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Vanguard International Value Fund Investment Advisors
  Fund Assets Managed  
Investment Advisor % $ Million Investment Strategy
Lazard Asset Management LLC 39 4,594 The advisor uses a research-driven, bottom-up, relative-value approach in selecting stocks. The goal is to identify individual stocks that offer an appropriate trade-off between low relative valuation and high financial productivity.
Sprucegrove Investment Management Ltd. 35 4,090 The advisor employs a concentrated, low-turnover, value-oriented investment approach that results in a portfolio of companies with good long-term prospects and below-market price/earnings ratios. In-depth fundamental research on industries and companies is central to this investment process.
ARGA Investment Management, LP 24 2,767 The advisor invests in deeply undervalued securities with long-term upside. Its valuation discipline is based on fundamental research and present value, with full integration of ESG risks and opportunities.
Cash Investments 2 281 These short-term reserves are invested by Vanguard in equity index products to simulate investments in stocks. Each advisor may also maintain a modest cash position.
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About Your Fund’s Expenses
As a shareholder of the fund, you incur ongoing costs, which include costs for portfolio management, administrative services, and shareholder reports (like this one), among others. Operating expenses, which are deducted from a fund’s gross income, directly reduce the investment return of the fund.
A fund‘s expenses are expressed as a percentage of its average net assets. This figure is known as the expense ratio. The following examples are intended to help you understand the ongoing costs (in dollars) of investing in your fund and to compare these costs with those of other mutual funds. The examples are based on an investment of $1,000 made at the beginning of the period shown and held for the entire period.
The accompanying table illustrates your fund’s costs in two ways:
Based on actual fund return. This section helps you to estimate the actual expenses that you paid over the period. The ”Ending Account Value“ shown is derived from the fund’s actual return, and the third column shows the dollar amount that would have been paid by an investor who started with $1,000 in the fund. You may use the information here, together with the amount you invested, to estimate the expenses that you paid over the period.
To do so, simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number given for your fund under the heading ”Expenses Paid During Period.“
Based on hypothetical 5% yearly return. This section is intended to help you compare your fund‘s costs with those of other mutual funds. It assumes that the fund had a yearly return of 5% before expenses, but that the expense ratio is unchanged. In this case—because the return used is not the fund’s actual return—the results do not apply to your investment. The example is useful in making comparisons because the Securities and Exchange Commission requires all mutual funds to calculate expenses based on a 5% return. You can assess your fund’s costs by comparing this hypothetical example with the hypothetical examples that appear in shareholder reports of other funds.
Note that the expenses shown in the table are meant to highlight and help you compare ongoing costs only and do not reflect transaction costs incurred by the fund for buying and selling securities. Further, the expenses do not include any purchase, redemption, or account service fees described in the fund prospectus. If such fees were applied to your account, your costs would be higher. Your fund does not carry a “sales load.”
The calculations assume no shares were bought or sold during the period. Your actual costs may have been higher or lower, depending on the amount of your investment and the timing of any purchases or redemptions.
You can find more information about the fund’s expenses, including annual expense ratios, in the Financial Statements section of this report. For additional information on operating expenses and other shareholder costs, please refer to your fund’s current prospectus.
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Six Months Ended October 31, 2022      
International Value Fund Beginning
Account Value
4/30/2022
Ending
Account Value
10/31/2022
Expenses
Paid During
Period
Based on Actual Fund Return $1,000.00 $884.60 $1.85
Based on Hypothetical 5% Yearly Return 1,000.00 1,023.24 1.99
The calculations are based on expenses incurred in the most recent six-month period. The fund's annualized six-month expense ratio for that period is 0.39%. The dollar amounts shown as ”Expenses Paid” are equal to the annualized expense ratio multiplied by the average account value over the period, multiplied by the number of days in the most recent six-month period, then divided by the number of days in the most recent 12-month period (184/365).
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Table of Contents
International Value Fund
Performance Summary
All of the returns in this report represent past performance, which is not a guarantee of future results that may be achieved by the fund. (Current performance may be lower or higher than the performance data cited. For performance data current to the most recent month-end, visit our website at vanguard.com/performance.) Note, too, that both investment returns and principal value can fluctuate widely, so an investor’s shares, when sold, could be worth more or less than their original cost. The returns shown do not reflect taxes that a shareholder would pay on fund distributions or on the sale of fund shares.
Cumulative Performance: October 31, 2012, Through October 31, 2022
Initial Investment of $10,000
    Average Annual Total Returns
Periods Ended October 31, 2022
 
    One
Year
Five
Years
Ten
Years
Final Value
of a $10,000
Investment
 International Value Fund -21.28% -0.13% 3.93% $14,703
 MSCI All Country World Index ex USA -24.73 -0.60 3.27 13,796
See Financial Highlights for dividend and capital gains information.
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International Value Fund
Fund Allocation
As of October 31, 2022
 
United Kingdom 13.9%
Japan 11.3
Germany 9.3
France 8.9
Switzerland 6.9
China 6.3
India 5.4
Hong Kong 4.7
Netherlands 4.4
Brazil 3.9
South Korea 3.4
United States 3.4
Singapore 2.6
Canada 2.5
Indonesia 2.4
Ireland 2.2
Finland 1.2
Other 7.3
The table reflects the fund’s investments, except for short-term investments and derivatives.
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International Value Fund
Financial Statements
Schedule of Investments
As of October 31, 2022
The fund files its complete schedule of portfolio holdings with the Securities and Exchange Commission (SEC) for the first and third quarters of each fiscal year as an exhibit to its reports on Form N-PORT. The fund’s Form N-PORT reports are available on the SEC’s website at www.sec.gov.
          Shares Market
Value

($000)
Common Stocks (94.6%)
Australia (0.8%)
National Australia Bank Ltd.   2,155,160     44,767
QBE Insurance Group Ltd.   4,298,322     33,677
Adbri Ltd.   9,598,354      9,677
                        88,121
Brazil (3.7%)
1 Banco Bradesco SA ADR  42,762,052    162,068
Ambev SA ADR  33,935,500    103,164
Gerdau SA Preference Shares  12,126,300     60,450
Petroleo Brasileiro SA Preference Shares  10,417,600     60,120
Petroleo Brasileiro SA ADR   3,893,780     49,918
                       435,720
Canada (2.3%)
Suncor Energy Inc.   3,256,143    112,000
Saputo Inc.   2,201,749     53,591
Bank of Nova Scotia     761,351     36,801
Alimentation Couche-Tard Inc.     693,700     31,061
Stella-Jones Inc.     915,400     27,569
North West Co. Inc.     435,500     11,332
                       272,354
China (5.9%)
* Alibaba Group Holding Ltd.  21,140,600    164,366
* Baidu Inc. ADR   1,152,791     88,269
Tencent Holdings Ltd.   3,113,800     81,821
ENN Energy Holdings Ltd.   4,943,400     49,148
China Longyuan Power Group Corp. Ltd. Class H  39,737,000     45,406
Shandong Weigao Group Medical Polymer Co. Ltd. Class H  32,448,000     44,706
Sungrow Power Supply Co. Ltd. Class A   2,380,460     42,769
          Shares Market
Value

($000)
* Alibaba Group Holding Ltd. ADR     620,407     39,445
Wuxi Lead Intelligent Equipment Co. Ltd. Class A   4,502,616     30,957
Autohome Inc. ADR   1,112,003     29,046
Hengan International Group Co. Ltd.   7,215,500     27,976
Ping An Insurance Group Co. of China Ltd. Class H   5,304,000     21,234
* Weibo Corp. ADR   1,429,981     16,187
* Trip.com Group Ltd. ADR     641,343     14,514
                       695,844
Denmark (0.8%)
Carlsberg A/S Class B     498,698     58,720
Vestas Wind Systems A/S   1,969,298     38,822
                        97,542
Egypt (0.3%)
Commercial International Bank Egypt SAE (Registered) GDR  25,685,548     32,597
Finland (1.2%)
Sampo OYJ Class A   1,571,237     71,849
Nokian Renkaat OYJ   2,855,350     32,199
Nokia OYJ   6,980,867     31,023
                       135,071
France (8.4%)
Airbus SE   1,637,523    177,186
TotalEnergies SE   3,033,640    165,495
Air Liquide SA     902,385    118,044
Engie SA   8,409,958    109,274
Bureau Veritas SA   2,962,936     73,304
Pernod Ricard SA     416,762     73,147
Thales SA     567,781     72,210
Legrand SA     842,306     64,188
Societe Generale SA   1,854,645     42,540
Teleperformance     158,348     42,426
* Accor SA   1,309,358     31,374
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Table of Contents
International Value Fund
          Shares Market
Value

($000)
Publicis Groupe SA     247,452     13,859
Safran SA      41,270      4,596
                       987,643
Germany (8.8%)
MTU Aero Engines AG     628,158    112,414
Henkel AG & Co. KGaA Preference Shares   1,561,313     98,361
Merck KGaA     531,717     86,651
Fresenius SE & Co. KGaA   3,519,031     80,984
Bayerische Motoren Werke AG     919,000     72,134
Porsche Automobil Holding SE Preference Shares   1,209,821     67,596
BASF SE   1,476,590     66,256
Infineon Technologies AG   2,451,511     59,487
Henkel AG & Co. KGaA     975,920     57,292
2 Covestro AG   1,681,860     57,093
SAP SE     478,150     46,023
Fresenius Medical Care AG & Co. KGaA   1,585,910     43,867
Continental AG     830,599     43,021
Jungheinrich AG Preference Shares   1,566,012     38,917
2 Siemens Healthineers AG     790,012     36,193
FUCHS PETROLUB SE Preference Shares   1,257,070     36,001
Vonovia SE   1,612,640     35,656
                     1,037,946
Hong Kong (4.4%)
AIA Group Ltd.  18,921,000    143,323
* Sands China Ltd.  47,010,000     82,184
* Melco Resorts & Entertainment Ltd. ADR  10,563,690     57,783
Jardine Matheson Holdings Ltd.   1,173,100     54,042
Galaxy Entertainment Group Ltd.   9,079,000     41,479
2 ESR Group Ltd.  19,250,600     32,829
Xinyi Glass Holdings Ltd.  20,644,000     26,531
Hongkong Land Holdings Ltd.   5,380,000     20,712
2 WH Group Ltd.  40,747,243     20,578
CK Asset Holdings Ltd.   3,466,500     19,165
Yue Yuen Industrial Holdings Ltd.  18,050,500     18,351
                       516,977
India (5.1%)
ICICI Bank Ltd. ADR   6,094,587    134,325
Zee Entertainment Enterprises Ltd. Class B  31,279,583     99,370
Housing Development Finance Corp. Ltd.   3,133,250     93,680
Reliance Industries Ltd.   2,790,471     86,105
Adani Ports & Special Economic Zone Ltd.   7,612,517     75,799
          Shares Market
Value

($000)
UPL Ltd.   5,608,124     49,509
GAIL India Ltd.  30,736,329     33,881
Ambuja Cements Ltd.   4,670,849     30,099
                       602,768
Indonesia (2.2%)
Astra International Tbk. PT 212,997,700     91,020
Bank Mandiri Persero Tbk. PT 133,290,200     90,045
Telkom Indonesia Persero Tbk. PT ADR   1,567,073     43,596
Telkom Indonesia Persero Tbk. PT  77,847,500     21,863
Selamat Sempurna Tbk. PT 164,317,700     15,797
                       262,321
Ireland (2.1%)
* Ryanair Holdings plc ADR   1,534,725    105,727
* ICON plc     379,267     75,034
CRH plc   1,732,400     62,398
                       243,159
Israel (0.1%)
* Check Point Software Technologies Ltd.      94,500     12,212
Italy (0.8%)
Brembo SpA   5,290,233     55,306
UniCredit SpA   2,776,866     34,437
                        89,743
Japan (10.7%)
Olympus Corp.   4,512,800     95,150
Mitsubishi Electric Corp.   9,260,100     81,476
Toyota Motor Corp.   5,410,100     75,063
Disco Corp.     285,100     68,190
Bandai Namco Holdings Inc.   1,022,700     67,603
Daikin Industries Ltd.     431,600     64,648
Denso Corp.   1,268,100     62,918
Nidec Corp.   1,066,800     58,657
Hoya Corp.     561,100     52,161
Nomura Research Institute Ltd.   2,304,800     51,006
Nitto Denko Corp.     953,000     50,210
Nihon Kohden Corp.   2,226,200     49,849
ITOCHU Corp.   1,803,300     46,605
Daiwa Securities Group Inc.  11,814,800     46,097
Kubota Corp.   3,035,300     42,341
Daito Trust Construction Co. Ltd.     400,000     39,610
Ain Holdings Inc.     939,600     39,473
Koito Manufacturing Co. Ltd.   2,623,200     37,241
Suzuki Motor Corp.   1,063,800     35,967
Shimano Inc.     227,500     35,204
Subaru Corp.   1,996,600     31,209
 
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International Value Fund
          Shares Market
Value

($000)
Kansai Electric Power Co. Inc.   4,020,200     30,454
Komatsu Ltd.   1,453,900     28,482
Nomura Holdings Inc.   7,414,800     23,994
Seria Co. Ltd.   1,123,400     18,352
FANUC Corp.      82,900     10,848
Omron Corp.     163,100      7,607
Taiheiyo Cement Corp.     222,600      3,025
                     1,253,440
Mexico (0.8%)
Grupo Financiero Banorte SAB de CV  11,158,700     90,703
Netherlands (4.1%)
Wolters Kluwer NV     729,476     77,513
Koninklijke DSM NV     561,313     66,028
Aegon NV  13,585,908     62,891
Universal Music Group NV   2,940,057     57,729
Akzo Nobel NV     749,534     46,273
SBM Offshore NV   3,001,810     40,625
* AerCap Holdings NV     563,815     30,113
2 ABN AMRO Bank NV    2,835,943     27,879
* Prosus NV     621,904     26,892
Koninklijke Vopak NV   1,229,500     25,121
IMCD NV     176,025     22,830
                       483,894
Norway (0.5%)
Equinor ASA   1,014,614     36,966
Bakkafrost P/F     481,190     24,068
                        61,034
Panama (0.7%)
* Copa Holdings SA Class A   1,114,653     83,855
Philippines (0.2%)
Puregold Price Club Inc.  43,303,300     22,468
Singapore (2.5%)
United Overseas Bank Ltd.   4,032,700     79,117
DBS Group Holdings Ltd.   2,860,400     69,154
Singapore Telecommunications Ltd.  28,890,600     50,869
Venture Corp. Ltd.   3,731,000     41,986
Sembcorp Industries Ltd.  20,083,100     41,284
*,1 SATS Ltd.   6,163,700     11,897
                       294,307
South Africa (0.3%)
Mr Price Group Ltd.   3,450,376     33,209
South Korea (3.3%)
Samsung Electronics Co. Ltd.   2,498,844    104,002
POSCO Holdings Inc.     568,173     99,027
          Shares Market
Value

($000)
2 Samsung Electronics Co. Ltd. GDR      91,980     94,997
SK Hynix Inc.   1,303,719     75,474
* SK Square Co. Ltd.     309,162      7,994
                       381,494
Spain (0.3%)
1 Industria de Diseno Textil SA   1,577,858     35,815
Sweden (0.3%)
Assa Abloy AB Class B   1,845,802     37,271
Switzerland (6.5%)
* Holcim AG   3,855,713    175,174
Novartis AG (Registered)   1,526,264    123,461
Roche Holding AG     332,866    110,444
Cie Financiere Richemont SA (Registered)     974,903     95,281
ABB Ltd. (Registered)   3,243,410     90,070
Adecco Group AG (Registered)   2,048,922     64,123
Credit Suisse Group AG (Registered)   9,768,204     40,464
Swatch Group AG     154,510     34,720
UBS Group AG (Registered)   1,811,608     28,722
                       762,459
Taiwan (0.6%)
Taiwan Semiconductor Manufacturing Co. Ltd.   5,694,000     68,454
United Kingdom (13.2%)
BP plc  32,156,484    177,909
RELX plc   5,282,048    141,878
Shell plc   4,693,650    130,022
Unilever plc   2,049,036     93,138
Compass Group plc   4,213,789     88,750
Anglo American plc   2,858,401     85,621
Smiths Group plc   4,720,940     84,564
HSBC Holdings plc (XHKG)  14,812,400     76,022
HSBC Holdings plc  14,415,035     73,979
Berkeley Group Holdings plc   1,592,176     63,349
IMI plc   4,136,690     58,273
Victrex plc   2,598,116     49,345
Weir Group plc   2,721,260     47,415
Travis Perkins plc   4,999,053     47,116
Ferguson plc     428,260     46,706
Spectris plc   1,176,470     40,775
Smith & Nephew plc   3,445,023     40,710
Barclays plc  22,953,206     39,003
RS Group plc   2,786,400     30,660
Prudential plc   2,736,608     25,422
*,1 easyJet plc   6,237,379     24,835
Taylor Wimpey plc  20,793,159     22,355
Renishaw plc     530,507     21,288
 
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          Shares Market
Value

($000)
Whitbread plc     653,543     19,235
Lloyds Banking Group plc  31,286,248     15,026
Direct Line Insurance Group plc     220,462        509
                     1,543,905
United States (3.2%)
Aon plc Class A     416,187    117,152
Accenture plc Class A     237,551     67,441
RenaissanceRe Holdings Ltd.     407,363     63,011
* TechnipFMC plc   4,627,975     49,010
1 Linde plc     130,895     39,083
NXP Semiconductors NV     201,591     29,448
* Capri Holdings Ltd.     317,426     14,500
                       379,645
Vietnam (0.5%)
Vietnam Dairy Products JSC  16,775,900     52,952
Phu Nhuan Jewelry JSC   2,229,200      9,251
                        62,203
Total Common Stocks
(Cost $12,065,534)
11,104,174
Temporary Cash Investments (5.9%)
Money Market Fund (5.9%)
3,4 Vanguard Market Liquidity Fund, 3.117% (Cost $685,572)   6,858,440    685,707
Total Investments (100.5%)
(Cost $12,751,106)
  11,789,881
Other Assets and Liabilities—Net (-0.5%)   (57,350)
Net Assets (100%)   11,732,531
Cost is in $000.
See Note A in Notes to Financial Statements.
* Non-income-producing security.
1 Includes partial security positions on loan to broker-dealers. The total value of securities on loan is $106,341,000.
2 Security exempt from registration under Rule 144A of the Securities Act of 1933. Such securities may be sold in transactions exempt from registration, normally to qualified institutional buyers. At October 31, 2022, the aggregate value was $269,569,000, representing 2.3% of net assets.
3 Affiliated money market fund available only to Vanguard funds and certain trusts and accounts managed by Vanguard. Rate shown is the 7-day yield.
4 Collateral of $113,548,000 was received for securities on loan.
  ADR—American Depositary Receipt.
  GDR—Global Depositary Receipt.
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Derivative Financial Instruments Outstanding as of Period End

Futures Contracts
      ($000)
  Expiration Number of
Long (Short)
Contracts
Notional
Amount
Value and
Unrealized
Appreciation
(Depreciation)
Long Futures Contracts
MSCI EAFE Index December 2022 2,328 204,387 (6,775)
MSCI Emerging Market Index December 2022 1,997 85,232 (9,844)
        (16,619)
See accompanying Notes, which are an integral part of the Financial Statements.
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Statement of Assets and Liabilities
As of October 31, 2022
($000s, except shares and per-share amounts) Amount
Assets  
Investments in Securities, at Value1  
Unaffiliated Issuers (Cost $12,065,534) 11,104,174
Affiliated Issuers (Cost $685,572) 685,707
Total Investments in Securities 11,789,881
Investment in Vanguard 452
Foreign Currency, at Value (Cost $18,195) 18,096
Cash Collateral Pledged—Futures Contracts 14,752
Receivables for Investment Securities Sold 27,765
Receivables for Accrued Income 42,841
Receivables for Capital Shares Issued 7,815
Total Assets 11,901,602
Liabilities  
Due to Custodian 860
Payables for Investment Securities Purchased 20,329
Collateral for Securities on Loan 113,548
Payables for Capital Shares Redeemed 11,894
Payables to Investment Advisor 5,305
Payables to Vanguard 1,496
Variation Margin Payable—Futures Contracts 2,122
Deferred Foreign Capital Gains Taxes 13,517
Total Liabilities 169,071
Net Assets 11,732,531
1 Includes $106,341 of securities on loan.  

At October 31, 2022, net assets consisted of:

   
Paid-in Capital 12,745,069
Total Distributable Earnings (Loss) (1,012,538)
Net Assets 11,732,531
   
Net Assets  
Applicable to 355,915,884 outstanding $.001 par value shares of
beneficial interest (unlimited authorization)
11,732,531
Net Asset Value Per Share $32.96
See accompanying Notes, which are an integral part of the Financial Statements.
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Statement of Operations
  Year Ended
October 31, 2022
  ($000)
Investment Income  
Income  
Dividends1 410,933
Interest2 5,917
Securities Lending—Net 822
Total Income 417,672
Expenses  
Investment Advisory Fees—Note B  
Basic Fee 22,279
Performance Adjustment 492
The Vanguard Group—Note C  
Management and Administrative 26,339
Marketing and Distribution 1,181
Custodian Fees 737
Auditing Fees 42
Shareholders’ Reports 223
Trustees’ Fees and Expenses 5
Other Expenses 545
Total Expenses 51,843
Net Investment Income 365,829
Realized Net Gain (Loss)  
Investment Securities Sold2,3 (230,362)
Futures Contracts (74,220)
Forward Currency Contracts 95
Foreign Currencies (9,992)
Realized Net Gain (Loss) (314,479)
Change in Unrealized Appreciation (Depreciation)  
Investment Securities2,4 (3,243,240)
Futures Contracts (13,965)
Foreign Currencies (2,315)
Change in Unrealized Appreciation (Depreciation) (3,259,520)
Net Increase (Decrease) in Net Assets Resulting from Operations (3,208,170)
1 Dividends are net of foreign withholding taxes of $28,171,000.
2 Interest income, realized net gain (loss), capital gain distributions received, and change in unrealized appreciation (depreciation) from an affiliated company of the fund were $5,917,000, ($263,000), $19,000, and $82,000, respectively. Purchases and sales are for temporary cash investment purposes.
3 Realized Gain (Loss) is net of foreign capital gains taxes of $4,497,000.
4 The change in unrealized appreciation (depreciation) is net of the change in deferred foreign capital gains taxes of ($7,973,000).
See accompanying Notes, which are an integral part of the Financial Statements.
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Statement of Changes in Net Assets
  Year Ended October 31,
  2022
($000)
2021
($000)
Increase (Decrease) in Net Assets    
Operations    
Net Investment Income 365,829 351,127
Realized Net Gain (Loss) (314,479) 897,431
Change in Unrealized Appreciation (Depreciation) (3,259,520) 2,275,436
Net Increase (Decrease) in Net Assets Resulting from Operations (3,208,170) 3,523,994
Distributions    
Total Distributions (633,591) (189,189)
Capital Share Transactions    
Issued 2,352,101 4,442,988
Issued in Lieu of Cash Distributions 576,930 173,403
Redeemed (2,573,910) (2,140,447)
Net Increase (Decrease) from Capital Share Transactions 355,121 2,475,944
Total Increase (Decrease) (3,486,640) 5,810,749
Net Assets    
Beginning of Period 15,219,171 9,408,422
End of Period 11,732,531 15,219,171
See accompanying Notes, which are an integral part of the Financial Statements.
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Financial Highlights
For a Share Outstanding
Throughout Each Period
Year Ended October 31,
2022 2021 2020 2019 2018
Net Asset Value, Beginning of Period $43.76 $32.48 $36.63 $35.86 $39.26
Investment Operations          
Net Investment Income1 1.019 1.091 .684 1.104 .950
Net Realized and Unrealized Gain (Loss) on Investments (10.011) 10.824 (3.723) 1.669 (3.607)
Total from Investment Operations (8.992) 11.915 (3.039) 2.773 (2.657)
Distributions          
Dividends from Net Investment Income (1.087) (.635) (1.111) (.943) (.743)
Distributions from Realized Capital Gains (.721) (1.060)
Total Distributions (1.808) (.635) (1.111) (2.003) (.743)
Net Asset Value, End of Period $32.96 $43.76 $32.48 $36.63 $35.86
Total Return2 -21.28% 36.91% -8.69% 8.48% -6.95%
Ratios/Supplemental Data          
Net Assets, End of Period (Millions) $11,733 $15,219 $9,408 $10,360 $9,524
Ratio of Total Expenses to Average Net Assets3 0.38% 0.36% 0.35% 0.37% 0.38%
Ratio of Net Investment Income to Average Net Assets 2.68% 2.56% 2.05% 3.15% 2.41%
Portfolio Turnover Rate 37% 33% 72% 38% 28%
1 Calculated based on average shares outstanding.
2 Total returns do not include account service fees that may have applied in the periods shown. Fund prospectuses provide information about any applicable account service fees.
3 Includes performance-based investment advisory fee increases (decreases) of 0.00%, (0.01%), (0.02%), (0.01%), and (0.01%).
See accompanying Notes, which are an integral part of the Financial Statements.
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Notes to Financial Statements
Vanguard International Value Fund is registered under the Investment Company Act of 1940 as an open-end investment company, or mutual fund. The fund invests in securities of foreign issuers, which may subject it to investment risks not normally associated with investing in securities of U.S. corporations. Significant market disruptions, such as those caused by pandemics (e.g., COVID-19 pandemic), natural or environmental disasters, war (e.g., Russia's invasion of Ukraine), acts of terrorism, or other events, can adversely affect local and global markets and normal market operations. Any such disruptions could have an adverse impact on the value of the fund's investments and fund performance.
A.  The following significant accounting policies conform to generally accepted accounting principles for U.S. investment companies. The fund consistently follows such policies in preparing its financial statements.
1. Security Valuation: Securities are valued as of the close of trading on the New York Stock Exchange (generally 4 p.m., Eastern time) on the valuation date. Equity securities are valued at the latest quoted sales prices or official closing prices taken from the primary market in which each security trades; such securities not traded on the valuation date are valued at the mean of the latest quoted bid and asked prices. Securities for which market quotations are not readily available, or whose values have been affected by events occurring before the fund’s pricing time but after the close of the securities’ primary markets, are valued by methods deemed by the valuation designee to represent fair value and subject to oversight by the board of trustees. These procedures include obtaining quotations from an independent pricing service, monitoring news to identify significant market- or security-specific events, and evaluating changes in the values of foreign market proxies (for example, ADRs, futures contracts, or exchange-traded funds), between the time the foreign markets close and the fund’s pricing time. When fair-value pricing is employed, the prices of securities used by a fund to calculate its net asset value may differ from quoted or published prices for the same securities. Investments in Vanguard Market Liquidity Fund are valued at that fund's net asset value.
2. Foreign Currency: Securities and other assets and liabilities denominated in foreign currencies are translated into U.S. dollars using exchange rates obtained from an independent third party as of the fund’s pricing time on the valuation date. Realized gains (losses) and unrealized appreciation (depreciation) on investment securities include the effects of changes in exchange rates since the securities were purchased, combined with the effects of changes in security prices. Fluctuations in the value of other assets and liabilities resulting from changes in exchange rates are recorded as unrealized foreign currency gains (losses) until the assets or liabilities are settled in cash, at which time they are recorded as realized foreign currency gains (losses).
3. Futures Contracts: The fund uses index futures contracts to a limited extent, with the objective of maintaining full exposure to the stock market while maintaining liquidity. The fund may purchase or sell futures contracts to achieve a desired level of investment, whether to accommodate portfolio turnover or cash flows from capital share transactions. The primary risks associated with the use of futures contracts are imperfect correlation between changes in market values of stocks held by the fund and the prices of futures contracts, and the possibility of an illiquid market. Counterparty risk involving futures is mitigated because a regulated clearinghouse is the counterparty instead of the clearing broker. To further mitigate counterparty risk, the fund trades futures contracts on an exchange, monitors the financial strength of its clearing brokers and clearinghouse, and has entered into clearing agreements with its clearing brokers. The
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clearinghouse imposes initial margin requirements to secure the fund’s performance and requires daily settlement of variation margin representing changes in the market value of each contract. Any securities pledged as initial margin for open contracts are noted in the Schedule of Investments.
Futures contracts are valued at their quoted daily settlement prices. The notional amounts of the contracts are not recorded in the Statement of Assets and Liabilities. Fluctuations in the value of the contracts are recorded in the Statement of Assets and Liabilities as an asset (liability) and in the Statement of Operations as unrealized appreciation (depreciation) until the contracts are closed, when they are recorded as realized gains (losses) on futures contracts.
During the year ended October 31, 2022, the fund’s average investments in long and short futures contracts represented 2% and 0% of net assets, respectively, based on the average of the notional amounts at each quarter-end during the period.
4. Forward Currency Contracts: The fund enters into forward currency contracts to protect the value of securities and related receivables and payables against changes in future foreign exchange rates. The fund’s risks in using these contracts include movement in the values of the foreign currencies relative to the U.S. dollar and the ability of the counterparties to fulfill their obligations under the contracts. The fund mitigates its counterparty risk by entering into forward currency contracts only with a diverse group of prequalified counterparties, monitoring their financial strength, entering into master netting arrangements with its counterparties, and requiring its counterparties to transfer collateral as security for their performance. In the absence of a default, the collateral pledged or received by the fund cannot be repledged, resold, or rehypothecated. The master netting arrangements provide that, in the event of a counterparty’s default (including bankruptcy), the fund may terminate the forward currency contracts, determine the net amount owed by either party in accordance with its master netting arrangements, and sell or retain any collateral held up to the net amount owed to the fund under the master netting arrangements. The forward currency contracts contain provisions whereby a counterparty may terminate open contracts if the fund’s net assets decline below a certain level, triggering a payment by the fund if the fund is in a net liability position at the time of the termination. The payment amount would be reduced by any collateral the fund has pledged. Any securities pledged as collateral for open contracts are noted in the Schedule of Investments. The value of collateral received or pledged is compared daily to the value of the forward currency contracts exposure with each counterparty, and any difference, if in excess of a specified minimum transfer amount, is adjusted and settled within two business days.
Forward currency contracts are valued at their quoted daily prices obtained from an independent third party, adjusted for currency risk based on the expiration date of each contract. The notional amounts of the contracts are not recorded in the Statement of Assets and Liabilities. Fluctuations in the value of the contracts are recorded in the Statement of Assets and Liabilities as an asset (liability) and in the Statement of Operations as unrealized appreciation (depreciation) until the contracts are closed, when they are recorded as realized gains (losses) on forward currency contracts.
During the year ended October 31, 2022, the fund’s average investment in forward currency contracts represented less than 1% of net assets, based on the average of the notional amounts at each quarter-end during the period. The fund had no open forward currency contracts at October 31, 2022.
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5. Federal Income Taxes: The fund intends to continue to qualify as a regulated investment company and distribute virtually all of its taxable income. The fund’s tax returns are open to examination by the relevant tax authorities until expiration of the applicable statute of limitations, which is generally three years after the filing of the tax return. Management has analyzed the fund’s tax positions taken for all open federal and state income tax years, and has concluded that no provision for income tax is required in the fund’s financial statements.
6. Distributions: Distributions to shareholders are recorded on the ex-dividend date. Distributions are determined on a tax basis at the fiscal year-end and may differ from net investment income and realized capital gains for financial reporting purposes.
7. Securities Lending: To earn additional income, the fund lends its securities to qualified institutional borrowers. Security loans are subject to termination by the fund at any time, and are required to be secured at all times by collateral in an amount at least equal to the market value of securities loaned. Daily market fluctuations could cause the value of loaned securities to be more or less than the value of the collateral received. When this occurs, the collateral is adjusted and settled before the opening of the market on the next business day. The fund further mitigates its counterparty risk by entering into securities lending transactions only with a diverse group of prequalified counterparties, monitoring their financial strength, and entering into master securities lending agreements with its counterparties. The master securities lending agreements provide that, in the event of a counterparty’s default (including bankruptcy), the fund may terminate any loans with that borrower, determine the net amount owed, and sell or retain the collateral up to the net amount owed to the fund; however, such actions may be subject to legal proceedings. While collateral mitigates counterparty risk, in the event of a default, the fund may experience delays and costs in recovering the securities loaned. The fund invests cash collateral received in Vanguard Market Liquidity Fund, and records a liability in the Statement of Assets and Liabilities for the return of the collateral, during the period the securities are on loan. Collateral investments in Vanguard Market Liquidity Fund are subject to market appreciation or depreciation. Securities lending income represents fees charged to borrowers plus income earned on invested cash collateral, less expenses associated with the loan. During the term of the loan, the fund is entitled to all distributions made on or in respect of the loaned securities.
8. Credit Facilities and Interfund Lending Program: The fund and certain other funds managed by The Vanguard Group ("Vanguard") participate in a $4.4 billion committed credit facility provided by a syndicate of lenders pursuant to a credit agreement and an uncommitted credit facility provided by Vanguard. Both facilities may be renewed annually. Each fund is individually liable for its borrowings, if any, under the credit facilities. Borrowings may be utilized for temporary or emergency purposes and are subject to the fund’s regulatory and contractual borrowing restrictions. With respect to the committed credit facility, the participating funds are charged administrative fees and an annual commitment fee of 0.10% of the undrawn committed amount of the facility, which are allocated to the funds based on a method approved by the fund’s board of trustees and included in Management and Administrative expenses on the fund’s Statement of Operations. Any borrowings under either facility bear interest at an agreed-upon spread plus the higher of the federal funds effective rate, the overnight bank funding rate, or the Daily Simple Secured Overnight Financing Rate inclusive of an additional agreed-upon spread. However, borrowings under the uncommitted credit facility may bear interest based upon an alternate rate agreed to by the fund and Vanguard.
In accordance with an exemptive order (the “Order”) from the SEC, the fund may participate in a joint lending and borrowing program that allows registered open-end Vanguard funds to borrow
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money from and lend money to each other for temporary or emergency purposes (the “Interfund Lending Program”), subject to compliance with the terms and conditions of the Order, and to the extent permitted by the fund’s investment objective and investment policies. Interfund loans and borrowings normally extend overnight but can have a maximum duration of seven days. Loans may be called on one business day’s notice. The interest rate to be charged is governed by the conditions of the Order and internal procedures adopted by the board of trustees. The board of trustees is responsible for overseeing the Interfund Lending Program.
For the year ended October 31, 2022, the fund did not utilize the credit facilities or the Interfund Lending Program.
9. Other: Dividend income is recorded on the ex-dividend date. Non-cash dividends included in income, if any, are recorded at the fair value of the securities received. Interest income includes income distributions received from Vanguard Market Liquidity Fund and is accrued daily. Security transactions are accounted for on the date securities are bought or sold. Costs used to determine realized gains (losses) on the sale of investment securities are those of the specific securities sold.
Taxes on foreign dividends and capital gains have been provided for in accordance with the fund’s understanding of the applicable countries’ tax rules and rates. Deferred foreign capital gains tax, if any, is accrued daily based upon net unrealized gains. The fund has filed tax reclaims for previously withheld taxes on dividends earned in certain European Union countries. These filings are subject to various administrative and judicial proceedings within these countries. Amounts related to these reclaims are recorded when there are no significant uncertainties as to the ‎ultimate resolution of proceedings, the likelihood of receipt of these reclaims, and the potential timing of ‎payment. Such tax reclaims and related professional fees, if any, are included in dividend income and other expenses, respectively.
B.  The investment advisory firms Lazard Asset Management LLC, ARGA Investment Management, LP, and Sprucegrove Investment Management Ltd. each provide investment advisory services to a portion of the fund for a fee calculated at an annual percentage rate of average net assets managed by the advisor. The basic fees of Lazard Asset Management LLC and ARGA Investment Management, LP, are subject to quarterly adjustments based on performance relative to the MSCI All Country World Index ex US for the preceding five years. The basic fee of Sprucegrove Investment Management Ltd. is subject to quarterly adjustments based on performance relative to the MSCI All Country World Index ex US since October 31, 2020.
Vanguard manages the cash reserves of the fund as described below.
For the year ended October 31, 2022, the aggregate investment advisory fee represented an effective annual basic rate of 0.16% of the fund’s average net assets, before a increase of $492,000 (0.00%) based on performance.
C.  In accordance with the terms of a Funds’ Service Agreement (the “FSA”) between Vanguard and the fund, Vanguard furnishes to the fund corporate management, administrative, marketing, distribution, and cash management services at Vanguard’s cost of operations (as defined by the FSA). These costs of operations are allocated to the fund based on methods and guidelines approved by the board of trustees and are generally settled twice a month.
Upon the request of Vanguard, the fund may invest up to 0.40% of its net assets as capital in Vanguard. At October 31, 2022, the fund had contributed to Vanguard capital in the amount of $452,000, representing less than 0.01% of the fund’s net assets and 0.18% of Vanguard’s capital
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International Value Fund
received pursuant to the FSA. The fund’s trustees and officers are also directors and employees, respectively, of Vanguard.
D.  Various inputs may be used to determine the value of the fund’s investments and derivatives. These inputs are summarized in three broad levels for financial statement purposes. The inputs or methodologies used to value securities are not necessarily an indication of the risk associated with investing in those securities.
Level 1—Quoted prices in active markets for identical securities.
Level 2—Other significant observable inputs (including quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.).
Level 3—Significant unobservable inputs (including the fund’s own assumptions used to determine the fair value of investments). Any investments and derivatives valued with significant unobservable inputs are noted on the Schedule of Investments.
The following table summarizes the market value of the fund's investments and derivatives as of October 31, 2022, based on the inputs used to value them:
  Level 1
($000)
Level 2
($000)
Level 3
($000)
Total
($000)
Investments        
Assets        
Common Stocks—North and South America 1,223,194 39,083 1,262,277
Common Stocks—Other 741,248 9,100,649 9,841,897
Temporary Cash Investments 685,707 685,707
Total 2,650,149 9,139,732 11,789,881
Derivative Financial Instruments        
Liabilities        
Futures Contracts1 16,619 16,619
1 Includes cumulative appreciation (depreciation) on futures contracts and centrally cleared swaps, if any, as reported in the Schedule of Investments. Only current day’s variation margin is reported within the Statement of Assets and Liabilities.
E.  Realized net gain (loss) and the change in unrealized appreciation (depreciation) on derivatives for the year ended October 31, 2022, were:
Realized Net Gain (Loss) on Derivatives Equity
Contracts
($000)
Foreign
Exchange
Contracts
($000)
Total
($000)
Futures Contracts (74,220) (74,220)
Forward Currency Contracts 95 95
Realized Net Gain (Loss) on Derivatives (74,220) 95 (74,125)
 
Change in Unrealized Appreciation (Depreciation) on Derivatives
Futures Contracts (13,965) (13,965)
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International Value Fund
F.  Permanent differences between book-basis and tax-basis components of net assets are reclassified among capital accounts in the financial statements to reflect their tax character. These reclassifications have no effect on net assets or net asset value per share. As of period end, permanent differences primarily attributable to the accounting for applicable foreign currency transactions, passive foreign investment companies, and tax expense on capital gains were reclassified between the individual components of total distributable earnings (loss).
Temporary differences between book-basis and tax-basis components of total distributable earnings (loss) arise when certain items of income, gain, or loss are recognized in different periods for financial statement and tax purposes; these differences will reverse at some time in the future. The differences are primarily related to the deferral of losses from wash sales; the recognition of unrealized gains or losses from certain derivative contracts; and the recognition of unrealized gains from passive foreign investment companies. As of period end, the tax-basis components of total distributable earnings (loss) are detailed in the table as follows:
  Amount
($000)
Undistributed Ordinary Income 303,807
Undistributed Long-Term Gains
Capital Loss Carryforwards (290,452)
Qualified Late-Year Losses
Net Unrealized Gains (Losses) (1,029,753)
The tax character of distributions paid was as follows:
  Year Ended October 31,
  2022
Amount
($000)
2021
Amount
($000)
Ordinary Income* 633,591 189,189
Long-Term Capital Gains
Total 633,591 189,189
* Includes short-term capital gains, if any.
As of October 31, 2022, gross unrealized appreciation and depreciation for investments and derivatives based on cost for U.S. federal income tax purposes were as follows:
  Amount
($000)
Tax Cost 12,804,237
Gross Unrealized Appreciation 1,279,290
Gross Unrealized Depreciation (2,293,646)
Net Unrealized Appreciation (Depreciation) (1,014,356)
G.  During the year ended October 31, 2022, the fund purchased $5,116,196,000 of investment securities and sold $4,812,568,000 of investment securities, other than temporary cash investments.
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International Value Fund
H.  Capital shares issued and redeemed were:
  Year Ended October 31,  
  2022
Shares
(000)
  2021
Shares
(000)
 
     
Issued 61,320   104,505  
Issued in Lieu of Cash Distributions 14,416   4,428  
Redeemed (67,638)   (50,767)  
Net Increase (Decrease) in Shares Outstanding 8,098   58,166  
I.  Management has determined that no events or transactions occurred subsequent to October 31, 2022, that would require recognition or disclosure in these financial statements.
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Report of Independent Registered
Public Accounting Firm
To the Board of Trustees of Vanguard Trustees' Equity Fund and Shareholders of Vanguard International Value Fund
Opinion on the Financial Statements
We have audited the accompanying statement of assets and liabilities, including the schedule of investments, of Vanguard International Value Fund (one of the funds constituting Vanguard Trustees' Equity Fund, referred to hereafter as the "Fund") as of October 31, 2022, the related statement of operations for the year ended October 31, 2022, the statement of changes in net assets for each of the two years in the period ended October 31, 2022, including the related notes, and the financial highlights for each of the five years in the period ended October 31, 2022 (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Fund as of October 31, 2022, the results of its operations for the year then ended, the changes in its net assets for each of the two years in the period ended October 31, 2022 and the financial highlights for each of the five years in the period ended October 31, 2022 in conformity with accounting principles generally accepted in the United States of America.
Basis for Opinion
These financial statements are the responsibility of the Fund’s management. Our responsibility is to express an opinion on the Fund’s financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Fund in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.
We conducted our audits of these financial statements in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud.
Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. Our procedures included confirmation of securities owned as of October 31, 2022 by correspondence with the custodian, transfer agent and brokers; when replies were not received from brokers, we performed other auditing procedures. We believe that our audits provide a reasonable basis for our opinion.
/s/PricewaterhouseCoopers LLP
Philadelphia, Pennsylvania
December 16, 2022
We have served as the auditor of one or more investment companies in The Vanguard Group of Funds since 1975.
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Tax information (unaudited)
The fund hereby designates $370,335,000, or if subsequently determined to be different, the maximum amount allowable by law, as qualified dividend income for individual shareholders for the fiscal year.
The fund hereby designates $31,000, or if subsequently determined to be different, the maximum amount allowable by law, of interest earned from obligations of the U.S. government which is generally exempt from state income tax.
For nonresident alien shareholders, 100% of short-term capital gain dividends distributed by the fund for the fiscal year are qualified short-term capital gains.
The fund designates to shareholders foreign source income of $439,020,000 and foreign taxes paid of $29,451,000, or if subsequently determined to be different, the maximum amounts allowable by law. Shareholders will receive more detailed information with their Form 1099-DIV to determine the calendar-year amounts to be included on their tax returns.
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The People Who Govern Your Fund
The trustees of your mutual fund are there to see that the fund is operated and managed in your best interests since, as a shareholder, you are a part owner of the fund. Your fund’s trustees also serve on the board of directors of The Vanguard Group, Inc., which is owned by the Vanguard funds and provides services to them.
A majority of Vanguard’s board members are independent, meaning that they have no affiliation with Vanguard or the funds they oversee, apart from the sizable personal investments they have made as private individuals. The independent board members have distinguished backgrounds in business, academia, and public service. Each of the trustees and executive officers oversees 206 Vanguard funds.
Information for each trustee and executive officer of the fund appears below. That information, as well as the Vanguard fund count, is as of the date on the cover of this fund report. The mailing address of the trustees and officers is P.O. Box 876, Valley Forge, PA 19482. More information about the trustees is in the Statement of Additional Information, which can be obtained, without charge, by contacting Vanguard at 800-662-7447, or online at vanguard.com.
Interested Trustee1
Mortimer J. Buckley
Born in 1969. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: chairman of the board (2019–present) of Vanguard and of each of the investment companies served by Vanguard; chief executive officer (2018–present) of Vanguard; chief executive officer, president, and trustee (2018–present) of each of the investment companies served by Vanguard; president and director (2017–present) of Vanguard; and president (2018–present) of Vanguard Marketing Corporation. Chief investment officer (2013–2017), managing director (2002–2017), head of the Retail Investor Group (2006–2012), and chief information officer (2001–2006) of Vanguard. Member of the board of governors of the Investment Company Institute and the board of governors of FINRA. Trustee and vice chair of The Shipley School.
Independent Trustees
Tara Bunch
Born in 1962. Trustee since November 2021. Principal occupation(s) during the past five years and other experience: head of global operations at Airbnb (2020–present). Vice president of AppleCare (2012–2020). Member of the board of directors of Out & Equal (2002–2006), the advisory board of the University of California, Berkeley School of Engineering (2020–present), and the advisory board of Santa Clara University’s Leavey School of Business (2018–present).
Emerson U. Fullwood
Born in 1948. Trustee since January 2008. Principal occupation(s) during the past five years and other experience: executive chief staff and marketing officer for North America and corporate vice president (retired 2008) of Xerox Corporation (document management products and services). Former president of the Worldwide Channels Group, Latin America, and Worldwide Customer Service and executive chief staff officer of Developing Markets of Xerox. Executive in residence and 2009–2010 Distinguished Minett Professor at the Rochester Institute of Technology. Member of the board of directors of the University of Rochester Medical Center, the Monroe Community College Foundation, the United Way of Rochester, North Carolina A&T University, Roberts Wesleyan College, and the Rochester Philharmonic Orchestra. Trustee of the University of Rochester.
 
1 Mr. Buckley is considered an “interested person,” as defined in the Investment Company Act of 1940, because he is an officer of the Vanguard funds.

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F. Joseph Loughrey
Born in 1949. Trustee since October 2009. Principal occupation(s) during the past five years and other experience: president and chief operating officer (retired 2009) and vice chairman of the board (2008–2009) of Cummins Inc. (industrial machinery). Chairman of the board of Hillenbrand, Inc. (specialized consumer services). Director of the V Foundation. Member of the advisory council for the College of Arts and Letters at the University of Notre Dame. Chairman of the board of Saint Anselm College.
Mark Loughridge
Born in 1953. Trustee since March 2012. Principal occupation(s) during the past five years and other experience: senior vice president and chief financial officer (retired 2013) of IBM (information technology services). Fiduciary member of IBM’s Retirement Plan Committee (2004–2013), senior vice president and general manager (2002–2004) of IBM Global Financing, vice president and controller (1998–2002) of IBM, and a variety of other prior management roles at IBM. Member of the Council on Chicago Booth.
Scott C. Malpass
Born in 1962. Trustee since March 2012. Principal occupation(s) during the past five years and other experience: adjunct professor of finance at the University of Notre Dame (2020–present). Chief investment officer (retired 2020) and vice president (retired 2020) of the University of Notre Dame. Assistant professor (retired June 2020) of finance at the Mendoza College of Business, University of Notre Dame, and member of the Notre Dame 403(b) Investment Committee. Member of the board of Catholic Investment Services, Inc. (investment advisors), the board of superintendence of the Institute for the Works of Religion, and the board of directors of Paxos Trust Company (finance).
Deanna Mulligan
Born in 1963. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: chief executive officer of Purposeful (advisory firm for CEOs and C-level executives; 2021–present). Board chair (2020), chief executive officer (2011–2020), and president (2010–2019) of The Guardian Life Insurance Company of America. Chief operating officer (2010–2011) and executive vice president (2008–2010) of Individual Life and Disability of the Guardian Life Insurance Company of America. Member of the board of the Economic Club of New York. Trustee of the Partnership for New York City (business leadership), Chief Executives for Corporate Purpose, and the NewYork-Presbyterian Hospital.
André F. Perold
Born in 1952. Trustee since December 2004. Principal occupation(s) during the past five years and other experience: George Gund Professor of Finance and Banking, Emeritus at the Harvard Business School (retired 2011). Chief investment officer and co-managing partner of HighVista Strategies (private investment firm). Member of the board (2018–present) of RIT Capital Partners (investment firm). Member of the investment committee of Partners Health Care System.
Sarah Bloom Raskin
Born in 1961. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: deputy secretary (2014–2017) of the United States Department of the Treasury. Governor (2010–2014) of the Federal Reserve Board. Commissioner (2007–2010) of financial regulation for the State of Maryland. Colin W. Brown Distinguished Professor of the Practice of Law (2021–present), professor (2020–present), Distinguished Fellow of the Global Financial Markets Center (2020–present), and Rubenstein Fellow (2017–2020) at Duke University. Trustee (2017–present) of Amherst College and member of Amherst College Investment Committee (2019–present). Member of the Regenerative Crisis Response Committee (2020–present).
David A. Thomas
Born in 1956. Trustee since July 2021. Principal occupation(s) during the past five years and other experience: president of Morehouse College (2018–present). Professor of business administration, emeritus at Harvard University (2017–2018). Dean (2011–2016) and professor of management (2016–2017) at the Georgetown University McDonough School of Business. Director of DTE Energy Company (2013–present). Trustee of Common Fund (2019–present).
Peter F. Volanakis
Born in 1955. Trustee since July 2009. Principal occupation(s) during the past five years and other experience: president and chief operating officer (retired 2010) of Corning Incorporated (communications equipment) and director of Corning Incorporated (2000–2010) and Dow Corning (2001–2010). Director (2012) of SPX Corporation (multi-industry manufacturing). Overseer of the Amos Tuck School of Business Administration, Dartmouth College (2001–2013). Member of the BMW Group Mobility Council.

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Executive Officers
Christine M. Buchanan
Born in 1970. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Chief financial officer (2021–present) and treasurer (2017–present) of each of the investment companies served by Vanguard. Partner (2005–2017) at KPMG (audit, tax, and advisory services).
John Galloway
Born in 1973. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Investment stewardship officer (September 2020–present) of each of the investment companies served by Vanguard. Head of Investor Advocacy (February 2020–present) and head of Marketing Strategy and Planning (2017–2020) at Vanguard. Special assistant to the President of the United States (2015).
Ashley Grim
Born in 1984. Principal occupation(s) during the past five years and other experience: treasurer (February 2022–present) of each of the ‎investment companies served by Vanguard. Fund transfer agent controller (2019–2022) and director of Audit Services (2017–2019) at ‎Vanguard. Senior manager (2015–2017) at PriceWaterhouseCoopers (audit and assurance, consulting, and tax services).
Peter Mahoney
Born in 1974. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Controller (2015–present) of each of the investment companies served by Vanguard. Head of International Fund Services (2008–2014) at Vanguard.
Anne E. Robinson
Born in 1970. Principal occupation(s) during the past five years and other experience: general counsel (2016–present) of Vanguard. Secretary (2016–present) of Vanguard and of each of the investment companies served by Vanguard. Managing director (2016–present) of Vanguard. Managing director and general counsel of Global Cards and Consumer Services (2014–2016) at Citigroup. Counsel (2003–2014) at American Express. Nonexecutive director of the board of National Grid (energy).
Michael Rollings
Born in 1963. Principal occupation(s) during the past five years and other experience: finance director (2017–present) and treasurer (2017) of each of the investment companies served by Vanguard. Managing director (2016–present) of Vanguard. Chief financial officer (2016–present) of Vanguard. Director (2016–present) of Vanguard Marketing Corporation. Executive vice president and chief financial officer (2006–2016) of MassMutual Financial Group.
John E. Schadl
Born in 1972. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Chief compliance officer (2019–present) of Vanguard and of each of the investment companies served by Vanguard. Assistant vice president (2019–present) of Vanguard Marketing Corporation.
Vanguard Senior Management Team
Matthew Benchener Thomas M. Rampulla
Joseph Brennan Karin A. Risi
Mortimer J. Buckley Anne E. Robinson
Gregory Davis Michael Rollings
John James Nitin Tandon
Chris D. McIsaac Lauren Valente

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Connect with Vanguard®>vanguard.com
Fund Information > 800-662-7447
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Institutional Investor Services > 800-523-1036
Text Telephone for People
Who Are Deaf or Hard of Hearing > 800-749-7273
This material may be used in conjunction with the offering of shares of any Vanguard fund only if preceded or accompanied by the fund’s current prospectus.
All comparative mutual fund data are from Morningstar, Inc., unless otherwise noted.
You can obtain a free copy of Vanguard’s proxy voting guidelines by visiting vanguard.com/proxyreporting or by calling Vanguard at 800-662-2739. The guidelines are also available from the SEC’s website, www.sec.gov. In addition, you may obtain a free report on how your fund voted the proxies for securities it owned during the 12 months ended June 30. To get the report, visit either vanguard.com/proxyreporting or www.sec.gov.
You can review information about your fund on the SEC’s website, and you can receive copies of this information, for a fee, by sending a request via email addressed to publicinfo@sec.gov.
Source for Bloomberg indexes: Bloomberg Index Services Limited. Copyright 2022, Bloomberg. All rights reserved.
CFA® is a registered trademark owned by CFA Institute.
© 2022 The Vanguard Group, Inc.
All rights reserved.
Vanguard Marketing Corporation, Distributor.
Q460 122022
Annual Report  |  October 31, 2022
Vanguard Diversified Equity Fund

Contents

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6
Please note: The opinions expressed in this report are just that—informed opinions. They should not be considered promises or advice. Also, please keep in mind that the information and opinions cover the period through the date on the front of this report. Of course, the risks of investing in your fund are spelled out in the prospectus.

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Your Fund’s Performance at a Glance
The 12 months ended October 31, 2022, were a volatile, challenging period for financial markets. Vanguard Diversified Equity Fund returned –21.42%, lagging the –16.50% return of its benchmark, the MSCI US Broad Market Index.
The economic backdrop deteriorated as inflation soared to multidecade highs, fueled in part by higher energy and food prices in the wake of Russia’s invasion of Ukraine. Then price increases broadened to other categories of goods and services, adding to concerns that inflation would remain stubbornly high. That prompted aggressive tightening by the Federal Reserve to bring inflation back in check and increased fears of a recession.
The Diversified Equity Fund invests in six actively managed Vanguard funds selected to provide broad exposure to all segments of the U.S. equity market. Together, these funds cover the style and capitalization spectrum.
Returns of the underlying funds ranged from about –39% for Vanguard U.S. Growth Fund to roughly –3% for Vanguard Windsor Fund. Value-oriented stocks generally held up better than growth stocks.
Market Barometer
  Average Annual Total Returns
Periods Ended October 31, 2022
  One Year Three Years Five Years
Stocks      
Russell 1000 Index (Large-caps) -16.38% 9.99% 10.19%
Russell 2000 Index (Small-caps) -18.54 7.05 5.56
Russell 3000 Index (Broad U.S. market) -16.52 9.79 9.87
FTSE All-World ex US Index (International) -24.20 -1.16 -0.18
Bonds      
Bloomberg U.S. Aggregate Float Adjusted Index
(Broad taxable market)
-15.69% -3.73% -0.50%
Bloomberg Municipal Bond Index
(Broad tax-exempt market)
-11.98 -2.18 0.37
FTSE Three-Month U.S. Treasury Bill Index 0.88 0.59 1.15
CPI      
Consumer Price Index 7.75% 5.01% 3.85%
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About Your Fund’s Expenses
As a shareholder of the fund, you incur ongoing costs, which include costs for portfolio management, administrative services, and shareholder reports (like this one), among others. Operating expenses, which are deducted from a fund’s gross income, directly reduce the investment return of the fund.
A fund’s expenses are expressed as a percentage of its average net assets. The Diversified Equity Fund has no direct expenses, but bears its proportionate share of the costs for the underlying funds in which it invests. These indirect expenses make up the acquired fund fees and expenses, also expressed as a percentage of average net assets. The following examples are intended to help you understand the ongoing cost (in dollars) of investing in your fund and to compare these costs with those of other mutual funds. The examples are based on an investment of $1,000 made at the beginning of the period shown and held for the entire period. The costs were calculated using the acquired fund fees and expenses for the Diversified Equity Fund.
The accompanying table illustrates your fund’s costs in two ways:
Based on actual fund return. This section helps you to estimate the actual expenses that you paid over the period. The ”Ending Account Value“ shown is derived from the fund’s actual return, and the third column shows the dollar amount that would have been paid by an investor who started with $1,000 in the fund. You may use the information here, together with the amount you invested, to estimate the expenses that you paid over the period.
To do so, simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number given for your fund under the heading ”Expenses Paid During Period.“
Based on hypothetical 5% yearly return. This section is intended to help you compare your fund‘s costs with those of other mutual funds. It assumes that the fund had a yearly return of 5% before expenses, but that the expense ratio is unchanged. In this case—because the return used is not the fund’s actual return—the results do not apply to your investment. The example is useful in making comparisons because the Securities and Exchange Commission requires all mutual funds to calculate expenses based on a 5% return. You can assess your fund’s costs by comparing this hypothetical example with the hypothetical examples that appear in shareholder reports of other funds.
Note that the expenses shown in the table are meant to highlight and help you compare ongoing costs only and do not reflect transaction costs incurred by the fund for buying and selling securities. Further, the expenses do not include any purchase, redemption, or account service fees described in the fund prospectus. If such fees were applied to your account, your costs would be higher. Your fund does not carry a “sales load.”
The calculations assume no shares were bought or sold during the period. Your actual costs may have been higher or lower, depending on the amount of your investment and the timing of any purchases or redemptions.
You can find more information about the fund’s expenses, including annual expense ratios, in the Financial Statements section of this report. For additional information on operating expenses and other shareholder costs, please refer to your fund’s current prospectus.
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Six Months Ended October 31, 2022      
Diversified Equity Fund Beginning
Account Value
4/30/2022
Ending
Account Value
10/31/2022
Expenses
Paid During
Period
Based on Actual Fund Return $1,000.00 $ 939.40 $1.71
Based on Hypothetical 5% Yearly Return 1,000.00 1,023.44 1.79
The calculations are based on acquired fund fees and expenses for the most recent six-month period. The underlying funds' annualized expense figure for that period is 0.35%. The dollar amounts shown as ”Expenses Paid” are equal to the annualized average weighted expense ratio for the underlying funds multiplied by the average account value over the period, multiplied by the number of days in the most recent six-month period, then divided by the number of days in the most recent 12-month period (184/365).
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Diversified Equity Fund
Performance Summary
All of the returns in this report represent past performance, which is not a guarantee of future results that may be achieved by the fund. (Current performance may be lower or higher than the performance data cited. For performance data current to the most recent month-end, visit our website at vanguard.com/performance.) Note, too, that both investment returns and principal value can fluctuate widely, so an investor’s shares, when sold, could be worth more or less than their original cost. The returns shown do not reflect taxes that a shareholder would pay on fund distributions or on the sale of fund shares.
Cumulative Performance: October 31, 2012, Through October 31, 2022
Initial Investment of $10,000
    Average Annual Total Returns
Periods Ended October 31, 2022
 
    One
Year
Five
Years
Ten
Years
Final Value
of a $10,000
Investment
 Diversified Equity Fund -21.42% 9.75% 12.31% $31,923
 MSCI US Broad Market Index -16.50 9.96 12.53 32,563
See Financial Highlights for dividend and capital gains information.
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Diversified Equity Fund
Underlying Vanguard Funds
As of October 31, 2022
Vanguard U.S. Growth Fund Investor Shares 29.3%
Vanguard WindsorTM Fund Investor Shares 20.3
Vanguard Growth and Income Fund Investor Shares 20.2
Vanguard Windsor II Fund Investor Shares 15.2
Vanguard ExplorerTM Fund Investor Shares 10.1
Vanguard Mid-Cap Growth Fund 4.9
The table reflects the fund's investments, except for short-term investments.
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Diversified Equity Fund
Financial Statements
Schedule of Investments
As of October 31, 2022
The fund files its complete schedule of portfolio holdings with the Securities and Exchange Commission (SEC) for the first and third quarters of each fiscal year as an exhibit to its reports on Form N-PORT. The fund’s Form N-PORT reports are available on the SEC’s website at www.sec.gov.
          Shares Market
Value

($000)
Investment Companies (100.0%)
U.S. Stock Funds (100.0%)
  Vanguard U.S. Growth Fund Investor Shares 15,410,935   638,320
  Vanguard Windsor Fund Investor Shares 19,507,240   443,595
  Vanguard Growth and Income Fund Investor Shares  8,285,085   440,104
  Vanguard Windsor II Fund Investor Shares  8,409,928   331,267
  Vanguard Explorer Fund Investor Shares  2,205,770   219,915
  Vanguard Mid-Cap Growth Fund  5,589,451   107,541
Total Investment Companies (Cost $1,670,038) 2,180,742
Temporary Cash Investments (0.0%)
Money Market Fund (0.0%)
1 Vanguard Market Liquidity Fund, 3.117% (Cost $—)          1          
Total Investments (100.0%) (Cost $1,670,038)   2,180,742
Other Assets and Liabilities—Net (0.0%)   (441)
Net Assets (100%)   2,180,301
Cost is in $000.
See Note A in Notes to Financial Statements.
1 Affiliated money market fund available only to Vanguard funds and certain trusts and accounts managed by Vanguard. Rate shown is the 7-day yield.
See accompanying Notes, which are an integral part of the Financial Statements.
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Diversified Equity Fund
Statement of Assets and Liabilities
As of October 31, 2022
($000s, except shares and per-share amounts) Amount
Assets  
Investments in Securities, at Value—Affiliated Funds (Cost $1,670,038) 2,180,742
Receivables for Investment Securities Sold 155
Receivables for Accrued Income 1
Receivables for Capital Shares Issued 674
Total Assets 2,181,572
Liabilities  
Due to Custodian 199
Payables for Capital Shares Redeemed 1,072
Total Liabilities 1,271
Net Assets 2,180,301

At October 31, 2022, net assets consisted of:

   
Paid-in Capital 1,443,943
Total Distributable Earnings (Loss) 736,358
Net Assets 2,180,301
   
Net Assets  
Applicable to 52,691,895 outstanding $.001 par value shares of
beneficial interest (unlimited authorization)
2,180,301
Net Asset Value Per Share $41.38
See accompanying Notes, which are an integral part of the Financial Statements.
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Diversified Equity Fund
Statement of Operations
  Year Ended
October 31, 2022
  ($000)
Investment Income  
Income  
Income Distributions Received from Affiliated Funds 19,185
Net Investment Income—Note B 19,185
Realized Net Gain (Loss)  
Capital Gain Distributions Received from Affiliated Funds 331,854
Affiliated Funds Sold (4,196)
Realized Net Gain (Loss) 327,658
Change in Unrealized Appreciation (Depreciation) from Affiliated Funds (967,703)
Net Increase (Decrease) in Net Assets Resulting from Operations (620,860)
See accompanying Notes, which are an integral part of the Financial Statements.
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Diversified Equity Fund
Statement of Changes in Net Assets
  Year Ended October 31,
  2022
($000)
2021
($000)
Increase (Decrease) in Net Assets    
Operations    
Net Investment Income 19,185 19,851
Realized Net Gain (Loss) 327,658 126,784
Change in Unrealized Appreciation (Depreciation) (967,703) 757,953
Net Increase (Decrease) in Net Assets Resulting from Operations (620,860) 904,588
Distributions    
Total Distributions (196,729) (129,748)
Capital Share Transactions    
Issued 293,317 591,473
Issued in Lieu of Cash Distributions 182,595 121,380
Redeemed (443,391) (441,166)
Net Increase (Decrease) from Capital Share Transactions 32,521 271,687
Total Increase (Decrease) (785,068) 1,046,527
Net Assets    
Beginning of Period 2,965,369 1,918,842
End of Period 2,180,301 2,965,369
See accompanying Notes, which are an integral part of the Financial Statements.
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Diversified Equity Fund
Financial Highlights
For a Share Outstanding
Throughout Each Period
Year Ended October 31,
2022 2021 2020 2019 2018
Net Asset Value, Beginning of Period $56.40 $40.98 $37.95 $35.88 $35.57
Investment Operations          
Net Investment Income1 .356 .385 .452 .455 .395
Capital Gain Distributions Received1 6.162 2.294 1.866 3.087 1.686
Net Realized and Unrealized Gain (Loss) on Investments (17.785) 15.438 3.447 .575 .206
Total from Investment Operations (11.267) 18.117 5.765 4.117 2.287
Distributions          
Dividends from Net Investment Income (.317) (.346) (.369) (.383) (.358)
Distributions from Realized Capital Gains (3.436) (2.351) (2.366) (1.664) (1.619)
Total Distributions (3.753) (2.697) (2.735) (2.047) (1.977)
Net Asset Value, End of Period $41.38 $56.40 $40.98 $37.95 $35.88
Total Return2 -21.42% 45.67% 15.73% 12.82% 6.55%
Ratios/Supplemental Data          
Net Assets, End of Period (Millions) $2,180 $2,965 $1,919 $1,789 $1,709
Ratio of Total Expenses to Average Net Assets
Acquired Fund Fees and Expenses 0.35% 0.35% 0.35% 0.35% 0.36%
Ratio of Net Investment Income to Average Net Assets 0.77% 0.76% 1.19% 1.27% 1.07%
Portfolio Turnover Rate 12% 6% 14% 9% 8%
1 Calculated based on average shares outstanding.
2 Total returns do not include account service fees that may have applied in the periods shown. Fund prospectuses provide information about any applicable account service fees.
See accompanying Notes, which are an integral part of the Financial Statements.
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Diversified Equity Fund
Notes to Financial Statements
Vanguard Diversified Equity Fund is registered under the Investment Company Act of 1940 as an open-end investment company, or mutual fund. The fund invests in selected Vanguard actively managed U.S. Stock Funds. Financial Statements and other information about each underlying fund are available on www.vanguard.com.
Significant market disruptions, such as those caused by pandemics (e.g., COVID-19 pandemic), natural or environmental disasters, war (e.g., Russia's invasion of Ukraine), acts of terrorism, or other events, can adversely affect local and global markets and normal market operations. Any such disruptions could have an adverse impact on the value of the fund's investments and fund performance.
A.  The following significant accounting policies conform to generally accepted accounting principles for U.S. investment companies. The fund consistently follows such policies in preparing its financial statements.
1. Security Valuation: Investments are valued at the net asset value of each underlying Vanguard fund determined as of the close of the New York Stock Exchange (generally 4 p.m., Eastern time) on the valuation date.
2. Federal Income Taxes: The fund intends to continue to qualify as a regulated investment company and distribute virtually all of its taxable income. The fund’s tax returns are open to examination by the relevant tax authorities until expiration of the applicable statute of limitations, which is generally three years after the filing of the tax return. Management has analyzed the fund’s tax positions taken for all open federal and state income tax years, and has concluded that no provision for income tax is required in the fund’s financial statements.
3. Distributions: Distributions to shareholders are recorded on the ex-dividend date. Distributions are determined on a tax basis at the fiscal year-end and may differ from net investment income and realized capital gains for financial reporting purposes.
4. Credit Facilities and Interfund Lending Program: The fund and certain other funds managed by The Vanguard Group ("Vanguard") participate in a $4.4 billion committed credit facility provided by a syndicate of lenders pursuant to a credit agreement and an uncommitted credit facility provided by Vanguard. Both facilities may be renewed annually. Each fund is individually liable for its borrowings, if any, under the credit facilities. Borrowings may be utilized for temporary or emergency purposes and are subject to the fund’s regulatory and contractual borrowing restrictions. With respect to the committed credit facility, the participating funds are charged administrative fees and an annual commitment fee of 0.10% of the undrawn committed amount of the facility, which are allocated to the funds based on a method approved by the fund’s board of trustees and borne by the funds in which the fund invests (see Note B). Any borrowings under either facility bear interest at an agreed-upon spread plus the higher of the federal funds effective rate, the overnight bank funding rate, or the Daily Simple Secured Overnight Financing Rate inclusive of an additional agreed-upon spread. However, borrowings under the uncommitted credit facility may bear interest based upon an alternate rate agreed to by the fund and Vanguard.
In accordance with an exemptive order (the “Order”) from the SEC, the fund may participate in a joint lending and borrowing program that allows registered open-end Vanguard funds to borrow money from and lend money to each other for temporary or emergency purposes (the “Interfund Lending Program”), subject to compliance with the terms and conditions of the Order, and to the extent permitted by the fund’s investment objective and investment policies. Interfund loans and
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Diversified Equity Fund
borrowings normally extend overnight but can have a maximum duration of seven days. Loans may be called on one business day’s notice. The interest rate to be charged is governed by the conditions of the Order and internal procedures adopted by the board of trustees. The board of trustees is responsible for overseeing the Interfund Lending Program.
For the year ended October 31, 2022, the fund did not utilize the credit facilities or the Interfund Lending Program.
5. Other: Income and capital gain distributions received are recorded on the ex-dividend date.
Security transactions are accounted for on the date securities are bought or sold. Costs used to determine realized gains (losses) on the sale of investment securities are those of the specific securities sold.
B.  In accordance with the terms of a Funds’ Service Agreement (the “FSA”) between Vanguard and the fund, Vanguard furnishes to the fund investment advisory, corporate management, administrative, marketing, and distribution services at Vanguard’s cost of operations (as defined by the FSA). These costs of operations are allocated to the fund based on methods and guidelines approved by the board of trustees. The FSA provides that expenses otherwise allocable to Vanguard funds-of-funds may be reduced or eliminated to the extent of savings realized by the underlying Vanguard funds by virtue of being part of a fund-of-funds. Accordingly, all expenses for services provided by Vanguard to the fund and all other expenses incurred by the fund during the year ended October 31, 2022, were borne by the underlying Vanguard funds in which the fund invests. The fund's trustees and officers are also trustees and officers, respectively, of the underlying Vanguard funds, as well as directors and employees, respectively, of Vanguard.
C.  Various inputs may be used to determine the value of the fund’s investments. These inputs are summarized in three broad levels for financial statement purposes. The inputs or methodologies used to value securities are not necessarily an indication of the risk associated with investing in those securities.
Level 1—Quoted prices in active markets for identical securities.
Level 2—Other significant observable inputs (including quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.).
Level 3—Significant unobservable inputs (including the fund’s own assumptions used to determine the fair value of investments). Any investments valued with significant unobservable inputs are noted on the Schedule of Investments.
At October 31, 2022, 100% of the market value of the fund's investments was determined based on Level 1 inputs.
D.  Permanent differences between book-basis and tax-basis components of net assets are reclassified among capital accounts in the financial statements to reflect their tax character. These reclassifications have no effect on net assets or net asset value per share. As of period end, permanent differences primarily attributable to the accounting for applicable distributions in connection with fund share redemptions were reclassified between the following accounts:
  Amount
($000)
Paid-in Capital 32,107
Total Distributable Earnings (Loss) (32,107)
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Diversified Equity Fund
Temporary differences between book-basis and tax-basis components of total distributable earnings (loss) arise when certain items of income, gain, or loss are recognized in different periods for financial statement and tax purposes; these differences will reverse at some time in the future. The differences are primarily related to the deferral of losses from wash sales. As of period end, the tax-basis components of total distributable earnings (loss) are detailed in the table as follows:
  Amount
($000)
Undistributed Ordinary Income
Undistributed Long-Term Gains 229,192
Capital Loss Carryforwards
Qualified Late-Year Losses
Net Unrealized Gains (Losses) 507,166
The tax character of distributions paid was as follows:
  Year Ended October 31,
  2022
Amount
($000)
2021
Amount
($000)
Ordinary Income* 100,746 31,671
Long-Term Capital Gains 95,983 98,077
Total 196,729 129,748
* Includes short-term capital gains, if any.
As of October 31, 2022, gross unrealized appreciation and depreciation for investments based on cost for U.S. federal income tax purposes were as follows:
  Amount
($000)
Tax Cost 1,673,576
Gross Unrealized Appreciation 641,596
Gross Unrealized Depreciation (134,430)
Net Unrealized Appreciation (Depreciation) 507,166
E.  Capital shares issued and redeemed were:
  Year Ended October 31,  
  2022
Shares
(000)
  2021
Shares
(000)
 
     
Issued 6,163   11,844  
Issued in Lieu of Cash Distributions 3,454   2,628  
Redeemed (9,499)   (8,723)  
Net Increase (Decrease) in Shares Outstanding 118   5,749  
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Diversified Equity Fund
F.   Transactions during the period in affiliated underlying Vanguard funds were as follows:
    Current Period Transactions  
  Oct. 31, 2021
Market Value
($000)
Purchases
at Cost
($000)
Proceeds
from
Securities
Sold
($000)
Realized
Net Gain
(Loss)
($000)
Change in
Unrealized
App. (Dep.)
($000)
Income
($000)
Capital Gain
Distributions
Received
($000)
Oct. 31, 2022
Market Value
($000)
Vanguard Explorer Fund 295,430 39,796 7,604 (2,898) (104,809) 540 39,256 219,915
Vanguard Growth and Income Fund 596,559 80,459 87,379 (2,132) (147,403) 6,506 73,955 440,104
Vanguard Market Liquidity Fund 145 NA 1 NA 1 2
Vanguard Mid-Cap Growth Fund 147,655 44,241 (84,355) 18 35,761 107,541
Vanguard U.S. Growth Fund 893,949 229,764 12,213 (4,119) (469,061) 15 100,709 638,320
Vanguard Windsor Fund 587,802 71,116 140,887 4,770 (79,206) 7,056 54,102 443,595
Vanguard Windsor II Fund 442,795 33,637 62,479 183 (82,869) 5,048 28,071 331,267
Total 2,964,335 499,013 310,562 (4,196) (967,703) 19,185 331,854 2,180,742
1 Not applicable—purchases and sales are for temporary cash investment purposes.
G.  Management has determined that no events or transactions occurred subsequent to October 31, 2022, that would require recognition or disclosure in these financial statements.
14

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Report of Independent Registered
Public Accounting Firm
To the Board of Trustees of Vanguard Trustees' Equity Fund and Shareholders of Vanguard Diversified Equity Fund
Opinion on the Financial Statements
We have audited the accompanying statement of assets and liabilities, including the schedule of investments, of Vanguard Diversified Equity Fund (one of the funds constituting Vanguard Trustees' Equity Fund, referred to hereafter as the "Fund") as of October 31, 2022, the related statement of operations for the year ended October 31, 2022, the statement of changes in net assets for each of the two years in the period ended October 31, 2022, including the related notes, and the financial highlights for each of the five years in the period ended October 31, 2022 (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Fund as of October 31, 2022, the results of its operations for the year then ended, the changes in its net assets for each of the two years in the period ended October 31, 2022 and the financial highlights for each of the five years in the period ended October 31, 2022 in conformity with accounting principles generally accepted in the United States of America.
Basis for Opinion
These financial statements are the responsibility of the Fund’s management. Our responsibility is to express an opinion on the Fund’s financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Fund in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.
We conducted our audits of these financial statements in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud.
Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. Our procedures included confirmation of securities owned as of October 31, 2022 by correspondence with the transfer agent and brokers; when replies were not received from brokers, we performed other auditing procedures. We believe that our audits provide a reasonable basis for our opinion.
/s/PricewaterhouseCoopers LLP
Philadelphia, Pennsylvania
December 15, 2022
We have served as the auditor of one or more investment companies in The Vanguard Group of Funds since 1975.
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Tax information (unaudited)
For corporate shareholders, 22.4%, or if subsequently determined to be different, the maximum percentage allowable by law, of ordinary income (dividend income plus short-term gains, if any) for the fiscal year qualified for the dividends-received deduction.
The fund hereby designates $21,425,000, or if subsequently determined to be different, the maximum amount allowable by law, as qualified dividend income for individual shareholders for the fiscal year.
The fund hereby designates $6,000, or if subsequently determined to be different, the maximum amount allowable by law, of interest earned from obligations of the U.S. government which is generally exempt from state income tax.
For nonresident alien shareholders, 100% of short-term capital gain dividends distributed by the fund for the fiscal year are qualified short-term capital gains.
The fund distributed $119,719,000 as capital gain dividends (20% rate gain distributions) to shareholders during the fiscal year.
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The People Who Govern Your Fund
The trustees of your mutual fund are there to see that the fund is operated and managed in your best interests since, as a shareholder, you are a part owner of the fund. Your fund’s trustees also serve on the board of directors of The Vanguard Group, Inc., which is owned by the Vanguard funds and provides services to them.
A majority of Vanguard’s board members are independent, meaning that they have no affiliation with Vanguard or the funds they oversee, apart from the sizable personal investments they have made as private individuals. The independent board members have distinguished backgrounds in business, academia, and public service. Each of the trustees and executive officers oversees 206 Vanguard funds.
Information for each trustee and executive officer of the fund appears below. That information, as well as the Vanguard fund count, is as of the date on the cover of this fund report. The mailing address of the trustees and officers is P.O. Box 876, Valley Forge, PA 19482. More information about the trustees is in the Statement of Additional Information, which can be obtained, without charge, by contacting Vanguard at 800-662-7447, or online at vanguard.com.
Interested Trustee1
Mortimer J. Buckley
Born in 1969. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: chairman of the board (2019–present) of Vanguard and of each of the investment companies served by Vanguard; chief executive officer (2018–present) of Vanguard; chief executive officer, president, and trustee (2018–present) of each of the investment companies served by Vanguard; president and director (2017–present) of Vanguard; and president (2018–present) of Vanguard Marketing Corporation. Chief investment officer (2013–2017), managing director (2002–2017), head of the Retail Investor Group (2006–2012), and chief information officer (2001–2006) of Vanguard. Member of the board of governors of the Investment Company Institute and the board of governors of FINRA. Trustee and vice chair of The Shipley School.
Independent Trustees
Tara Bunch
Born in 1962. Trustee since November 2021. Principal occupation(s) during the past five years and other experience: head of global operations at Airbnb (2020–present). Vice president of AppleCare (2012–2020). Member of the board of directors of Out & Equal (2002–2006), the advisory board of the University of California, Berkeley School of Engineering (2020–present), and the advisory board of Santa Clara University’s Leavey School of Business (2018–present).
Emerson U. Fullwood
Born in 1948. Trustee since January 2008. Principal occupation(s) during the past five years and other experience: executive chief staff and marketing officer for North America and corporate vice president (retired 2008) of Xerox Corporation (document management products and services). Former president of the Worldwide Channels Group, Latin America, and Worldwide Customer Service and executive chief staff officer of Developing Markets of Xerox. Executive in residence and 2009–2010 Distinguished Minett Professor at the Rochester Institute of Technology. Member of the board of directors of the University of Rochester Medical Center, the Monroe Community College Foundation, the United Way of Rochester, North Carolina A&T University, Roberts Wesleyan College, and the Rochester Philharmonic Orchestra. Trustee of the University of Rochester.
 
1 Mr. Buckley is considered an “interested person,” as defined in the Investment Company Act of 1940, because he is an officer of the Vanguard funds.

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F. Joseph Loughrey
Born in 1949. Trustee since October 2009. Principal occupation(s) during the past five years and other experience: president and chief operating officer (retired 2009) and vice chairman of the board (2008–2009) of Cummins Inc. (industrial machinery). Chairman of the board of Hillenbrand, Inc. (specialized consumer services). Director of the V Foundation. Member of the advisory council for the College of Arts and Letters at the University of Notre Dame. Chairman of the board of Saint Anselm College.
Mark Loughridge
Born in 1953. Trustee since March 2012. Principal occupation(s) during the past five years and other experience: senior vice president and chief financial officer (retired 2013) of IBM (information technology services). Fiduciary member of IBM’s Retirement Plan Committee (2004–2013), senior vice president and general manager (2002–2004) of IBM Global Financing, vice president and controller (1998–2002) of IBM, and a variety of other prior management roles at IBM. Member of the Council on Chicago Booth.
Scott C. Malpass
Born in 1962. Trustee since March 2012. Principal occupation(s) during the past five years and other experience: adjunct professor of finance at the University of Notre Dame (2020–present). Chief investment officer (retired 2020) and vice president (retired 2020) of the University of Notre Dame. Assistant professor (retired June 2020) of finance at the Mendoza College of Business, University of Notre Dame, and member of the Notre Dame 403(b) Investment Committee. Member of the board of Catholic Investment Services, Inc. (investment advisors), the board of superintendence of the Institute for the Works of Religion, and the board of directors of Paxos Trust Company (finance).
Deanna Mulligan
Born in 1963. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: chief executive officer of Purposeful (advisory firm for CEOs and C-level executives; 2021–present). Board chair (2020), chief executive officer (2011–2020), and president (2010–2019) of The Guardian Life Insurance Company of America. Chief operating officer (2010–2011) and executive vice president (2008–2010) of Individual Life and Disability of the Guardian Life Insurance Company of America. Member of the board of the Economic Club of New York. Trustee of the Partnership for New York City (business leadership), Chief Executives for Corporate Purpose, and the NewYork-Presbyterian Hospital.
André F. Perold
Born in 1952. Trustee since December 2004. Principal occupation(s) during the past five years and other experience: George Gund Professor of Finance and Banking, Emeritus at the Harvard Business School (retired 2011). Chief investment officer and co-managing partner of HighVista Strategies (private investment firm). Member of the board (2018–present) of RIT Capital Partners (investment firm). Member of the investment committee of Partners Health Care System.
Sarah Bloom Raskin
Born in 1961. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: deputy secretary (2014–2017) of the United States Department of the Treasury. Governor (2010–2014) of the Federal Reserve Board. Commissioner (2007–2010) of financial regulation for the State of Maryland. Colin W. Brown Distinguished Professor of the Practice of Law (2021–present), professor (2020–present), Distinguished Fellow of the Global Financial Markets Center (2020–present), and Rubenstein Fellow (2017–2020) at Duke University. Trustee (2017–present) of Amherst College and member of Amherst College Investment Committee (2019–present). Member of the Regenerative Crisis Response Committee (2020–present).
David A. Thomas
Born in 1956. Trustee since July 2021. Principal occupation(s) during the past five years and other experience: president of Morehouse College (2018–present). Professor of business administration, emeritus at Harvard University (2017–2018). Dean (2011–2016) and professor of management (2016–2017) at the Georgetown University McDonough School of Business. Director of DTE Energy Company (2013–present). Trustee of Common Fund (2019–present).
Peter F. Volanakis
Born in 1955. Trustee since July 2009. Principal occupation(s) during the past five years and other experience: president and chief operating officer (retired 2010) of Corning Incorporated (communications equipment) and director of Corning Incorporated (2000–2010) and Dow Corning (2001–2010). Director (2012) of SPX Corporation (multi-industry manufacturing). Overseer of the Amos Tuck School of Business Administration, Dartmouth College (2001–2013). Member of the BMW Group Mobility Council.

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Executive Officers
Christine M. Buchanan
Born in 1970. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Chief financial officer (2021–present) and treasurer (2017–present) of each of the investment companies served by Vanguard. Partner (2005–2017) at KPMG (audit, tax, and advisory services).
John Galloway
Born in 1973. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Investment stewardship officer (September 2020–present) of each of the investment companies served by Vanguard. Head of Investor Advocacy (February 2020–present) and head of Marketing Strategy and Planning (2017–2020) at Vanguard. Special assistant to the President of the United States (2015).
Ashley Grim
Born in 1984. Principal occupation(s) during the past five years and other experience: treasurer (February 2022–present) of each of the ‎investment companies served by Vanguard. Fund transfer agent controller (2019–2022) and director of Audit Services (2017–2019) at ‎Vanguard. Senior manager (2015–2017) at PriceWaterhouseCoopers (audit and assurance, consulting, and tax services).
Peter Mahoney
Born in 1974. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Controller (2015–present) of each of the investment companies served by Vanguard. Head of International Fund Services (2008–2014) at Vanguard.
Anne E. Robinson
Born in 1970. Principal occupation(s) during the past five years and other experience: general counsel (2016–present) of Vanguard. Secretary (2016–present) of Vanguard and of each of the investment companies served by Vanguard. Managing director (2016–present) of Vanguard. Managing director and general counsel of Global Cards and Consumer Services (2014–2016) at Citigroup. Counsel (2003–2014) at American Express. Nonexecutive director of the board of National Grid (energy).
Michael Rollings
Born in 1963. Principal occupation(s) during the past five years and other experience: finance director (2017–present) and treasurer (2017) of each of the investment companies served by Vanguard. Managing director (2016–present) of Vanguard. Chief financial officer (2016–present) of Vanguard. Director (2016–present) of Vanguard Marketing Corporation. Executive vice president and chief financial officer (2006–2016) of MassMutual Financial Group.
John E. Schadl
Born in 1972. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Chief compliance officer (2019–present) of Vanguard and of each of the investment companies served by Vanguard. Assistant vice president (2019–present) of Vanguard Marketing Corporation.
Vanguard Senior Management Team
Matthew Benchener Thomas M. Rampulla
Joseph Brennan Karin A. Risi
Mortimer J. Buckley Anne E. Robinson
Gregory Davis Michael Rollings
John James Nitin Tandon
Chris D. McIsaac Lauren Valente

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Connect with Vanguard®>vanguard.com
Fund Information > 800-662-7447
Direct Investor Account Services > 800-662-2739
Institutional Investor Services > 800-523-1036
Text Telephone for People
Who Are Deaf or Hard of Hearing > 800-749-7273
This material may be used in conjunction with the offering of shares of any Vanguard fund only if preceded or accompanied by the fund’s current prospectus.
All comparative mutual fund data are from Morningstar, Inc., unless otherwise noted.
You can obtain a free copy of Vanguard’s proxy voting guidelines by visiting vanguard.com/proxyreporting or by calling Vanguard at 800-662-2739. The guidelines are also available from the SEC’s website, www.sec.gov. In addition, you may obtain a free report on how your fund voted the proxies for securities it owned during the 12 months ended June 30. To get the report, visit either vanguard.com/proxyreporting or www.sec.gov.
You can review information about your fund on the SEC’s website, and you can receive copies of this information, for a fee, by sending a request via email addressed to publicinfo@sec.gov.
Source for Bloomberg indexes: Bloomberg Index Services Limited. Copyright 2022, Bloomberg. All rights reserved.
© 2022 The Vanguard Group, Inc.
All rights reserved.
Vanguard Marketing Corporation, Distributor.
Q6080 122022

Annual Report   |   October 31, 2022
Vanguard Emerging Markets Select Stock Fund

Contents
Your Fund’s Performance at a Glance

1
Advisors’ Report

2
About Your Fund’s Expenses

7
Performance Summary

9
Financial Statements

11
Please note: The opinions expressed in this report are just that—informed opinions. They should not be considered promises or advice. Also, please keep in mind that the information and opinions cover the period through the date on the front of this report. Of course, the risks of investing in your fund are spelled out in the prospectus.

Your Fund’s Performance at a Glance
The 12 months ended October 31, 2022, were a volatile, challenging period for financial markets. Vanguard Emerging Markets Select Stock Fund returned –31.16%, lagging the –28.35% return of its benchmark, the FTSE Emerging Index.
The economic backdrop deteriorated as inflation soared to multidecade highs, fueled in part by higher energy and food prices in the wake of Russia’s invasion of Ukraine. Then price increases broadened to other categories of goods and services, adding to concerns that inflation would remain stubbornly high. That prompted aggressive tightening by many central banks to bring inflation back in check and increased fears of a recession.
Most countries posted negative returns for the period, but declines were much steeper in places such as Russia and Hong Kong. The fund’s modest weightings in those two markets were a drag on both absolute and relative performance. However, the fund’s superior stock selection in Hong Kong offset some of the gap in underperformance relative to the index. (The fund’s weighting in Russia was 6.4% at the start of the period and near zero at the end.)
With the sole exception of utilities, declines were universal across sectors in both the fund and the benchmark. The fund’s stocks in materials and financials substantially trailed their benchmark counterparts, contributing the most to underperformance.
 Market Barometer
  Average Annual Total Returns
Periods Ended October 31, 2022
  One Year Three Years Five Years
Stocks      
Russell 1000 Index (Large-caps) -16.38% 9.99% 10.19%
Russell 2000 Index (Small-caps) -18.54 7.05 5.56
Russell 3000 Index (Broad U.S. market) -16.52 9.79 9.87
FTSE All-World ex US Index (International) -24.20 -1.16 -0.18
Bonds      
Bloomberg U.S. Aggregate Float Adjusted Index
(Broad taxable market)
-15.69% -3.73% -0.50%
Bloomberg Municipal Bond Index
(Broad tax-exempt market)
-11.98 -2.18 0.37
FTSE Three-Month U.S. Treasury Bill Index 0.88 0.59 1.15
CPI      
Consumer Price Index 7.75% 5.01% 3.85%
1

Advisors’ Report
For the 12 months ended October 31, 2022, Vanguard Emerging Markets Select Stock Fund returned –31.16%. Your fund is managed by four independent advisors, a strategy that enhances the fund’s diversification by providing exposure to distinct yet complementary investment approaches. It’s not uncommon for different advisors to have different views about individual securities or the broader investment environment.
The advisors, the percentage of fund assets each manages, and brief descriptions of their investment strategies are presented in the accompanying table. The advisors have also prepared a discussion of the investment environment that existed during the fiscal year and of how portfolio positioning reflects this assessment.
These comments were prepared on November 10, 2022.
Pzena Investment Management, LLC
Portfolio Managers:
Rakesh Bordia, Principal
Caroline Cai, CFA, Managing Principal
Allison Fisch, Principal 
The one-year period can be summed up by a relatively stagnant Chinese economy, predominantly because of the zero-COVID policy, and Russia’s war in Ukraine—both of which contributed to the material rise in global inflation. The result has been weaker GDP growth, higher global interest rates, and sinking
emerging-market currencies, which hurt emerging-market stocks. The portfolio posted a negative return but outpaced the benchmark. Only the defensive utilities sector contributed positively to absolute performance.
Brazilian utility Cemig was the portfolio’s top performer; the rebounding Brazilian economy boosted the company’s power and gas distribution volumes. Indonesian lender PT Bank Mandiri also was up materially on rising interest rates and benign credit costs, and investors bought up shares of Brazilian lender Itaú Unibanco after management raised forecasts on net interest margins and loan growth.
Russian oil company Lukoil was the largest detractor. With heavy trading restrictions resulting in no clear price discovery, we fair-valued the position at US$0.01 in all our portfolios. We subsequently found some liquidity in Lukoil and were able to dispose of our remaining position. Shares of Chinese e-commerce giant Alibaba have been pressured for months by myriad issues that were mostly systematic, including the Chinese government’s crackdown on technology companies, the threat of American depositary receipts being delisted from U.S. exchanges, and, perhaps most consequentially, the government’s zero-COVID policy impacting consumer spending. TSMC, the world’s largest chipmaker, was lower after softening global demand and U.S. regulations affected the sector.
 
2

Fear of recession, rising rates, and heightened geopolitical tensions are likely to hurt emerging-market valuations regardless of geography, market cap, or style. But short-term market dislocations have enabled us to uncover high-quality businesses trading at bargain-basement prices, sowing the seeds for long-term alpha generation—a strategy that’s particularly effective in developing markets.
Oaktree Fund Advisors, LLC
Portfolio Manager:
Frank J. Carroll III,
Managing Director and Co-Head
of Emerging Markets Equities
Janet Wang,
Managing Director and Co-Portfolio Manager
Emerging markets equities fell sharply during the 12 months. Stocks tumbled from a number of macro headwinds, including Russia’s invasion of Ukraine, China’s zero-COVID policy, rising inflation, tightening monetary policy, and fears of slowing global economic growth. 
Despite weak absolute performance for the asset class, our portfolio outpaced the benchmark. At the country level, stock selection in China contributed the most to our relative results, followed by selection in Brazil and India. Our overweight allocations to Brazil and Indonesia also contributed positively, as did our underweight exposure to Taiwan. Stock selection in Russia, Indonesia, Taiwan, and Mexico detracted from our relative
performance, as did our underweight exposures to Saudi Arabia, India, and the UAE.
By sector, stock selection in consumer discretionary helped our relative returns, while selection in materials, real estate, health care, energy, and financials hurt. Overweight allocations to materials, energy, and industrials contributed positively to relative performance, as did underweight exposures to communication services, consumer discretionary, and information technology. Underweights in utilities and consumer staples detracted.
We maintain our view that emerging markets will be hurt less during this downturn than in previous cycles. Many of the biggest emerging-market economies are in sound fiscal shape, and most emerging-market governments understand how to manage their economies in an inflationary environment. We’ve remained disciplined in our research process and conduct thorough due diligence on high-quality, fundamentally sound companies. We expect the market to remain volatile through year-end, as election news and geopolitical headlines dominate the conversation about emerging-market countries. But much of this negative sentiment is already reflected in today’s prices.
Baillie Gifford Overseas Ltd.
Portfolio Managers: 
Mike Gush
Andrew Stobart
3

The 12 months have been terrible for growth equities, with rising inflation and interest rates dominating the market narrative and sentiment. The news around the Chinese Communist Party’s National Congress has left sentiment on China particularly weak in the near term.
On top of this, there appears to be a belief in the markets that a strong U.S. dollar is always bad for emerging markets. We need to be careful not to lazily bucket together all emerging-market currencies, as some of the commodity-exporting currencies have held up well this year. But perhaps more importantly, we should also point out that the risk of capital outflow from emerging markets is materially different now than it was in the early 2010s. Put simply, if capital flight is one of the biggest triggers for emerging-market crises, then it's significant that these markets have already experienced outflows for almost a decade.
Emerging-market countries have been relatively swift in raising interest rates to counter inflation and, unlike in developed markets, inflation is not materially different from the average over the last decade. Emerging markets’ macro health is relatively good.
Looking at market performance, apart from energy, very little that is of long-term interest to us has held up well this year, with “capital preservation” sectors such as utilities and consumer staples doing best. Long-duration growth stocks have been savaged by the anticipation of higher interest rates.
Against this backdrop, we have been careful to remember where we believe we can add value. We have very little to add to the debate around the next movements of the Federal Reserve or the direction of the U.S. dollar over the next quarter. Instead, we have been re-examining our holdings’ fundamentals and finding real dissonance between their operational and share-price performance. 
Wellington Management Company LLP
Portfolio Manager:
Mary Pryshlak, CFA,
Senior Managing Director and
Head of Investment Research
Emerging-market equities fell sharply during the 12 months. Within the FTSE Emerging Index, the consumer discretionary, communication services, and real estate sectors experienced the steepest declines, while utilities, financials, and industrials performed better.
Emerging markets were pressured by persistent inflation, rising interest rates, elevated geopolitical tensions, and concerns of a deeper economic slowdown, which we believe will continue to create volatility moving forward. However, the market downturn has not been felt equally across all regions as it has become increasingly evident that there is divergence in both policy and performance across economies. Central and Eastern European countries continue to feel the spillover effects of the war in Ukraine that have driven increases in food and energy costs. In contrast, soaring
4

commodity prices have benefited export-oriented economies such as Brazil, Indonesia, and Saudi Arabia. In China, uncertainty around the government’s zero-COVID policy, rising geopolitical tension with the U.S., and a downturn in the property market have caused volatility.
In this environment, our portion of the portfolio underperformed the benchmark index. Most notably, security selection in energy, materials, and information technology detracted most from relative results. On a regional basis, stock selection in China and our exposure to Russia were the primary drivers of underperformance, while selection within India and Brazil contributed.
At the security level, Russian energy companies Gazprom and Lukoil were the
top relative detractors. Bharti Airtel, an Indian telecommunications services company, and Sabesp, a Brazilian waste management company, partially offset the underperformance.
Our global industry analysts will continue to focus on identifying companies with the potential to emerge from this period of volatility stronger than their peers. We believe that the team’s deep fundamental research, experience managing in a variety of market environments, and long-term orientation will be critical in navigating today’s market environment. We maintain conviction that we will be able to generate alpha for Vanguard shareholders over the long term.
5

Vanguard Emerging Markets Select Stock Fund Investment Advisors
 
  Fund Assets Managed  
Investment Advisor % $ Million Investment Strategy
Pzena Investment Management, LLC 25 156 Uses a deep-value approach that focuses on the most undervalued companies based on price-to-normalized earnings. The firm believes that this value philosophy works well globally and is especially effective in emerging markets because of generally wider valuation spreads.
Oaktree Fund Advisors, LLC 24 153 Seeks securities that have been undervalued by investors. Oaktree’s investment process is driven by bottom-up research, which includes extensive travel to meet company management and maintaining in-house models focused on deriving reliable cash-flow projections.
Baillie Gifford Overseas Ltd. 24 152 Believes that companies that can sustainably grow their business and increase earnings faster than market average will perform best. Stock selection is driven by bottom-up, fundamental analysis, focusing on a company’s potential over a meaningful time period, typically three to five years and beyond.
Wellington Management Company LLP 24 148 Allocates the assets in its portion of the fund to a team of global analysts who seek to add value through in-depth fundamental research and understanding of their industries. By covering the same companies over a period of many years, these investment professionals gain comprehensive insight to guide decisions for their subportfolios.
Cash Investments 3 20 These short-term reserves are invested by Vanguard in equity index products to simulate investment in stocks. Each advisor may also maintain a modest cash position.
6

About Your Fund’s Expenses
As a shareholder of the fund, you incur ongoing costs, which include costs for portfolio management, administrative services, and shareholder reports (like this one), among others. Operating expenses, which are deducted from a fund’s gross income, directly reduce the investment return of the fund.
A fund’s expenses are expressed as a percentage of its average net assets. This figure is known as the expense ratio. The following examples are intended to help you understand the ongoing costs (in dollars) of investing in your fund and to compare these costs with those of other mutual funds. The examples are based on an investment of $1,000 made at the beginning of the period shown and held for the entire period.
The accompanying table illustrates your fund’s costs in two ways:
Based on actual fund return. This section helps you to estimate the actual expenses that you paid over the period. The ”Ending Account Value“ shown is derived from the fund‘s actual return, and the third column shows the dollar amount that would have been paid by an investor who started with $1,000 in the fund. You may use the information here, together with the amount you invested, to estimate the expenses that you paid over the period.
To do so, simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number given for your fund under the heading ”Expenses Paid During Period.“
Based on hypothetical 5% yearly return. This section is intended to help you compare your fund‘s costs with those of other mutual funds. It assumes that the fund had a yearly return of 5% before expenses, but that the expense ratio is unchanged. In this case—because the return used is not the fund’s actual return—the results do not apply to your investment. The example is useful in making comparisons because the Securities and Exchange Commission requires all mutual funds to calculate expenses based on a 5% return. You can assess your fund’s costs by comparing this hypothetical example with the hypothetical examples that appear in shareholder reports of other funds.
Note that the expenses shown in the table are meant to highlight and help you compare ongoing costs only and do not reflect transaction costs incurred by the fund for buying and selling securities. Further, the expenses do not include any purchase, redemption, or account service fees described in the fund prospectus. If such fees were applied to your account, your costs would be higher. Your fund does not carry a “sales load.”
The calculations assume no shares were bought or sold during the period. Your actual costs may have been higher or lower, depending on the amount of your investment and the timing of any purchases or redemptions.
You can find more information about the fund’s expenses, including annual expense ratios, in the Financial Statements section of this report. For additional information on operating expenses and other shareholder costs, please refer to your fund’s current prospectus.
7

Six Months Ended October 31, 2022      
Emerging Markets Select Stock Fund Beginning
Account Value
4/30/2022
Ending
Account Value
10/31/2022
Expenses
Paid During
Period
Based on Actual Fund Return $1,000.00 $824.00 $3.49
Based on Hypothetical 5% Yearly Return 1,000.00 1,021.37 3.87
The calculations are based on expenses incurred in the most recent six-month period. The fund’s annualized six-month expense ratio for that period is 0.76%. The dollar amounts shown as “Expenses Paid” are equal to the annualized expense ratio multiplied by the average account value over the period, multiplied by the number of days in the most recent six-month period, then divided by the number of days in the most recent 12-month period (184/365).
8

Emerging Markets Select Stock Fund
Performance Summary
All of the returns in this report represent past performance, which is not a guarantee of future results that may be achieved by the fund. (Current performance may be lower or higher than the performance data cited. For performance data current to the most recent month-end, visit our website at vanguard.com/performance.) Note, too, that both investment returns and principal value can fluctuate widely, so an investor’s shares, when sold, could be worth more or less than their original cost. The returns shown do not reflect taxes that a shareholder would pay on fund distributions or on the sale of fund shares.
Cumulative Performance: October 31, 2012, Through October 31, 2022
Initial Investment of $10,000
    Average Annual Total Returns
Periods Ended October 31, 2022
 
    One
Year
Five
Years
Ten
Years
Final Value
of a $10,000
Investment
 Emerging Markets Select Stock Fund -31.16% -2.34% 1.41% $11,498
 FTSE Emerging Index -28.35 -1.78 1.35 11,434
 MSCI All Country World Index ex USA -24.73 -0.60 3.27 13,796
See Financial Highlights for dividend and capital gains information.
9

Emerging Markets Select Stock Fund
Fund Allocation
As of October 31, 2022
China 24.9%
India 13.1
Brazil 11.9
Taiwan 10.8
South Korea 7.9
United States 5.5
Hong Kong 4.6
Indonesia 3.8
Thailand 3.5
South Africa 2.4
Mexico 2.2
United Kingdom 1.7
Canada 1.1
Hungary 1.0
Other 5.6
The table reflects the fund’s investments, except for short-term investments and derivatives.
10

Emerging Markets Select Stock Fund
Financial Statements
Schedule of Investments
As of October 31, 2022
The fund files its complete schedule of portfolio holdings with the Securities and Exchange Commission (SEC) for the first and third quarters of each fiscal year as an exhibit to its reports on Form N-PORT. The fund’s Form N-PORT reports are available on the SEC’s website at www.sec.gov.
    Shares Market
Value

($000)
Common Stocks (95.3%)
Brazil (11.4%)
  Petroleo Brasileiro SA ADR (XNYS)    904,674   11,598
  Vale SA Class B ADR    563,073    7,286
  Ambev SA  2,121,666    6,572
  Cia Energetica de Minas Gerais Preference Shares  2,746,665    6,046
  Banco Bradesco SA ADR  1,411,609    5,350
  Itau Unibanco Holding SA Preference Shares    698,900    4,113
  B3 SA - Brasil Bolsa Balcao  1,332,100    3,879
  Centrais Eletricas Brasileiras SA    379,218    3,657
  Itau Unibanco Holding SA ADR    593,658    3,455
  Raizen SA Preference Shares  4,023,535    3,342
  Banco Bradesco SA Preference Shares    798,600    3,070
  Petroleo Brasileiro SA ADR    183,700    2,114
  Neoenergia SA    570,300    1,832
  Cia de Saneamento Basico do Estado de Sao Paulo    146,947    1,710
  Petroleo Brasileiro SA    264,473    1,703
* Azul SA ADR    160,531    1,507
  TIM SA    478,100    1,222
  Banco Do Brasil SA    162,600    1,165
* Magazine Luiza SA    621,020      537
1 Hapvida Participacoes e Investimentos SA    324,862      491
  Raia Drogasil SA     94,470      481
  Hypera SA     18,424      181
  Totvs SA     21,400      137
  Caixa Seguridade Participacoes SA     68,870      118
        71,566
Canada (1.0%)
  First Quantum Minerals Ltd.    160,978    2,839
  Lundin Mining Corp.    372,945    1,955
  Parex Resources Inc.    102,230    1,559
* Valeura Energy Inc.    264,800      132
         6,485
    Shares Market
Value

($000)
China (23.7%)
* Alibaba Group Holding Ltd.  2,134,340   16,594
  Tencent Holdings Ltd.    528,550   13,889
*,1 Meituan Class B    359,392    5,754
* Trip.com Group Ltd. ADR    247,376    5,598
  Ping An Insurance Group Co. of China Ltd. Class H    990,527    3,965
  China Merchants Bank Co. Ltd. Class H  1,099,289    3,599
  China Overseas Land & Investment Ltd.  1,740,805    3,327
  Zijin Mining Group Co. Ltd. Class H  3,426,446    3,268
  JD.com Inc. Class A    169,070    3,079
1 Ganfeng Lithium Co. Ltd. Class H    450,517    3,047
* Shanghai International Airport Co. Ltd. Class A    407,510    2,981
* Baidu Inc. Class A    296,686    2,844
  Contemporary Amperex Technology Co. Ltd. Class A (XSHE)     54,273    2,785
  China Construction Bank Corp. Class H  5,188,694    2,754
  China Tourism Group Duty Free Corp. Ltd. Class A    123,549    2,715
  Anhui Conch Cement Co. Ltd. Class H  1,006,625    2,591
  Aluminum Corp. of China Ltd. Class H  8,785,233    2,505
  Midea Group Co. Ltd. Class A    424,086    2,336
  Geely Automobile Holdings Ltd.  2,157,301    2,322
* Air China Ltd. Class H  3,156,872    2,197
1 WuXi AppTec Co. Ltd. Class H    267,524    2,147
* Baidu Inc. ADR     27,944    2,140
  China Longyuan Power Group Corp. Ltd. Class H  1,786,350    2,041
  GF Securities Co. Ltd. Class H  1,948,400    1,982
* China Tourism Group Duty Free Corp. Ltd. Class A (XHKG)     94,746    1,687
  ANTA Sports Products Ltd.    188,013    1,653
11

Emerging Markets Select Stock Fund
    Shares Market
Value

($000)
  Muyuan Foods Co. Ltd.Class A    245,170    1,579
  Haier Smart Home Co. Ltd. Class H    625,800    1,566
* Brilliance China Automotive Holdings Ltd.  3,486,000    1,501
* KE Holdings Inc. ADR    147,459    1,501
  Nine Dragons Paper Holdings Ltd.  2,388,888    1,416
  Contemporary Amperex Technology Co. Ltd. Class A     27,500    1,411
  CITIC Securities Co. Ltd. Class H    903,554    1,350
  Riyue Heavy Industry Co. Ltd. Class A (XSHG)    439,054    1,332
  Weichai Power Co. Ltd. Class H  1,387,349    1,329
  ENN Energy Holdings Ltd.    132,041    1,313
  Li Ning Co. Ltd.    251,768    1,302
  Dongfeng Motor Group Co. Ltd. Class H  2,838,000    1,284
  Midea Group Co. Ltd. Class A (XSEC)    205,194    1,130
  Ping An Bank Co. Ltd. Class A    768,940    1,092
  Xtep International Holdings Ltd.  1,119,891    1,026
  China Oilfield Services Ltd. Class H    904,508    1,018
  Industrial & Commercial Bank of China Ltd. Class H  2,267,666      985
1 Pharmaron Beijing Co. Ltd. Class H    283,084      955
  Minth Group Ltd.    474,000      935
  Sinoma Science & Technology Co. Ltd. Class A    353,800      869
* BeiGene Ltd.     66,950      863
  Yunnan Energy New Material Co. Ltd. Class A     42,200      856
1 CSC Financial Co. Ltd. Class H  1,047,657      760
  Yihai International Holding Ltd.    452,690      746
  Guangzhou Tinci Materials Technology Co. Ltd. Class A    126,300      736
  Shenzhou International Group Holdings Ltd.    105,500      732
* Trip.com Group Ltd.     31,278      703
  Suofeiya Home Collection Co. Ltd. Class A    354,790      680
  China Resources Beer Holdings Co. Ltd.    131,800      622
* Zai Lab Ltd.    266,900      614
  China Yangtze Power Co. Ltd. Class A    217,600      606
  Anker Innovations Technology Co. Ltd. Class A     80,600      598
  Bank of Ningbo Co. Ltd. Class A    160,000      522
    Shares Market
Value

($000)
  China National Building Material Co. Ltd. Class H    884,093      513
* Kingdee International Software Group Co. Ltd.    304,575      499
*,1 Haidilao International Holding Ltd.    326,000      484
* Tencent Music Entertainment Group ADR    132,550      479
* XPeng Inc. Class A    148,952      477
  China Railway Group Ltd. Class A    683,200      467
  CSPC Pharmaceutical Group Ltd.    443,199      455
  China Pacific Insurance Group Co. Ltd. Class H    281,922      454
  Shanghai Putailai New Energy Technology Co. Ltd. Class A     65,720      450
  Zoomlion Heavy Industry Science and Technology Co. Ltd. Class A    591,100      434
  JD.com Inc. ADR     11,146      416
  Baoshan Iron & Steel Co. Ltd. Class A    630,300      416
  Shandong Weigao Group Medical Polymer Co. Ltd. Class H    294,318      406
* KE Holdings Inc. Class A    121,500      403
  Suofeiya Home Collection Co. Ltd. Class A (XSHE)    207,345      397
  Glodon Co. Ltd. Class A (XSHE)     58,400      396
*,1 Kuaishou Technology     95,900      396
  Lufax Holding Ltd. ADR    245,187      390
  Hangzhou Tigermed Consulting Co. Ltd. Class A     32,600      373
* Yatsen Holding Ltd. ADR    326,250      369
  Shenzhen Mindray Bio-Medical Electronics Co. Ltd. Class A      8,100      362
  Zhejiang HangKe Technology Inc. Co Class A     47,879      328
  WuXi AppTec Co. Ltd. Class A     30,200      316
* Grand Baoxin Auto Group Ltd.  6,482,000      313
  China Vanke Co. Ltd. Class H    243,700      313
  Sany Heavy Industry Co. Ltd. Class A    168,200      312
  NetEase Inc.     26,901      298
  Wuxi Lead Intelligent Equipment Co. Ltd. Class A     41,400      285
  Metallurgical Corp of China Ltd. Class A    652,600      258
  Zhongsheng Group Holdings Ltd.     66,311      252
* Qinghai Salt Lake Industry Co. Ltd. Class A     79,800      236
*,1 Remegen Co. Ltd. Class H     37,359      235
 
12

Emerging Markets Select Stock Fund
    Shares Market
Value

($000)
  CIMC Enric Holdings Ltd.    240,000      234
* New Oriental Educatio Sp ADR      9,612      228
  SAIC Motor Corp. Ltd. Class A    114,500      216
  Yifeng Pharmacy Chain Co. Ltd. Class A (XSHG)     27,170      209
  Angang Steel Co. Ltd.Class A    560,600      189
* Alibaba Group Holding Ltd. ADR      2,826      180
  Great Wall Motor Co. Ltd. Class H    146,500      160
  Yifeng Pharmacy Chain Co. Ltd. Class A     19,300      149
1 Asymchem Laboratories Tianjin Co. Ltd. Class H     11,491      123
* Microport Scientific Corp.     56,946      120
  Amoy Diagnostics Co. Ltd. Class A     37,094      119
  NetEase Inc. ADR      2,103      117
* Vnet Group Inc. ADR     27,521      115
  Shanghai Fosun Pharmaceutical Group Co. Ltd. Class H     44,000      111
  Vinda International Holdings Ltd.     57,000      107
1 Hangzhou Tigermed Consulting Co. Ltd. Class H     15,616      106
  Shenzhen Mindray Bio-Medical Electronics Co. Ltd. Class A (XSHE)      2,300      103
  Asymchem Laboratories Tianjin Co. Ltd. Class A      5,160      101
  Jinyu Bio-Technology Co. Ltd. Class A     73,900       84
* Onewo Inc. Class H     21,415       81
  H World Group Ltd. AD      2,393       65
  Poly Developments and Holdings Group Co. Ltd. Class A     34,300       65
  Proya Cosmetics Co. Ltd. Class A      2,800       64
*,1 Venus MedTech Hangzhou Inc. Class H     48,977       60
* GDS Holdings Ltd. ADR      6,127       53
  Country Garden Services Holdings Co. Ltd.     40,440       35
  Angang Steel Co. Ltd. Class H     73,662       15
  Amoy Diagnostics Co. Ltd. Class A (XSHE)      3,080       10
*,2 Tianhe Chemicals Group Ltd.  4,142,000       —
       149,133
Cyprus (0.0%)
* Galaxy Cosmos Mezz plc    110,618       18
Czech Republic (0.4%)
  Komercni banka A/S     73,436    2,103
  CEZ A/S      8,341      273
         2,376
    Shares Market
Value

($000)
Egypt (0.0%)
  Commercial International Bank Egypt SAE GDR (Registered)          2       —
Greece (0.6%)
* Alpha Services and Holdings SA  2,986,676    2,766
  Hellenic Telecommunications Organization SA     75,316    1,183
         3,949
Hong Kong (4.4%)
  Galaxy Entertainment Group Ltd.  1,952,070    8,918
  Pacific Basin Shipping Ltd. 14,975,140    3,625
* Sands China Ltd.  1,847,505    3,230
  Lenovo Group Ltd.  3,878,000    3,099
  Yue Yuen Industrial Holdings Ltd.  2,572,000    2,615
  AIA Group Ltd.    274,437    2,079
  VTech Holdings Ltd.    289,500    1,541
  Orient Overseas International Ltd.    104,814    1,532
* Melco Resorts & Entertainment Ltd. ADR    130,301      713
  Kerry Properties Ltd.     99,000      156
1 ESR Cayman Ltd.     45,606       78
        27,586
Hungary (0.9%)
  OTP Bank Nyrt    241,310    5,264
  MOL Hungarian Oil & Gas plc     98,379      591
         5,855
India (12.5%)
  Reliance Industries Ltd.    612,122   18,888
  Housing Development Finance Corp. Ltd.    172,975    5,172
  Axis Bank Ltd.    469,483    5,149
  Larsen & Toubro Ltd.    200,033    4,897
  Shriram Transport Finance Co. Ltd.    317,842    4,727
  ICICI Bank Ltd. ADR    192,267    4,238
  Bharti Airtel Ltd (XNSE)    413,482    4,158
  UltraTech Cement Ltd.     47,059    3,823
  Aurobindo Pharma Ltd.    524,778    3,412
  Tata Consultancy Services Ltd.     86,478    3,337
  Tech Mahindra Ltd.    204,449    2,629
  State Bank of India    377,274    2,620
1 HDFC Life Insurance Co. Ltd.    376,278    2,459
  Kotak Mahindra Bank Ltd.     92,184    2,123
  Infosys Ltd. ADR     82,214    1,540
  Mahindra & Mahindra Ltd.     86,547    1,412
  ICICI Bank Ltd.    114,287    1,257
  Power Grid Corp. of India Ltd.    386,533    1,066
1 SBI Life Insurance Co. Ltd.     60,556      928
  Piramal Enterprises Ltd.     66,542      684
  Bharat Electronics Ltd.    508,827      657
  UPL Ltd.     73,290      647
 
13

Emerging Markets Select Stock Fund
    Shares Market
Value

($000)
* Piramal Pharma Ltd.    266,168      530
  Apollo Hospitals Enterprise Ltd.      8,998      491
* Zomato Ltd.    502,368      383
* Fortis Healthcare Ltd.     96,586      324
  Tata Steel Ltd.    240,069      294
  Dabur India Ltd.     41,301      277
  PI Industries Ltd.      4,819      189
  Bharti Airtel Ltd.     31,225      166
        78,477
Indonesia (3.6%)
  Bank Rakyat Indonesia Persero Tbk PT 39,396,025   11,753
  Bank Mandiri Persero Tbk PT  7,321,200    4,946
  Semen Indonesia Persero Tbk PT  4,429,400    2,260
  Telkom Indonesia Persero Tbk PT  7,196,637    2,021
  Bank Central Asia Tbk PT  2,712,155    1,533
  Aneka Tambang Tbk  1,641,300      194
        22,707
Japan (0.1%)
* Universal Entertainment Corp.     41,000      553
Kenya (0.2%)
  Equity Group Holdings plc  2,758,414    1,062
Mexico (2.1%)
  Grupo Financiero Banorte SAB de CV Class O  1,028,915    8,363
  Wal-Mart de Mexico SAB de CV    540,268    2,087
* Cemex SAB de CV ADR    308,447    1,191
  Qualitas Controladora SAB de CV    143,044      562
  Grupo Mexico SAB de CV Series B    111,163      403
  Corp. Inmobiliaria Vesta SAB de CV    108,500      236
  Orbia Advance Corp. SAB de CV    132,500      224
        13,066
Netherlands (0.1%)
  ASML Holding NV      1,329      623
Other (0.8%)
3 Vanguard FTSE Emerging Markets ETF    150,681    5,342
Philippines (0.4%)
  Bdo Unibank Inc.  1,037,747    2,294
  Ayala Land Inc.    484,700      215
         2,509
Poland (0.2%)
*,1 Allegro.eu SA    147,294      714
  KGHM Polska Miedz SA     34,440      689
         1,403
Romania (0.2%)
  Banca Transilvania SA    441,537    1,512
Russia (0.0%)
2 MMC Norilsk Nickel PJSC ADR    200,203       —
*,2 Sberbank of Russia PJSC  1,473,153       —
    Shares Market
Value

($000)
*,2 Mobile TeleSystems PJSC ADR     93,946       —
*,2 Moscow Exchange MICEX-RTS PJSC    536,630       —
2 Magnit PJSC GDR (Registered)          2       —
2 MMC Norilsk Nickel PJSC      1,247       —
*,2 Sberbank of Russia PJSC ADR    476,234       —
2 LUKOIL PJSC ADR    102,385       —
2 Novatek PJSC GDR (Registered)      6,724       —
*,2,4 Ozon Holdings plc ADR     37,493       —
2 Magnit PJSC     12,527       —
2 Gazprom PJSC    926,846       —
            —
Saudi Arabia (0.6%)
  Saudi British Bank    180,813    2,095
1 Saudi Arabian Oil Co.    163,398    1,516
         3,611
Singapore (0.7%)
  Wilmar International Ltd.  1,612,000    4,416
South Africa (2.3%)
  Sasol Ltd.    210,194    3,533
  AngloGold Ashanti Ltd. ADR    267,213    3,487
  Impala Platinum Holdings Ltd.    224,903    2,303
  FirstRand Ltd.    315,005    1,101
  Thungela Resources Ltd.     51,383      784
  Gold Fields Ltd.     85,598      686
  Naspers Ltd. Class N      6,400      660
  Reunert Ltd.    262,523      660
* Discovery Ltd.     80,486      527
  Sibanye Stillwater Ltd.    193,046      452
  Harmony Gold Mining Co. Ltd.     81,675      226
  Old Mutual Ltd. (XZIM)    365,405      207
        14,626
South Korea (7.5%)
  Samsung Electronics Co. Ltd.    305,176   12,701
  LG Chem Ltd.     12,491    5,482
  SK Hynix Inc.     80,367    4,653
  Samsung SDI Co. Ltd.      6,880    3,550
  Hankook Tire & Technology Co. Ltd.    136,687    3,501
  POSCO Holdings Inc.     18,626    3,246
  Hyundai Motor Co.     23,863    2,750
  Samsung Electronics Co. Ltd. Preference Shares     71,045    2,655
  DB Insurance Co. Ltd.     61,070    2,410
  Hana Financial Group Inc.     60,283    1,743
  Shinhan Financial Group Co. Ltd.     53,870    1,369
* Korea Shipbuilding & Offshore Engineering Co. Ltd.     21,091    1,074
  KB Financial Group Inc.     26,800      902
  Doosan Bobcat Inc.     36,396      854
  NAVER Corp.      4,531      538
        47,428
 
14

Emerging Markets Select Stock Fund
    Shares Market
Value

($000)
Taiwan (10.3%)
  Taiwan Semiconductor Manufacturing Co. Ltd.  2,854,656   34,319
  Hon Hai Precision Industry Co. Ltd.  2,323,685    7,380
  MediaTek Inc.    281,014    5,122
  Compal Electronics Inc.  6,334,000    4,143
  Lite-On Technology Corp.  1,878,000    3,719
  Elite Material Co. Ltd.    504,000    2,280
  United Microelectronics Corp.  1,455,926    1,751
  United Integrated Services Co. Ltd.    328,000    1,472
  E Ink Holdings Inc.    221,000    1,404
  Chroma ATE Inc.    160,000      874
  ASPEED Technology Inc.     11,553      599
  Airtac International Group     25,783      590
  Nanya Technology Corp.    199,000      335
  Realtek Semiconductor Corp.     33,738      266
  Unimicron Technology Corp.     60,800      234
  Globalwafers Co. Ltd.     14,456      160
  Parade Technologies Ltd.      3,058       58
        64,706
Thailand (3.3%)
  PTT Exploration & Production PCL    912,100    4,361
  Charoen Pokphand Foods PCL  5,818,600    3,869
  SCB X PCL NVDR  1,316,300    3,678
  Kasikornbank PCL    644,207    2,479
  Kasikornbank PCL NVDR    499,579    1,922
  Bangkok Bank PCL NVDR    469,100    1,796
  Bangkok Bank PCL (Registered)    215,800      827
* Thai Life Insurance PCL  1,897,897      774
  Bangkok Dusit Medical Services PCL Class F    469,300      364
  CP ALL PCL    181,500      286
  PTT Exploration & Production PCL (XBKK)     39,800      190
  Central Pattana PCL     92,270      167
        20,713
Turkey (0.4%)
  Akbank TAS  2,890,926    2,273
United Arab Emirates (0.7%)
  Abu Dhabi Commercial Bank PJSC  1,508,969    3,884
  Emaar Properties PJSC    182,311      301
  Borouge plc    351,373      260
         4,445
United Kingdom (1.6%)
  Standard Chartered plc    762,825    4,558
  Fresnillo plc    241,232    2,017
  Antofagasta plc     88,926    1,198
*,1 Network International Holdings plc    285,409    1,069
  Anglo American plc     29,712      890
  Polymetal International plc    121,016      286
  Hikma Pharmaceuticals plc     16,009      230
        10,248
    Shares Market
Value

($000)
United States (5.3%)
  Credicorp Ltd.     52,800    7,728
* Flex Ltd.    241,216    4,723
* MercadoLibre Inc.      4,814    4,340
  Freeport-McMoRan Inc.    126,596    4,012
  Cognizant Technology Solutions Corp. Class A     51,280    3,192
* Coupang Inc.    128,048    2,211
* Copa Holdings SA Class A     25,130    1,890
* Afya Ltd. Class A     87,070    1,283
* PagSeguro Digital Ltd. Class A     87,254    1,194
  Ternium SA ADR     25,307      729
  Patria Investments Ltd. Class A     44,816      637
* Sea Ltd. ADR     12,438      618
  Yum China Holdings Inc.      5,513      228
* StoneCo. Ltd. Class A     18,159      191
* MakeMyTrip Ltd.      3,118       87
*,2 Yandex NV Class A     11,746       —
        33,063
Vietnam (0.0%)
1 Vinhomes JSC    107,002      194
Total Common Stocks
(Cost $714,406)
599,945
Temporary Cash Investments (4.3%)
Money Market Fund (4.3%)
5,6 Vanguard Market Liquidity Fund, 3.117% (Cost $27,135)    271,459         27,141
Total Investments (99.6%) (Cost $741,541) 627,086
Other Assets and Liabilities—Net (0.4%) 2,316
Net Assets (100%) 629,402
Cost is in $000.
See Note A in Notes to Financial Statements.
* Non-income-producing security.
1 Security exempt from registration under Rule 144A of the Securities Act of 1933. Such securities may be sold in transactions exempt from registration, normally to qualified institutional buyers. At October 31, 2022, the aggregate value was $21,516,000, representing 3.4% of net assets.
2 Security value determined using significant unobservable inputs.
3 Considered an affiliated company of the fund as the issuer is another member of The Vanguard Group.
4 Includes partial security positions on loan to broker-dealers. The total value of securities on loan is $0.
5 Affiliated money market fund available only to Vanguard funds and certain trusts and accounts managed by Vanguard. Rate shown is the 7-day yield.
6 Collateral of $630,000 was received for securities on loan.
  ADR—American Depositary Receipt.
  GDR—Global Depositary Receipt.
  NVDR—Non-Voting Depository Receipt.
 
15

Emerging Markets Select Stock Fund

Derivative Financial Instruments Outstanding as of Period End

Futures Contracts
      ($000)
  Expiration Number of
Long (Short)
Contracts
Notional
Amount
Value and
Unrealized
Appreciation
(Depreciation)
Long Futures Contracts        
MSCI Emerging Markets Index December 2022 519 22,151 (2,014)
  
See accompanying Notes, which are an integral part of the Financial Statements.
16

Emerging Markets Select Stock Fund
Statement of Assets and Liabilities
As of October 31, 2022
($000s, except shares and per-share amounts) Amount
Assets  
Investments in Securities, at Value1  
Unaffiliated Issuers (Cost $707,872) 594,603
Affiliated Issuers (Cost $33,669) 32,483
Total Investments in Securities 627,086
Investment in Vanguard 26
Cash 1,530
Cash Collateral Pledged—Futures Contracts 1,137
Foreign Currency, at Value (Cost $1,406) 1,432
Receivables for Investment Securities Sold 1,866
Receivables for Accrued Income 1,287
Receivables for Capital Shares Issued 252
Total Assets 634,616
Liabilities  
Payables for Investment Securities Purchased 1,622
Collateral for Securities on Loan 630
Payables to Investment Advisor 803
Payables for Capital Shares Redeemed 501
Payables to Vanguard 87
Variation Margin Payable—Futures Contracts 67
Deferred Foreign Capital Gains Taxes 1,504
Total Liabilities 5,214
Net Assets 629,402
1 Includes $0 of securities on loan.  
At October 31, 2022, net assets consisted of:  
   
Paid-in Capital 789,080
Total Distributable Earnings (Loss) (159,678)
Net Assets 629,402
 
Net Assets  
Applicable to 36,122,580 outstanding $.001 par value shares of
beneficial interest (unlimited authorization)
629,402
Net Asset Value Per Share $17.42
  
See accompanying Notes, which are an integral part of the Financial Statements.
17

Emerging Markets Select Stock Fund
Statement of Operations
  Year Ended
October 31, 2022
  ($000)
Investment Income  
Income  
Dividends—Unaffiliated Issuers1 32,105
Dividends—Affiliated Issuers 169
Interest—Unaffiliated Issuers 10
Interest—Affiliated Issuers 384
Securities Lending—Net 30
Total Income 32,698
Expenses  
Investment Advisory Fees—Note B  
Basic Fee 4,203
Performance Adjustment (315)
The Vanguard Group—Note C  
Management and Administrative 2,110
Marketing and Distribution 72
Custodian Fees 158
Auditing Fees 35
Shareholders’ Reports 41
Trustees’ Fees and Expenses
Other Expenses 16
Total Expenses 6,320
Net Investment Income 26,378
Realized Net Gain (Loss)  
Capital Gains Distributions Received – Affiliated Issuers 1
Investment Securities Sold—Unaffiliated Issuers2 (47,847)
Investment Securities Sold—Affiliated Issuers (548)
Futures Contracts (10,831)
Forward Currency Contracts (18)
Foreign Currencies (624)
Realized Net Gain (Loss) (59,867)
Change in Unrealized Appreciation (Depreciation)  
Investment Securities—Unaffiliated Issuers3 (258,668)
Investment Securities—Affiliated Issuers (1,205)
Futures Contracts (1,775)
Foreign Currencies 36
Change in Unrealized Appreciation (Depreciation) (261,612)
Net Increase (Decrease) in Net Assets Resulting from Operations (295,101)
1 Dividends are net of foreign withholding taxes of $2,401,000.
2 Realized gain (loss) is net of foreign capital gain taxes of $644,000.
3 The change in unrealized appreciation (depreciation) is net of the change in deferred foreign capital gains taxes of ($1,654,000).
  
See accompanying Notes, which are an integral part of the Financial Statements.
18

Emerging Markets Select Stock Fund
Statement of Changes in Net Assets
  Year Ended October 31,
  2022
($000)
2021
($000)
     
Increase (Decrease) in Net Assets    
Operations    
Net Investment Income 26,378 15,932
Realized Net Gain (Loss) (59,867) 57,460
Change in Unrealized Appreciation (Depreciation) (261,612) 77,997
Net Increase (Decrease) in Net Assets Resulting from Operations (295,101) 151,389
Distributions    
Total Distributions (59,107) (8,567)
Capital Share Transactions    
Issued 179,568 384,600
Issued in Lieu of Cash Distributions 50,609 7,584
Redeemed (220,976) (230,893)
Net Increase (Decrease) from Capital Share Transactions 9,201 161,291
Total Increase (Decrease) (345,007) 304,113
Net Assets    
Beginning of Period 974,409 670,296
End of Period 629,402 974,409
  
See accompanying Notes, which are an integral part of the Financial Statements.
19

Emerging Markets Select Stock Fund
Financial Highlights
For a Share Outstanding
Throughout Each Period 
Year Ended October 31,
2022 2021 2020 2019 2018
Net Asset Value, Beginning of Period $27.09 $22.18 $21.87 $19.68 $22.56
Investment Operations          
Net Investment Income1 .715 .457 .298 .4742 .414
Net Realized and Unrealized Gain (Loss) on Investments (8.724) 4.729 .483 2.208 (2.943)
Total from Investment Operations (8.009) 5.186 .781 2.682 (2.529)
Distributions          
Dividends from Net Investment Income (.486) (.276) (.471) (.492) (.351)
Distributions from Realized Capital Gains (1.175)
Total Distributions (1.661) (.276) (.471) (.492) (.351)
Net Asset Value, End of Period $17.42 $27.09 $22.18 $21.87 $19.68
Total Return3 -31.16% 23.44% 3.51% 13.96% -11.39%
Ratios/Supplemental Data          
Net Assets, End of Period (Millions) $629 $974 $670 $702 $564
Ratio of Total Expenses to Average Net Assets4 0.78% 0.84% 0.85% 0.93% 0.94%
Ratio of Net Investment Income to Average Net Assets 3.26% 1.65% 1.43% 2.25%2 1.85%
Portfolio Turnover Rate 41% 48% 52% 46% 76%
1 Calculated based on average shares outstanding.
2 Net investment income per share and the ratio of net investment income to average net assets include $0.071 and 0.34%, respectively, resulting from a special dividend from Naspers Ltd. in September 2019.
3 Total returns do not include account service fees that may have applied in the periods shown. Fund prospectuses provide information about any applicable account service fees.
4 Includes performance-based investment advisory fee increases (decreases) of (0.04%), 0.02%, (0.01%), 0.07%, and 0.05%.
  
See accompanying Notes, which are an integral part of the Financial Statements.
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Emerging Markets Select Stock Fund
Notes to Financial Statements
Vanguard Emerging Markets Select Stock Fund is registered under the Investment Company Act of 1940 as an open-end investment company, or mutual fund.
The fund invests in securities of foreign issuers, which may subject it to investment risks not normally associated with investing in securities of U.S. corporations. Significant market disruptions, such as those caused by pandemics (e.g., COVID-19 pandemic), natural or environmental disasters, war (e.g., Russia’s invasion of Ukraine), acts of terrorism, or other events, can adversely affect local and global markets and normal market operations. Any such disruptions could have an adverse impact on the value of the fund’s investments and fund performance.
A. The following significant accounting policies conform to generally accepted accounting principles for U.S. investment companies. The fund consistently follows such policies in preparing its financial statements.
1. Security Valuation: Securities are valued as of the close of trading on the New York Stock Exchange (generally 4 p.m., Eastern time) on the valuation date. Equity securities are valued at the latest quoted sales prices or official closing prices taken from the primary market in which each security trades; such securities not traded on the valuation date are valued at the mean of the latest quoted bid and asked prices. Securities for which market quotations are not readily available, or whose values have been affected by events occurring before the fund’s pricing time but after the close of the securities’ primary markets, are valued by methods deemed by the valuation designee to represent fair value and subject to oversight by the board of trustees. These procedures include obtaining quotations from an independent pricing service, monitoring news to identify significant market- or security-specific events, and evaluating changes in the values of foreign market proxies (for example, ADRs, futures contracts, or exchange-traded funds), between the time the foreign markets close and the fund’s pricing time. When fair-value pricing is employed, the prices of securities used by a fund to calculate its net asset value may differ from quoted or published prices for the same securities. Investments in Vanguard Market Liquidity Fund are valued at that fund's net asset value. Temporary cash investments are valued using the latest bid prices or using valuations based on a matrix system (which considers such factors as security prices, yields, maturities, and ratings), both as furnished by independent pricing services.
2. Foreign Currency: Securities and other assets and liabilities denominated in foreign currencies are translated into U.S. dollars using exchange rates obtained from an independent third party as of the fund’s pricing time on the valuation date. Realized gains (losses) and unrealized appreciation (depreciation) on investment securities include the effects of changes in exchange rates since the securities were purchased, combined with the effects of changes in security prices. Fluctuations in the value of other assets and liabilities resulting from changes in exchange rates are recorded as unrealized foreign currency gains (losses) until the assets or liabilities are settled in cash, at which time they are recorded as realized foreign currency gains (losses).
3. Futures Contracts: The fund uses index futures contracts to a limited extent, with the objective of maintaining full exposure to the stock market while maintaining liquidity. The fund may purchase or sell futures contracts to achieve a desired level of investment, whether to accommodate portfolio turnover or cash flows from capital share transactions. The primary risks associated with the use of futures contracts are imperfect correlation between changes in market values of stocks held by the fund and the prices of futures contracts, and the possibility of an illiquid market. Counterparty risk involving futures is mitigated because a regulated clearinghouse is the counterparty instead of the clearing broker. To further mitigate counterparty risk, the fund trades futures contracts on an exchange, monitors the financial strength of its clearing brokers and
21

Emerging Markets Select Stock Fund
clearinghouse, and has entered into clearing agreements with its clearing brokers. The clearinghouse imposes initial margin requirements to secure the fund’s performance and requires daily settlement of variation margin representing changes in the market value of each contract. Any securities pledged as initial margin for open contracts are noted in the Schedule of Investments.
Futures contracts are valued at their quoted daily settlement prices. The notional amounts of the contracts are not recorded in the Statement of Assets and Liabilities. Fluctuations in the value of the contracts are recorded in the Statement of Assets and Liabilities as an asset (liability) and in the Statement of Operations as unrealized appreciation (depreciation) until the contracts are closed, when they are recorded as realized gains (losses) on futures contracts.
During the year ended October 31, 2022, the fund’s average investments in long and short futures contracts represented 4% and 0% of net assets, respectively, based on the average of the notional amounts at each quarter-end during the period.
4. Forward Currency Contracts: The fund enters into forward currency contracts to protect the value of securities and related receivables and payables against changes in future foreign exchange rates. The fund’s risks in using these contracts include movement in the values of the foreign currencies relative to the U.S. dollar and the ability of the counterparties to fulfill their obligations under the contracts. The fund mitigates its counterparty risk by entering into forward currency contracts only with a diverse group of prequalified counterparties, monitoring their financial strength, entering into master netting arrangements with its counterparties, and requiring its counterparties to transfer collateral as security for their performance. In the absence of a default, the collateral pledged or received by the fund cannot be repledged, resold, or rehypothecated. The master netting arrangements provide that, in the event of a counterparty’s default (including bankruptcy), the fund may terminate the forward currency contracts, determine the net amount owed by either party in accordance with its master netting arrangements, and sell or retain any collateral held up to the net amount owed to the fund under the master netting arrangements. The forward currency contracts contain provisions whereby a counterparty may terminate open contracts if the fund’s net assets decline below a certain level, triggering a payment by the fund if the fund is in a net liability position at the time of the termination. The payment amount would be reduced by any collateral the fund has pledged. Any securities pledged as collateral for open contracts are noted in the Schedule of Investments. The value of collateral received or pledged is compared daily to the value of the forward currency contracts exposure with each counterparty, and any difference, if in excess of a specified minimum transfer amount, is adjusted and settled within two business days.
Forward currency contracts are valued at their quoted daily prices obtained from an independent third party, adjusted for currency risk based on the expiration date of each contract. The notional amounts of the contracts are not recorded in the Statement of Assets and Liabilities. Fluctuations in the value of the contracts are recorded in the Statement of Assets and Liabilities as an asset (liability) and in the Statement of Operations as unrealized appreciation (depreciation) until the contracts are closed, when they are recorded as realized gains (losses) on forward currency contracts.
During the year ended October 31, 2022, the fund’s average investment in forward currency contracts represented less than 1% of net assets, based on the average of the notional amounts at each quarter-end during the period. The fund had no open forward currency contracts at October 31, 2022.
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Emerging Markets Select Stock Fund
5. Federal Income Taxes: The fund intends to continue to qualify as a regulated investment company and distribute virtually all of its taxable income. The fund’s tax returns are open to examination by the relevant tax authorities until expiration of the applicable statute of limitations, which is generally three years after the filing of the tax return. Management has analyzed the fund’s tax positions taken for all open federal and state income tax years, and has concluded that no provision for income tax is required in the fund’s financial statements.
6. Distributions: Distributions to shareholders are recorded on the ex-dividend date. Distributions are determined on a tax basis at the fiscal year-end and may differ from net investment income and realized capital gains for financial reporting purposes.
7. Securities Lending: To earn additional income, the fund lends its securities to qualified institutional borrowers. Security loans are subject to termination by the fund at any time, and are required to be secured at all times by collateral in an amount at least equal to the market value of securities loaned. Daily market fluctuations could cause the value of loaned securities to be more or less than the value of the collateral received. When this occurs, the collateral is adjusted and settled before the opening of the market on the next business day. The fund further mitigates its counterparty risk by entering into securities lending transactions only with a diverse group of prequalified counterparties, monitoring their financial strength, and entering into master securities lending agreements with its counterparties. The master securities lending agreements provide that, in the event of a counterparty’s default (including bankruptcy), the fund may terminate any loans with that borrower, determine the net amount owed, and sell or retain the collateral up to the net amount owed to the fund; however, such actions may be subject to legal proceedings. While collateral mitigates counterparty risk, in the event of a default, the fund may experience delays and costs in recovering the securities loaned. The fund invests cash collateral received in Vanguard Market Liquidity Fund, and records a liability in the Statement of Assets and Liabilities for the return of the collateral, during the period the securities are on loan. Collateral investments in Vanguard Market Liquidity Fund are subject to market appreciation or depreciation. Securities lending income represents fees charged to borrowers plus income earned on invested cash collateral, less expenses associated with the loan. During the term of the loan, the fund is entitled to all distributions made on or in respect of the loaned securities.
8. Credit Facilities and Interfund Lending Program: The fund and certain other funds managed by The Vanguard Group ("Vanguard") participate in a $4.4 billion committed credit facility provided by a syndicate of lenders pursuant to a credit agreement and an uncommitted credit facility provided by Vanguard. Both facilities may be renewed annually. Each fund is individually liable for its borrowings, if any, under the credit facilities. Borrowings may be utilized for temporary or emergency purposes and are subject to the fund’s regulatory and contractual borrowing restrictions. With respect to the committed credit facility, the participating funds are charged administrative fees and an annual commitment fee of 0.10% of the undrawn committed amount of the facility, which are allocated to the funds based on a method approved by the fund’s board of trustees and included in Management and Administrative expenses on the fund’s Statement of Operations. Any borrowings under either facility bear interest at an agreed-upon spread plus the higher of the federal funds effective rate, the overnight bank funding rate, or the Daily Simple Secured Overnight Financing Rate inclusive of an additional agreed-upon spread. However, borrowings under the uncommitted credit facility may bear interest based upon an alternate rate agreed to by the fund and Vanguard.
In accordance with an exemptive order (the “Order”) from the SEC, the fund may participate in a joint lending and borrowing program that allows registered open-end Vanguard funds to borrow
23

Emerging Markets Select Stock Fund
money from and lend money to each other for temporary or emergency purposes (the “Interfund Lending Program”), subject to compliance with the terms and conditions of the Order, and to the extent permitted by the fund’s investment objective and investment policies. Interfund loans and borrowings normally extend overnight but can have a maximum duration of seven days. Loans may be called on one business day’s notice. The interest rate to be charged is governed by the conditions of the Order and internal procedures adopted by the board of trustees. The board of trustees is responsible for overseeing the Interfund Lending Program.
For the year ended October 31, 2022, the fund did not utilize the credit facilities or the Interfund Lending Program.
9. Other: Dividend income is recorded on the ex-dividend date. Non-cash dividends included in income, if any, are recorded at the fair value of the securities received. Interest income includes income distributions received from Vanguard Market Liquidity Fund and is accrued daily. Premiums and discounts on debt securities are amortized and accreted, respectively, to interest income over the lives of the respective securities, except for premiums on certain callable debt securities that are amortized to the earliest call date. Security transactions are accounted for on the date securities are bought or sold. Costs used to determine realized gains (losses) on the sale of investment securities are those of the specific securities sold.
Taxes on foreign dividends and capital gains have been provided for in accordance with the fund’s understanding of the applicable countries’ tax rules and rates. Deferred foreign capital gains tax, if any, is accrued daily based upon net unrealized gains.
B. The investment advisory firms Wellington Management Company llp, Baillie Gifford Overseas Ltd., Oaktree Fund Advisors, LLC, and Pzena Investment Management, LLC, each provide investment advisory services to a portion of the fund for a fee calculated at an annual percentage rate of average net assets managed by the advisor. The basic fees of Wellington Management Company llp, Baillie Gifford Overseas Ltd., Oaktree Fund Advisors, LLC, and Pzena Investment Management, LLC are subject to quarterly adjustments based on performance relative to the FTSE Emerging Index for the preceding three years.
Vanguard manages the cash reserves of the fund as described below.
For the year ended October 31, 2022, the aggregate investment advisory fee paid to all advisors represented an effective annual basic rate of 0.52% of the fund’s average net assets, before a net decrease of $315,000 (0.04%) based on performance.
C. In accordance with the terms of a Funds' Service Agreement (the “FSA”) between Vanguard and the fund, Vanguard furnishes to the fund corporate management, administrative, marketing, distribution and cash management services at Vanguard’s cost of operations (as defined by the FSA). These costs of operations are allocated to the fund based on methods and guidelines approved by the board of trustees and are generally settled twice a month.
Upon the request of Vanguard, the fund may invest up to 0.40% of its net assets as capital in Vanguard. At October 31, 2022, the fund had contributed to Vanguard capital in the amount of $26,000, representing less than 0.01% of the fund’s net assets and 0.01% of Vanguard’s capital received pursuant to the FSA. The fund’s trustees and officers are also directors and employees, respectively, of Vanguard.
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Emerging Markets Select Stock Fund
D. Various inputs may be used to determine the value of the fund’s investments and derivatives. These inputs are summarized in three broad levels for financial statement purposes. The inputs or methodologies used to value securities are not necessarily an indication of the risk associated with investing in those securities.
Level 1—Quoted prices in active markets for identical securities.
Level 2—Other significant observable inputs (including quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.).
Level 3—Significant unobservable inputs (including the fund’s own assumptions used to determine the fair value of investments). Any investments and derivatives valued with significant unobservable inputs are noted on the Schedule of Investments.
The following table summarizes the market value of the fund’s investments and derivatives as of October 31, 2022, based on the inputs used to value them:
  Level 1
($000)
Level 2
($000)
Level 3
($000)
Total
($000)
Investments        
Assets        
Common Stocks—North and South America 124,180 124,180
Common Stocks—Other 26,971 448,794 475,765
Temporary Cash Investments 27,141 27,141
Total 178,292 448,794 627,086
Derivative Financial Instruments        
Liabilities        
Futures Contracts1 2,014 2,014
1 Includes cumulative appreciation (depreciation) on futures contracts and centrally cleared swaps, if any, as reported in the Schedule of Investments. Only current day’s variation margin is reported within the Statement of Assets and Liabilities.
E. At October 31, 2022, the fair values of derivatives were reflected in the Statement of Assets and Liabilities as follows:
    
Statement of Assets and Liabilities Equity
Contracts
($000)
Foreign
Exchange
Contracts
($000)
Total
($000)
Unrealized Depreciation—Futures Contracts1 2,014 2,014
1 Includes cumulative appreciation (depreciation) on futures contracts and centrally cleared swaps, if any, as reported in the Schedule of Investments. Only current day’s variation margin is reported within the Statement of Assets and Liabilities.
Realized net gain (loss) and the change in unrealized appreciation (depreciation) on derivatives for the year ended October 31, 2022, were:
Realized Net Gain (Loss) on Derivatives Equity
Contracts
($000)
Foreign
Exchange
Contracts
($000)
Total
($000)
Futures Contracts (10,831) (10,831)
Forward Currency Contracts (18) (18)
Realized Net Gain (Loss) on Derivatives (10,831) (18) (10,849)
25

Emerging Markets Select Stock Fund
  Equity
Contracts
($000)
Foreign
Exchange
Contracts
($000)
Total
($000)
Change in Unrealized Appreciation (Depreciation) on Derivatives
Futures Contracts (1,775) (1,775)
F. Permanent differences between book-basis and tax-basis components of net assets are reclassified among capital accounts in the financial statements to reflect their tax character. These reclassifications have no effect on net assets or net asset value per share. As of period end, permanent differences primarily attributable to the accounting for applicable foreign currency transactions, passive foreign investment companies, and tax expense on capital gains were reclassified between the individual components of total distributable earnings (loss).
Temporary differences between book-basis and tax-basis components of total distributable earnings (loss) arise when certain items of income, gain, or loss are recognized in different periods for financial statement and tax purposes; these differences will reverse at some time in the future. The differences are primarily related to the deferral of losses from wash sales; the recognition of unrealized gains or losses from certain derivative contracts; and the recognition of unrealized gains from passive foreign investment companies. As of period end, the tax-basis components of total distributable earnings (loss) are detailed in the table as follows:
  Amount
($000)
Undistributed Ordinary Income 21,737
Undistributed Long-Term Gains
Capital Loss Carryforwards (52,483)
Qualified Late-Year Losses
Net Unrealized Gains (Losses) (128,932)
The tax character of distributions paid was as follows:
  Year Ended October 31,
  2022
Amount
($000)
2021
Amount
($000)
Ordinary Income* 32,782 8,567
Long-Term Capital Gains 26,325
Total 59,107 8,567
* Includes short-term capital gains, if any.
As of October 31, 2022, gross unrealized appreciation and depreciation for investments and derivatives based on cost for U.S. federal income tax purposes were as follows:
  Amount
($000)
Tax Cost 754,528
Gross Unrealized Appreciation 82,789
Gross Unrealized Depreciation (210,232)
Net Unrealized Appreciation (Depreciation) (127,443)
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Emerging Markets Select Stock Fund
G. During the year ended October 31, 2022, the fund purchased $307,393,000 of investment securities and sold $317,198,000 of investment securities, other than temporary cash investments.
H. Capital shares issued and redeemed were:
    
  Year Ended October 31,
  2022
Shares
(000)
2021
Shares
(000)
     
Issued 8,139 13,807
Issued in Lieu of Cash Distributions 2,150 294
Redeemed (10,131) (8,359)
Net Increase (Decrease) in Shares Outstanding 158 5,742
I. Transactions during the period in investments where the issuer is another member of The Vanguard Group were as follows:
    Current Period Transactions  
  Oct. 31,
2021
Market
Value
($000)
Purchases
at Cost
($000)
Proceeds
from
Securities
Sold
($000)
Realized
Net
Gain
(Loss)
($000)
Change in
Unrealized
App. (Dep.)
($000)
Income
($000)
Capital Gain
Distributions
Received
($000)
Oct. 31,
2022
Market
Value
($000)
Vanguard FTSE Emerging Markets ETF 1,764 15,842 10,522 (536) (1,206) 169 5,342
Vanguard Market Liquidity Fund 59,595 NA1 NA1 (12) 1 384 1 27,141
Total 61,359 15,842 10,522 (548) (1,205) 553 1 32,483
1 Not applicable—purchases and sales are for temporary cash investment purposes.
J. Management has determined that no events or transactions occurred subsequent to October 31, 2022, that would require recognition or disclosure in these financial statements.
27

Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Vanguard Trustees' Equity Fund and Shareholders of Vanguard Emerging Markets Select Stock Fund
Opinion on the Financial Statements
We have audited the accompanying statement of assets and liabilities, including the schedule of investments, of Vanguard Emerging Markets Select Stock Fund (one of the funds constituting Vanguard Trustees' Equity Fund, referred to hereafter as the "Fund") as of October 31, 2022, the related statement of operations for the year ended October 31, 2022, the statement of changes in net assets for each of the two years in the period ended October 31, 2022, including the related notes, and the financial highlights for each of the five years in the period ended October 31, 2022 (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Fund as of October 31, 2022, the results of its operations for the year then ended, the changes in its net assets for each of the two years in the period ended October 31, 2022 and the financial highlights for each of the five years in the period ended October 31, 2022 in conformity with accounting principles generally accepted in the United States of America.
Basis for Opinion
These financial statements are the responsibility of the Fund’s management. Our responsibility is to express an opinion on the Fund’s financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Fund in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.
We conducted our audits of these financial statements in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud.
Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. Our procedures included confirmation of securities owned as of October 31, 2022 by correspondence with the custodian, transfer agent and brokers; when replies were not received from brokers, we performed other auditing procedures. We believe that our audits provide a reasonable basis for our opinion.
/s/PricewaterhouseCoopers LLP
Philadelphia, Pennsylvania
December 16, 2022
We have served as the auditor of one or more investment companies in The Vanguard Group of Funds since 1975.
28


Tax information (unaudited)
The fund hereby designates $12,675,000, or if subsequently determined to be different, the maximum amount allowable by law, as qualified dividend income for individual shareholders for the fiscal year.
The fund hereby designates $111,000, or if subsequently determined to be different, the maximum amount allowable by law, of interest earned from obligations of the U.S. government which is generally exempt from state income tax.
For nonresident alien shareholders, 100% of short-term capital gain dividends distributed by the fund for the fiscal year are qualified short-term capital gains.
The fund distributed $26,325,000 as capital gain dividends (20% rate gain distributions) to shareholders during the fiscal year.
The fund designates to shareholders foreign source income of $34,364,000 and foreign taxes paid of $2,784,000, or if subsequently determined to be different, the maximum amounts allowable by law. Shareholders will receive more detailed information with their Form 1099-DIV to determine the calendar-year amounts to be included on their tax returns.
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The People Who Govern Your Fund
The trustees of your mutual fund are there to see that the fund is operated and managed in your best interests since, as a shareholder, you are a part owner of the fund. Your fund’s trustees also serve on the board of directors of The Vanguard Group, Inc., which is owned by the Vanguard funds and provides services to them. 
A majority of Vanguard’s board members are independent, meaning that they have no affiliation with Vanguard or the funds they oversee, apart from the sizable personal investments they have made as private individuals. The independent board members have distinguished backgrounds in business, academia, and public service. Each of the trustees and executive officers oversees 206 Vanguard funds.
Information for each trustee and executive officer of the fund appears below. That information, as well as the Vanguard fund count, is as of the date on the cover of this fund report. The mailing address of the trustees and officers is P.O. Box 876, Valley Forge, PA 19482. More information about the trustees is in the Statement of Additional Information, which can be obtained, without charge, by contacting Vanguard at 800-662-7447, or online at vanguard.com.
Interested Trustee1
Mortimer J. Buckley
Born in 1969. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: chairman of the board (2019–present) of Vanguard and of each of the investment companies served by Vanguard; chief executive officer (2018–present) of Vanguard; chief executive officer, president, and trustee (2018–present) of each of the investment companies served by Vanguard; president and director (2017–present) of Vanguard; and president (2018–present) of Vanguard Marketing Corporation. Chief investment officer (2013–2017), managing director (2002–2017), head of the Retail Investor Group (2006–2012), and chief information officer (2001–2006) of Vanguard. Member of the board of governors of the Investment Company Institute and the board of governors of FINRA. Trustee and vice chair of The Shipley School.
Independent Trustees
Tara Bunch
Born in 1962. Trustee since November 2021. Principal occupation(s) during the past five years and other experience: head of global operations at Airbnb (2020–present). Vice president of AppleCare (2012–2020). Member of the board of directors of Out & Equal (2002–2006), the advisory board of the University of California, Berkeley School of Engineering (2020–present), and the advisory board
of Santa Clara University’s Leavey School of Business (2018–present).
Emerson U. Fullwood
Born in 1948. Trustee since January 2008. Principal occupation(s) during the past five years and other experience: executive chief staff and marketing officer for North America and corporate vice president (retired 2008) of Xerox Corporation (document management products and services). Former president of the Worldwide Channels Group, Latin America, and Worldwide Customer Service and executive chief staff officer of Developing Markets of Xerox. Executive in residence and 2009–2010 Distinguished Minett Professor at the Rochester Institute of Technology. Member of the board of directors of the University of Rochester Medical Center, the Monroe Community College Foundation, the United Way of Rochester, North Carolina A&T University, Roberts Wesleyan College, and the Rochester Philharmonic Orchestra. Trustee of the University of Rochester.                       
F. Joseph Loughrey
Born in 1949. Trustee since October 2009. Principal occupation(s) during the past five years and other experience: president and chief operating officer (retired 2009) and vice chairman of the board (2008–2009) of Cummins Inc. (industrial machinery). Chairman of the board of Hillenbrand, Inc. (specialized consumer services). Director of the V Foundation. Member of the advisory council for the College of
 
1  Mr. Buckley is considered an “interested person,” as defined in the Investment Company Act of 1940, because he is an officer of the Vanguard funds.

Arts and Letters at the University of Notre Dame. Chairman of the board of Saint Anselm College.
Mark Loughridge
Born in 1953. Trustee since March 2012. Principal occupation(s) during the past five years and other experience: senior vice president and chief financial officer (retired 2013) of IBM (information technology services). Fiduciary member of IBM’s Retirement Plan Committee (2004–2013), senior vice president and general manager (2002–2004) of IBM Global Financing, vice president and controller (1998–2002) of IBM, and a variety of other prior management roles at IBM. Member of the Council on Chicago Booth.
Scott C. Malpass
Born in 1962. Trustee since March 2012. Principal occupation(s) during the past five years and other experience: adjunct professor of finance at the University of Notre Dame (2020–present). Chief investment officer (retired 2020) and vice president (retired 2020) of the University of Notre Dame. Assistant professor (retired June 2020) of finance at the Mendoza College of Business, University of Notre Dame, and member of the Notre Dame 403(b) Investment Committee. Member of the board of Catholic Investment Services, Inc. (investment advisors), the board of superintendence of the Institute for the Works of Religion, and the board of directors of Paxos Trust Company (finance).
Deanna Mulligan
Born in 1963. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: chief executive officer of Purposeful (advisory firm for CEOs and C-level executives; 2021–present). Board chair (2020), chief executive officer (2011–2020), and president (2010–2019) of The Guardian Life Insurance Company of America. Chief operating officer (2010–2011) and executive vice president (2008–2010) of Individual Life and Disability of the Guardian Life Insurance Company of America. Member of the board of the Economic Club of New York. Trustee of the Partnership for New York City (business leadership), Chief Executives for Corporate Purpose, and the NewYork-Presbyterian Hospital.
André F. Perold
Born in 1952. Trustee since December 2004. Principal occupation(s) during the past five years and other experience: George Gund Professor of Finance and Banking, Emeritus at the Harvard Business School (retired 2011). Chief investment officer and co-managing partner of HighVista Strategies (private investment firm). Member of the board (2018–present) of RIT Capital Partners (investment
firm). Member of the investment committee of Partners Health Care System.
Sarah Bloom Raskin
Born in 1961. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: deputy secretary (2014–2017) of the United States Department of the Treasury. Governor (2010–2014) of the Federal Reserve Board. Commissioner (2007–2010) of financial regulation for the State of Maryland. Colin W. Brown Distinguished Professor of the Practice of Law (2021–present), professor (2020–present), Distinguished Fellow of the Global Financial Markets Center (2020–present), and Rubenstein Fellow (2017–2020) at Duke University. Trustee (2017–present) of Amherst College and member of Amherst College Investment Committee (2019–present). Member of the Regenerative Crisis Response Committee (2020–present).
David A. Thomas
Born in 1956. Trustee since July 2021. Principal occupation(s) during the past five years and other experience: president of Morehouse College (2018–present). Professor of business administration, emeritus at Harvard University (2017–2018). Dean (2011–2016) and professor of management (2016–2017) at the Georgetown University McDonough School of Business. Director of DTE Energy Company (2013–present). Trustee of Common Fund (2019–present).
Peter F. Volanakis
Born in 1955. Trustee since July 2009. Principal occupation(s) during the past five years and other experience: president and chief operating officer (retired 2010) of Corning Incorporated (communications equipment) and director of Corning Incorporated (2000–2010) and Dow Corning (2001–2010). Director (2012) of SPX Corporation (multi-industry manufacturing). Overseer of the Amos Tuck School of Business Administration, Dartmouth College (2001–2013). Member of the BMW Group Mobility Council.

Executive Officers
Christine M. Buchanan
Born in 1970. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Chief financial officer (2021–present) and treasurer (2017–present) of each of the investment companies served by Vanguard. Partner (2005–2017) at KPMG (audit, tax, and advisory services).
John Galloway
Born in 1973. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Investment stewardship officer (September 2020–present) of each of the investment companies served by Vanguard. Head of Investor Advocacy (February 2020–present) and head of Marketing Strategy and Planning (2017–2020) at Vanguard. Special assistant to the President of the United States (2015).
Ashley Grim
Born in 1984. Principal occupation(s) during the past five years and other experience: treasurer (February 2022–present) of each of the investment companies served by Vanguard. Fund transfer agent controller (2019–2022) and director of Audit Services (2017–2019) at Vanguard. Senior manager (2015–2017) at PriceWaterhouseCoopers (audit and assurance, consulting, and tax services).
Peter Mahoney
Born in 1974. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Controller (2015–present) of each of the investment companies served by Vanguard. Head of International Fund Services (2008–2014) at Vanguard.
Anne E. Robinson
Born in 1970. Principal occupation(s) during the past five years and other experience: general counsel (2016–present) of Vanguard. Secretary (2016–present) of Vanguard and of each of the investment companies served by Vanguard. Managing director (2016–present) of Vanguard. Managing director and general counsel of Global Cards and Consumer Services (2014–2016) at Citigroup. Counsel (2003–2014) at American Express. Nonexecutive director of the board of National Grid (energy).
Michael Rollings
Born in 1963. Principal occupation(s) during the past five years and other experience: finance director (2017–present) and treasurer (2017) of each of the investment companies served by Vanguard. Managing director (2016–present) of Vanguard. Chief financial officer (2016–present) of Vanguard. Director (2016–present) of Vanguard Marketing Corporation. Executive vice president and chief financial officer (2006–2016) of MassMutual Financial Group.
John E. Schadl
Born in 1972. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Chief compliance officer (2019–present) of Vanguard and of each of the investment companies served by Vanguard. Assistant vice president (2019–present) of Vanguard Marketing Corporation.
Vanguard Senior Management Team
Matthew Benchener Thomas M. Rampulla
Joseph Brennan Karin A. Risi
Mortimer J. Buckley Anne E. Robinson
Gregory Davis Michael Rollings
John James Nitin Tandon
Chris D. Mclsaac Lauren Valente

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Q7520 122022
Annual Report   |   October 31, 2022
Vanguard Alternative Strategies Fund

Contents
Your Fund’s Performance at a Glance

1
Advisor's Report

2
About Your Fund’s Expenses

5
Performance Summary

7
Consolidated Financial Statements

9
Please note: The opinions expressed in this report are just that—informed opinions. They should not be considered promises or advice. Also, please keep in mind that the information and opinions cover the period through the date on the front of this report. Of course, the risks of investing in your fund are spelled out in the prospectus.

Your Fund’s Performance at a Glance
Vanguard Alternative Strategies Fund returned 2.38% for the 12 months ended October 31, 2022. Its benchmark, the FTSE 3-Month Treasury Bill Index, returned 0.88%.
The fund seeks to generate returns using a combination of alternative strategies that collectively are expected to have low correlation with traditional capital markets. These strategies are long/short equity, event-driven, fixed income relative value, currencies, equity futures, and commodity-linked investments.
Five of the six strategies contributed to returns for the 12-month period. Fixed income relative value was the sole detractor, hurt by a focus on longer-duration issues, which suffered during a rising interest rate environment.
The diversification resulting from the fund’s variety of exposures helped reduce overall volatility compared with the broad U.S. stock market.
The fund regularly uses derivatives to hedge portfolio risks. Its holdings in forward foreign currencies and futures contributed to total returns.
Market Barometer
  Average Annual Total Returns
Periods Ended October 31, 2022
  One Year Three Years Five Years
Stocks      
Russell 1000 Index (Large-caps) -16.38% 9.99% 10.19%
Russell 2000 Index (Small-caps) -18.54 7.05 5.56
Russell 3000 Index (Broad U.S. market) -16.52 9.79 9.87
FTSE All-World ex US Index (International) -24.20 -1.16 -0.18
Bonds      
Bloomberg U.S. Aggregate Float Adjusted Index
(Broad taxable market)
-15.69% -3.73% -0.50%
Bloomberg Municipal Bond Index
(Broad tax-exempt market)
-11.98 -2.18 0.37
FTSE Three-Month U.S. Treasury Bill Index 0.88 0.59 1.15
CPI      
Consumer Price Index 7.75% 5.01% 3.85%
1

Advisor’s Report
For the 12 months ended October 31, 2022, Vanguard Alternative Strategies Fund returned 2.38%. The fund outpaced its benchmark, the FTSE 3-Month Treasury Bill Index, which returned 0.88%.
Investment objective and strategy
The Alternative Strategies Fund seeks both capital appreciation and low correlations with the returns of stock and bond markets. We target a fixed range of volatility and expect to produce a portfolio with lower volatility than that of the broader U.S. stock market. The range of volatility may change from time to time. In determining it, we consider the risk levels of our individual strategies, the composition of the portfolio, and market conditions.
To achieve our objectives, we combine six alternative investment strategies that span multiple asset classes: equities, fixed income, currencies, and commodities. Each strategy can use long and short positions to try to minimize market exposure while attempting to capture attractive risk premiums. Individually, the strategies are expected to have low long-term correlation with one another and with traditional capital markets.
In addition, the fund can use limited amounts of leverage as it seeks to match the expected risk profile for each strategy. The goal is to achieve a similar risk profile across the portfolio to maximize diversification and performance.
The strategies the fund currently employs are:
Long/short equity. This approach focuses on building a long/short portfolio of equity securities based on their volatility characteristics by executing long positions in low-volatility stocks and short positions in high-volatility stocks. It seeks to capture a risk-adjusted spread by constructing positions to reduce the net market exposure of the overall portfolio to general market movements (beta).
Event-driven. This strategy seeks to profit from the expectation that a specific event or catalyst (such as a merger/acquisition deal closure) will affect the stock price of a U.S. or foreign company.
Fixed income relative value. This approach seeks to exploit the steepness of the U.S. Treasury yield curve that is created by investors’ desire to hold shorter-maturity bonds because they tend to be more liquid (easily traded) and less sensitive to growth and inflation risk. We try to capture this premium by investing in Treasury futures with longer times to maturity and borrowing those with short maturities.
Currencies. The fund seeks to benefit from expected currency movements by using long and short foreign currency exchange forward contracts. It does this by selling currencies of countries with poor fundamental characteristics and buying those of countries with strong ones.
 
2

Commodity-linked investments. This strategy seeks to capture the risk premium associated with inventory levels of commodities, which are reflected in the prices of their futures contracts. We take long positions in commodities whose prices are expected to rise because of limited inventory and short positions in those whose prices are expected to fall.
Equity futures. The fund uses long and short positions in global equity index futures to capture excess return opportunities. The strategy seeks to benefit from global differences in market and fundamental characteristics by buying equity index futures with strong characteristics and selling those with poor characteristics.
Investment environment
The economic backdrop deteriorated as inflation soared to multidecade highs, fueled in part by higher energy and food prices in the wake of Russia’s invasion of Ukraine. Then price increases broadened to other categories of goods and services, adding to concerns that inflation would remain stubbornly high. That prompted aggressive tightening by many central banks to bring inflation back in check and increased fears of a recession.
Within the U.S., the Federal Reserve raised interest rates six times during the year (the most recent increase was announced on November 2, right after the end of the fund’s fiscal year) and committed to further hikes until they’re “sufficiently restrictive” to quell inflation.
In this environment, there were few safe havens for investors. For the 12-month period, both stock and bond markets around the world experienced significant losses.
Successes and shortfalls
Five of the six strategies contributed to returns for the 12-month period. Our long/short equity holdings responded well to our selected combination of low-volatility, high-dividend-paying stocks (on the long end) and highly cyclical and speculative stocks (on the short end). Equity futures benefited from global dividend harvesting. In the commodity-linked investments strategy, we selectively overweighted commodities in short supply while underweighting those available in ample quantities.
The currency strategy allowed us to benefit from the interest rate differentials between currencies, particularly as central banks pushed through rate hikes. (This led to the most attractive carry environment we’ve experienced in many years.) Finally, event-driven performance reflected a combination of benign conditions in the credit market and our selection of lower-yield, close-to-maturity securities.
Our fixed income relative value strategy was the sole detractor, hurt by our focus on longer-duration issues, which suffered during a rising interest rate environment.
Despite heightened uncertainty, the diversification resulting from the fund’s variety of exposures helped reduce overall volatility compared with that of the broad stock market. The correlations of the
3

fund’s daily returns with the equity markets fell to 0.02, compared with 0.15 over the previous 12 months. Fixed income markets were held back by the uncertain interest rate environment and, as a result, had a higher correlation with the fund.
Although markets can be unpredictable, we are confident that our team of experienced managers and analysts can find opportunities to produce competitive returns over the long term at volatility levels lower than those of the market.
Portfolio Manager:
Fei Xu, CFA, FRM
Vanguard Quantitative Equity Group
November 15, 2022
4

About Your Fund’s Expenses
As a shareholder of the fund, you incur ongoing costs, which include costs for portfolio management, administrative services, and shareholder reports (like this one), among others. Operating expenses, which are deducted from a fund’s gross income, directly reduce the investment return of the fund.
A fund’s expenses are expressed as a percentage of its average net assets. This figure is known as the expense ratio. The following examples are intended to help you understand the ongoing costs (in dollars) of investing in your fund and to compare these costs with those of other mutual funds. The examples are based on an investment of $1,000 made at the beginning of the period shown and held for the entire period.
The accompanying table illustrates your fund’s costs in two ways:
Based on actual fund return. This section helps you to estimate the actual expenses that you paid over the period. The ”Ending Account Value“ shown is derived from the fund‘s actual return, and the third column shows the dollar amount that would have been paid by an investor who started with $1,000 in the fund. You may use the information here, together with the amount you invested, to estimate the expenses that you paid over the period.
To do so, simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number given for your fund under the heading ”Expenses Paid During Period.“
Based on hypothetical 5% yearly return. This section is intended to help you compare your fund‘s costs with those of other mutual funds. It assumes that the fund had a yearly return of 5% before expenses, but that the expense ratio is unchanged. In this case—because the return used is not the fund’s actual return—the results do not apply to your investment. The example is useful in making comparisons because the Securities and Exchange Commission requires all mutual funds to calculate expenses based on a 5% return. You can assess your fund’s costs by comparing this hypothetical example with the hypothetical examples that appear in shareholder reports of other funds.
Note that the expenses shown in the table are meant to highlight and help you compare ongoing costs only and do not reflect transaction costs incurred by the fund for buying and selling securities. Further, the expenses do not include any purchase, redemption, or account service fees described in the fund prospectus. If such fees were applied to your account, your costs would be higher. Your fund does not carry a “sales load.”
The calculations assume no shares were bought or sold during the period. Your actual costs may have been higher or lower, depending on the amount of your investment and the timing of any purchases or redemptions.
You can find more information about the fund’s expenses, including annual expense ratios, in the Consolidated Financial Statements section of this report. For additional information on operating expenses and other shareholder costs, please refer to your fund’s current prospectus.
5

Six Months Ended October 31, 2022      
Alternative Strategies Fund Beginning
Account Value
4/30/2022
Ending
Account Value
10/31/2022
Expenses
Paid During
Period
Based on Actual Fund Return $1,000.00 $1,007.70 $1.32
Based on Hypothetical 5% Yearly Return 1,000.00 1,023.90 1.33
The calculations are based on expenses incurred in the most recent six-month period. The fund’s annualized six-month expense ratio for that period is 0.26%. The dollar amounts shown as “Expenses Paid” are equal to the annualized expense ratio multiplied by the average account value over the period, multiplied by the number of days in the most recent six-month period, then divided by the number of days in the most recent 12-month period (184/365).
6

Alternative Strategies Fund
Performance Summary
All of the returns in this report represent past performance, which is not a guarantee of future results that may be achieved by the fund. (Current performance may be lower or higher than the performance data cited. For performance data current to the most recent month-end, visit our website at vanguard.com/performance.) Note, too, that both investment returns and principal value can fluctuate widely, so an investor’s shares, when sold, could be worth more or less than their original cost. The returns shown do not reflect taxes that a shareholder would pay on fund distributions or on the sale of fund shares.
Cumulative Performance: August 11, 2015, Through October 31, 2022
Initial Investment of $50,000
    Average Annual Total Returns
Periods Ended October 31, 2022
 
    One
Year
Five
Years
Since
Inception
(8/11/2015)
Final Value
of a $50,000
Investment
 Alternative Strategies Fund 2.38% -1.53% -0.13% $49,523
 Spliced Alternative Strategies Index 0.88 2.79 3.33 63,349
  FTSE Three-Month Treasury Bill Index 0.88 1.16 0.93 53,460
Spliced Alternative Strategies Index: FTSE 3-Month U.S. T-Bill Index + 4% through October 31, 2019; FTSE 3-Month Treasury Bill Index thereafter.
"Since Inception" performance is calculated from the fund’s inception date for both the fund and its comparative standard(s).
See Financial Highlights for dividend and capital gains information.
7

Alternative Strategies Fund
Fund Allocation
As of October 31, 2022
  Long
Portfolio1
Short
Portfolio2
Communication Services 4.8% 8.0%
Consumer Discretionary 12.2 16.0
Consumer Staples 6.4 1.1
Energy 8.3
Financials 7.0
Health Care 12.3 13.7
Industrials 12.8 11.7
Information Technology 26.0 34.8
Materials 5.1 2.8
Real Estate 7.7 1.8
Utilities 5.7 1.8
1 Percentage of investments in long portfolio.
2 Percentage of investments in short portfolio.
The table reflects the fund’s investments, except for short-term investments and derivatives. Sector categories are based on the Global Industry Classification Standard (“GICS”), except for the “Other” category (if applicable), which includes securities that have not been provided a GICS classification as of the effective reporting period.
Global Industry Classification Standard (“GICS”) was developed by and is the exclusive property and a service mark of MSCI Inc. (“MSCI”) and Standard and Poor’s, a division of McGraw-Hill Companies, Inc. (“S&P”), and is licensed for use by Vanguard. Neither MSCI, S&P nor any third party involved in making or compiling the GICS or any GICS classification makes any express or implied warranties or representations with respect to such standard or classification (or the results to be obtained by the use thereof), and all such parties hereby expressly disclaim all warranties of originality, accuracy, completeness, merchantability or fitness for a particular purpose with respect to any such standard or classification. Without limiting any of the foregoing, in no event shall MSCI, S&P, any of its affiliates or any third party involved in making or compiling the GICS or any GICS classification have any liability for any direct, indirect, special, punitive, consequential or any other damages (including lost profits) even if notified of the possibility of such damages.
8

Alternative Strategies Fund
Consolidated Financial Statements
Consolidated Schedule of Investments
As of October 31, 2022
The fund files its complete schedule of portfolio holdings with the Securities and Exchange Commission (SEC) for the first and third quarters of each fiscal year as an exhibit to its reports on Form N-PORT. The fund’s Form N-PORT reports are available on the SEC’s website at www.sec.gov.
    Shares Market
Value

($000)
Common Stocks—Long Positions (32.3%)
Communication Services (1.5%)
  TEGNA Inc.  35,000      731
1 Electronic Arts Inc.     906      114
1 Madison Square Garden Sports Corp.     668      105
  Sirius XM Holdings Inc.  17,354      105
* Liberty Media Corp.-Liberty Formula One Class C   1,757      101
1 Verizon Communications Inc.   2,446       91
1 Comcast Corp. Class A   2,631       84
* Alphabet Inc. Class A     860       81
*,1 Charter Communications Inc. Class A     183       67
*,1 Liberty Broadband Corp. Class C     777       66
         1,545
Consumer Discretionary (3.9%)
* iRobot Corp.  20,500    1,158
* Tenneco Inc. Class A  51,000    1,005
*,1 O'Reilly Automotive Inc.     151      126
1 Genuine Parts Co.     689      123
1 McDonald's Corp.     452      123
*,1 AutoZone Inc.      48      122
  Advance Auto Parts Inc.     615      117
  Darden Restaurants Inc.     810      116
1 Dollar General Corp.     442      113
1 Yum! Brands Inc.     929      110
  Lowe's Cos. Inc.     560      109
1 Starbucks Corp.   1,265      109
1 Wendy's Co.   5,108      106
1 Gentex Corp.   3,825      101
1 Service Corp. International   1,656      100
1 Home Depot Inc.     326       97
  Leggett & Platt Inc.   2,865       97
1 Columbia Sportswear Co.   1,200       89
         3,921
Consumer Staples (2.1%)
1 Flowers Foods Inc.   4,154      119
1 J M Smucker Co.     776      117
1 Mondelez International Inc. Class A   1,883      116
  Hershey Co.     483      115
  Kellogg Co.   1,491      115
1 PepsiCo Inc.     633      115
  Casey's General Stores Inc.     490      114
  General Mills Inc.   1,391      114
    Shares Market
Value

($000)
  Reynolds Consumer Products Inc.   3,730      114
  Keurig Dr Pepper Inc.   2,749      107
1 Coca-Cola Co.   1,762      105
1 Colgate-Palmolive Co.   1,400      103
1 Kimberly-Clark Corp.     823      102
1 Brown-Forman Corp. Class B   1,484      101
1 Altria Group Inc.   2,162      100
1 McCormick & Co. Inc.   1,269      100
1 Procter & Gamble Co.     726       98
1 Philip Morris International Inc.     982       90
1 Church & Dwight Co. Inc.   1,072       79
1 Archer-Daniels-Midland Co.     313       30
  Campbell Soup Co.     185       10
         2,064
Financials (2.3%)
  First Horizon Corp.  13,918      341
  Travelers Cos. Inc.     635      117
  Aflac Inc.   1,802      117
1 W R Berkley Corp.   1,548      115
*,1 Berkshire Hathaway Inc. Class B     390      115
1 Arthur J Gallagher & Co.     606      113
1 Hanover Insurance Group Inc.     764      112
1 White Mountains Insurance Group Ltd.      79      112
1 Marsh & McLennan Cos. Inc.     672      109
  Cboe Global Markets Inc.     870      108
  Nasdaq Inc.   1,739      108
  Starwood Property Trust Inc.   5,092      105
1 CNA Financial Corp.   2,472      103
1 TFS Financial Corp.   6,660       94
  Moody's Corp.     327       87
  Assurant Inc.     615       84
1 Intercontinental Exchange Inc.     836       80
  Chubb Ltd.     349       75
1 Annaly Capital Management Inc.   3,828       71
1 AGNC Investment Corp.   7,713       63
* Markel Corp.      10       12
1 Allstate Corp.      83       11
  Willis Towers Watson plc      45       10
         2,262
Health Care (4.0%)
* Meridian Bioscience Inc.  34,400    1,100
  Gilead Sciences Inc.   1,602      126
  Cigna Corp.     382      123
1 Merck & Co. Inc.   1,208      122
9

Alternative Strategies Fund
    Shares Market
Value

($000)
1 Amgen Inc.     447      121
  McKesson Corp.     312      121
1 Quest Diagnostics Inc.     798      115
1 AmerisourceBergen Corp. Class A     720      113
1 UnitedHealth Group Inc.     200      111
1 Johnson & Johnson     623      108
1 Bristol-Myers Squibb Co.   1,385      107
  Stryker Corp.     467      107
  AbbVie Inc.     712      104
1 Becton Dickinson and Co.     436      103
1 Medtronic plc   1,185      103
1 CVS Health Corp.   1,076      102
  Premier Inc. Class A   2,925      102
1 Danaher Corp.     395       99
* Hologic Inc.   1,454       99
* Integra LifeSciences Holdings Corp.   1,969       99
  Laboratory Corp. of America Holdings     444       99
*,1 QIAGEN NV   2,272       99
1 Abbott Laboratories     918       91
1 Baxter International Inc.   1,656       90
*,1 Henry Schein Inc.   1,310       90
1 STERIS plc     471       81
* Enovis Corp.   1,613       80
1 Zoetis Inc.     525       79
1 Thermo Fisher Scientific Inc.      42       22
* Boston Scientific Corp.     407       18
  Elevance Health Inc.      20       11
         3,945
Industrials (4.1%)
* Atlas Air Worldwide Holdings Inc.  10,000    1,011
1 General Dynamics Corp.     493      123
  Eaton Corp. plc     790      119
1 Cummins Inc.     481      118
1 Honeywell International Inc.     578      118
  MSC Industrial Direct Co. Inc. Class A   1,416      117
1 AMETEK Inc.     896      116
1 Illinois Tool Works Inc.     544      116
  MSA Safety Inc.     867      116
1 PACCAR Inc.   1,189      115
1 Hubbell Inc. Class B     478      114
1 Ingersoll Rand Inc.   2,250      114
1 IDEX Corp.     508      113
  Lincoln Electric Holdings Inc.     797      113
  Nordson Corp.     502      113
1 Lockheed Martin Corp.     224      109
1 Expeditors International of Washington Inc.   1,104      108
  Otis Worldwide Corp.   1,505      106
1 Waste Management Inc.     664      105
  MDU Resources Group Inc.   3,641      104
1 AMERCO     179      103
  3M Co.     822      103
1 Republic Services Inc. Class A     772      102
1 Fastenal Co.   2,040       99
1 Norfolk Southern Corp.     425       97
1 Verisk Analytics Inc. Class A     523       96
* FTI Consulting Inc.     588       91
  Union Pacific Corp.     419       83
  Pentair plc   1,879       81
  Johnson Controls International plc     898       52
    Shares Market
Value

($000)
  Donaldson Co. Inc.     696       40
1 Allegion plc     178       19
         4,134
Information Technology (8.4%)
  Computer Services Inc.  16,500      953
* Sierra Wireless Inc.  27,500      816
* ChannelAdvisor Corp.  29,700      684
* Evo Payments Inc. Class A  18,902      637
* CyberOptics Corp.   9,500      513
* Zendesk Inc.   5,000      383
* MoneyGram International Inc.  30,000      318
* BTRS Holdings Inc. Class 1  31,947      302
  Switch Inc. Class A   8,000      272
* ForgeRock Inc. Class A  10,000      226
1 International Business Machines Corp.     856      118
*,1 VeriSign Inc.     585      117
  Genpact Ltd.   2,404      117
1 Amphenol Corp. Class A   1,531      116
1 Automatic Data Processing Inc.     471      114
1 Motorola Solutions Inc.     449      112
1 Amdocs Ltd.   1,292      112
*,1 Keysight Technologies Inc.     639      111
  Cisco Systems Inc.   2,429      110
1 Jack Henry & Associates Inc.     545      109
*,1 Fiserv Inc.   1,053      108
* Teledyne Technologies Inc.     270      108
1 Visa Inc. Class A     518      107
1 CDW Corp.     613      106
1 Apple Inc.     683      105
1 Broadridge Financial Solutions Inc.     698      105
  NetApp Inc.   1,521      105
1 Roper Technologies Inc.     252      105
1 Texas Instruments Inc.     656      105
1 Juniper Networks Inc.   3,344      102
  Cognizant Technology Solutions Corp. Class A   1,619      101
  National Instruments Corp.   2,647      101
1 Accenture plc Class A     357      101
1 Paychex Inc.     843      100
1 Analog Devices Inc.     689       98
1 Microsoft Corp.     414       96
1 Dolby Laboratories Inc. Class A   1,398       93
1 Broadcom Inc.     195       92
*,1 Akamai Technologies Inc.   1,004       89
1 SS&C Technologies Holdings Inc.   1,710       88
1 Western Union Co.   6,459       87
  Skyworks Solutions Inc.     132       11
         8,353
Materials (1.6%)
1 RPM International Inc.   1,252      118
  Silgan Holdings Inc.   2,498      118
1 Sonoco Products Co.   1,862      116
  Amcor plc   9,649      112
  Linde plc     370      110
1 Ecolab Inc.     692      109
1 Air Products and Chemicals Inc.     431      108
  Ashland Inc.   1,022      107
1 Avery Dennison Corp.     611      104
  AptarGroup Inc.   1,022      101
1 Sherwin-Williams Co.     432       97
 
10

Alternative Strategies Fund
    Shares Market
Value

($000)
  PPG Industries Inc.     817       93
1 Packaging Corp. of America     755       91
  International Flavors & Fragrances Inc.     893       87
  International Paper Co.   2,536       85
  Sealed Air Corp.   1,760       84
         1,640
Real Estate (2.5%)
  STORE Capital Corp.  18,000      572
  Gaming and Leisure Properties Inc.   2,233      112
  WP Carey Inc. REIT   1,436      110
  National Retail Properties Inc.   2,474      104
1 Prologis Inc.     934      103
1 AvalonBay Communities Inc.     526       92
1 CubeSmart   2,172       91
1 Invitation Homes Inc.   2,826       90
1 Public Storage     291       90
1 Life Storage Inc.     807       89
  Spirit Realty Capital Inc.   2,297       89
1 Mid-America Apartment Communities Inc.     558       88
  Realty Income Corp.   1,420       88
1 American Homes 4 Rent Class A   2,726       87
  Healthpeak Properties Inc.   3,686       87
  First Industrial Realty Trust Inc.   1,808       86
1 Extra Space Storage Inc.     472       84
1 Equity Residential   1,317       83
1 Sun Communities Inc.     616       83
1 Camden Property Trust     697       81
1 UDR Inc.   1,979       79
1 Equinix Inc.      75       43
  Healthcare Realty Trust Inc. Class A   1,511       31
  Essex Property Trust Inc.      60       13
  Apartment Income REIT Corp.     301       12
         2,487
Utilities (1.9%)
1 Consolidated Edison Inc.   1,220      107
1 OGE Energy Corp.   2,886      106
  PPL Corp.   3,994      106
1 IDACORP Inc.   1,006      105
1 NextEra Energy Inc.   1,326      103
1 Atmos Energy Corp.     954      102
1 Ameren Corp.   1,237      101
1 American Electric Power Co. Inc.   1,118       98
1 DTE Energy Co.     876       98
  Xcel Energy Inc.   1,503       98
1 Southern Co.   1,486       97
1 Alliant Energy Corp.   1,811       95
1 CMS Energy Corp.   1,671       95
1 Dominion Energy Inc.   1,352       95
1 Duke Energy Corp.   1,020       95
1 Avangrid Inc.   2,317       94
1 Exelon Corp.   2,367       91
  Public Service Enterprise Group Inc.   1,631       91
  Hawaiian Electric Industries Inc.   1,853       71
         1,848
Total Common Stocks—Long Positions
(Cost $28,521)
32,199
    Shares Market
Value

($000)
Temporary Cash Investments (39.3%)
Money Market Fund (39.3%)
2 Vanguard Market Liquidity Fund, 3.117% (Cost$39,087) 390,991         39,091
Common Stocks Sold Short (-8.8%)
Communication Services (-0.7%)
* Roblox Corp. Class A   (2,615)      (117)
* Netflix Inc.     (388)      (113)
* Pinterest Inc. Class A   (4,575)      (113)
* ZoomInfo Technologies Inc. Class A   (2,529)      (113)
* DISH Network Corp. Class A   (5,933)       (88)
* Roku Inc.   (1,504)       (83)
* Playtika Holding Corp.   (8,035)       (76)
           (703)
Consumer Discretionary (-1.4%)
  Macy's Inc.   (5,807)      (121)
* Carnival Corp.  (12,298)      (111)
* Victoria's Secret & Co.   (2,953)      (111)
* Capri Holdings Ltd.   (2,403)      (110)
* Penn National Gaming Inc.   (3,229)      (107)
* DraftKings Inc. Class A   (6,530)      (103)
* Etsy Inc.   (1,048)       (98)
* Peloton Interactive Inc. Class A  (11,588)       (97)
* Under Armour Inc. Class A  (12,771)       (95)
* Norwegian Cruise Line Holdings Ltd.   (5,354)       (91)
* Kohl's Corp.   (2,981)       (89)
* Nordstrom Inc.   (3,931)       (80)
* Wayfair Inc. Class A   (1,843)       (70)
* DoorDash Inc. Class A   (1,503)       (66)
* Royal Caribbean Cruises Ltd.   (1,007)       (54)
         (1,403)
Consumer Staples (-0.1%)
* Freshpet Inc.   (1,685)       (99)
Energy (-0.7%)
  New Fortress Energy Inc. Class A   (2,084)      (115)
  APA Corp.   (2,463)      (112)
* Antero Resources Corp.   (2,916)      (107)
  EQT Corp.   (2,529)      (106)
  Range Resources Corp.   (3,388)       (96)
* Southwestern Energy Co.  (13,656)       (95)
  Ovintiv Inc. (XNYS)   (1,837)       (93)
           (724)
Health Care (-1.2%)
* Moderna Inc.     (773)      (116)
* Sarepta Therapeutics Inc.     (964)      (110)
* Natera Inc.   (2,325)      (109)
* QuidelOrtho Corp.   (1,152)      (103)
* Mirati Therapeutics Inc.   (1,464)       (99)
* Guardant Health Inc.   (1,980)       (98)
* Teladoc Health Inc.   (3,203)       (95)
* Novocure Ltd.   (1,310)       (93)
* agilon health Inc.   (4,442)       (88)
* Oak Street Health Inc.   (3,863)       (78)
* Definitive Healthcare Corp. Class A   (4,170)       (66)
* Maravai LifeSciences Holdings Inc. Class A   (3,744)       (62)
* 10X Genomics Inc. Class A   (2,190)       (60)
 
11

Alternative Strategies Fund
    Shares Market
Value

($000)
* Novavax Inc.     (917)       (20)
         (1,197)
Industrials (-1.0%)
* Avis Budget Group Inc.     (490)      (116)
  Ingersoll Rand Inc.   (2,250)      (114)
  Vertiv Holdings Co. Class A   (7,986)      (114)
* AZEK Co. Inc. Class A   (5,894)      (103)
* Hertz Global Holdings Inc.   (5,541)      (102)
* Lyft Inc. Class A   (6,849)      (100)
* Uber Technologies Inc.   (3,404)       (91)
  Spirit AeroSystems Holdings Inc. Class A   (3,631)       (84)
* Sunrun Inc.   (3,639)       (82)
* Plug Power Inc.   (4,311)       (69)
* Generac Holdings Inc.     (466)       (54)
         (1,029)
Information Technology (-3.1%)
* Toast Inc. Class A   (5,403)      (119)
* Enphase Energy Inc.     (383)      (118)
* Wix.com Ltd.   (1,363)      (115)
* New Relic Inc.   (1,840)      (109)
* Smartsheet Inc. Class A   (3,102)      (108)
* Kyndryl Holdings Inc.  (10,877)      (105)
* Crowdstrike Holdings Inc. Class A     (634)      (102)
* Shift4 Payments Inc. Class A   (2,213)      (102)
* Jamf Holding Corp.   (4,295)      (102)
* Zscaler Inc.     (649)      (100)
* Confluent Inc. Class A   (3,720)      (100)
* Cloudflare Inc. Class A   (1,758)       (99)
* Snowflake Inc. Class A     (607)       (97)
* Informatica Inc. Class A   (4,973)       (96)
* ON Semiconductor Corp.   (1,539)       (95)
* EPAM Systems Inc.     (272)       (95)
* Bill.com Holdings Inc.     (710)       (95)
* Palantir Technologies Inc. Class A  (10,804)       (95)
* ViaSat Inc.   (2,296)       (94)
* Trade Desk Inc. Class A   (1,716)       (91)
* Elastic NV   (1,409)       (90)
* SentinelOne Inc. Class A   (3,899)       (89)
* nCino Inc.   (2,790)       (88)
* Coupa Software Inc.   (1,616)       (86)
* DocuSign Inc. Class A   (1,718)       (83)
    Shares Market
Value

($000)
* Datadog Inc. Class A   (1,032)       (83)
* Block Inc. (XNYS)   (1,363)       (82)
* Wolfspeed Inc.     (999)       (79)
* NCR Corp.   (3,419)       (73)
* RingCentral Inc. Class A   (2,036)       (72)
* UiPath Inc. Class A   (5,406)       (68)
* Okta Inc.   (1,087)       (61)
* MongoDB Inc. Class A     (333)       (61)
         (3,052)
Materials (-0.2%)
  US Steel Corp.   (5,010)      (102)
* Cleveland-Cliffs Inc.   (6,397)       (83)
  Alcoa Corp.   (1,543)       (60)
           (245)
Real Estate (-0.2%)
* Zillow Group Inc. Class A   (2,156)       (67)
* Opendoor Technologies Inc.  (23,622)       (61)
* Zillow Group Inc. Class C     (940)       (29)
           (157)
Utilities (-0.2%)
  Constellation Energy Corp.   (1,281)      (121)
  NRG Energy Inc.     (906)       (40)
           (161)
Total Common Stocks Sold Short
(Proceeds $11,093)
(8,770)
Other Assets and Other Liabilities—Net (37.2%) 37,039
Net Assets (100%) 99,559
Cost is in $000.
See Note A in Notes to Consolidated Financial Statements.
* Non-income-producing security.
1 Long security positions with a value of $13,414,000 are held in a segregated account at the fund's custodian bank and pledged to a broker-dealer as collateral for the fund's obligation to return borrowed securities. For so long as such obligations continue, the fund’s access to these assets is subject to authorization from the broker-dealer.
2 Affiliated money market fund available only to Vanguard funds and certain trusts and accounts managed by Vanguard. Rate shown is the 7-day yield.
  REIT—Real Estate Investment Trust.
 
12

Alternative Strategies Fund

Derivative Financial Instruments Outstanding as of Period End

Futures Contracts
      ($000)
  Expiration Number of
Long (Short)
Contracts
Notional
Amount
Value and
Unrealized
Appreciation
(Depreciation)
Long Futures Contracts        
2-Year U.S. Treasury Note December 2022 237 48,439 (1,070)
5-Year U.S. Treasury Note December 2022 107 11,406 (518)
10-Year U.S. Treasury Note December 2022 66 7,299 (470)
AEX Index November 2022 31 4,098 169
Coffee1 December 2022 18 1,199 (212)
Cotton No. 21 December 2022 7 252 (67)
FTSE MIB Index December 2022 38 4,233 338
FTSE Taiwan Index November 2022 89 4,074 30
IBEX 35 Index November 2022 54 4,243 219
Lean Hogs1 December 2022 17 577 6
LME Aluminum1 November 2022 17 944 (44)
LME Lead1 November 2022 13 642 (29)
LME Nickel1 November 2022 12 1,564 (28)
LME Tin1 November 2022 6 530 (75)
Low Sulphur Gasoil1 December 2022 13 1,326 (25)
NY Harbor ULSD1 November 2022 9 1,389 2
S&P ASX 200 Index December 2022 38 4,166 (84)
S&P TSX 60 Index December 2022 24 4,149 (61)
Soybean1 January 2023 12 852 9
Soybean Meal1 December 2022 33 1,413 16
Soybean Oil1 December 2022 34 1,493 176
Sugar #111 February 2023 64 1,288 5
        (1,713)
13

Alternative Strategies Fund
Futures Contracts (continued)
      ($000)
  Expiration Number of
Long (Short)
Contracts
Notional
Amount
Value and
Unrealized
Appreciation
(Depreciation)
Short Futures Contracts        
CAC40 Index November 2022 (67) (4,151) (139)
Cattle Feeder1 January 2023 (9) (808) (16)
Cocoa1 December 2022 (11) (257) 9
Copper1 December 2022 (16) (1,350) 75
DAX Index December 2022 (13) (4,268) 50
E-Mini S&P 500 Index December 2022 (21) (4,077) 190
FTSE 100 Index December 2022 (51) (4,157) 217
KC HRW Wheat1 December 2022 (17) (832) (71)
KOSPI 200 Index December 2022 (79) (4,169) (168)
Live Cattle1 December 2022 (14) (854) (12)
LME Aluminum1 November 2022 (17) (944) 31
LME Aluminum1 December 2022 (23) (1,280) 61
LME Lead1 November 2022 (13) (642) (11)
LME Lead1 December 2022 (10) (494) 20
LME Nickel1 November 2022 (12) (1,564) 126
LME Nickel1 December 2022 (10) (1,305) 18
LME Tin1 November 2022 (6) (530) 92
LME Tin1 December 2022 (5) (442) 62
MSCI Singapore Index November 2022 (216) (4,242) (204)
Natural Gas1 November 2022 (8) (508) 43
Wheat1 December 2022 (31) (1,367) (87)
        286
        (1,427)
1 Security is owned by the Vanguard ASF Portfolio, which is a wholly owned subsidiary of the Alternative Strategies Fund.
    
Forward Currency Contracts
  Contract
Settlement
Date
Contract Amount (000) Unrealized
Appreciation
($000)
Unrealized
Depreciation
($000)
Counterparty Receive Deliver
Morgan Stanley Capital Services Inc. 11/10/22 AUD 9,023 USD 5,846 (73)
Morgan Stanley Capital Services Inc. 11/10/22 BRL 12,551 USD 2,382 42
Royal Bank of Canada 11/10/22 CAD 7,971 USD 5,821 30
Morgan Stanley Capital Services Inc. 11/10/22 CLP 2,222,876 USD 2,309 44
Standard Chartered Bank 11/10/22 HUF 1,002,134 USD 2,283 128
Morgan Stanley Capital Services Inc. 11/10/22 MXN 46,659 USD 2,311 40
Bank of America, N.A. 11/10/22 NOK 63,217 USD 5,856 226
Morgan Stanley Capital Services Inc. 11/10/22 PLN 11,461 USD 2,308 90
Morgan Stanley Capital Services Inc. 11/10/22 USD 5,781 CHF 5,710 73
Standard Chartered Bank 11/10/22 USD 5,798 EUR 5,922 (58)
14

Alternative Strategies Fund
Forward Currency Contracts (continued)
  Contract
Settlement
Date
Contract Amount (000) Unrealized
Appreciation
($000)
Unrealized
Depreciation
($000)
Counterparty Receive Deliver
Bank of America, N.A. 11/10/22 USD 2,312 ILS 8,254 (25)
Morgan Stanley Capital Services Inc. 11/10/22 USD 5,813 JPY 839,698 159
BNP Paribas 11/10/22 USD 2,306 KRW 3,319,922 (24)
Royal Bank of Canada 11/10/22 USD 2,322 SGD 3,330 (30)
Bank of America, N.A. 11/10/22 USD 2,306 THB 87,529 5
Royal Bank of Canada 11/10/22 USD 2,310 TWD 73,673 22
            859 (210)
AUD—Australian dollar.
BRL—Brazilian real.
CAD—Canadian dollar.
CHF—Swiss franc.
CLP—Chilean peso.
EUR—euro.
HUF—Hungarian forint.
ILS—Israeli shekel.
JPY—Japanese yen.
KRW—Korean won.
MXN—Mexican peso.
NOK—Norwegian krone.
PLN—Polish zloty.
SGD—Singapore dollar.
THB—Thai baht.
TWD—Taiwanese dollar.
USD—U.S. dollar.
  
See accompanying Notes, which are an integral part of the Financial Statements.
15

Alternative Strategies Fund
Consolidated Statement of Assets and Liabilities
As of October 31, 2022
($000s, except shares and per-share amounts) Amount
Assets  
Investments in Securities, at Value  
Unaffiliated Issuers (Cost $28,521) 32,199
Affiliated Issuers (Cost $39,087) 39,091
Total Investments in Securities 71,290
Investment in Vanguard 6
Cash 16,307
Cash Segregated for Short Positions 14,540
Cash Collateral Pledged—Futures Contracts 5,154
Cash Collateral Pledged—Forward Currency Contracts 110
Receivables for Accrued Income 133
Receivables for Capital Shares Issued 3
Unrealized Appreciation—Forward Currency Contracts 859
Receivables from Broker-Dealer 393
Other Assets 2,493
Total Assets 111,288
Liabilities  
Securities Sold Short, at Value (Proceeds $11,093) 8,770
Payables for Investment Securities Purchased 103
Payables for Capital Shares Redeemed 121
Payables to Vanguard 52
Variation Margin Payable—Futures Contracts 2,472
Unrealized Depreciation—Forward Currency Contracts 210
Accrued Dividend Expense on Securities Sold Short 1
Total Liabilities 11,729
Net Assets 99,559
At October 31, 2022, net assets consisted of:  
   
Paid-in Capital 133,627
Total Distributable Earnings (Loss) (34,068)
Net Assets 99,559
 
Net Assets  
Applicable to 5,816,801 outstanding $.001 par value shares of
beneficial interest (unlimited authorization)
99,559
Net Asset Value Per Share $17.12
  
See accompanying Notes, which are an integral part of the Financial Statements.
16

Alternative Strategies Fund
Consolidated Statement of Operations
  Year Ended
October 31, 2022
  ($000)
Investment Income  
Income  
Dividends1 500
Interest2 471
Total Income 971
Expenses  
The Vanguard Group—Note B  
Investment Advisory Services 28
Management and Administrative 242
Marketing and Distribution 11
Custodian Fees 27
Auditing Fees 56
Shareholders’ Reports 25
Trustees’ Fees and Expenses—Note B 15
Dividend Expense on Securities Sold Short 55
Borrowing Expense on Securities Sold Short 111
Other Expenses 24
Total Expenses 594
Expenses Paid Indirectly (1)
Net Expenses 593
Net Investment Income 378
Payment from Affiliate - Note B 637
Realized Net Gain (Loss)  
Investment Securities Sold—Long Positions2 3,831
Investment Securities Sold—Short Positions 1,286
Futures Contracts (2,408)
Forward Currency Contracts (61)
Foreign Currencies 18
Realized Net Gain (Loss) 2,666
Change in Unrealized Appreciation (Depreciation)  
Investment Securities—Long Positions2 (5,100)
Investment Securities—Short Positions 4,442
Futures Contracts (929)
Forward Currency Contracts 903
Foreign Currencies (464)
Change in Unrealized Appreciation (Depreciation) (1,148)
Net Increase (Decrease) in Net Assets Resulting from Operations 2,533
1 Dividends are net of foreign withholding taxes of $5,000.
2 Interest income, realized net gain (loss), capital gain distributions received, and change in unrealized appreciation (depreciation) from an affiliated company of the fund were $457,000, ($1,000), $2,000, and ($2,000), respectively. Purchases and sales are for temporary cash investment purposes.
  
See accompanying Notes, which are an integral part of the Financial Statements.
17

Alternative Strategies Fund
Consolidated Statement of Changes in Net Assets
  Year Ended October 31,
  2022
($000)
2021
($000)
     
Increase (Decrease) in Net Assets    
Operations    
Net Investment Income 378 (439)
Payment from Affiliate - Note B 637
Realized Net Gain (Loss) 2,666 7,084
Change in Unrealized Appreciation (Depreciation) (1,148) (8,835)
Net Increase (Decrease) in Net Assets Resulting from Operations 2,533 (2,190)
Distributions    
Total Distributions (2,262) (2,074)
Capital Share Transactions    
Issued 21,574 31,827
Issued in Lieu of Cash Distributions 2,197 2,047
Redeemed (61,620) (198,840)
Net Increase (Decrease) from Capital Share Transactions (37,849) (164,966)
Total Increase (Decrease) (37,578) (169,230)
Net Assets    
Beginning of Period 137,137 306,367
End of Period 99,559 137,137
  
See accompanying Notes, which are an integral part of the Financial Statements.
18

Alternative Strategies Fund
Consolidated Financial Highlights
For a Share Outstanding
Throughout Each Period 
Year Ended October 31,
2022 2021 2020 2019 2018
Net Asset Value, Beginning of Period $17.00 $17.15 $22.23 $20.41 $20.46
Investment Operations          
Net Investment Income (Loss)1 .055 (.042) .023 .252 .197
Payment from Affiliate .092
Net Realized and Unrealized Gain (Loss) on Investments .251 .020 (3.835) 1.828 (.143)
Total from Investment Operations .398 (.022) (3.812) 2.080 .054
Distributions          
Dividends from Net Investment Income (.278) (.128) (.385) (.260) (.104)
Distributions from Realized Capital Gains (.883)
Total Distributions (.278) (.128) (1.268) (.260) (.104)
Net Asset Value, End of Period $17.12 $17.00 $17.15 $22.23 $20.41
Total Return2 2.38%3 -0.12% -18.17% 10.30% 0.27%
Ratios/Supplemental Data          
Net Assets, End of Period (Millions) $100 $137 $306 $297 $320
Ratio of Total Expenses
to Average Net Assets
         
Based on Total Expenses4,5 0.51%6 1.28% 0.78% 0.79%6 0.66%6
Net of Dividend and Borrowing Expense on Securities Sold Short 0.37%6 0.35% 0.34% 0.38%6 0.33%6
Ratio of Net Investment Income (Loss) to Average Net Assets 0.32% (0.25)% 0.12% 1.18% 0.93%
Portfolio Turnover Rate 112% 166% 173% 157% 131%
1 Calculated based on average shares outstanding.
2 Total returns do not include account service fees that may have applied in the periods shown. Fund prospectuses provide information about any applicable account service fees.
3 Payment received from an affiliate increased the fund's total return by 0.68%. See Note B in the Notes to Financial Statements.
4 Includes dividend expense on securities sold short of 0.05%, 0.37%, 0.44%, 0.41% and 0.33%, respectively.
5 Includes borrowing expense on securities sold short of 0.09%, 0.56%, 0.00%, 0.00%, and 0.00%, respectively.
6 The ratio of total expenses to average net assets for the periods ended 2022, 2019, and 2018, net of reduction from custody fee offset arrangement for total expenses and net of dividend and borrowing expense on securities sold short, was 0.51% and 0.37%, 0.74% and 0.33%, and 0.65% and 0.32%, respectively.
  
See accompanying Notes, which are an integral part of the Financial Statements.
19

Alternative Strategies Fund
Notes to Consolidated Financial Statements
Vanguard Alternative Strategies Fund is registered under the Investment Company Act of 1940 as an open-end investment company, or mutual fund. Significant market disruptions, such as those caused by pandemics (e.g., COVID-19 pandemic), natural or environmental disasters, war (e.g., Russia’s invasion of Ukraine), acts of terrorism, or other events, can adversely affect local and global markets and normal market operations. Any such disruptions could have an adverse impact on the value of the fund’s investments and fund performance.
The Consolidated Financial Statements include Vanguard ASF Portfolio ("the subsidiary"), which commenced operations on August 11, 2015. The subsidiary is wholly owned by the fund and is a unit trust established in the Cayman Islands under the Trusts Law (2011 Revision) of the Cayman Islands, which is organized to invest in certain commodity-linked investments on behalf of the fund, consistent with the fund's investment objectives and policies. The commodity-linked investments and other investments held by the subsidiary are subject to the same risks that apply to similar investments if held directly by the fund. As of October 31, 2022, the fund held $16,712,000 in the subsidiary, representing 17% of the fund's net assets. All inter-fund transactions and balances (including the fund's investment in the subsidiary) have been eliminated, and the Consolidated Financial Statements include all investments and other accounts of the subsidiary as if held directly by the fund.
A. The following significant accounting policies conform to generally accepted accounting principles for U.S. investment companies. The fund consistently follows such policies in preparing its financial statements.
1. Security Valuation: Securities are valued as of the close of trading on the New York Stock Exchange (generally 4 p.m., Eastern time) on the valuation date. Equity securities are valued at the latest quoted sales prices or official closing prices taken from the primary market in which each security trades; such securities not traded on the valuation date are valued at the mean of the latest quoted bid and asked prices. Securities for which market quotations are not readily available, or whose values have been affected by events occurring before the fund’s pricing time but after the close of the securities’ primary markets, are valued by methods deemed by the valuation designee to represent fair value and subject to oversight by the board of trustees.  Investments in Vanguard Market Liquidity Fund are valued at that fund's net asset value.
2. Foreign Currency: Securities and other assets and liabilities denominated in foreign currencies are translated into U.S. dollars using exchange rates obtained from an independent third party as of the fund’s pricing time on the valuation date. Realized gains (losses) and unrealized appreciation (depreciation) on investment securities include the effects of changes in exchange rates since the securities were purchased, combined with the effects of changes in security prices. Fluctuations in the value of other assets and liabilities resulting from changes in exchange rates are recorded as unrealized foreign currency gains (losses) until the assets or liabilities are settled in cash, at which time they are recorded as realized foreign currency gains (losses).
3. Short Sales: Short sales are the sales of securities that the fund does not own. The fund sells a security it does not own in anticipation of a decline in the value of that security. In order to deliver the security to the purchaser, the fund borrows the security from a broker-dealer. The fund must segregate, as collateral for its obligation to return the borrowed security, an amount of cash and long security positions at least equal to the market value of the security sold short. In the absence of a default, the collateral segregated by the fund cannot be repledged, resold or rehypothecated. This results in the fund holding a significant portion of its assets in cash. The fund later closes out the position by returning the security to the lender, typically by purchasing the security in the open
20

Alternative Strategies Fund
market. A gain, limited to the price at which the fund sold the security short, or a loss, theoretically unlimited in size, is recognized upon the termination of the short sale. The fund may receive a portion of the income from the investment of collateral, or be charged a fee on borrowed securities, based on the market value of each borrowed security and a variable rate that is dependent upon the availability of such security. The net amounts of income or fees are recorded as interest income (for net income received) or borrowing expense on securities sold short (for net fees charged) on the Consolidated Statement of Operations. Dividends on securities sold short are reported as an expense in the Consolidated Statement of Operations. Cash collateral segregated for securities sold short is recorded as an asset in the Consolidated Statement of Assets and Liabilities. Long security positions segregated as collateral are shown in the Consolidated Schedule of Investments.
4. Futures Contracts: The fund gains exposure to commodities through the subsidiary’s investment in exchange-traded commodity futures contracts. The fund also uses interest rate futures contracts to invest in fixed income asset classes with greater efficiency and lower cost than is possible through direct investment, to add value when these instruments are attractively priced, or to adjust sensitivity to changes in interest rates. The fund uses global equity index futures contracts to capture excess return opportunities. The primary risk associated with the use of futures contracts are imperfect correlation between changes in market values of the underlying securities or commodities and the prices of futures contracts, and the possibility of an illiquid market. In addition, commodity futures trading is volatile, and even a small movement in market prices could cause large losses. Counterparty risk involving futures is mitigated because a regulated clearinghouse is the counterparty instead of the clearing broker. To further mitigate counterparty risk, the fund trades futures contracts on an exchange, monitors the financial strength of its clearing brokers and clearinghouse, and has entered into clearing agreements with its clearing brokers. The clearinghouse imposes initial margin requirements to secure the fund’s performance and requires daily settlement of variation margin representing changes in the market value of each contract. Any assets pledged as initial margin for open contracts are noted in the Consolidated Schedule of Investments.
Futures contracts are valued at their quoted daily settlement prices. The notional amounts of the contracts are not recorded in the Consolidated Statement of Assets and Liabilities. Fluctuations in the value of the contracts are recorded in the Consolidated Statement of Assets and Liabilities as an asset (liability) and in the Consolidated Statement of Operations as unrealized appreciation (depreciation) until the contracts are closed, when they are recorded as realized gains (losses) on futures contracts.
During the year ended October 31, 2022, the fund average investments in long and short futures contracts represented 148% and 43% of net assets, respectively, based on the average of the notional amounts at each quarter-end during the period.
5. Forward Currency Contracts: The fund enters into forward currency contracts to protect the value of securities and related receivables and payables against changes in future foreign exchange rates. The fund’s risks in using these contracts include movement in the values of the foreign currencies relative to the U.S. dollar and the ability of the counterparties to fulfill their obligations under the contracts. The fund mitigates its counterparty risk by entering into forward currency contracts only with a diverse group of prequalified counterparties, monitoring their financial strength, entering into master netting arrangements with its counterparties, and requiring its counterparties to transfer collateral as security for their performance. In the absence of a default, the collateral pledged or received by the fund cannot be repledged, resold, or rehypothecated. The
21

Alternative Strategies Fund
master netting arrangements provide that, in the event of a counterparty’s default (including bankruptcy), the fund may terminate the forward currency contracts, determine the net amount owed by either party in accordance with its master netting arrangements, and sell or retain any collateral held up to the net amount owed to the fund under the master netting arrangements. The forward currency contracts contain provisions whereby a counterparty may terminate open contracts if the fund’s net assets decline below a certain level, triggering a payment by the fund if the fund is in a net liability position at the time of the termination. The payment amount would be reduced by any collateral the fund has pledged. Any securities pledged as collateral for open contracts are noted in the Consolidated Schedule of Investments. The value of collateral received or pledged is compared daily to the value of the forward currency contracts exposure with each counterparty, and any difference, if in excess of a specified minimum transfer amount, is adjusted and settled within two business days.
Forward currency contracts are valued at their quoted daily prices obtained from an independent third party, adjusted for currency risk based on the expiration date of each contract. The notional amounts of the contracts are not recorded in the Consolidated Statement of Assets and Liabilities. Fluctuations in the value of the contracts are recorded in the Consolidated Statement of Assets and Liabilities as an asset (liability) and in the Consolidated Statement of Operations as unrealized appreciation (depreciation) until the contracts are closed, when they are recorded as realized gains (losses) on forward currency contracts.
During the year ended October 31, 2022, the fund’s average investment in forward currency contracts represented 60% of net assets, based on the average of the notional amounts at each quarter-end during the period.
The following table summarizes the fund’s derivative assets and liabilities by counterparty for derivatives subject to arrangements that provide for offsetting assets and liabilities. Exchange-traded and centrally cleared derivatives are listed separately.
  Assets
Reflected in
Consolidated
Statement of
Assets and
Liabilities1
($000)
Liabilities
Reflected in
Consolidated
Statement of
Assets and
Liabilities1
($000)
Net Amount
Receivable
(Payable)
($000)
Amounts Not Offset in
the Consolidated
Statement of Assets
and Liabilities
Net
Exposure3
(Not Less
Than $0)
($000)
  Collateral
Pledged2
($000)
Collateral
Received2
($000)
Derivatives Subject to
Offsetting Arrangements, by Counterparty
           
Bank of America, N.A. 231 (25) 206 206
BNP Paribas (24) (24)
Morgan Stanley Capital Services Inc. 448 (73) 375 110 375
Royal Bank of Canada 52 (30) 22 22
Standard Chartered Bank 128 (58) 70 70
Exchange-Traded
Futures Contracts
(2,472) (2,472) 5,154
Total 859 (2,682) (1,823) 5,264 673
1  Absent an event of default or early termination, derivative assets and liabilities are presented gross and not offset in the Consolidated Statement of Assets and Liabilities.
22

Alternative Strategies Fund
2  Securities or other assets pledged as collateral are noted in the Consolidated Schedule of Investments and Consolidated Statement of Assets and Liabilities. Securities or other assets received as collateral are held in a segregated account and not included in the fund’s security holdings in the Consolidated Schedule of Investments.
3  Net Exposure represents the net amount receivable from the counterparty in the event of default. Counterparties are not required to exchange collateral if amount is below a specified minimum transfer amount.
6. Federal Income Taxes: The fund intends to continue to qualify as a regulated investment company and distribute virtually all of its taxable income. The subsidiary is classified as a foreign corporation for U.S. tax purposes, and because it does not carry on a U.S. trade or business, is generally not subject to U.S. federal income tax. The subsidiary also complies with the Foreign Account Tax Compliance Act ("FATCA") and thus will not be subject to 30% withholding under FATCA on any income from U.S. investments. In addition, the subsidiary is not subject to Cayman Islands income tax. The subsidiary is not required to distribute any earnings and profits to the fund. The fund’s tax returns are open to examination by the relevant tax authorities until expiration of the applicable statute of limitations, which is generally three years after filing the tax return. Management has analyzed the fund’s tax positions taken for all open federal and state income tax years, and has concluded that no provision for income tax is required in the fund’s financial statements.
7. Distributions: Distributions to shareholders are recorded on the ex-dividend date. Distributions are determined on a tax basis at the fiscal year-end and may differ from net investment income and realized capital gains for financial reporting purposes.
8. Credit Facilities and Interfund Lending Program: The fund and certain other funds managed by The Vanguard Group ("Vanguard") participate in a $4.4 billion committed credit facility provided by a syndicate of lenders pursuant to a credit agreement and an uncommitted credit facility provided by Vanguard. Both facilities may be renewed annually. Each fund is individually liable for its borrowings, if any, under the credit facilities. Borrowings may be utilized for temporary or emergency purposes and are subject to the fund’s regulatory and contractual borrowing restrictions. With respect to the committed credit facility, the participating funds are charged administrative fees and an annual commitment fee of 0.10% of the undrawn committed amount of the facility, which are allocated to the funds based on a method approved by the fund’s board of trustees and included in Management and Administrative expenses on the fund’s Consolidated Statement of Operations. Any borrowings under either facility bear interest at an agreed-upon spread plus the higher of the federal funds effective rate, the overnight bank funding rate, or the Daily Simple Secured Overnight Financing Rate inclusive of an additional agreed-upon spread. However, borrowings under the uncommitted credit facility may bear interest based upon an alternate rate agreed to by the fund and Vanguard.
In accordance with an exemptive order (the “Order”) from the SEC, the fund may participate in a joint lending and borrowing program that allows registered open-end Vanguard funds to borrow money from and lend money to each other for temporary or emergency purposes (the “Interfund Lending Program”), subject to compliance with the terms and conditions of the Order, and to the extent permitted by the fund’s investment objective and investment policies. Interfund loans and borrowings normally extend overnight but can have a maximum duration of seven days. Loans may be called on one business day’s notice. The interest rate to be charged is governed by the conditions of the Order and internal procedures adopted by the board of trustees. The board of trustees is responsible for overseeing the Interfund Lending Program.
For the year ended October 31, 2022, the fund did not utilize the credit facilities or the Interfund Lending Program.
23

Alternative Strategies Fund
9. Other: Dividend income (or dividend expense on short positions) is recorded on the ex-dividend date. Non-cash dividends included in income, if any, are recorded at the fair value of the securities received. Interest income includes income distributions received from Vanguard Market Liquidity Fund and is accrued daily. Security transactions are accounted for on the date securities are bought or sold. Costs used to determine realized gains (losses) on the sale of investment securities are those of the specific securities sold.
B. In accordance with the terms of a Funds' Service Agreement (the “FSA”) between Vanguard and the fund, Vanguard furnishes to the fund investment advisory, corporate management, administrative, marketing, and distribution services at Vanguard’s cost of operations (as defined by the FSA). These costs of operations are allocated to the fund based on methods and guidelines approved by the board of trustees and are generally settled twice a month.
During the period ended October 31, 2022, the fund received a voluntary payment of $637,000 from Vanguard related to higher-than-anticipated costs associated with short sale transactions, which is included in Payment from Affiliate on the Consolidated Statement of Operations; the fund is not obligated to repay this amount to Vanguard.
Under a separate agreement, Vanguard provides corporate management and administrative services to the subsidiary for an annual fee of 0.40% of average net assets of the subsidiary, generally settled once a month. In addition, the subsidiary pays an unaffiliated third party, VGMF I (Cayman) Limited, an affiliate of Maples Trustee Services (Cayman) Limited, a fee plus reasonable additional expenses for trustee services. All of the subsidiary’s expenses are reflected in the Consolidated Statement of Operations and in the Ratio of Total Expenses to Average Net Assets in the Consolidated Financial Highlights.
Upon the request of Vanguard, the fund may invest up to 0.40% of its net assets as capital in Vanguard. At October 31, 2022, the fund had contributed to Vanguard capital in the amount of $6,000, representing 0.01% of the fund’s net assets and less than 0.01% of Vanguard’s capital received pursuant to the FSA. The fund’s trustees and officers are also directors and employees, respectively, of Vanguard.
C. The fund’s custodian bank has agreed to reduce its fees when the fund maintains cash on deposit in the non-interest-bearing custody account. For the year ended October 31, 2022, custodian fee offset arrangements reduced the fund’s expenses by $1,000 (an annual rate of less than 0.01% of average net assets).
D. Various inputs may be used to determine the value of the fund’s investments and derivatives. These inputs are summarized in three broad levels for financial statement purposes. The inputs or methodologies used to value securities are not necessarily an indication of the risk associated with investing in those securities.
Level 1—Quoted prices in active markets for identical securities.
Level 2—Other significant observable inputs (including quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.).
Level 3—Significant unobservable inputs (including the fund’s own assumptions used to determine the fair value of investments). Any investments and derivatives valued with significant unobservable inputs are noted on the Consolidated Schedule of Investments.
24

Alternative Strategies Fund
The following table summarizes the market value of the fund’s investments and derivatives as of October 31, 2022, based on the inputs used to value them:
  Level 1
($000)
Level 2
($000)
Level 3
($000)
Total
($000)
Investments        
Assets        
Common Stocks 32,199 32,199
Temporary Cash Investments 39,091 39,091
Total 71,290 71,290
Liabilities        
Common Stocks 8,770 8,770
Derivative Financial Instruments        
Assets        
Futures Contracts1 1,964 1,964
Forward Currency Contracts 859 859
Total 1,964 859 2,823
Liabilities        
Futures Contracts1 3,391 3,391
Forward Currency Contracts 210 210
Total 3,391 210 3,601
1 Includes cumulative appreciation (depreciation) on futures contracts and centrally cleared swaps, if any, as reported in the Consolidated Schedule of Investments. Only current day’s variation margin is reported within the Consolidated Statement of Assets and Liabilities.
E. At October 31, 2022, the fair values of derivatives were reflected in the Consolidated Schedule of Investments and Consolidated Statement of Assets and Liabilities as follows:
    
Consolidated Statement of Assets and Liabilities Caption Equity
Contracts
($000)
Commodity
Contracts
($000)
Interest Rate
Contracts
($000)
Foreign
Exchange
Contracts
($000)
Total
($000)
Unrealized Appreciation—Futures Contracts1 1,213 751 1,964
Unrealized Appreciation—Forward Currency Contracts 859 859
Total Assets 1,213 751 859 2,823
           
Unrealized Depreciation—Futures Contracts1 656 677 2,058 3,391
Unrealized Depreciation—Forward Currency Contracts 210 210
Total Liabilities 656 677 2,058 210 3,601
1 Includes cumulative appreciation (depreciation) on futures contracts and centrally cleared swaps, if any, as reported in the Consolidated Schedule of Investments. Only current day’s variation margin is reported within the Consolidated Statement of Assets and Liabilities.
25

Alternative Strategies Fund
Realized net gain (loss) and the change in unrealized appreciation (depreciation) on derivatives for the year ended October 31, 2022, were:
Realized Net Gain (Loss) on Derivatives Equity
Contracts
($000)
Commodity
Contracts
($000)
Interest Rate
Contracts
($000)
Foreign
Exchange
Contracts
($000)
Total
($000)
Futures Contracts 4,197 1,729 (8,334) (2,408)
Forward Currency Contracts (61) (61)
Realized Net Gain (Loss) on Derivatives 4,197 1,729 (8,334) (61) (2,469)
Change in Unrealized Appreciation (Depreciation) on Derivatives
Futures Contracts (210) 106 (825) (929)
Forward Currency Contracts 903 903
Change in Unrealized Appreciation (Depreciation) on Derivatives (210) 106 (825) 903 (26)
F. Permanent differences between book-basis and tax-basis components of net assets are reclassified among capital accounts in the financial statements to reflect their tax character. These reclassifications have no effect on net assets or net asset value per share. As of period end, permanent differences primarily attributable to the accounting for applicable foreign currency transactions, passive foreign investment companies, and operations of the subsidiary were reclassified between the following accounts:
  Amount
($000)
Paid-in Capital 23
Total Distributable Earnings (Loss) (23)
Temporary differences between book-basis and tax-basis components of total distributable earnings (loss) arise when certain items of income, gain, or loss are recognized in different periods for financial statement and tax purposes; these differences will reverse at some time in the future. The differences are primarily related to the deferral of losses from wash sales; the recognition of unrealized gains or losses from certain derivative contracts; and the recognition of unrealized gain from constructive sales. As of period end, the tax-basis components of total distributable earnings (loss) are detailed in the table as follows:
  Amount
($000)
Undistributed Ordinary Income 2,674
Undistributed Long-Term Gains
Capital Loss Carryforwards (42,375)
Qualified Late-Year Losses
Net Unrealized Gains (Losses) 5,633
26

Alternative Strategies Fund
The tax character of distributions paid was as follows:
  Year Ended October 31,
  2022
Amount
($000)
2021
Amount
($000)
Ordinary Income* 2,262 2,074
Long-Term Capital Gains
Total 2,262 2,074
* Includes short-term capital gains, if any.
As of October 31, 2022, gross unrealized appreciation and depreciation for investments and derivatives based on cost for U.S. federal income tax purposes were as follows:
  Amount
($000)
Tax Cost 67,773
Gross Unrealized Appreciation 15,211
Gross Unrealized Depreciation (9,051)
Net Unrealized Appreciation (Depreciation) 6,160
G. During the year ended October 31, 2022, the fund purchased $44,128,000 of investment securities and sold $72,004,000 of investment securities, other than temporary cash investments. The proceeds of short sales and the cost of purchases to cover short sales were $13,338,000 and $12,352,000, respectively.
H. Capital shares issued and redeemed were:
    
  Year Ended October 31,
  2022
Shares
(000)
2021
Shares
(000)
     
Issued 1,266 1,865
Issued in Lieu of Cash Distributions 132 122
Redeemed (3,647) (11,786)
Net Increase (Decrease) in Shares Outstanding (2,249) (9,799)
At October 31, 2022, Vanguard Managed Allocation Fund, was the record or beneficial owner of 72% of the fund’s net assets. If this shareholder were to redeem its investment in the fund, the redemption might result in an increase in the fund’s expense ratio, cause the fund to incur higher transaction costs, or lead to the realization of taxable capital gains.
I. Management has determined that no material events or transactions occurred subsequent to October 31, 2022, that would require recognition or disclosure in these financial statements.
27

Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Vanguard Trustees' Equity Fund and Shareholders of Vanguard Alternative Strategies Fund
Opinion on the Financial Statements
We have audited the accompanying consolidated statement of assets and liabilities, including the consolidated schedule of investments, of Vanguard Alternative Strategies Fund and its subsidiary (one of the funds constituting Vanguard Trustees' Equity Fund, referred to hereafter as the "Fund") as of October 31, 2022, the related consolidated statement of operations for the year ended October 31, 2022, the consolidated statement of changes in net assets for each of the two years in the period ended October 31, 2022, including the related notes, and the consolidated financial highlights for each of the five years in the period ended October 31, 2022 (collectively referred to as the "consolidated financial statements"). In our opinion, the consolidated financial statements present fairly, in all material respects, the financial position of the Fund as of October 31, 2022, the results of its operations for the year then ended, the changes in its net assets for each of the two years in the period ended October 31, 2022 and the financial highlights for each of the five years in the period ended October 31, 2022 in conformity with accounting principles generally accepted in the United States of America.
Basis for Opinion
These consolidated financial statements are the responsibility of the Fund’s management. Our responsibility is to express an opinion on the Fund’s consolidated financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Fund in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.
We conducted our audits of these consolidated financial statements in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the consolidated financial statements are free of material misstatement, whether due to error or fraud.
Our audits included performing procedures to assess the risks of material misstatement of the consolidated financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the consolidated financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the consolidated financial statements. Our procedures included confirmation of securities owned as of October 31, 2022 by correspondence with the custodian, transfer agent and brokers; when replies were not received from brokers, we performed other auditing procedures. We believe that our audits provide a reasonable basis for our opinion.
/s/PricewaterhouseCoopers LLP
Philadelphia, Pennsylvania
December 16, 2022
We have served as the auditor of one or more investment companies in The Vanguard Group of Funds since 1975.
28


Tax information (unaudited)
For corporate shareholders, 16.1%, or if subsequently determined to be different, the maximum percentage allowable by law, of ordinary income (dividend income plus short-term gains, if any) for the fiscal year qualified for the dividends-received deduction.
The fund hereby designates $1,355,000, or if subsequently determined to be different, the maximum amount allowable by law, as qualified dividend income for individual shareholders for the fiscal year.
The fund hereby designates $136,000, or if subsequently determined to be different, the maximum amount allowable by law, of interest earned from obligations of the U.S. government which is generally exempt from state income tax.
The fund hereby designates $114,000, or if subsequently determined to be different, the maximum amount allowable by law, of qualified business income for individual shareholders for the fiscal year.
29

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The People Who Govern Your Fund
The trustees of your mutual fund are there to see that the fund is operated and managed in your best interests since, as a shareholder, you are a part owner of the fund. Your fund’s trustees also serve on the board of directors of The Vanguard Group, Inc., which is owned by the Vanguard funds and provides services to them. 
A majority of Vanguard’s board members are independent, meaning that they have no affiliation with Vanguard or the funds they oversee, apart from the sizable personal investments they have made as private individuals. The independent board members have distinguished backgrounds in business, academia, and public service. Each of the trustees and executive officers oversees 206 Vanguard funds.
Information for each trustee and executive officer of the fund appears below. That information, as well as the Vanguard fund count, is as of the date on the cover of this fund report. The mailing address of the trustees and officers is P.O. Box 876, Valley Forge, PA 19482. More information about the trustees is in the Statement of Additional Information, which can be obtained, without charge, by contacting Vanguard at 800-662-7447, or online at vanguard.com.
Interested Trustee1
Mortimer J. Buckley
Born in 1969. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: chairman of the board (2019–present) of Vanguard and of each of the investment companies served by Vanguard; chief executive officer (2018–present) of Vanguard; chief executive officer, president, and trustee (2018–present) of each of the investment companies served by Vanguard; president and director (2017–present) of Vanguard; and president (2018–present) of Vanguard Marketing Corporation. Chief investment officer (2013–2017), managing director (2002–2017), head of the Retail Investor Group (2006–2012), and chief information officer (2001–2006) of Vanguard. Member of the board of governors of the Investment Company Institute and the board of governors of FINRA. Trustee and vice chair of The Shipley School.
Independent Trustees
Tara Bunch
Born in 1962. Trustee since November 2021. Principal occupation(s) during the past five years and other experience: head of global operations at Airbnb (2020–present). Vice president of AppleCare (2012–2020). Member of the board of directors of Out & Equal (2002–2006), the advisory board of the University of California, Berkeley School of Engineering (2020–present), and the advisory board
of Santa Clara University’s Leavey School of Business (2018–present).
Emerson U. Fullwood
Born in 1948. Trustee since January 2008. Principal occupation(s) during the past five years and other experience: executive chief staff and marketing officer for North America and corporate vice president (retired 2008) of Xerox Corporation (document management products and services). Former president of the Worldwide Channels Group, Latin America, and Worldwide Customer Service and executive chief staff officer of Developing Markets of Xerox. Executive in residence and 2009–2010 Distinguished Minett Professor at the Rochester Institute of Technology. Member of the board of directors of the University of Rochester Medical Center, the Monroe Community College Foundation, the United Way of Rochester, North Carolina A&T University, Roberts Wesleyan College, and the Rochester Philharmonic Orchestra. Trustee of the University of Rochester.                       
F. Joseph Loughrey
Born in 1949. Trustee since October 2009. Principal occupation(s) during the past five years and other experience: president and chief operating officer (retired 2009) and vice chairman of the board (2008–2009) of Cummins Inc. (industrial machinery). Chairman of the board of Hillenbrand, Inc. (specialized consumer services). Director of the V Foundation. Member of the advisory council for the College of
 
1  Mr. Buckley is considered an “interested person,” as defined in the Investment Company Act of 1940, because he is an officer of the Vanguard funds.

Arts and Letters at the University of Notre Dame. Chairman of the board of Saint Anselm College.
Mark Loughridge
Born in 1953. Trustee since March 2012. Principal occupation(s) during the past five years and other experience: senior vice president and chief financial officer (retired 2013) of IBM (information technology services). Fiduciary member of IBM’s Retirement Plan Committee (2004–2013), senior vice president and general manager (2002–2004) of IBM Global Financing, vice president and controller (1998–2002) of IBM, and a variety of other prior management roles at IBM. Member of the Council on Chicago Booth.
Scott C. Malpass
Born in 1962. Trustee since March 2012. Principal occupation(s) during the past five years and other experience: adjunct professor of finance at the University of Notre Dame (2020–present). Chief investment officer (retired 2020) and vice president (retired 2020) of the University of Notre Dame. Assistant professor (retired June 2020) of finance at the Mendoza College of Business, University of Notre Dame, and member of the Notre Dame 403(b) Investment Committee. Member of the board of Catholic Investment Services, Inc. (investment advisors), the board of superintendence of the Institute for the Works of Religion, and the board of directors of Paxos Trust Company (finance).
Deanna Mulligan
Born in 1963. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: chief executive officer of Purposeful (advisory firm for CEOs and C-level executives; 2021–present). Board chair (2020), chief executive officer (2011–2020), and president (2010–2019) of The Guardian Life Insurance Company of America. Chief operating officer (2010–2011) and executive vice president (2008–2010) of Individual Life and Disability of the Guardian Life Insurance Company of America. Member of the board of the Economic Club of New York. Trustee of the Partnership for New York City (business leadership), Chief Executives for Corporate Purpose, and the NewYork-Presbyterian Hospital.
André F. Perold
Born in 1952. Trustee since December 2004. Principal occupation(s) during the past five years and other experience: George Gund Professor of Finance and Banking, Emeritus at the Harvard Business School (retired 2011). Chief investment officer and co-managing partner of HighVista Strategies (private investment firm). Member of the board (2018–present) of RIT Capital Partners (investment
firm). Member of the investment committee of Partners Health Care System.
Sarah Bloom Raskin
Born in 1961. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: deputy secretary (2014–2017) of the United States Department of the Treasury. Governor (2010–2014) of the Federal Reserve Board. Commissioner (2007–2010) of financial regulation for the State of Maryland. Colin W. Brown Distinguished Professor of the Practice of Law (2021–present), professor (2020–present), Distinguished Fellow of the Global Financial Markets Center (2020–present), and Rubenstein Fellow (2017–2020) at Duke University. Trustee (2017–present) of Amherst College and member of Amherst College Investment Committee (2019–present). Member of the Regenerative Crisis Response Committee (2020–present).
David A. Thomas
Born in 1956. Trustee since July 2021. Principal occupation(s) during the past five years and other experience: president of Morehouse College (2018–present). Professor of business administration, emeritus at Harvard University (2017–2018). Dean (2011–2016) and professor of management (2016–2017) at the Georgetown University McDonough School of Business. Director of DTE Energy Company (2013–present). Trustee of Common Fund (2019–present).
Peter F. Volanakis
Born in 1955. Trustee since July 2009. Principal occupation(s) during the past five years and other experience: president and chief operating officer (retired 2010) of Corning Incorporated (communications equipment) and director of Corning Incorporated (2000–2010) and Dow Corning (2001–2010). Director (2012) of SPX Corporation (multi-industry manufacturing). Overseer of the Amos Tuck School of Business Administration, Dartmouth College (2001–2013). Member of the BMW Group Mobility Council.

Executive Officers
Christine M. Buchanan
Born in 1970. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Chief financial officer (2021–present) and treasurer (2017–present) of each of the investment companies served by Vanguard. Partner (2005–2017) at KPMG (audit, tax, and advisory services).
John Galloway
Born in 1973. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Investment stewardship officer (September 2020–present) of each of the investment companies served by Vanguard. Head of Investor Advocacy (February 2020–present) and head of Marketing Strategy and Planning (2017–2020) at Vanguard. Special assistant to the President of the United States (2015).
Ashley Grim
Born in 1984. Principal occupation(s) during the past five years and other experience: treasurer (February 2022–present) of each of the investment companies served by Vanguard. Fund transfer agent controller (2019–2022) and director of Audit Services (2017–2019) at Vanguard. Senior manager (2015–2017) at PriceWaterhouseCoopers (audit and assurance, consulting, and tax services).
Peter Mahoney
Born in 1974. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Controller (2015–present) of each of the investment companies served by Vanguard. Head of International Fund Services (2008–2014) at Vanguard.
Anne E. Robinson
Born in 1970. Principal occupation(s) during the past five years and other experience: general counsel (2016–present) of Vanguard. Secretary (2016–present) of Vanguard and of each of the investment companies served by Vanguard. Managing director (2016–present) of Vanguard. Managing director and general counsel of Global Cards and Consumer Services (2014–2016) at Citigroup. Counsel (2003–2014) at American Express. Nonexecutive director of the board of National Grid (energy).
Michael Rollings
Born in 1963. Principal occupation(s) during the past five years and other experience: finance director (2017–present) and treasurer (2017) of each of the investment companies served by Vanguard. Managing director (2016–present) of Vanguard. Chief financial officer (2016–present) of Vanguard. Director (2016–present) of Vanguard Marketing Corporation. Executive vice president and chief financial officer (2006–2016) of MassMutual Financial Group.
John E. Schadl
Born in 1972. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Chief compliance officer (2019–present) of Vanguard and of each of the investment companies served by Vanguard. Assistant vice president (2019–present) of Vanguard Marketing Corporation.
Vanguard Senior Management Team
Matthew Benchener Thomas M. Rampulla
Joseph Brennan Karin A. Risi
Mortimer J. Buckley Anne E. Robinson
Gregory Davis Michael Rollings
John James Nitin Tandon
Chris D. Mclsaac Lauren Valente

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This material may be used in conjunction with the offering of shares of any Vanguard fund only if preceded or accompanied by the fund’s current prospectus.
All comparative mutual fund data are from Lipper, a Thomson Reuters Company, or Morningstar, Inc., unless otherwise noted.
You can obtain a free copy of Vanguard’s proxy voting guidelines by visiting vanguard.com/proxyreporting or by calling Vanguard at 800-662-2739. The guidelines are also available from the SEC’s website, www.sec.gov. In addition, you may obtain a free report on how your fund voted the proxies for securities it owned during the 12 months ended June 30. To get the report, visit either vanguard.com/proxyreporting or www.sec.gov.
You can review information about your fund on the SEC’s website, and you can receive copies of this information, for a fee, by sending a request via email addressed to publicinfo@sec.gov.
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© 2022 The Vanguard Group, Inc.
All rights reserved.
Vanguard Marketing Corporation, Distributor.
Q12980 122022
Annual Report   |   October 31, 2022
Vanguard Commodity Strategy Fund

Contents
Your Fund’s Performance at a Glance

1
Advisors' Report

2
About Your Fund’s Expenses

4
Performance Summary

6
Consolidated Financial Statements

8
Please note: The opinions expressed in this report are just that—informed opinions. They should not be considered promises or advice. Also, please keep in mind that the information and opinions cover the period through the date on the front of this report. Of course, the risks of investing in your fund are spelled out in the prospectus.

Your Fund’s Performance at a Glance
For the 12 months ended October 31, 2022, Vanguard Commodity Strategy Fund returned 9.80%, falling short of its benchmark, the Bloomberg Commodity Total Return Index, which returned 11.15%.
The economic backdrop deteriorated as inflation soared to multidecade highs, fueled in part by higher energy and food prices in the wake of Russia’s invasion of Ukraine. Then price increases broadened to other categories of goods and services, adding to concerns that inflation would remain stubbornly high. That prompted aggressive tightening by the Federal Reserve to bring inflation back in check, which increased fears of recession.
Commodities generally performed well due to limited supply and increased demand. West Texas Intermediate Crude rose and grain prices soared. Gold and other precious metals fell. 
The fund benefited from its positions in commodities but fell short of its benchmark, largely because of its exposure to short-term U.S.Treasury Inflation-Protected Securities (TIPS) as the market began to price in higher inflation and real yields soared.
The fund uses derivatives to obtain its exposure to commodities. Its holdings of commodity index swaps contributed to total returns.
Market Barometer
  Average Annual Total Returns
Periods Ended October 31, 2022
  One Year Three Years Five Years
Stocks      
Russell 1000 Index (Large-caps) -16.38% 9.99% 10.19%
Russell 2000 Index (Small-caps) -18.54 7.05 5.56
Russell 3000 Index (Broad U.S. market) -16.52 9.79 9.87
FTSE All-World ex US Index (International) -24.20 -1.16 -0.18
Bonds      
Bloomberg U.S. Aggregate Float Adjusted Index
(Broad taxable market)
-15.69% -3.73% -0.50%
Bloomberg Municipal Bond Index
(Broad tax-exempt market)
-11.98 -2.18 0.37
FTSE Three-Month U.S. Treasury Bill Index 0.88 0.59 1.15
CPI      
Consumer Price Index 7.75% 5.01% 3.85%
1

Advisors’ Report
For the 12 months ended October 31, 2022, Vanguard Commodity Strategy Fund returned 9.80%. It underperformed its benchmark, the Bloomberg Commodity Total Return Index, which returned 11.15%.
Investment objective and strategy
The Commodity Strategy Fund is designed to serve investors as a potential hedge against inflation risk and as further diversification for a traditional stock/bond portfolio. It invests in commodity-linked derivative investments, such as commodity futures and swaps, collateralized by a mix of short-term U.S. Treasury Inflation-Protected Securities (TIPS) and U.S. Treasury bills. This blend of investments is expected to offer a controlled approach with the potential to enhance returns over time without taking on excessive risk.
The fund uses multiple strategies to enhance commodity returns, such as commodity curve positioning and over- and underweighting securities. It also takes advantage of roll schedules, a practice that involves rolling over commodity futures before or after the Bloomberg Commodity Total Return Index rolls shorter-term futures contracts into longer-term contracts.
Investment environment
The period was defined by a sharp rise in interest rates, which caused ripple effects across every sector of the financial markets and brought with it renewed volatility.
Concerns that had been weighing on market sentiment in late 2021 carried into 2022. Supply-chain bottlenecks persisted, labor remained in short supply in some sectors of the economy as unemployment rates continued to fall, and year-on-year inflation readings—which had been accelerating—climbed to multidecade highs across much of the world.
In late February, Russia’s invasion of Ukraine injected more uncertainty into the markets. Oil headed north of $100 per barrel and staple food prices soared. Energy prices eventually began to cool amid slowing economic growth and the U.S. government’s release of some of its strategic oil reserves to boost supply. But price increases broadened to other categories of goods and services, heightening concerns that inflation might remain stubbornly high.
Equity and fixed income markets suffered as, in response to this environment, major central banks wound down their bond-purchasing programs and began raising short-term interest rates. The Federal Reserve was especially aggressive, raising rates five times during the period to bring inflation in check, which increased fears of recession. The yield on the benchmark 10-year Treasury rose 250 basis points during the period. (A basis point is one-hundredth of a percentage point.)
The environment for commodities remained strong in general because of limited supply and increased demand worldwide. West Texas Intermediate Crude continued to climb while natural
 
2

gas fell modestly after a strong 2021. Prices for corn, soybeans, and wheat soared while safe-haven commodities such as gold continued to lag. 
Successes and shortfalls
Our positions in commodities benefited from the geopolitical environment and supply constraints, producing nearly 70 basis points of outperformance. Exposure to energy and grains helped the most but was somewhat offset by industrial metals, which were in negative territory due to recessionary concerns, and precious metals, which fell due to declining gold prices on the strength of the U.S. dollar.
Relative performance was held back by our exposure to short-term TIPS as the market began to price in high inflation and inflation expectations modified. This development, along with the spike in real yields, created headwinds for inflation-linked bonds.
The fund continued to fulfill its mandate of providing further diversification for a stock/bond portfolio as correlations with other asset classes remained low during the period.
Although markets can be unpredictable, we are confident that our team of experienced managers and analysts can find opportunities to produce competitive returns without taking excessive risks.
Portfolio Managers:
Fei Xu, CFA, FRM
Vanguard Quantitative Equity Group
Joshua C. Barrickman, CFA, Principal
Vanguard Fixed Income Group
November 11, 2022
3

About Your Fund’s Expenses
As a shareholder of the fund, you incur ongoing costs, which include costs for portfolio management, administrative services, and shareholder reports (like this one), among others. Operating expenses, which are deducted from a fund’s gross income, directly reduce the investment return of the fund.
A fund’s expenses are expressed as a percentage of its average net assets. This figure is known as the expense ratio. The following examples are intended to help you understand the ongoing costs (in dollars) of investing in your fund and to compare these costs with those of other mutual funds. The examples are based on an investment of $1,000 made at the beginning of the period shown and held for the entire period.
The accompanying table illustrates your fund’s costs in two ways:
Based on actual fund return. This section helps you to estimate the actual expenses that you paid over the period. The ”Ending Account Value“ shown is derived from the fund‘s actual return, and the third column shows the dollar amount that would have been paid by an investor who started with $1,000 in the fund. You may use the information here, together with the amount you invested, to estimate the expenses that you paid over the period.
To do so, simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number given for your fund under the heading ”Expenses Paid During Period.“
Based on hypothetical 5% yearly return. This section is intended to help you compare your fund‘s costs with those of other mutual funds. It assumes that the fund had a yearly return of 5% before expenses, but that the expense ratio is unchanged. In this case—because the return used is not the fund’s actual return—the results do not apply to your investment. The example is useful in making comparisons because the Securities and Exchange Commission requires all mutual funds to calculate expenses based on a 5% return. You can assess your fund’s costs by comparing this hypothetical example with the hypothetical examples that appear in shareholder reports of other funds.
Note that the expenses shown in the table are meant to highlight and help you compare ongoing costs only and do not reflect transaction costs incurred by the fund for buying and selling securities. Further, the expenses do not include any purchase, redemption, or account service fees described in the fund prospectus. If such fees were applied to your account, your costs would be higher. Your fund does not carry a “sales load.”
The calculations assume no shares were bought or sold during the period. Your actual costs may have been higher or lower, depending on the amount of your investment and the timing of any purchases or redemptions.
You can find more information about the fund’s expenses, including annual expense ratios, in the Consolidated Financial Statements section of this report. For additional information on operating expenses and other shareholder costs, please refer to your fund’s current prospectus.
4

Six Months Ended October 31, 2022      
Commodity Strategy Fund Beginning
Account Value
4/30/2022
Ending
Account Value
10/31/2022
Expenses
Paid During
Period
Based on Actual Fund Return $1,000.00 $867.40 $0.99
Based on Hypothetical 5% Yearly Return 1,000.00 1,024.15 1.07
The calculations are based on expenses incurred in the most recent six-month period. The fund’s annualized six-month expense ratio for that period is 0.21%. The dollar amounts shown as “Expenses Paid” are equal to the annualized expense ratio multiplied by the average account value over the period, multiplied by the number of days in the most recent six-month period, then divided by the number of days in the most recent 12-month period (184/365).
5

Commodity Strategy Fund
Performance Summary
All of the returns in this report represent past performance, which is not a guarantee of future results that may be achieved by the fund. (Current performance may be lower or higher than the performance data cited. For performance data current to the most recent month-end, visit our website at vanguard.com/performance.) Note, too, that both investment returns and principal value can fluctuate widely, so an investor’s shares, when sold, could be worth more or less than their original cost. The returns shown do not reflect taxes that a shareholder would pay on fund distributions or on the sale of fund shares.
Cumulative Performance: June 25, 2019, Through October 31, 2022
Initial Investment of $50,000
    Average Annual Total Returns
Periods Ended October 31, 2022
 
    One
Year
Since
Inception
(6/25/2019)
Final Value
of a $50,000
Investment
 Commodity Strategy Fund 9.80% 15.84% $81,832
 Bloomberg Commodity Index Total Return 11.15 11.93 72,947
"Since Inception" performance is calculated from the fund’s inception date for both the fund and its comparative standard(s).
See Financial Highlights for dividend and capital gains information.
6

Commodity Strategy Fund
Fund Allocation
As of October 31, 2022
U.S. Government Securities 100.0%
The table reflects the fund’s investments, except for short-term investments and derivatives. The agency and mortgage-backed securities may include issues from government-sponsored enterprises; such issues are generally not backed by the full faith and credit of the U.S. government.
7

Commodity Strategy Fund
Consolidated Financial Statements
Consolidated Schedule of Investments
As of October 31, 2022
The fund files its complete schedule of portfolio holdings with the Securities and Exchange Commission (SEC) for the first and third quarters of each fiscal year as an exhibit to its reports on Form N-PORT. The fund’s Form N-PORT reports are available on the SEC’s website at www.sec.gov.
      Coupon Maturity
Date
Face
Amount
($000)
Market
Value
($000)
U.S. Government and Agency Obligations (77.9%)
U.S. Government Securities (77.9%)
  United States Treasury Inflation Indexed Bonds        0.125%  1/15/23 104,744   104,499
  United States Treasury Inflation Indexed Bonds        0.625%  4/15/23  89,406    88,819
  United States Treasury Inflation Indexed Bonds        0.375%  7/15/23 100,557    99,724
  United States Treasury Inflation Indexed Bonds        0.625%  1/15/24  95,737    94,166
  United States Treasury Inflation Indexed Bonds        0.500%  4/15/24  53,759    52,625
  United States Treasury Inflation Indexed Bonds        0.125%  7/15/24  86,924    84,669
  United States Treasury Inflation Indexed Bonds        0.125% 10/15/24  77,537    75,223
  United States Treasury Inflation Indexed Bonds        0.250%  1/15/25  79,492    76,772
  United States Treasury Inflation Indexed Bonds        2.375%  1/15/25  54,180    54,756
  United States Treasury Inflation Indexed Bonds        0.125%  4/15/25  63,516    60,906
  United States Treasury Inflation Indexed Bonds        0.375%  7/15/25  87,168    84,212
  United States Treasury Inflation Indexed Bonds        0.125% 10/15/25  77,276    73,883
  United States Treasury Inflation Indexed Bonds        0.625%  1/15/26  73,389    70,740
  United States Treasury Inflation Indexed Bonds        2.000%  1/15/26  34,969    35,155
  United States Treasury Inflation Indexed Bonds        0.125%  4/15/26  59,708    56,331
  United States Treasury Inflation Indexed Bonds        0.125%  7/15/26  73,147    69,136
  United States Treasury Inflation Indexed Bonds        0.125% 10/15/26  82,599    77,733
  United States Treasury Inflation Indexed Bonds        0.375%  1/15/27  68,117    64,381
  United States Treasury Inflation Indexed Bonds        2.375%  1/15/27  33,809    34,644
  United States Treasury Inflation Indexed Bonds        0.125%  4/15/27  84,379    78,737
  United States Treasury Inflation Indexed Bonds        0.375%  7/15/27  75,099    70,922
  United States Treasury Inflation Indexed Bonds        1.625% 10/15/27  43,992    44,067
Total U.S. Government and Agency Obligations (Cost $1,657,236) 1,552,100
          Shares  
Temporary Cash Investments (22.8%)
Money Market Fund (3.3%)
1 Vanguard Market Liquidity Fund         3.117%          657,830    65,770
        Maturity
Date
Face
Amount
($000)
 
U.S. Government and Agency Obligations (19.5%)
2 United States Cash Management Bill        3.949%  1/24/23  25,900    25,659
2 United States Cash Management Bill 4.082%–4.094%   2/7/23  36,300    35,899
8

Commodity Strategy Fund
      Coupon Maturity
Date
Face
Amount
($000)
Market
Value

($000)
2,3 United States Treasury Bill        1.998%  11/3/22  23,700    23,697
2,3 United States Treasury Bill        2.058% 11/10/22  40,300    40,273
2,3 United States Treasury Bill        2.897%  1/19/23  52,400    51,943
2,3 United States Treasury Bill 2.842%–2.885%  1/26/23  49,300    48,829
2 United States Treasury Bill 3.023%–3.050%   2/9/23  84,500    83,539
2,3 United States Treasury Bill 3.722%–3.755%   3/9/23  56,800    55,948
2,3 United States Treasury Bill        3.784%  3/16/23  24,000    23,618
                         389,405
Total Temporary Cash Investments (Cost $455,874) 455,175
Total Investments (100.7%) (Cost $2,113,110) 2,007,275
Other Assets and Liabilities—Net (-0.7%) (13,020)
Net Assets (100%) 1,994,255
Cost is in $000.      
See Note A in Notes to Consolidated Financial Statements.
1 Affiliated money market fund available only to Vanguard funds and certain trusts and accounts managed by Vanguard. Rate shown is the 7-day yield.
2 Security is owned by the Vanguard CSF Portfolio, which is a wholly owned subsidiary of the Commodity Strategy Fund.
3 Securities with a value of $34,816,000 have been segregated as collateral for open over-the-counter swap contracts.
  

Derivative Financial Instruments Outstanding as of Period End

Over-the-Counter Total Return Swaps
Reference Entity Termination
Date
Counterparty Notional
Amount
($000)
Fixed
Interest Rate
Received
(Paid)1
(%)
Value and
Unrealized
Appreciation
($000)
Value and
Unrealized
(Depreciation)
($000)
Bloomberg Commodity Index2 11/9/22 MLI 220,000 (0.060) (3,999)
Bloomberg Commodity Index2 11/22/22 BARC 20,000 (0.100) 92
Bloomberg Commodity Index 2 Month Forward2 11/22/22 BARC 215,000 (0.110) 364
Bloomberg Commodity Index 3 Month Forward2 11/22/22 GSI 30,000 (0.120) 63
BofA Merrill Lynch Commodity MLBXAKSV Excess Return Strategy2,3 11/9/22 MLI 130,000 (0.170) (1,072)
BofA Merrill Lynch Commodity MLBXSTGV Excess Return Strategy2,3 11/9/22 MLI 320,000 (0.110) (6,444)
BofA Merrill Lynch Commodity MLCILP3E Excess Return Strategy2,3 11/9/22 MLI 230,000 (0.140) (5,244)
CIBC Commodity CIBZC51EC Excess Return Strategy2,3 11/9/22 CIBC 200,000 (0.160) (3,433)
Goldman Sachs Commodity i-Select Strategy 11292,3 11/22/22 GSI 450,000 (0.120) 582
9

Commodity Strategy Fund
Over-the-Counter Total Return Swaps (continued)
Reference Entity Termination
Date
Counterparty Notional
Amount
($000)
Fixed
Interest Rate
Received
(Paid)1
(%)
Value and
Unrealized
Appreciation
($000)
Value and
Unrealized
(Depreciation)
($000)
Modified Strategy DBS18 on the Bloomberg Commodity Index2,3 11/22/22 GSI 30,000 (0.120) 50
Societe Generale Commodity SGIXCSB1 Excess
Return Strategy2,3
11/9/22 SOCG 150,000 (0.180) (3,507)
          1,151 (23,699)
1 Fixed interest payment received/paid monthly.
2 Security is owned by the subsidiary.
3 Information on the components of the reference entity is available on www.vanguard.com.
  BARC—Barclays Bank plc.
  CIBC—Canadian Imperial Bank of Commerce.
  GSI—Goldman Sachs International.
  MLI—Merrill Lynch International.
  SOCG—Société Generale.
At October 31, 2022, the counterparties had deposited in segregated accounts securities with a value of $4,827,000 in connection with open over-the-counter swap contracts.
See accompanying Notes, which are an integral part of the Financial Statements.
10

Commodity Strategy Fund
Consolidated Statement of Assets and Liabilities
As of October 31, 2022
($000s, except shares and per-share amounts) Amount
Assets  
Investments in Securities, at Value  
Unaffiliated Issuers (Cost $2,047,352) 1,941,505
Affiliated Issuers (Cost $65,758) 65,770
Total Investments in Securities 2,007,275
Investment in Vanguard 80
Cash 118
Receivables for Investment Securities Sold 54,107
Receivables for Accrued Income 1,937
Receivables for Capital Shares Issued 4,624
Unrealized Appreciation—Over-the-Counter Swap Contracts 1,151
Receivables from Broker-Dealer 235
Total Assets 2,069,527
Liabilities  
Payables for Investment Securities Purchased 44,292
Payables for Capital Shares Redeemed 7,086
Payables to Vanguard 195
Unrealized Depreciation—Over-the-Counter Swap Contracts 23,699
Total Liabilities 75,272
Net Assets 1,994,255
At October 31, 2022, net assets consisted of:  
   
Paid-in Capital 1,885,044
Total Distributable Earnings (Loss) 109,211
Net Assets 1,994,255
 
Net Assets  
Applicable to 64,979,653 outstanding $.001 par value shares of
beneficial interest (unlimited authorization)
1,994,255
Net Asset Value Per Share $30.69
  
See accompanying Notes, which are an integral part of the Financial Statements.
11

Commodity Strategy Fund
Consolidated Statement of Operations
  Year Ended
October 31, 2022
  ($000)
Investment Income  
Income  
Interest1 98,752
Total Income 98,752
Expenses  
The Vanguard Group—Note B  
Investment Advisory Services 283
Management and Administrative 3,755
Marketing and Distribution 114
Custodian Fees 24
Auditing Fees 96
Shareholders’ Reports 48
Trustees’ Fees and Expenses—Note B 15
Other Expenses 16
Total Expenses 4,351
Expenses Paid Indirectly (13)
Net Expenses 4,338
Net Investment Income 94,414
Realized Net Gain (Loss)  
Investment Securities Sold1 (22,628)
Swap Contracts 154,601
Realized Net Gain (Loss) 131,973
Change in Unrealized Appreciation (Depreciation)  
Investment Securities1 (120,812)
Swap Contracts (2,731)
Change in Unrealized Appreciation (Depreciation) (123,543)
Net Increase (Decrease) in Net Assets Resulting from Operations 102,844
   
1 Interest income, realized net gain (loss), capital gain distributions received, and change in unrealized appreciation (depreciation) from an affiliated company of the fund were $1,427,000, ($71,000), $4,000, and $2,000, respectively. Purchases and sales are for temporary cash investment purposes.
  
See accompanying Notes, which are an integral part of the Financial Statements.
12

Commodity Strategy Fund
Consolidated Statement of Changes in Net Assets
  Year Ended October 31,
  2022
($000)
2021
($000)
     
Increase (Decrease) in Net Assets    
Operations    
Net Investment Income 94,414 28,926
Realized Net Gain (Loss) 131,973 364,225
Change in Unrealized Appreciation (Depreciation) (123,543) (672)
Net Increase (Decrease) in Net Assets Resulting from Operations 102,844 392,479
Distributions    
Total Distributions (390,043) (2,526)
Capital Share Transactions    
Issued 1,800,077 1,233,852
Issued in Lieu of Cash Distributions 271,967 2,099
Redeemed (1,476,116) (313,092)
Net Increase (Decrease) from Capital Share Transactions 595,928 922,859
Total Increase (Decrease) 308,729 1,312,812
Net Assets    
Beginning of Period 1,685,526 372,714
End of Period 1,994,255 1,685,526
  
See accompanying Notes, which are an integral part of the Financial Statements.
13

Commodity Strategy Fund
Consolidated Financial Highlights
For a Share Outstanding
Throughout Each Period 
Year Ended October 31, June 25,
20191 to
October 31,
2019
2022 2021 2020  
Net Asset Value, Beginning of Period $36.85 $24.32 $24.83 $25.00
Investment Operations        
Net Investment Income2 1.474 .890 .265 .143
Net Realized and Unrealized Gain (Loss) on Investments .751 11.774 (.620) (.313)
Total from Investment Operations 2.225 12.664 (.355) (.170)
Distributions        
Dividends from Net Investment Income (8.385) (.134) (.155)
Distributions from Realized Capital Gains
Total Distributions (8.385) (.134) (.155)
Net Asset Value, End of Period $30.69 $36.85 $24.32 $24.83
Total Return3 9.80% 52.30% -1.45% -0.68%
Ratios/Supplemental Data        
Net Assets, End of Period (Millions) $1,994 $1,686 $373 $207
Ratio of Total Expenses to Average Net Assets 0.21%4 0.20% 0.20% 0.20%5
Ratio of Net Investment Income to Average Net Assets 4.47% 2.79% 1.15% 1.65%5
Portfolio Turnover Rate 47% 15% 38% 7%
1 Inception.
2 Calculated based on average shares outstanding.
3 Total returns do not include account service fees that may have applied in the periods shown. Fund prospectuses provide information about any applicable account service fees.
4 The ratio of expenses to average net assets for the period net of reduction from custody fee offset arrangements was 0.21%.
5 Annualized.
  
See accompanying Notes, which are an integral part of the Financial Statements.
14

Commodity Strategy Fund
Notes to Consolidated Financial Statements
Vanguard Commodity Strategy Fund is registered under the Investment Company Act of 1940 as an open-end investment company, or mutual fund. Significant market disruptions, such as those caused by pandemics (e.g., COVID-19 pandemic), natural or environmental disasters, war (e.g., Russia’s invasion of Ukraine), acts of terrorism, or other events, can adversely affect local and global markets and normal market operations. Any such disruptions could have an adverse impact on the value of the fund’s investments and fund performance.
The Consolidated Financial Statements include Vanguard CSF Portfolio (“the subsidiary”), which commenced operations on June 25, 2019. The subsidiary is wholly owned by the fund and is a unit trust established in the Cayman Islands under the Trusts Law (2011 Revision) of the Cayman Islands, which is organized to invest in certain commodity-linked investments on behalf of the fund, consistent with the fund’s investment objectives and policies. The commodity-linked investments and other investments held by the subsidiary are subject to the same risks that apply to similar investments if held directly by the fund. As of October 31, 2022, the fund held $367,184,000 in the subsidiary, representing 18% of the fund’s net assets. All inter-fund transactions and balances (including the fund’s investment in the subsidiary) have been eliminated, and the Consolidated Financial Statements include all investments and other accounts of the subsidiary as if held directly by the fund.
A. The following significant accounting policies conform to generally accepted accounting principles for U.S. investment companies. The fund consistently follows such policies in preparing its financial statements.
1. Security Valuation: Securities are valued as of the close of trading on the New York Stock Exchange (generally 4 p.m., Eastern time) on the valuation date. Bonds and temporary cash investments are valued using the latest bid prices or using valuations based on a matrix system (which considers such factors as security prices, yields, maturities, and ratings), both as furnished by independent pricing services. Investments in Vanguard Market Liquidity Fund are valued at that fund's net asset value. Securities for which market quotations are not readily available, or whose values have been affected by events occurring before the fund’s pricing time but after the close of the securities’ primary markets, are valued by methods deemed by the valuation designee to represent fair value and subject to oversight by the board of trustees.
2. Swap Contracts: The fund gains exposure to commodities through the subsidiary's investment in swaps that earn the total return on a specified commodity index. Under the terms of the swaps, the subsidiary receives the total return on the specified index (receiving the increase or paying the decrease in the value of the specified index), applied to a notional amount. The subsidiary also pays a fixed rate applied to the notional amount. At the same time, the subsidiary invests an amount approximating the notional amount of the swap in high-quality temporary cash investments.
A risk associated with all types of swaps is the possibility that a counterparty may default on its obligation to pay net amounts due to the subsidiary. The subsidiary’s maximum amount subject to counterparty risk is the unrealized appreciation on the swap contract. The subsidiary mitigates its counterparty risk by entering into swaps only with a diverse group of prequalified counterparties, monitoring their financial strength, entering into master netting arrangements with its counterparties, and requiring its counterparties to transfer collateral as security for their performance. In the absence of a default, the collateral pledged or received by the subsidiary cannot be repledged, resold, or rehypothecated. In the event of a counterparty’s default (including bankruptcy), the subsidiary may terminate any swap contracts with that counterparty, determine
15

Commodity Strategy Fund
the net amount owed by either party in accordance with its master netting arrangements, and sell or retain any collateral held up to the net amount owed to the subsidiary under the master netting arrangements. The swap contracts contain provisions whereby a counterparty may terminate open contracts if the subsidiary net assets decline below a certain level, triggering a payment by the subsidiary if the subsidiary is in a net liability position at the time of the termination. The payment amount would be reduced by any collateral the subsidiary has pledged. Any securities pledged as collateral for open contracts are noted in the Consolidated Schedule of Investments. The value of collateral received or pledged is compared daily to the value of the swap contracts exposure with each counterparty, and any difference, if in excess of a specified minimum transfer amount, is adjusted and settled within two business days.
The notional amounts of swap contracts are not recorded in the Consolidated Statement of Assets and Liabilities. Swaps are valued daily based on market quotations received from independent pricing services or recognized dealers and the change in value is recorded in the Consolidated Statement of Assets and Liabilities as an asset (liability) and in the Consolidated Statement of Operations as unrealized appreciation (depreciation) until periodic payments are made or the termination of the swap, at which time realized gain (loss) is recorded.
During the year ended October 31, 2022, the fund’s average amounts of investments in total return swaps represented 99% of net assets, based on the average of notional amounts at each quarter-end during the period.
The following table summarizes the fund’s derivative assets and liabilities by counterparty for derivatives subject to arrangements that provide for offsetting assets and liabilities.
  Assets
Reflected in
Consolidated
Statement of
Assets and
Liabilities1
($000)
Liabilities
Reflected in
Consolidated
Statement of
Assets and
Liabilities1
($000)
Net Amount
Receivable
(Payable)
($000)
Amounts Not Offset in
the Consolidated
Statement of Assets
and Liabilities
Net
Exposure3
(Not Less
Than $0)
($000)
  Collateral
Pledged2
($000)
Collateral
Received2
($000)
Derivatives Subject to
Offsetting Arrangements, by Counterparty
           
Barclays Bank plc 456 456 2,070 456
Canadian Imperial Bank of Commerce (3,433) (3,433) 1,679
Goldman Sachs International 695 695 4,827
Merrill Lynch International (16,759) (16,759) 25,931
Société Generale (3,507) (3,507) 5,136
Total 1,151 (23,699) (22,548) 34,816 4,827 456
1  Absent an event of default or early termination, derivative assets and liabilities are presented gross and not offset in the Consolidated Statement of Assets and Liabilities.
2  Securities or other assets pledged as collateral are noted in the Consolidated Schedule of Investments and Consolidated Statement of Assets and Liabilities. Securities or other assets received as collateral are held in a segregated account and not included in the fund’s security holdings in the Consolidated Schedule of Investments.
3  Net Exposure represents the net amount receivable from the counterparty in the event of default. Counterparties are not required to exchange collateral if amount is below a specified minimum transfer amount.
16

Commodity Strategy Fund
3. Federal Income Taxes: The fund intends to continue to qualify as a regulated investment company and distribute virtually all of its taxable income. The subsidiary is classified as a foreign corporation for U.S. tax purposes, and because it does not carry on a U.S. trade or business, is generally not subject to U.S. federal income tax. The subsidiary also complies with the Foreign Account Tax Compliance Act ("FATCA") and thus will not be subject to 30% withholding under FATCA on any income from U.S. investments. In addition, the subsidiary is not subject to Cayman Islands income tax. The subsidiary is not required to distribute any earnings and profits to the fund. The fund’s tax returns are open to examination by the relevant tax authorities until expiration of the applicable statute of limitations, which is generally three years after filing the tax return. Management has analyzed the fund’s tax positions taken for all open federal and state income tax years, and has concluded that no provision for income tax is required in the fund’s financial statements.
4. Distributions: Distributions to shareholders are recorded on the ex-dividend date. Distributions are determined on a tax basis at the fiscal year-end and may differ from net investment income and realized capital gains for financial reporting purposes.
5. Credit Facilities and Interfund Lending Program: The fund and certain other funds managed by The Vanguard Group ("Vanguard") participate in a $4.4 billion committed credit facility provided by a syndicate of lenders pursuant to a credit agreement and an uncommitted credit facility provided by Vanguard. Both facilities may be renewed annually. Each fund is individually liable for its borrowings, if any, under the credit facilities. Borrowings may be utilized for temporary or emergency purposes and are subject to the fund’s regulatory and contractual borrowing restrictions. With respect to the committed credit facility, the participating funds are charged administrative fees and an annual commitment fee of 0.10% of the undrawn committed amount of the facility, which are allocated to the funds based on a method approved by the fund’s board of trustees and included in Management and Administrative expenses on the fund’s Consolidated Statement of Operations. Any borrowings under either facility bear interest at an agreed-upon spread plus the higher of the federal funds effective rate, the overnight bank funding rate, or the Daily Simple Secured Overnight Financing Rate inclusive of an additional agreed-upon spread. However, borrowings under the uncommitted credit facility may bear interest based upon an alternate rate agreed to by the fund and Vanguard.
In accordance with an exemptive order (the “Order”) from the SEC, the fund may participate in a joint lending and borrowing program that allows registered open-end Vanguard funds to borrow money from and lend money to each other for temporary or emergency purposes (the “Interfund Lending Program”), subject to compliance with the terms and conditions of the Order, and to the extent permitted by the fund’s investment objective and investment policies. Interfund loans and borrowings normally extend overnight but can have a maximum duration of seven days. Loans may be called on one business day’s notice. The interest rate to be charged is governed by the conditions of the Order and internal procedures adopted by the board of trustees. The board of trustees is responsible for overseeing the Interfund Lending Program.
For the year ended October 31, 2022, the fund did not utilize the credit facilities or the Interfund Lending Program.
6. Other: Interest income includes income distributions received from Vanguard Market Liquidity Fund and is accrued daily. Premiums and discounts on debt securities are amortized and accreted, respectively, to interest income over the lives of the respective securities, except for premiums on certain callable debt securities that are amortized to the earliest call date. Inflation adjustments to
17

Commodity Strategy Fund
the face amount of inflation-indexed securities are included in interest income. Security transactions are accounted for on the date securities are bought or sold. Costs used to determine realized gains (losses) on the sale of investment securities are those of the specific securities sold.
B. In accordance with the terms of a Funds' Service Agreement (the “FSA”) between Vanguard and the fund, Vanguard furnishes to the fund investment advisory, corporate management, administrative, marketing, and distribution services at Vanguard’s cost of operations (as defined by the FSA). These costs of operations are allocated to the fund based on methods and guidelines approved by the board of trustees and are generally settled twice a month.
Under a separate agreement, Vanguard provides corporate management and administrative services to the subsidiary for an annual fee of 0.10% of average net assets of the subsidiary, generally settled once a month. In addition, the subsidiary pays an unaffiliated third party, VGMF I (Cayman) Limited, an affiliate of Maples Trustee Services (Cayman) Limited, a fee plus reasonable additional expenses for trustee services. All of the subsidiary’s expenses are reflected in the Consolidated Statement of Operations and in the Ratio of Total Expenses to Average Net Assets in the Consolidated Financial Highlights.
Upon the request of Vanguard, the fund may invest up to 0.40% of its net assets as capital in Vanguard. At October 31, 2022, the fund had contributed to Vanguard capital in the amount of $80,000, representing less than 0.01% of the fund’s net assets and 0.03% of Vanguard’s capital received pursuant to the FSA. The fund’s trustees and officers are also directors and employees, respectively, of Vanguard.
C. The fund’s custodian bank has agreed to reduce its fees when the fund maintains cash on deposit in the non-interest-bearing custody account. For the year ended October 31, 2022, custodian fee offset arrangements reduced the fund’s expenses by $13,000 (an annual rate of less than 0.01% of average net assets).
D. Various inputs may be used to determine the value of the fund’s investments and derivatives. These inputs are summarized in three broad levels for financial statement purposes. The inputs or methodologies used to value securities are not necessarily an indication of the risk associated with investing in those securities.
Level 1—Quoted prices in active markets for identical securities.
Level 2—Other significant observable inputs (including quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.).
Level 3—Significant unobservable inputs (including the fund’s own assumptions used to determine the fair value of investments). Any investments and derivatives valued with significant unobservable inputs are noted on the Consolidated Schedule of Investments.
18

Commodity Strategy Fund
The following table summarizes the market value of the fund’s investments and derivatives as of October 31, 2022, based on the inputs used to value them:
  Level 1
($000)
Level 2
($000)
Level 3
($000)
Total
($000)
Investments        
Assets        
U.S. Government and Agency Obligations 1,552,100 1,552,100
Temporary Cash Investments 65,770 389,405 455,175
Total 65,770 1,941,505 2,007,275
Derivative Financial Instruments        
Assets        
Swap Contracts 1,151 1,151
Liabilities        
Swap Contracts 23,699 23,699
E. Permanent differences between book-basis and tax-basis components of net assets are reclassified among capital accounts in the financial statements to reflect their tax character. These reclassifications have no effect on net assets or net asset value per share. As of period end, permanent differences primarily attributable to the accounting for applicable operations of the subsidiary were reclassified between the individual components of total distributable earnings (loss).
Temporary differences between book-basis and tax-basis components of total distributable earnings (loss) arise when certain items of income, gain, or loss are recognized in different periods for financial statement and tax purposes; these differences will reverse at some time in the future. The differences are primarily related to the deferral of losses from wash sales; and amortization adjustments from certain fixed income securities. As of period end, the tax-basis components of total distributable earnings (loss) are detailed in the table as follows:
  Amount
($000)
Undistributed Ordinary Income 237,921
Undistributed Long-Term Gains
Capital Loss Carryforwards (18,622)
Qualified Late-Year Losses
Net Unrealized Gains (Losses) (110,088)
19

Commodity Strategy Fund
The tax character of distributions paid was as follows:
  Year Ended October 31,
  2022
Amount
($000)
2021
Amount
($000)
Ordinary Income* 390,043 2,526
Long-Term Capital Gains
Total 390,043 2,526
* Includes short-term capital gains, if any.
As of October 31, 2022, gross unrealized appreciation and depreciation for investments and derivatives based on cost for U.S. federal income tax purposes were as follows:
  Amount
($000)
Tax Cost 2,117,363
Gross Unrealized Appreciation 3,351
Gross Unrealized Depreciation (113,439)
Net Unrealized Appreciation (Depreciation) (110,088)
F. During the year ended October 31, 2022, the fund purchased $1,150,565,000 of investment securities and sold $661,128,000 of investment securities, other than temporary cash investments.
G. Capital shares issued and redeemed were:
    
  Year Ended October 31,
  2022
Shares
(000)
2021
Shares
(000)
     
Issued 54,611 40,091
Issued in Lieu of Cash Distributions 10,325 81
Redeemed (45,700) (9,752)
Net Increase (Decrease) in Shares Outstanding 19,236 30,420
H. Management has determined that no events or transactions occurred subsequent to October 31, 2022, that would require recognition or disclosure in these financial statements.
20

Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Vanguard Trustees' Equity Fund and Shareholders of Vanguard Commodity Strategy Fund
Opinion on the Financial Statements
We have audited the accompanying consolidated statement of assets and liabilities, including the consolidated schedule of investments, of Vanguard Commodity Strategy Fund and its subsidiary (one of the funds constituting Vanguard Trustees' Equity Fund, referred to hereafter as the "Fund") as of October 31, 2022, the related consolidated statement of operations for the year ended October 31, 2022, the consolidated statement of changes in net assets for each of the two years in the period ended October 31, 2022, including the related notes, and the consolidated financial highlights for each of the three years in the period ended October 31, 2022 and for the period June 25, 2019 (inception) through October 31, 2019 (collectively referred to as the "consolidated financial statements"). In our opinion, the consolidated financial statements present fairly, in all material respects, the financial position of the Fund as of October 31, 2022, the results of its operations for the year then ended, the changes in its net assets for each of the two years in the period ended October 31, 2022 and the financial highlights for each of the three years in the period ended October 31, 2022 and for the period June 25, 2019 (inception) through October 31, 2019 in conformity with accounting principles generally accepted in the United States of America.
Basis for Opinion
These consolidated financial statements are the responsibility of the Fund’s management. Our responsibility is to express an opinion on the Fund’s consolidated financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Fund in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.
We conducted our audits of these consolidated financial statements in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the consolidated financial statements are free of material misstatement, whether due to error or fraud.
Our audits included performing procedures to assess the risks of material misstatement of the consolidated financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the consolidated financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the consolidated financial statements. Our procedures included confirmation of securities owned as of October 31, 2022 by correspondence with the custodian, transfer agent and brokers; when replies were not received from brokers, we performed other auditing procedures. We believe that our audits provide a reasonable basis for our opinion.
/s/PricewaterhouseCoopers LLP
Philadelphia, Pennsylvania
December 16, 2022
We have served as the auditor of one or more investment companies in The Vanguard Group of Funds since 1975.
21


Tax information (unaudited)
The fund hereby designates $91,946,000, or if subsequently determined to be different, the maximum amount allowable by law, of interest earned from obligations of the U.S. government which is generally exempt from state income tax.
The fund hereby designates 23.8%, or if subsequently determined to be different, the maximum percentage allowable by law, of ordinary income dividends eligible to be treated as interest income for purposes of Section 163(j) and the regulations thereunder for the fiscal year.
22

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The People Who Govern Your Fund
The trustees of your mutual fund are there to see that the fund is operated and managed in your best interests since, as a shareholder, you are a part owner of the fund. Your fund’s trustees also serve on the board of directors of The Vanguard Group, Inc., which is owned by the Vanguard funds and provides services to them. 
A majority of Vanguard’s board members are independent, meaning that they have no affiliation with Vanguard or the funds they oversee, apart from the sizable personal investments they have made as private individuals. The independent board members have distinguished backgrounds in business, academia, and public service. Each of the trustees and executive officers oversees 206 Vanguard funds.
Information for each trustee and executive officer of the fund appears below. That information, as well as the Vanguard fund count, is as of the date on the cover of this fund report. The mailing address of the trustees and officers is P.O. Box 876, Valley Forge, PA 19482. More information about the trustees is in the Statement of Additional Information, which can be obtained, without charge, by contacting Vanguard at 800-662-7447, or online at vanguard.com.
Interested Trustee1
Mortimer J. Buckley
Born in 1969. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: chairman of the board (2019–present) of Vanguard and of each of the investment companies served by Vanguard; chief executive officer (2018–present) of Vanguard; chief executive officer, president, and trustee (2018–present) of each of the investment companies served by Vanguard; president and director (2017–present) of Vanguard; and president (2018–present) of Vanguard Marketing Corporation. Chief investment officer (2013–2017), managing director (2002–2017), head of the Retail Investor Group (2006–2012), and chief information officer (2001–2006) of Vanguard. Member of the board of governors of the Investment Company Institute and the board of governors of FINRA. Trustee and vice chair of The Shipley School.
Independent Trustees
Tara Bunch
Born in 1962. Trustee since November 2021. Principal occupation(s) during the past five years and other experience: head of global operations at Airbnb (2020–present). Vice president of AppleCare (2012–2020). Member of the board of directors of Out & Equal (2002–2006), the advisory board of the University of California, Berkeley School of Engineering (2020–present), and the advisory board
of Santa Clara University’s Leavey School of Business (2018–present).
Emerson U. Fullwood
Born in 1948. Trustee since January 2008. Principal occupation(s) during the past five years and other experience: executive chief staff and marketing officer for North America and corporate vice president (retired 2008) of Xerox Corporation (document management products and services). Former president of the Worldwide Channels Group, Latin America, and Worldwide Customer Service and executive chief staff officer of Developing Markets of Xerox. Executive in residence and 2009–2010 Distinguished Minett Professor at the Rochester Institute of Technology. Member of the board of directors of the University of Rochester Medical Center, the Monroe Community College Foundation, the United Way of Rochester, North Carolina A&T University, Roberts Wesleyan College, and the Rochester Philharmonic Orchestra. Trustee of the University of Rochester.                       
F. Joseph Loughrey
Born in 1949. Trustee since October 2009. Principal occupation(s) during the past five years and other experience: president and chief operating officer (retired 2009) and vice chairman of the board (2008–2009) of Cummins Inc. (industrial machinery). Chairman of the board of Hillenbrand, Inc. (specialized consumer services). Director of the V Foundation. Member of the advisory council for the College of
 
1  Mr. Buckley is considered an “interested person,” as defined in the Investment Company Act of 1940, because he is an officer of the Vanguard funds.

Arts and Letters at the University of Notre Dame. Chairman of the board of Saint Anselm College.
Mark Loughridge
Born in 1953. Trustee since March 2012. Principal occupation(s) during the past five years and other experience: senior vice president and chief financial officer (retired 2013) of IBM (information technology services). Fiduciary member of IBM’s Retirement Plan Committee (2004–2013), senior vice president and general manager (2002–2004) of IBM Global Financing, vice president and controller (1998–2002) of IBM, and a variety of other prior management roles at IBM. Member of the Council on Chicago Booth.
Scott C. Malpass
Born in 1962. Trustee since March 2012. Principal occupation(s) during the past five years and other experience: adjunct professor of finance at the University of Notre Dame (2020–present). Chief investment officer (retired 2020) and vice president (retired 2020) of the University of Notre Dame. Assistant professor (retired June 2020) of finance at the Mendoza College of Business, University of Notre Dame, and member of the Notre Dame 403(b) Investment Committee. Member of the board of Catholic Investment Services, Inc. (investment advisors), the board of superintendence of the Institute for the Works of Religion, and the board of directors of Paxos Trust Company (finance).
Deanna Mulligan
Born in 1963. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: chief executive officer of Purposeful (advisory firm for CEOs and C-level executives; 2021–present). Board chair (2020), chief executive officer (2011–2020), and president (2010–2019) of The Guardian Life Insurance Company of America. Chief operating officer (2010–2011) and executive vice president (2008–2010) of Individual Life and Disability of the Guardian Life Insurance Company of America. Member of the board of the Economic Club of New York. Trustee of the Partnership for New York City (business leadership), Chief Executives for Corporate Purpose, and the NewYork-Presbyterian Hospital.
André F. Perold
Born in 1952. Trustee since December 2004. Principal occupation(s) during the past five years and other experience: George Gund Professor of Finance and Banking, Emeritus at the Harvard Business School (retired 2011). Chief investment officer and co-managing partner of HighVista Strategies (private investment firm). Member of the board (2018–present) of RIT Capital Partners (investment
firm). Member of the investment committee of Partners Health Care System.
Sarah Bloom Raskin
Born in 1961. Trustee since January 2018. Principal occupation(s) during the past five years and other experience: deputy secretary (2014–2017) of the United States Department of the Treasury. Governor (2010–2014) of the Federal Reserve Board. Commissioner (2007–2010) of financial regulation for the State of Maryland. Colin W. Brown Distinguished Professor of the Practice of Law (2021–present), professor (2020–present), Distinguished Fellow of the Global Financial Markets Center (2020–present), and Rubenstein Fellow (2017–2020) at Duke University. Trustee (2017–present) of Amherst College and member of Amherst College Investment Committee (2019–present). Member of the Regenerative Crisis Response Committee (2020–present).
David A. Thomas
Born in 1956. Trustee since July 2021. Principal occupation(s) during the past five years and other experience: president of Morehouse College (2018–present). Professor of business administration, emeritus at Harvard University (2017–2018). Dean (2011–2016) and professor of management (2016–2017) at the Georgetown University McDonough School of Business. Director of DTE Energy Company (2013–present). Trustee of Common Fund (2019–present).
Peter F. Volanakis
Born in 1955. Trustee since July 2009. Principal occupation(s) during the past five years and other experience: president and chief operating officer (retired 2010) of Corning Incorporated (communications equipment) and director of Corning Incorporated (2000–2010) and Dow Corning (2001–2010). Director (2012) of SPX Corporation (multi-industry manufacturing). Overseer of the Amos Tuck School of Business Administration, Dartmouth College (2001–2013). Member of the BMW Group Mobility Council.

Executive Officers
Christine M. Buchanan
Born in 1970. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Chief financial officer (2021–present) and treasurer (2017–present) of each of the investment companies served by Vanguard. Partner (2005–2017) at KPMG (audit, tax, and advisory services).
John Galloway
Born in 1973. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Investment stewardship officer (September 2020–present) of each of the investment companies served by Vanguard. Head of Investor Advocacy (February 2020–present) and head of Marketing Strategy and Planning (2017–2020) at Vanguard. Special assistant to the President of the United States (2015).
Ashley Grim
Born in 1984. Principal occupation(s) during the past five years and other experience: treasurer (February 2022–present) of each of the investment companies served by Vanguard. Fund transfer agent controller (2019–2022) and director of Audit Services (2017–2019) at Vanguard. Senior manager (2015–2017) at PriceWaterhouseCoopers (audit and assurance, consulting, and tax services).
Peter Mahoney
Born in 1974. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Controller (2015–present) of each of the investment companies served by Vanguard. Head of International Fund Services (2008–2014) at Vanguard.
Anne E. Robinson
Born in 1970. Principal occupation(s) during the past five years and other experience: general counsel (2016–present) of Vanguard. Secretary (2016–present) of Vanguard and of each of the investment companies served by Vanguard. Managing director (2016–present) of Vanguard. Managing director and general counsel of Global Cards and Consumer Services (2014–2016) at Citigroup. Counsel (2003–2014) at American Express. Nonexecutive director of the board of National Grid (energy).
Michael Rollings
Born in 1963. Principal occupation(s) during the past five years and other experience: finance director (2017–present) and treasurer (2017) of each of the investment companies served by Vanguard. Managing director (2016–present) of Vanguard. Chief financial officer (2016–present) of Vanguard. Director (2016–present) of Vanguard Marketing Corporation. Executive vice president and chief financial officer (2006–2016) of MassMutual Financial Group.
John E. Schadl
Born in 1972. Principal occupation(s) during the past five years and other experience: principal of Vanguard. Chief compliance officer (2019–present) of Vanguard and of each of the investment companies served by Vanguard. Assistant vice president (2019–present) of Vanguard Marketing Corporation.
Vanguard Senior Management Team
Matthew Benchener Thomas M. Rampulla
Joseph Brennan Karin A. Risi
Mortimer J. Buckley Anne E. Robinson
Gregory Davis Michael Rollings
John James Nitin Tandon
Chris D. Mclsaac Lauren Valente

Connect with Vanguard®>vanguard.com
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This material may be used in conjunction with the offering of shares of any Vanguard fund only if preceded or accompanied by the fund’s current prospectus.
All comparative mutual fund data are from Morningstar, Inc., unless otherwise noted.
You can obtain a free copy of Vanguard’s proxy voting guidelines by visiting vanguard.com/proxyreporting or by calling Vanguard at 800-662-2739. The guidelines are also available from the SEC’s website, www.sec.gov. In addition, you may obtain a free report on how your fund voted the proxies for securities it owned during the 12 months ended June 30. To get the report, visit either vanguard.com/proxyreporting or www.sec.gov.
You can review information about your fund on the SEC’s website, and you can receive copies of this information, for a fee, by sending a request via email addressed to publicinfo@sec.gov.
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Q5170 122022

 

Item 2: Code of Ethics.

 

The Registrant has adopted a code of ethics that applies to the Registrant’s principal executive officer, principal financial officer, principal accounting officer or controller or persons performing similar functions. The Code of Ethics was amended during the reporting period covered by this report to make certain technical, non-material changes.

 

Item 3: Audit Committee Financial Expert.

 

All members of the Audit Committee have been determined by the Registrant’s Board of Trustees to be Audit Committee Financial Experts and to be independent: F. Joseph Loughrey, Mark Loughridge, Sarah Bloom Raskin, and Peter F. Volanakis.

 

Item 4: Principal Accountant Fees and Services.

 

(a)        Audit Fees.

 

Audit Fees of the Registrant.

 

Fiscal Year Ended October 31, 2022: $182,000
Fiscal Year Ended October 31, 2021: $192,000

 

Aggregate Audit Fees of Registered Investment Companies in the Vanguard Group.

 

Fiscal Year Ended October 31, 2022: $10,494,508
Fiscal Year Ended October 31, 2021: $11,244,694

 

Includes fees billed in connection with audits of the Registrant, other registered investment companies in the Vanguard complex, The Vanguard Group, Inc., and Vanguard Marketing Corporation.

 

(b)          Audit-Related Fees.

 

Fiscal Year Ended October 31, 2022: $2,757,764
Fiscal Year Ended October 31, 2021: $2,955,181

 

Includes fees billed in connection with assurance and related services provided to the Registrant, other registered investment companies in the Vanguard complex, The Vanguard Group, Inc., and Vanguard Marketing Corporation.

 

(c)          Tax Fees.

 

Fiscal Year Ended October 31, 2022: $5,202,689
Fiscal Year Ended October 31, 2021: $2,047,574

 

Includes fees billed in connection with tax compliance, planning, and advice services provided to the Registrant, other registered investment companies in the Vanguard complex, The Vanguard Group, Inc., and Vanguard Marketing Corporation.

 

(d)          All Other Fees.

 

Fiscal Year Ended October 31, 2022: $298,000
Fiscal Year Ended October 31, 2021: $280,000

 

Includes fees billed for services related to tax reported information provided to the Registrant, other registered investment companies in the Vanguard complex, The Vanguard Group, Inc., and Vanguard Marketing Corporation.

 

(e)          (1) Pre-Approval Policies. The policy of the Registrant’s Audit Committee is to consider, and, if appropriate, approve before the principal accountant is engaged for such services, all specific audit and non-audit services provided to: the Registrant, other registered investment companies in the Vanguard complex, The Vanguard Group, Inc., and entities controlled by The Vanguard Group, Inc. that provide ongoing services to the Registrant. In making a determination, the Audit Committee considers whether the services are consistent with maintaining the principal accountant’s independence.

 

 

 

 

In the event of a contingency situation in which the principal accountant is needed to provide services in between scheduled Audit Committee meetings, the Chairman of the Audit Committee would be called on to consider and, if appropriate, pre-approve audit or permitted non-audit services in an amount sufficient to complete services through the next Audit Committee meeting, and to determine if such services would be consistent with maintaining the accountant’s independence. At the next scheduled Audit Committee meeting, services and fees would be presented to the Audit Committee for formal consideration, and, if appropriate, approval by the entire Audit Committee. The Audit Committee would again consider whether such services and fees are consistent with maintaining the principal accountant’s independence.

 

The Registrant’s Audit Committee is informed at least annually of all audit and non-audit services provided by the principal accountant to the Vanguard complex, whether such services are provided to: the Registrant, other registered investment companies in the Vanguard complex, The Vanguard Group, Inc., or other entities controlled by The Vanguard Group, Inc. that provide ongoing services to the Registrant.

 

(2) No percentage of the principal accountant’s fees or services were approved pursuant to the waiver provision of paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X.

 

(f)          For the most recent fiscal year, over 50% of the hours worked under the principal accountant’s engagement were not performed by persons other than full-time, permanent employees of the principal accountant.

 

(g)         Aggregate Non-Audit Fees.

 

Fiscal Year Ended October 31, 2022: $5,500,689
Fiscal Year Ended October 31, 2021: $2,327,574

 

Includes fees billed for non-audit services provided to the Registrant, other registered investment companies in the Vanguard complex, The Vanguard Group, Inc., and Vanguard Marketing Corporation.

 

(h)          For the most recent fiscal year, the Audit Committee has determined that the provision of all non-audit services was consistent with maintaining the principal accountant’s independence.

 

Item 5: Audit Committee of Listed Registrants.

 

The Registrant is a listed issuer as defined in rule 10A-3 under the Securities Exchange Act of 1934 (“Exchange Act”). The Registrant has a separately-designated standing audit committee established in accordance with Section 3(a)(58)(A) of the Exchange Act. The Registrant’s audit committee members are: F. Joseph Loughrey, Mark Loughridge, Sarah Bloom Raskin, and Peter F. Volanakis.

 

 

 

 

Item 6: Investments.

 

Not applicable. The complete schedule of investments is included as part of the report to shareholders filed under Item 1 of this Form.

 

Item 7: Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.

 

Not applicable.

 

Item 8: Portfolio Managers of Closed-End Management Investment Companies.

 

Not applicable.

 

Item 9: Purchase of Equity Securities by Closed-End Management Investment Company and Affiliated Purchasers.

 

Not applicable.

 

Item 10: Submission of Matters to a Vote of Security Holders.

 

Not applicable.

 

Item 11: Controls and Procedures.

 

(a) Disclosure Controls and Procedures. The Principal Executive and Financial Officers concluded that the Registrant’s Disclosure Controls and Procedures are effective based on their evaluation of the Disclosure Controls and Procedures as of a date within 90 days of the filing date of this report.

 

(b) Internal Control Over Financial Reporting. There were no significant changes in the Registrant’s Internal Control Over Financial Reporting or in other factors that could significantly affect this control subsequent to the date of the evaluation, including any corrective actions with regard to significant deficiencies and material weaknesses.

 

Item 12: Disclosure of Securities Lending Activities for Closed-End Management Investment Companies.

 

Not applicable.

 

Item 13: Exhibits.

 

(a)(1) Code of Ethics filed herewith.
(a)(2) Certifications filed herewith.
(b) Certifications filed herewith.

 

 

 

 

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

 

  VANGUARD TRUSTEES’ EQUITY fund
     
BY: /s/ MORTIMER J. BUCKLEY*  
  MORTIMER J. BUCKLEY  
  CHIEF EXECUTIVE OFFICER  

 

Date: December 19, 2022

 

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

 

  VANGUARD trustees’ equity fund
     
BY: /s/ MORTIMER J. BUCKLEY*  
  MORTIMER J. BUCKLEY  
  CHIEF EXECUTIVE OFFICER  

 

Date: December 19, 2022

 

  VANGUARD trustees’ equity fund
     
BY: /s/ CHRISTINE BUCHANAN*  
  CHRISTINE BUCHANAN  
  CHIEF FINANCIAL OFFICER  

 

Date: December 19, 2022

 

* By:/s/ Anne E. Robinson  

 

Anne E. Robinson, pursuant to a Power of Attorney filed on October 11, 2022 (see File Number 333-11763), Incorporated by Reference.

 

 

 

 

Exhibit 99.CODEETH

 

 

 

Access Person Code of Conduct

 

Effective Date: 01 March 2022 | Contact: Code_of_Ethics@vanguard.com

 

 

Background – Why This Access Person Code of Conduct Matters 

 

Vanguard was founded with a singular focus on clients and serving their best interests, and this has been the foundation of our strong ethical culture. One way in which we consistently seek to earn and maintain the trust and loyalty of our clients is by adhering to the highest standards of ethical behavior. Acting with integrity and complying with applicable laws and regulations necessarily extends to your conduct in general and to your personal investing and trading activities in particular.

 

Some crew and contingent workers at Vanguard, by virtue of their role or department, are designated as an “Access Person” (i.e., an Advisor Access Person, Fund Access Person, or Investment Access Person) because they or their department are authorized to know about present or future transactions by Vanguard funds, or have the authority to influence those transactions, or otherwise have access to sensitive market or client activity. Because of that knowledge, authority, and access, Access Persons are subject to additional standards of business conduct, stricter personal investment rules, and greater oversight, among other things. These standards and rules, as set forth in this Access Person Code of Conduct (APCC)1, have been adopted with the goals of ensuring we comply with applicable law and avoiding conflicts of interest or the appearance of conflicts of interest. This is especially true regarding any potential conflicts of interest that could arise between the securities trading that Vanguard undertakes on behalf of the Vanguard funds or our clients and the personal securities trading by crew, contingent workers, and their household or family members.

 

Policy Coverage

 

To Whom Does the APCC Apply? 

 

This policy2 applies to all crew members and contingent workers globally who are in a role that has been designated as an “Access Person” role. Certain provisions of this policy also apply to Associated Persons. 

 

Are you an Access Person? Visit Appendix A to learn whether the role you’re in is an Access Person role, and if so, which Access Person “designation” applies.

 

What about Non-Access Persons? Any crew member or contingent worker who is not in a role that has been designated as an Access Person role is a “Non-Access Person” and must comply with the Personal Investment Activity Policy for Non-Access Persons, not this policy.

 

Are you a contingent worker? A “contingent worker” is any person other than a crew member who provides services to or on behalf of Vanguard through staffing firms, consulting

 

 

 

1 The APCC constitutes the code of ethics that the Vanguard funds have adopted in compliance with U.S. SEC Rules 17j-1 and 204A-1.

 

2 The APCC is a policy that has been created and approved, and is governed, similar to other policies at Vanguard. As used herein, references to “this policy” mean the APCC.

 

Page 1 of 37

 

 

 

 

firms, service providers, or as independent contractors. Like crew, a contingent worker can be in either an Access Person or Non-Access Person role.

 

What about Associated Persons? For U.S. crew and contingent workers who are Associated Persons (to reiterate, not Access Persons, but Associated Persons) under FINRA rules and regulations, please note you have additional investment-related obligations under the FINRA Licensing Policy, including the Securities Account Reporting Obligations for Associated Persons. Please review and comply with those documents, as well.

 

Policy Overview 

 

There are four primary sections to this policy: 

 

Section 1 – Standards of Business Conduct, sets forth rules and expectations regarding your behavior and conduct. 

 

Section 2 – Personal Investment Activities, contains rules on how you and your Household or Family Members may own and trade securities for your own personal benefit. Note that some of these rules differ based on your Access Person designation. While the details are set forth in Section 2, at a high level there are four subsections applicable to you and your personal investment activities: 

A – Reminders on who is covered 

B – Brokerage firms you may use 

C – Disclosure obligations 

D – Investment and trading restrictions  

 

Section 3 – Penalties and Sanctions, describes how violations of this policy are addressed and enforced.

 

Section 4 – Defined terms, provides definitions for the capitalized terms used in this policy.

 

Please carefully read the rest of this policy and ensure you understand and comply with its terms. Understanding and following this policy is one of the most important ways we can ensure our clients’ interests always come first.

 

Be sure you are familiar with the following other Vanguard policies that relate to your ethical conduct and personal investment activities:

 

·       Standards of Conduct Policy

·       Conflicts of Interest Policy

·       Insider Trading Policy

·       Outside Business Activity Policy

 

Please also ensure you are familiar with Vanguard’s Code of Ethical Conduct

 

 

Policy Requirements 

 

Section 1 – Standards of Business Conduct 

 

Everyone at Vanguard is expected to promote high standards of integrity and manage the company’s affairs honestly and ethically. We all have a personal responsibility to conduct ourselves

 

Page 2 of 37

 

 

 

 

in a manner that reflects a commitment to ethics and compliance with all applicable laws and regulations. Doing so is part and parcel of Vanguard’s mission to “take a stand for all investors, to treat them fairly, and to give them the best chance for investment success.”

 

Putting these values into practice means having and adhering to expected standards of business conduct. The Vanguard policy that explains these standards is the Standards of Conduct Policy, which is incorporated herein by reference. You must comply with that policy, including the following standards of conduct that are explained therein:

 

1.Always put Vanguard clients’ interests first and treat them fairly. 
2.Avoid conflicts of interest. 
3.Be candid and clear with clients and provide them with accurate information. 
4.Comply with applicable laws, rules, regulations, and policies. 
5.Comply with applicable professional standards. 
6.Complete mandatory training and regularly certify that you are compliant with our policies. 
7.Maintain accurate, timely, and complete business records. 
8.Protect against fraud. 
9.Lead by example. 
10.Speak up. 

 

At Vanguard, you are expected to always do the right thing. It sounds simple and it’s usually very clear what doing the right thing entails. But sometimes it isn’t. How do you make the best choice when facing difficult or unclear circumstances? How do you navigate an ethical dilemma?

 

In those situations, you should pause and reflect, and then work through the following “ethical decision-making guide.” This guide will help you consider important questions before deciding whether or how to proceed with an action. It is not a substitute for this or any policy, and it may not tell you exactly what to do in every situation, but it can be used as a tool to help guide you when you face an ethical dilemma or a complex situation where the answer might not be clear.

 

If you’re still in doubt as you work through the decision-making guide, err on the side of caution—ask questions, elevate the issue, and enlist the help of others to ensure we reach the right answer every time for Vanguard and our clients.

 

 

Page 3 of 37

 

 

 

 

Speaking Up – As mentioned above, you are encouraged to help protect our clients, crew, and Vanguard by reporting concerns about ethics, financial or business integrity, information security and privacy, workplace practices, or alleged violations of policy, regulation, or law. Indeed, speaking up is one of the most effective ways to help ensure Vanguard maintains its high standards for ethics and compliance. To that end, if you become aware that you or anyone else violated any of the terms of this policy, you must contact Compliance immediately.

 

Likewise, it is your responsibility to know whether the role you are in is designated as an Access Person, and if so, which Access Person designation applies to you (visit the Appendix A to learn more). It is also your responsibility to know the policies and trading restrictions that apply to you accordingly, and to ask questions if you are unsure.

 

Section 2 – Personal Investment Activities 

 

Introduction 

 

Vanguard recognizes the importance to crew and contingent workers of being able to manage and develop their own financial resources through long-term investments and strategies. With that in mind, the rules and requirements set forth in this policy have been adopted with the goals of (1) ensuring we comply with all applicable laws and regulations, and (2) avoiding any conflicts of interest, or any appearances of conflicts of interest, between the securities trading that Vanguard undertakes on behalf of Vanguard funds or our clients and the personal securities trading or investing by crew, contingent workers, or their Household or Family Members (defined in Section 4, below). Our industry and Vanguard have implemented certain standards and limitations designed to minimize these conflicts and help ensure that we focus on meeting our duty to clients.

 

Granted, the rules in this policy are demanding and strict and they may feel like an imposition. But at Vanguard, we take our ethical obligations very seriously, and the rules in this policy are intended to ensure that trading on behalf of Vanguard funds and clients are given priority over trading for your personal accounts, and that trades for your personal accounts do not adversely affect trades for our funds or clients.

 

Similarly, keep in mind that you must comply with applicable securities laws and must avoid taking personal advantage of your knowledge of securities activity in Vanguard funds or client accounts.

 

This policy includes specific restrictions on personal investing but cannot anticipate every fact pattern or situation. You should adhere to the spirit, and not just the letter, of this policy.

 

Compliance will keep all records relating to personal account trading as confidential as necessary. Information will be accessible within Compliance and may be reported to senior management or HR. Records may also need to be made available to Internal Audit and/or any regulator. All non-U.S. crew and contingent workers are required to sign a data consent / data privacy notice.

 

The Compliance Department reserves the right to monitor any and all investment or trading activity by you or by any Household or Family Member based on any information or system to which it has access.

 

Page 4 of 37

 

 

 

 

Checklist 

 

Given the complexity of this policy and the steps you must take to ensure you remain in compliance with it, we have created this brief checklist to help you keep track of your obligations. This is merely a summary, so be sure to comply with the full terms of this policy as well.

 

Checklist item  Where this topic is covered in this policy 
¨       I know my Access Person “designation,” and I am aware that this policy applies not only to me but also to my Household or Family Members Subsection 2-A – Who Is Covered Under this Policy 
¨       For the region where I work, I know what brokerage firm I and my Household or Family Members may use to maintain the accounts where I or they hold and trade Reportable Securities Subsection 2-B – Brokerage Firms You May Use 
¨       For my Access Person designation, I know the initial and ongoing account and holdings disclosure obligations that apply to me and my Household or Family Members Subsection 2-C – Disclosure Obligations 
¨       For my Access Person designation, I know the rules and limitations for transacting securities in my personal accounts and those of my Household or Family Members Subsections 2-D-1 and 2-D-2 – Investment and Trading Restrictions 
¨       For Fund Access Person and Investment Access Person designations, I know how to seek trade preclearance Subsection 2-D-3 – How to Seek and Abide by Preclearance Requirements 
¨       I know the penalties and sanctions that may apply for violations of any of the requirements under this policy Section 3 – Penalties and Sanctions 
¨       I understand the meaning of the defined terms used in this policy  Section 4 – Defined Terms 

 

 

Quick Tip: 

 

The rules in this policy cover most of the personal investing situations you are likely to find. Yet it’s always possible you will encounter a situation that isn’t fully addressed by the rules. If that happens, you need to know what to do. The easiest way to make sure you are making the right decision is to follow these three principles: 

 

1. Know the policy. If you think your situation isn’t covered, check again. It never hurts to take a second look at the rules. 

 

2. Seek guidance. Asking questions is always appropriate. Talk with your manager or contact Compliance if you’re not sure about the policy requirements or how they apply to your situation. 

 

3. Use sound judgment. Analyze the situation and weigh the options. Think about how your decision would look to someone outside of Vanguard. 

 

 

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Note for crew in China: 

 

Because you may not have access to MCO, different systems and procedures are in place for you to disclose accounts and holdings. Please consult with your manager or the China Compliance team to learn more.

 

Subsection 2-A – Who Is Covered Under this Policy 

 

As stated in the introduction to this policy, above, this policy applies to all crew members and contingent workers globally who are in a role that has been designated as an “Access Person” role.

 

Access Persons are covered – This policy applies to crew and contingent worker Access Persons and, in certain instances, to their Household or Family Members.

 

oAccess Persons – Please note that the specific trading prohibitions and reporting requirements vary depending on your Access Person “designation,” meaning Advisor Access Person, Fund Access Person, or Investment Access Person. To learn the Access Person designation that applies to your role, visit Appendix A. Note further that, regardless of your designation, the Compliance Department has the authority, with appropriate notice to you, to apply to you any or all of the trading restrictions within this policy

 

oHousehold or Family Members – Certain aspects of this policy apply not only to you but to your Household or Family Members, as well. Why? Doing so is required by applicable law and regulations in many jurisdictions. It is also consistent with industry best practices and helps Vanguard ensure we are effectively monitoring and guarding against conflicts of interest and other issues. See Section 4, below, for the definition of Household or Family Members in the region where you work.

 

Non-Access Persons are not covered – If the role you are in is not an Access Person role, you do not need to comply with this policy; instead, with regard to your personal investments, you must comply with the Personal Investment Activity Policy for Non-Access Persons (and other applicable policies). Note, however, that in the event a Non-Access Person is a Household or Family Member of an Access Person, then the terms of this policy will apply to the Non-Access Person as a Household or Family Member hereunder and any conflicting terms of this policy will take precedence over the Personal Investment Activity Policy for Non-Access Persons.

 

Associated Persons also have obligations under other policies and documents – For U.S. crew and contingent workers who are deemed to be Associated Persons (to reiterate, not Access Persons, but Associated Persons) under the FINRA Licensing Policy, you have certain obligations under this policy and have additional investment-related obligations under the FINRA Licensing Policy and the Securities Account Reporting Obligations for Associated Persons.

 

Your designation may change – Keep in mind that your Access Person designation may change over time, for instance if you change roles, if there are changes made in your department, or if the Compliance Department determines a designation change is appropriate. You are advised to regularly consult the My Ethics and Compliance Resource Center available on CrewNet to check your designation. 

 

Subsection 2-B – Brokerage Firms You May Use 

 

The terms of Subsection 2-B apply to all Access Person designations.

 

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The following requirements and restrictions on which brokerage firms you may use to hold and transact Reportable Securities apply to you based on whether you are a crew member or contingent worker and where you work:

 

 

U.S. Crew:

Crew who are Access Persons employed in the U.S., and their Household or Family Members (parts (a) and (b) of that defined term only), must maintain and trade all Reportable Securities in a Vanguard Brokerage Account (VBA). This obligation does not apply to any Household or Family Members covered under part (c) of that defined term. See the Defined Terms in Section 4, below, for all definitions.

 

Securities or investments that are not “Reportable Securities” may be held in a brokerage account at the firm of your choice.

 

Employer-sponsored retirement accounts (e.g., 401(k) and 403(b)), 529 college savings plans, and Compliance-approved accounts (e.g., Approved Managed Accounts) may be held in a brokerage account at the firm of your choice. However, if you hold any Reportable Securities through any of those accounts, then such accounts are considered Covered Accounts under this policy and you are required to disclose them to Compliance under Subsection 2-C of this policy.

 

Newly hired U.S. crew who are Access Persons, and their Household or Family Members (parts (a) and (b) of that defined term only), must transfer any existing applicable Reportable Securities to a VBA by submitting a request or other applicable paperwork with Vanguard and each firm at which you have an existing applicable brokerage account within 60 days of your joining Vanguard. Visit Vanguard.com > Personal Investors > Open an Account to transfer assets from another firm to Vanguard. 

 

For a more detailed list of Securities that must be held in a VBA, as well as Securities that may be held elsewhere, visit the Appendices C-F.  

 

Ex-U.S. Crew:

Crew who are Access Persons employed outside the U.S., and their Household or Family Members, may maintain Reportable Securities (as well as Securities or investments that are not Reportable Securities) in a brokerage account or other type of account at the firm of their choice

 

Contingent Workers, Globally

Contingent workers who are Access Persons may maintain Reportable Securities (as well as Securities or investments that are not Reportable Securities) in a brokerage account at the firm of their choice

 

 

Subsection 2-C – Disclosure Obligations 

 

The terms of this Subsection 2-C apply to all Access Person designations and to all Associated Persons.

 

This policy requires the disclosure of a variety of account and holdings information to the Compliance Department for monitoring and oversight. This policy requires (1) an initial disclosure of information, and (2) periodic ongoing disclosures. Even if you do not have any personal brokerage

 

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account holdings or do not trade in Reportable Securities, you are still required to complete the necessary initial and periodic disclosures.

 

1. Initial Disclosure of Accounts and Holdings

 

Within ten (10) calendar days of joining Vanguard, or if applicable within ten (10) calendar days of moving from a Non-Access Person role at Vanguard into an Access Person role, all Access Persons and Associated Persons must disclose the following to Compliance:

 

(a) All Covered Accounts and all Reportable Securities held by you or a Household or Family Member;

 

(b) All Covered Accounts in which you exercise Investment Discretion;

 

(c) All Covered Accounts over which you exercise control (e.g., agent authority (full or limited), trustee, power of attorney authority, etc.);

 

(d) All accounts in which you have, or will acquire, Beneficial Ownership of Securities; and

 

(e) All accounts held by you and any Household or Family Member in which there are college saving plan products (including, in the U.S., 529 plans), annuity products, or other insurance products that, in turn, hold or invest in Vanguard Funds.

 

This includes Brokerage Accounts held at Vanguard, as well as those held at another financial institution. For clarity, you do not need to disclose an account or submit transaction confirmations or statements if the account does not have the ability to hold Securities – for example, a traditional checking, savings, or deposit account with a bank, credit union, or building society for holding cash would not need to be disclosed.

 

This information must be current as of no more than 45 calendar days before joining Vanguard.

 

To make this initial disclosure, you will receive an Initial Certification assignment by email to complete which will include a section to disclose Covered Accounts and all Reportable Securities by including account information in the “Account Attestation” section of the assignment and uploading corresponding account statements via MCO. You must complete and submit the Initial Certification within ten (10) calendar days of receiving it; the failure to do so may be considered a violation of this policy.

 

Note: We use an application called MyComplianceOffice, or MCO, to help manage this policy. You may use MCO to disclose accounts and holdings, and to secure trading permissions, if those obligations apply to you. Visit My Ethics and Compliance Resource Center on CrewNet for resources on how to access and use MCO

 

 

2. Ongoing Disclosure of Accounts, Transactions, and Duplicate Statements

 

After the Initial Disclosure, Access Persons and Associated Persons may need to disclose account and transaction information to Compliance on a periodic basis regarding Covered Accounts and any transactions in Reportable Securities made by you and your Household or Family Members.

 

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Further, if at any time you or a Household or Family Member subsequently:

 

·open, or intend to open, a Covered Account with a financial institution (e.g., broker, dealer, advisor, or any other professional money manager), or
·acquire holdings in Reportable Securities, or
·have a preexisting Covered Account (including a Vanguard Brokerage Account) that becomes associated with you or a Household or Family Member (such as through marriage or inheritance or some other life event),

 

or there becomes an account in which you acquire Beneficial Ownership of Securities, then you must notify Compliance as soon as possible (and in any event within 10 calendar days) and disclose these Covered Accounts and Reportable Securities by listing them and including associated information in the Accounts tab in MCO.

 

For U.S. crew, keep in mind that, as explained in Section 2-B of this policy above, you and your Household or Family Members (parts (a) and (b) of that defined term only) must maintain Reportable Securities in a VBA.

 

What and how to disclose this information:

 

·For VBAs disclosed by U.S. crew as required under this policy, Compliance will receive transaction confirmations automatically. No additional action by you is needed to disclose transactions of Reportable Securities in VBAs you have disclosed.

 

·For Covered Accounts and holdings of Reportable Securities held outside of Vanguard (including in any account that would require disclosure under Section 2-C(1) of this policy), it is your responsibility to ensure that duplicate statements and transaction confirmations are available to or delivered to Compliance:
oBecause Vanguard has file feed contracts in place with many brokerage firms worldwide, for many Covered Accounts you disclose the holdings and transactions information will be sent to Compliance electronically with no additional action needed by you.
oFor Covered Accounts held at firms where Vanguard does not have a file feed in place, you must do the following:
§Contact the firm where your Covered Account is held and take steps to send duplicate statements and daily transaction confirmations (electronic or paper) to Vanguard. You do this often by making Vanguard Compliance an interested party and having duplicate statements and confirmations sent to the third party scanning service Vanguard uses, called “Earth Class Mail” at this address: Vanguard, c/o TerraNua, 9450 SW Gemini Drive #37880, Beaverton, OR, 97008-7105.
§If the firm where your Covered Account is held is not able to send statements and daily transaction confirmations (electronic or paper) to Vanguard, you are required to scan and upload copies into the Trading Documents folder in MCO immediately after you receive them, unless you receive an exemption from this requirement from Compliance. You must ensure the documents you upload clearly show the firm/institution at which the account is held, the account number or ID, the account owner, and the account type.

 

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·If Compliance does not receive the information automatically via a file feed, you will receive email notifications on a calendar quarterly basis to complete a Quarterly Securities Transaction Report and thereby disclose Covered Accounts and Reportable Securities, via MCO. You must complete and submit that assignment within 30 calendar days; the failure to do so may be considered a violation of this policy.
·On an annual basis (usually in January or February), you will receive an assignment from Compliance in which you must certify, among other things, that all Covered Accounts and Reportable Securities are recorded accurately in MCO.

 

3.  Additional notes related to disclosures under this policy: 

 

·For clarity, you do not need to disclose an account or submit transaction confirmations or statements if the account does not have the ability to hold Securities (for example, a traditional checking, savings, or deposit account with a bank, credit union, or building society for holding cash would not need to be disclosed). 
·As stated above, U.S. crew and contingent workers who are Associated Persons are also required to comply with and are subject to the FINRA Licensing Policy and Securities Account Reporting Obligations. 
·The Compliance Department will keep personal trading information confidential, but please note that such information may be accessible to authorized personnel within Compliance and may be reported to or summarized for senior management, HR, or the OGC for investigative purposes. Applicable records may also be provided to internal or external auditors and/or to any regulator if required. All ex-U.S. crew and contingent workers are required to sign a data consent / data privacy notice.
·Please note that crew and contingent workers in Australia are required to disclose all transactions in VIA funds in MCO in the same manner as is required for Reportable Securities.

 

Subsection 2-D – Investment and Trading Restrictions 

 

This Subsection 2-D contains three segments: 

 

Segment 2-D-1 applies to all Access Person designations.

 

Segment 2-D-2 has terms and requirements that differ based on your Access Person designation.

 

oSegment 2-D-2(a): Advisor Access Person requirements
oSegment 2-D-2(b): Fund Access Person requirements
oSegment 2-D-2(c): Investment Access Person requirements

 

Segment 2-D-3 explains how to seek and abide by preclearance requirements, if applicable to your activity.

 

Segment 2-D-1: Rules and Limitations applicable to all Access Person designations

 

The terms of this Segment 2-D-1 apply to all Access Person designations.

 

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(a)General Obligations

 

i)Comply with the law:

 

(1)You must comply with all applicable securities-related rules and laws.
(2)You may not engage in conduct that is deceitful, fraudulent, or manipulative, or that involves false or misleading statements, in connection with the purchase or sale of a Security by a Vanguard Fund or Vanguard Client account or otherwise.
(3)You may not intentionally, recklessly, or negligently circulate false information or rumors that may affect the securities markets or may be perceived as market manipulation.

 

ii)Use of Information:

 

(1)You may not take personal advantage of knowledge of recent, impending, or planned Securities activities of the Vanguard Funds or their investment advisors or any Vanguard Client. You are prohibited from purchasing or selling—directly or indirectly—any Security or Related Security when you know that the Security is being purchased or sold, or considered for purchase or sale, by a Vanguard Fund (with the exception of an index fund) or by a Vanguard Client.
(2)You are subject to and must comply with the Insider Trading Policy and/or any similar policy of the Vanguard affiliate or region for which you work. Each of these policies is considered an integral part of your obligations under this policy. Each policy prohibits you from buying or selling any Security while in possession of material, nonpublic information about the issuer of the Security. The policies also prohibit you from communicating any nonpublic information about any Security or issuer of Securities to third parties.
(3)You must comply with the Confidential Information Policy, including that you may not share information with any third party about any planned, upcoming, or recently executed trading activity by any Vanguard Fund or Vanguard Client unless such information is publicly available through no action by you.

 

iii)Fund policies and excessive trading:

 

(1)When purchasing, exchanging, or redeeming shares of a Vanguard Fund, you must adhere to the policies and standards set forth in the fund’s prospectus, or offering document, including policies on market-timing and frequent trading.
(2)Excessive trading in Covered Accounts is strongly discouraged. The Compliance Department reserves the right to monitor trading across all of your Covered Accounts, and may conduct scrutiny of any trades in your Covered Accounts where such trading may appear excessive in nature (including, but not limited to, if the number of trades is so frequent as to potentially impact your ability to carry out your assigned responsibilities or the trades involve positions that are disproportionate to your net assets). If Compliance in its sole discretion determines you have engaged in excessive trading, then Compliance may limit the number of trades allowed in your Covered Accounts during a given period. This Section 2-D-1(a)(iii)(2) does not apply to transactions in an Approved Managed Account.

 

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iv)Beneficial ownership and discretion:

 

(1)The terms and restrictions of this policy apply to all Securities in which you have acquired or will acquire Beneficial Ownership.
(2)You must comply with these investment and trading restrictions with respect to any account you own as well as any account over which you have Investment Discretion or in which you have the authority to transact.

 

v)No circumventionYou are not permitted to assist, aid, or enable any other person in doing anything that you are prohibited from doing under this policy.

 

vi)Waivers:

 

(1)The Chief Compliance Officer may grant exceptions to this policy, including preclearance, other trading restrictions, and certain reporting requirements on a case-by-case basis if it is determined that (1) the proposed conduct involves no opportunity for abuse, (2) the proposed conduct does not conflict with Vanguard’s interests, and (3) not granting an exception would result in an unfair or unjust outcome.
(2)The Chief Compliance Officer may waive the applicability of this policy for a contingent worker if the policy’s requirements are covered through the applicable service provider’s contract with Vanguard.

 

 

(b)Rules regarding specific investments or investment types:

 

i)Use of derivatives:

 

(1)You and your Household or Family Members may not use a derivative to avoid or circumvent a rule or requirement set forth in this policy. If something is prohibited by these rules, then it is also against these rules to effectively accomplish the same thing by using a derivative. This includes futures, options, and other types of derivatives.
(2)You and your Household or Family Members are permitted to trade futures or options on commodities.

 

ii)IPOs and ICOs:

 

(1)You and your Household or Family Members are prohibited from acquiring Securities in an Initial Public Offering (IPO) or Secondary Offering.
(2)You and your Household or Family Members are prohibited from participating in an Initial Coin Offering (ICO).

 

iii)Private Placements:

 

(1)You and your Household or Family Members are not permitted to invest in securities offered to potential investors in a Private Placement or other limited investment offering without first obtaining preclearance from Compliance.
(2)You must provide documentation describing the investment (e.g., offering memorandum, subscription documents, etc.) so as to enable Compliance to conduct a thorough review of the investment.

 

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(3)Approval by Compliance may be granted or denied after a review of the facts and circumstances, including whether:
·An investment in the securities is likely to result in future conflicts with Vanguard Client accounts.
·You are being offered the opportunity due to your employment at, or association with, Vanguard.
(4)If you or your Household or Family Members receive approval to purchase Securities in a Private Placement, you must immediately inform Compliance if that Security goes to public offer or is pending listing on an exchange.
(5)To initiate the process for obtaining preclearance of a Private Placement, complete the Outside Business Activity request form (the form for U.S. crew is in LARS, and for ex-U.S. crew is in MCO).

 

iv)  SPACs – You and your Household or Family Members are prohibited from acquiring a SPAC at any stage of its lifecycle (i.e., pre-IPO, IPO, pre-merger, post-merger).

 

v)  Short-Selling – You are prohibited from selling short any Security that you do not own or from otherwise engaging in short-selling activities.

 

vi)  Limit Orders – Same-day limit orders are permitted; however, good 'til cancelled orders (such as limit orders that stay open over the course of multiple trading days until a security reaches a specified market price) are not permitted.

 

vii) Digital Currencies and Related Investments – Refer to the Trading and Reporting Requirements for Digital Currency Investments and Activities for details on which digital currency account and product types are permitted, and what must be disclosed, under this policy.

 

(c)Short term trading in a Vanguard Fund (other than Vanguard ETFs): 

 

i)    Compliance may monitor trading in Vanguard Funds, other than Vanguard ETFs, and will review situations where Vanguard Fund shares are redeemed within 30 calendar days of purchase (a “short-term trade”). You may be required to relinquish to Vanguard any profit made on a short-term trade and will be subject to disciplinary action if Compliance determines the short-term trade was detrimental to a Vanguard Fund or a Vanguard Client or that there is a history of frequent trading by you or your Household or Family Members. For purposes of this paragraph:

 

(1)A redemption includes a redemption by any means, including an exchange out of a Vanguard Fund.
(2)This policy does not cover purchases and redemptions/sales (i) into or out of Vanguard money market funds, Vanguard short-term bond funds, or (ii) through an Automatic Investment Program.

 

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ii)  Nothing in this section is intended to replace, nullify, or modify any requirements imposed by a Vanguard Fund.

 

Segment 2-D-2: Specific Limitations and Prohibitions that Apply Based on Access Person Designation

 

The terms and requirements of this Segment 2-D-2 are in addition to the terms and requirement of Segment 2-D-1, and you must comply with the portions of this Segment 2-D-2 that apply to your Access Person designation. Note, an Access Person designation can apply to crew members or contingent workers.

 

Segment 2-D-2(a): Advisor Access Person requirements

 

The following terms and requirements apply to Advisor Access Persons only and are in addition to the terms and requirements of Segment 2-D-1:

 

Securities transactions for which you must obtain preclearance (meaning, approval from Compliance before transacting)

None. You are not required to obtain preclearance of any Covered Securities transactions by you or your Household or Family Members, except Private Placements as described above.

Prohibited Securities transactions

In addition to Segment 2-D-1, you are subject to the following restrictions with respect to any transaction in which you will acquire any direct or indirect Beneficial Ownership:

 

·    Short-Term Trading. You are prohibited from purchasing and then selling any Covered Security at a profit, as well as selling and then repurchasing a Covered Security at a lower price, within 60 calendar days. A last-in/first-out accounting methodology will be applied to a series of Security purchases when applying this rule. (Note, as stated, this is based on last-in/first-out accounting regardless of how you placed the trade or plan to report it for tax purposes.) If you realize profits on short-term trades, you will be required to relinquish the profits to Vanguard (exclusive of commissions). In addition, the trade will be recorded as a violation of this policy. For example: you would not be permitted to sell a Covered Security at $12 that you purchased within the prior 60 days for $10. Similarly, you would not be permitted to purchase a Covered Security at $10 that you had sold within the prior 60 days for $12.

 

·    Short-term trading on options. You may hold options on a Covered Security until you exercise the options or the options expire. However, you may not otherwise close any open positions within 60 calendar days. If you realize profits on such short-term trades, you must relinquish such profits to Vanguard (exclusive of commissions). In addition, the trade will be recorded as a violation of this policy. Note: These types of transactions can have unintended consequences.

 

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For example, your call option could be assigned, causing the underlying Security to be called away within sixty (60) calendar days following the purchase of the Covered Security.

 

  Visit the Appendix C for a table summarizing the trading and reporting requirements for Advisor Access Persons.

 

Segment 2-D-2(b): Fund Access Person requirements 

 

The following terms and requirements apply to Fund Access Persons only and are in addition to the terms and requirements of Segment 2-D-1:

 

Securities transactions for which you must obtain preclearance (meaning, approval from Compliance before transacting)

Yes, you must obtain, for yourself and on behalf of your Household or Family Members, preclearance for any transaction of a Covered Security by you or any Household or Family Member.

 

See Segment 2-D-3, below, for instructions on how to seek preclearance.

Securities transactions that do not require preclearance

You are not required to obtain preclearance for the following:

 

·     Purchases or sales of Vanguard Funds.

·     Purchases or sales where the person requesting preclearance has no direct or indirect influence or control over the account (e.g., you have a trust in your name but you are not the trustee who places the transaction, provided you have granted Investment Discretion to the trustee and there has been no prior communication between you and the trustee regarding the transaction).

·    Corporate actions in Covered Securities such as stock dividends, stock splits, mergers, consolidations, spin-offs, or other similar corporate reorganizations or distributions.

·     Purchases or sales made as a part of an Automatic Investment Program.

·     Purchases effected upon the exercise of Rights which were issued by an issuer pro rata to all holders of a class of its Securities, to the extent such Rights were acquired from such issuer.

·    Acquisitions of Covered Securities through gifts or bequests.

 

Visit the Appendix D for a table summarizing the trading and reporting requirements for Fund Access Persons.

Is preclearance required for trades in an Approved Managed Account?

No, you are not required to seek preclearance of a transaction in a Covered Security in an Approved Managed Account so long as you have no prior communication with the portfolio manager of that account in connection with that transaction.

 

Note, Vanguard PAS accounts generally do not qualify as Approved Managed Accounts because PAS account owners generally retain some level of investment discretion. Further, any

 

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  trades of Covered Securities in a PAS account must be precleared under this policy.

“Blackout period” restrictions that may apply to personal trading in Covered Securities

You may be subject to certain restrictions if you purchase or sell a Covered Security within seven (7) days before or after a Vanguard Fund purchases or sells the same Covered Security or a Related Security (the “blackout period”).

 

Purchasing or selling before a Vanguard Fund:

 

·     If you purchase a Covered Security within seven days before a Vanguard Fund purchases the same Covered Security or a Related Security, you may be required to hold the Covered Security for 6 months before being permitted to sell the Covered Security for a profit.

·     If you sell a Covered Security within seven days before a Vanguard Fund sells the same Covered Security or a Related Security, you may be required to relinquish to Vanguard any profits earned from your sale of the Covered Security (exclusive of commissions), where profits are calculated based on the price that the Vanguard Fund received for selling the Covered Security or a Related Security. Note: Compliance will review your sale to determine if the relinquishment is required. This decision will be based on several factors, such as your role, access to fund trades, and the Covered Security sold.

 

Purchasing or selling after a Vanguard Fund:

 

·     In general, you will not receive preclearance to purchase a Covered Security within seven days after a Vanguard Fund trades the same Covered Security or a Related Security. If you execute the transaction without receiving preclearance, you will have violated this policy and must immediately sell the Covered Security and relinquish all profits received from the sale to Vanguard (exclusive of commissions).

·     In general, you will not receive preclearance to sell a Covered Security within seven days after a Vanguard Fund trades the same Covered Security or a Related Security. If you execute the transaction without receiving preclearance, you will have violated this policy and must relinquish to Vanguard the difference (exclusive of commissions) between the sale price you received and the Vanguard Fund's sale price (as long as your sales price is higher), multiplied by the number of shares you sold.

 

In addition to these restrictions, local law may dictate the extent to which any gains must be relinquished.

 

Compliance may exempt from these restrictions certain trades during blackout periods that coincide with trading by certain Vanguard Funds (e.g., index funds).

 

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The blackout period restrictions set forth above will not apply to a Fund Access Person’s sale of stock of any issuer which has a market capitalization that exceeds US$5 billion (or local currency equivalent), provided that the total value of any sales of the Security by the Fund Access Person do not exceed US$10,000 (or local currency equivalent) in any 30-day rolling period. Sales of securities of issuers with market capitalizations below US$5 billion, or that exceed US$10,000 in any 30-day rolling period, will continue to be subject to the blackout periods unless Compliance grants a waiver.

 

Compliance may waive the blackout period as it applies to the sale of a Covered Security if the Chief Compliance Officer determines its application creates a significant hardship to you (e.g., you need cash for a home purchase or to cover a major medical expense) and, in the opinion of the Chief Compliance Officer, satisfies the requirements for a waiver in the Waivers paragraph of Segment 2-D-1, above. Request and complete a Hardship Waiver Request Form. 

Prohibited Securities transactions

In addition to Segment 2-D-1, you are subject to the following restrictions with respect to any transaction in which you will acquire any direct or indirect Beneficial Ownership:

 

·     Futures and Options. You are prohibited from entering into, acquiring, or selling any Futures contract (including single stock futures) or any Option on any Security (including Options on ETFs, Digital Utility Tokens, Digital Security Tokens, and Digital Currencies).

 

·    Short-Term Trading. You are prohibited from purchasing and then selling any Covered Security at a profit, as well as selling and then repurchasing a Covered Security at a lower price, within 60 calendar days. A last-in/first-out accounting methodology will be applied to a series of Security purchases when applying this rule. (Note, as stated, this is based on last-in/first-out accounting regardless of how you placed the trade or plan to report it for tax purposes.) If you realize profits on short-term trades, you will be required to relinquish the profits to Vanguard (exclusive of commissions). In addition, the trade will be recorded as a violation of this policy. Example: You are not permitted to sell a security at $12 that you purchased within the prior 60 days for $10. Similarly, you are not permitted to purchase a security at $10 that you sold within the prior 60 days for $12.

 

·    Spread Bets. You are prohibited from participating in Spread Betting on Securities, indexes, interest rates, currencies, or commodities.

 

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Segment 2-D-2(c): Investment Access Person requirements 

 

The following terms and requirements apply to Investment Access Persons only and are in addition to the terms and requirements of Segment 2-D-1:

 

Securities transactions for which you must obtain preclearance (meaning, approval from Compliance before transacting)

Yes, you must obtain, for yourself and on behalf of your Household or Family Members, preclearance for any transaction of (i) a Covered Security, or (ii) a Vanguard ETF, by you or any Household or Family Member.

 

See Segment 2-D-3, below, for instructions on how to seek preclearance.

 

Securities transactions that do not require preclearance

You are not required to obtain preclearance for the following:

 

·        Purchases or sales of Vanguard Funds. (Reminder: The purchase or sale of Vanguard ETFs does require preclearance.)

·        Purchases or sales where the person requesting preclearance has no direct or indirect influence or control over the Covered Security (e.g., you have a trust in your name but you are not the trustee who places the transaction, provided you have granted Investment Discretion to the trustee and there has been no prior communication between you and the trustee regarding the transaction).

·        Corporate actions in Covered Securities such as stock dividends, stock splits, mergers, consolidations, spin-offs, or other similar corporate reorganizations or distributions.

·        Purchases or sales made as a part of an Automatic Investment Program.

·        Purchases effected upon the exercise of Rights which were issued by an issuer pro rata to all holders of a class of its Securities, to the extent such Rights were acquired from such issuer.

·        Acquisitions of Covered Securities through gifts or bequests.

 

Visit the Appendix for a table summarizing the trading and reporting requirements for Investment Access Persons. 

 

Is preclearance required for trades in an Approved Managed Account?

No, you are not required to seek preclearance of a transaction in a Covered Security in an Approved Managed Account so long as you have no prior communication with the portfolio manager of that account in connection with that transaction.

 

Note, Vanguard PAS accounts generally do not qualify as Approved Managed Accounts because PAS account owners generally retain some level of investment discretion. Further, any trades of Covered Securities (but not trades of Vanguard ETFs) in a PAS account must be precleared under this policy. 

 

 

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“Blackout period” restrictions that may apply to personal trading in Covered Securities

You may be subject to certain restrictions if you purchase or sell a Covered Security within seven (7) days before or after a Vanguard Fund purchases or sells the same Covered Security or a Related Security (the “blackout period”).

 

Purchasing or selling before a Vanguard Fund:

 

·        If you purchase a Covered Security within seven days before a Vanguard Fund purchases the same Covered Security or a Related Security, you may be required to hold the Covered Security for 6 months before being permitted to sell the Covered Security for a profit.

·        If you sell a Covered Security within seven days before a Vanguard Fund sells the same Covered Security or a Related Security, you may be required to relinquish to Vanguard any profits earned from your sale of the Covered Security (exclusive of commissions), where profits are calculated based on the price that the Vanguard Fund received for selling the Covered Security or a Related Security.

 

Purchasing or selling after a Vanguard Fund:

 

·        In general, you will not receive preclearance to purchase a Covered Security within seven days after a Vanguard Fund trades the same Covered Security or a Related Security. If you execute the transaction without receiving preclearance, you will have violated this policy and must immediately sell the Covered Security and relinquish all profits received from the sale to Vanguard (exclusive of commissions).

·        In general, you will not receive preclearance to sell a Covered Security within seven days after a Vanguard Fund trades the same Covered Security or a Related Security. If you execute the transaction without receiving preclearance, you will have violated this policy and must relinquish to Vanguard the difference (exclusive of commissions) between the sale price you received and the Vanguard Fund’s sale price (as long as your sales price is higher), multiplied by the number of shares you sold.

 

In addition to these restrictions, local law may dictate the extent to which any gains must be relinquished.

 

Compliance may exempt from these restrictions certain trades during blackout periods that coincide with trading by certain Vanguard Funds (e.g., index funds).

 

Compliance may waive the blackout period as it applies to the sale of a Covered Security if the Chief Compliance Officer determines its application creates a significant hardship to you (e.g., you need cash for a home purchase or to cover a major medical expense) and, in the opinion of the Chief Compliance Officer, satisfies the requirements for a waiver in the Waivers

 

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paragraph of Segment D-1, above. Request and complete a Hardship Waiver Request Form.

 

Prohibited Securities transactions 

In addition to Segment 2-D-1, you are subject to the following restrictions with respect to any transaction in which you will acquire any direct or indirect Beneficial Ownership:

 

Futures and Options. You are prohibited from entering into, acquiring, or selling any Futures contract (including single stock futures) or any Option on any Security (including Options on ETFs, Digital Utility Tokens, Digital Security Tokens, and Digital Currencies).

 

Short-Term Trading. You are prohibited from purchasing and then selling any Covered Security or a Vanguard ETF at a profit, as well as selling and then repurchasing a Covered Security or a Vanguard ETF at a lower price, within 60 calendar days. A last-in/first-out accounting methodology will be applied to a series of Security purchases when applying this rule. (Note, as stated, this is based on last-in/first-out accounting regardless of how you placed the trade or plan to report it for tax purposes.) If you realize profits on short-term trades, you will be required to relinquish the profits to Vanguard (exclusive of commissions). In addition, the trade will be recorded as a violation of this policy. Example: You are not permitted to sell a security at $12 that you purchased within the prior 60 days for $10. Similarly, you are not permitted to purchase a security at $10 that you sold within the prior 60 days for $12.

 

Spread Bets. You are prohibited from participating in Spread Betting on Securities, indexes, interest rates, currencies, or commodities.

 

 

Segment 2-D-3:  How to Seek and Abide by Preclearance Requirements 

 

If you are required to obtain preclearance of any trade or transaction under this policy, then the terms of this Segment 2-D-3 apply to that trade or transaction.

 

Preclearance representations.

 

By seeking preclearance, you will be deemed to be advising and representing to Compliance that you:

 

·Do not possess any material, nonpublic information relating to the security.
·Do not use knowledge of any proposed trade or investment program relating to the Vanguard Funds for personal benefit.
·Believe the proposed trade is available to any market participant on the same terms.

 

How do I obtain preclearance?

 

Preclearance must be obtained via the “Personal Trade Pre-Clearance” path in MCO. Once the required information is submitted, your preclearance request will usually be approved or denied

 

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immediately. Transactions in Covered Securities (including, for Investment Access Persons, transactions in Vanguard ETFs) may not be executed before you receive approval.

 

As a reminder, preclearance of Private Placements is addressed in Segment 2-D-1 of this policy, above.

 

Attempting to gain approval after the transaction has occurred is not permitted. Completing a personal trade before receiving approval or after the approval window expires constitutes a violation of this policy. See Section 3 of this policy for more information regarding the sanctions that may be imposed as a result of a violation.

 

How long is my preclearance approval valid?

 

In the U.S.: Preclearance approval will expire at the end of the trading day on which it is issued (e.g., if you receive approval for a trade on Monday, it is effective until the market closes on that Monday).  Preclearance for permitted limit orders is good for transactions on the same day that approval is granted only.  If you receive approval for a limit order, it must be executed or expire at the close of regular trading on the same business day for which approval was granted.  If you wish to execute the limit order after the close of regular trading on the day you received approval, you must submit a new preclearance request for the day you wish to execute the trade.

 

Outside the U.S.: If you receive approval, transactions must be executed no later than the end of trading on the next business day after the preclearance is granted. If the transaction is not placed within that time, you must submit a new request for approval before placing the transaction. If you preclear a limit order, that limit order must either be executed or expire at the end of the next business day. If you want to execute the order after the next business day period expires, you must resubmit your preclearance request. 

 

Section 3 – Penalties and Sanctions 

 

How we enforce this policy 

 

The Compliance Department regularly reviews the forms, reports, and other information it receives. If these reviews turn up information that is incomplete, questionable, or potentially in violation of this policy, the Compliance Department will investigate the matter and may contact you. If it is determined that you or any of your Household or Family Members have violated this policy, the Compliance Department or another appropriate party may take action.

 

Violations 

 

If the Compliance Department determines that there has been a violation, you may be subject to penalties and sanctions as described in this policy and otherwise as described in the Disciplinary Action Policy and, for crew and contingent workers in Australia, the Managing Misconduct Policy. The Compliance Department will generally utilize a rolling 24-month period when evaluating whether and how to sanction a violation. Any violation of this policy may result in disciplinary action up to and including termination of employment.

 

Vanguard takes all policy violations seriously and at times provides the Vanguard Funds’ board with a summary of actions taken in response to material violations of this policy and other policies. You should be aware that other securities laws and regulations not addressed by this policy may also apply to you, depending upon your role at Vanguard.

 

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Exceptions 

 

The Chief Compliance Officer or designee retains the discretion to interpret and grant exceptions to this policy and to decide how the rules apply to any given situation for the purpose of protecting the funds and being consistent with the general principles of this policy and the Code of Ethical Conduct.

 

In cases where exceptions to this policy are noted and you may qualify for them, you need to get prior written approval from the Compliance Department. If you believe that you have a situation that warrants an exception that is not discussed in this policy, you may submit a written request to the Compliance Department, which will consider your request and notify you of the outcome.

 

Section 4 – Defined Terms 

 

The following definitions apply throughout this policy:

 

Access Person Any person designated as an Investment Access Person, Fund Access Person, or Advisor Access Person.
Approved Managed Account An investment account where (i) the account is owned by an investor and overseen by a hired professional money manager, (ii) the investor has no trading discretion on the account, and (iii) Compliance has approved it as an Approved Managed Account.
Associated Person Any person who conducts securities business on behalf of Vanguard Marketing Corporation (VMC). This includes all FINRA-licensed contingent workers, as well as non-licensed contingent workers who perform certain operational and administrative functions for VMC.
Automatic Investment Program  A program in which regular periodic purchases (or withdrawals) are made automatically in (or from) Investment accounts, according to a predetermined schedule and allocation. An Automatic Investment Program includes a dividend reinvestment plan.
Bankers’ Acceptance A time draft drawn on a commercial bank by a borrower usually in connection with an international commercial transaction. Bankers’ Acceptances are usually guaranteed by the bank.
Beneficial Ownership

The opportunity to directly or indirectly—through any contract, arrangement, understanding, relationship, or otherwise—share at any time in any economic interest or profit derived from an ownership of or a transaction in a Security. For clarity, what you are deemed to have Beneficial Ownership of includes the following:

 

·        Any Security owned individually by you.

·        Any Security owned by a Household or Family Member.

·        Any Security owned in joint tenancy, as tenants in common, or in other joint ownership arrangements.

·        Any Security in which a Household or Family Member has Beneficial Ownership if the Security is held in a Covered Account over which you have decision making authority (for example, you act as a trustee, executor, or guardian or you provide Investment advice).

·        Your interest as a general partner or manager/member in Securities held by a general or limited partnership or limited liability company.

 

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·        Your interest as a member of an Investment club or an organization that is formed for the purpose of investing in a pool of monies or Securities.

·        Your ownership of Securities as a trustee of a trust in which either you or a Household or Family Member has a vested interest in the principal or income of the trust or your ownership of a vested interest in a trust.

·        Securities owned by a corporation which is directly or indirectly controlled by, or under common control with, such person.

Bond  A debt obligation issued by a corporation, government, or government agency that entails repayment of the principal amount of the obligation at a future date, usually with interest.
Certificate  In Germany, a right or obligation issued by a bank where the payout profile or benefit of ownership depends upon or is tied to the performance of an agreed-upon underlying asset or security. 
Certificate of Deposit (CD)  An insured, interest-bearing deposit at a bank that requires the depositor to keep the money invested for a specified period.
Commercial Paper A promissory note issued by a large company in need of short-term financing.
Covered Account Any Vanguard Fund account, any brokerage account, and any other type of account that holds, or is capable of holding, Reportable Securities.
Covered Security

Any Security (including through an IPO), but not including any:

 

·         Direct Obligations of a Government;

·         Bankers' Acceptances, Certificates of Deposit (CD), Commercial Paper, and High-Quality Short-Term Debt Instruments, including Repurchase Agreements;

·         Shares issued by Open-End Funds (although for European subsidiaries, this is limited to UCITS schemes, a non-UCITS retail scheme, or another fund subject to supervision under the law of an European Economic Area (EEA) state which is an index fund or which requires an equivalent level of risk spreading in their assets);

·         Life policies;

·         ETFs;

·         ETNs; or

·         Digital Currencies.

Debenture An unsecured debt obligation backed only by the general credit of the borrower.
Digital Currency A digital asset that: (1) serves solely as a store of value, a medium of exchange, or a unit of account; (2) is not issued or guaranteed by any jurisdiction, central bank, or public authority; (3) relies on algorithmic techniques to regulate the generation of new units of the digital asset; and (4) has transactions involving the digital asset recorded on a decentralized network or distributed ledger (e.g., blockchain). Common examples of a Digital Currency are Bitcoin and Ether. A Digital Currency is distinguishable from a Digital Security Token or a Digital Utility Token.
Digital Security Token

Any digital asset that is not a Digital Currency or Digital Utility Token. In general, a Digital Security Token may: (1) derive its value primarily from, or represent an interest in, a separate asset or pool of assets; or (2) represent an interest in an enterprise or venture. A Digital Security Token may provide owners or holders with voting rights, rights to distributions, or other rights associated with ownership. Digital Security

 

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Tokens are generally held for speculative investment purposes and not to provide holders with access to a particular network, product, or service. Digital Security Tokens, like other investments, are generally not used as a medium of exchange.

Note, whether or not an asset is a Digital Security Token depends on specific facts and circumstances. Merely referring to an asset as a Digital Currency or Digital Utility Token does not prevent the asset from being a Digital Security Token. Furthermore, an asset may be a Digital Security Token even if it has some purported utility. Please contact Compliance if you have any questions regarding whether an asset is a Digital Security Token.

Digital Utility Token  A digital asset that (1) provides access to a particular network, product, or service; (2) derives its value primarily from providing access to a particular network, product, or service; and (3) does not function as a Digital Currency or Digital Security Token. 
Direct Obligation of a Government  A debt that is backed by the full taxing power of any government. These Securities are generally considered to be of the very highest quality. 
ETF or Exchange-Traded Fund  An investment with characteristics of both mutual funds and individual stocks. Many ETFs track an index, a commodity, or a basket of assets. Unlike mutual funds, ETFs can be traded throughout the day. ETFs often have lower expense ratios but must be purchased and sold through a broker, which means you may incur commissions.
ETN or Exchange-Traded Note  A senior, unsecured, unsubordinated debt Security issued by a financial institution, whose returns are based on the performance of an underlying index and backed only by the credit of the issuer. ETNs have a maturity date, but typically pay no periodic coupon interest and offer no principal protection. At maturity an ETN investor receives a cash payment linked to the performance of the corresponding index, less fees.
Futures / Futures Contract  A contract to buy or sell specific amounts of a commodity or financial instrument (such as grain, a currency, including foreign currencies and Digital Currencies (e.g., Bitcoin), a Digital Security Token, or an index) for an agreed-upon price at a certain time in the future. Sometimes the arrangements in a contract prescribe that settlements are made through cash payments, rather than the delivery of physical goods or Securities; this is called Contract for Difference.
High-Quality Short-Term Debt Instrument  An instrument that has a maturity at issuance of less than 366 days and is rated in one of the two highest ratings categories by a nationally recognized statistical rating organization, or an instrument that is unrated but determined by Vanguard to be of comparable quality.
Household or Family Member (U.S., Australia, Canada, China, Hong Kong, and Mexico) 

For the U.S., Australia, Canada, China, Hong Kong, and Mexico regions, the term “Household or Family Member” includes:

 

a)     Your spouse or domestic partner (an unrelated adult with whom you share your home and contribute to each other's support);

b)     Any child of yours or of your spouse or domestic partner, provided that the child resides in the same household as or is financially dependent upon you; or

c)     Any other individual over whose accounts you have control (e.g., agent authority (full or limited), trustee, power of attorney authority) and to whose financial support you materially contribute.

 

 

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  For purposes of parts (a) and (b) of this definition, those persons may not be deemed Household or Family Members under this policy if you demonstrate, to the satisfaction of the Compliance Department, that you derive no economic benefit from, and exercise no control over, that person’s accounts.
Household or Family Member (Europe)  For Europe crew members, the term “Household or Family Member” includes your spouse, domestic partner (an unrelated adult with whom you share your home and contribute to each other's support), and minor children, as well as relatives whether by blood, adoption, or marriage (e.g., children, grandchildren, siblings, parents, parents-in-law, stepchildren) residing in the same household for at least one year prior to the date of the personal transaction.
Initial Coin Offering (ICO)  An initial offer or sale of Digital Currencies or Digital Security Tokens. Note, whether or not an offering is an ICO depends on specific facts and circumstances. Please contact Compliance before participating in an initial offering of a Digital Currency, Digital Security Token, or Digital Utility Token
Initial Public Offering (IPO)  A corporation's first offering of common stock to the public.
Investment Contract  Any contract, transaction, or scheme whereby a person invests money in a common enterprise and is led to expect profits solely from the efforts of the promoter or third party.
Investment Discretion  The authority an individual may exercise, with respect to investment control or trading discretion, on another person's account (e.g., executor, trustee, power of attorney).
Non-Access Person  Any person in a role that has not been designated as an Access Person role.
Note  A financial security that generally has a longer term than a bill, but a shorter term than a Bond. However, the duration of a note can vary significantly and may not always fall neatly into this categorization. Notes are similar to Bonds in that they are sold at, above, or below face (par) value; make regular interest payments; and have a specified term until maturity.
Open-End Fund  A mutual fund that has an unlimited number of shares available for purchase.
Option  The right, but not the obligation, to buy (for a call option) or sell (for a put option) a specific amount of a given stock, commodity, currency, including foreign currencies and Digital Currencies (e.g., Bitcoin), index, or debt, at a specified price (the strike price) during a specified period or on one particular date.
Private Placement  A Security that is not registered or required to be registered under applicable securities laws. Private Placements are generally sold to a relatively small number of select investors (as opposed to a public issue, in which Securities are made available for sale on the open market) in order to raise capital. Private Placements may include, among others, interests in hedge funds (including limited partnership interests) and shares of private companies. Investors in Private Placements are usually banks, mutual funds, insurance companies, pension funds, hedge funds, and high net worth individuals. Private Placements are typically held or maintained outside of Vanguard.
Related Security  Any Security or instrument that provides economic exposure to the same company or entity—provided, however, that equity instruments will

 

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  generally not be considered related to fixed income instruments (other than convertible Bonds) and vice versa. For example, all of the following instruments would be related to the common Stock of Company X: Options, Futures, Rights, and Warrants on Company X common Stock; preferred Stock issued by Company X; and Bonds convertible into Company X common Stock. Similarly, different Bonds issued by Company X would be related to one another.
Reportable Security  Any Covered Security, ETF, ETN, or Digital Security Token.
Repurchase Agreement  An arrangement by which the seller of an asset agrees, at the time of the sale, to buy back the asset at a specific price and, typically, on a given date (normally the next day).
Right  A Security giving stockholders entitlement to purchase new shares issued by the corporation issuer at a predetermined price (normally at a discount to the current market price) in proportion to the number of shares already owned. Rights are issued only for a short period of time, after which they expire.
Secondary Offering  The sale of new or closely held shares by a company that has already made an Initial Public Offering.
Security  Any Stock, Bond, money market instrument, Note, evidence of indebtedness, Debenture, Warrant, Option, Right, Investment Contract, ETF, ETN, Digital Currency that has been deemed to be a security by the US Securities and Exchange Commission, Certificate, or any other investment or interest commonly known as a Security.
SPAC (Special Purpose Acquisition Company)  A shell company or company with no commercial operations that is formed strictly to raise capital through an Initial Public Offering (IPO) for the purpose of acquiring an existing company.
Spread Betting  A way of trading that enables you to profit from movements in a wide range of markets from Securities to currencies, including foreign currencies and Digital Currencies, Digital Security Tokens, commodities, and interest rates. Spread betting allows you to trade on whether the price quoted for these financial instruments will go up or down.
Stock  A Security that represents part ownership, or equity, in a corporation. Each share of stock is a proportional stake in the corporation's assets and profits, some of which could be paid out as dividends.
UCITS (Undertakings for the Collective Investment of Transferable Securities)  A regulatory framework of the European Commission that creates a harmonized regime throughout Europe for the management and sale of mutual funds. UCITS funds can be registered in Europe and sold to investors worldwide using unified regulatory and investor protection requirements.
Vanguard Client  The clients of VGI, or any of the International Subsidiaries, and investors in the Vanguard Funds, including the Vanguard Funds themselves.
Vanguard Fund  Vanguard mutual funds, Vanguard managed funds, Vanguard UCITS funds, Vanguard ETFs, and any other accounts sponsored or managed by Vanguard. This includes, but is not limited to, separately managed accounts and collective trusts.
Warrant  An entitlement to purchase a certain amount of common Stock at a set price (usually higher than the current price) during an extended period of time. Usually issued with a fixed-income security to enhance its marketability, a Warrant can be transferred, traded, or exercised by the holder.

 

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Policy Compliance 

 

Questions regarding this policy may be submitted to Code_of_Ethics@vanguard.com.

 

Please be aware of and comply with any supplemental policies that may apply to your role, department, or geographic region. Check with your manager for more information.

 

If you believe you may have breached this policy, you should immediately report it to your manager, notify the policy contact for your region, and work with them to take swift corrective action. Alternatively, you may report concerns regarding this policy via the Anonymous Reporting channel that Vanguard has arranged for your region. You are expected to cooperate with any research or investigation into conduct regarding this policy. 

 

The Compliance Department is the owner of this policy. Any violations or potential violations of this policy may be investigated by the Compliance Department, and if it is determined that there has been a violation, you may be subject to penalties and sanctions as described in the Disciplinary Action Policy and, for crew and contingent workers in Australia, the Managing Misconduct Policy. Any violation of this policy may result in disciplinary action up to and including termination of employment. 

 

Refer to the Policy Disclaimer Statement for more information. 

 

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Appendix

 

 

Appendix A

Am I an Access Person, and if so, which Access Person “designation” applies?

 

Appendix B

What accounts must be disclosed?

 

Appendix C

Trading and Reporting Requirements for Advisor Access Persons

 

Appendix D

Trading and Reporting Requirements for Fund Access Persons

 

Appendix E

Trading and Reporting Requirements for Fund Access Persons

 

Appendices Endnotes

Clarifications and explanations to the content within the appendices

 

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APPENDIX A

Am I an Access Person, and if so, which Access Person “designation” applies?

 

To determine if you are designated as an Access Person, review your offer letter for specifics. If you are unsure, ask your recruiter to confirm for you which designation you fall under. They can look up your designation by referencing our internal Access Person Code of Conduct policy. Your designation will be one of the following:

 

1.Advisor Access
2.Fund Access
3.Investment Access
4.Non-Access (If this is your designation, this packet does not apply to you.)

 

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APPENDIX B  

What accounts must be disclosed?

 

This list provides a snapshot of what accounts you will need to disclose. Come prepared knowing how to access the statements for these accounts. Please note, this is list is subject to change.

 

Common Account Types Access
Person
disclosure
required?
   

Employer sponsored retirement plans (plan doesn't have the ability to hold Vanguard funds) 

Examples: 401k, 403b, 457b, Employee Stock Options Plan (ESOP), Employee Stock Purchase Plan (ESPP), and pension plans 

No
   

Employer sponsored retirement plans (plan does have the ability to hold Vanguard funds) 

Examples: 401k, 403b, 457b, Employee Stock Options Plan (ESOP), Employee Stock Purchase Plan (ESPP), and pension plans 

Yes
   
529 Plans (plan doesn't have the ability to hold Vanguard funds) No
   
529 plans (plan does have the ability to hold Vanguard funds) Yes
   
Health Savings Account (plan doesn't have the ability to hold Vanguard funds) No
   
Health Savings Account (plan does have the ability to hold Vanguard funds) - Including Vanguard's HSA Yes
   

Vanguard personal accountsi 

Examples: Vanguard Brokerage Accounts, Transfer Agent Accounts (Mutual Fund Only account) 

Yes
   

Outside brokerage accounts (including retirement accounts not listed above)3 

Please Note: Accounts that are open but have a $0 balance also must be reported because they still have the ability to hold securities. 

Yes
   
Bank accounts - checking and savings No
   
Annuities No
   
Fully managed accountsii Yes2

 

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APPENDIX C

Trading and Reporting Requirements for Advisor Access Persons

 

Securities and Activities Can I Trade 60 Day Hold Reportableiii
American Depository Receipts (ADRs) Yes Yes Yes
Annuities and Insurance Products Yes No No
Bankers' Acceptances, Certificates of Deposits, and Commercial Paper Yes No No
Bonds (municipal and corporate) Yes Yes Yes
Cash No No No
Closed-End Funds Yes Yes Yes
Commodities (ex: futures & options) Yes No No
Currencies Yes No No
Debentures Yes Yes Yes
Digital Currency Yes No No
Digital Utility Tokens Yes No Yes
Digital Security Tokens Yes No Yes
Direct Obligations Yes No No
Non-Vanguard ETFs and ETNs Yes No Yes
Evidence of Indebtedness Yes Yes Yes
Government bonds Yes No No
High Quality Short Term Debt Instruments Yes No Yes
Investment Contracts Yes Yes Yes
IPOs (and ICOs) Prohibited
Money market instruments (non-Vanguard) Yes No No
Money market instruments (Vanguard) Yes No Yes
Open-End funds (non-Vanguard) Yes No No
Notes Yes Yes Yes
Options on Covered Securities Yes Yesiv Yes
Private placements (unlisted securities) Yesv No Yes
Rights Yes Yes Yes
Real Estate Investment Trusts Yes Yes Yes
Security Futures Prohibited
Short Positions Prohibited
SPACs Prohibited
Stocks Yes Yes Yes
Unit Investment Trusts Yes Yes Yes

 

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Securities and Activities Can I Trade 60 Day Hold Reportableiii
UCITs Funds (non-Vanguard) Yes No No
Vanguard Annuities and Insurance Products Yes No Yes
Vanguard ETFs Yes No Yes
Vanguard Funds Yes No Yes
Warrants Yes Yes Yes

 

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APPENDIX D

Trading and Reporting Requirements for Fund Access Persons

 

Securities and Activities Can I Trade Preclear 7 Day Blackout 60 Day Hold Reportableiii
American Depository Receipts (ADRs) Yes Yes Yes Yes Yes
Annuities and Insurance Products Yes No No No No
Bankers' Acceptances, Certificates of Deposits, and Commercial Paper Yes No No No No
Bonds (municipal and corporate) Yes Yes Yes Yes Yes
Cash No No No No No
Closed-End Funds Yes Yes No Yes Yes
Commodities (ex: futures & options) Yes No No No No
Currencies Yes No No No No
Debentures Yes Yes Yes Yes Yes
Digital Currency Yes No No No No
Digital Utility Tokens Yes No No No Yes
Digital Security Tokens Yes No No No Yes
Direct Obligations Yes No No No No
Non-Vanguard ETFs and ETNs Yes No No No Yes
Evidence of Indebtedness Yes Yes Yes Yes Yes
Government bonds Yes No No No No
High Quality Short Term Debt Instruments Yes No No No Yes
Investment Contracts Yes Yes Yes Yes Yes
IPOs (and ICOs) Prohibited
Money market instruments (non-Vanguard) Yes No No No No
Money market instruments (Vanguard) Yes No No No Yes
Open-End funds (non-Vanguard) Yes No No No No
Notes Yes Yes Yes Yes Yes
Options on Securities Prohibited
Private placements (unlisted securities) Yesv Yes No No Yes
Rights Yes Yes Yes Yes Yes
Real Estate Investment Trusts Yes Yes Yes Yes Yes
Security Futures Prohibited
Short Positions Prohibited

 

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Securities and Activities Can I Trade Preclear 7 Day Blackout 60 Day Hold Reportableiii
SPACs Prohibited
Stocks Yes Yes Yesvi Yes Yes
Unit Investment Trusts Yes Yes Yes Yes Yes
UCIT Funds (non-Vanguard) Yes No No No No
Vanguard Annuities and Insurance Products Yes No No No Yes
Vanguard ETFs Yes No No No Yes
Vanguard Funds Yes No No No Yes
Warrants Yes Yes Yes Yes Yes

 

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APPENDIX E

 

Trading and Reporting Requirements for Investment Access Persons

 

Securities and Activities Can I Trade Preclear 7 Day Blackout 60 Day Hold Reportableiii
American Depository Receipts (ADRs) Yes Yes Yes Yes Yes
Annuities and Insurance Products Yes No No No No
Bankers' Acceptances, Certificates of Deposits, and Commercial Paper Yes No No No No
Bonds (municipal and corporate) Yes Yes Yes Yes Yes
Cash No No No No No
Closed-End Funds Yes Yes No Yes Yes
Commodities (ex: futures & options) Yes No No No No
Currencies Yes No No No No
Debentures Yes Yes Yes Yes Yes
Digital Currency Yes No No No No
Digital Utility Tokens Yes No No No Yes
Digital Security Tokens Yes No No No Yes
Direct Obligations Yes No No No No
Non-Vanguard ETFs and ETNs Yes No No No Yes
Evidence of Indebtedness Yes Yes Yes Yes Yes
Government bonds Yes No No No No
High Quality Short Term Debt Instruments Yes No No No Yes
Investment Contracts Yes Yes Yes Yes Yes
IPOs (and ICOs) Prohibited
Money market instruments (non-Vanguard) Yes No No No No
Money market instruments (Vanguard) Yes No No No Yes
Open-End funds (non-Vanguard) Yes No No No No
Notes Yes Yes Yes Yes Yes
Options on Securities Prohibited
Private placements (unlisted securities) Yesv Yes No No Yes
Rights Yes Yes Yes Yes Yes
Real Estate Investment Trusts Yes Yes Yes Yes Yes
Security Futures Prohibited
Short Positions Prohibited

 

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Securities and Activities Can I Trade Preclear 7 Day Blackout 60 Day Hold Reportableiii
SPACs Prohibited
Stocks Yes Yes Yes Yes Yes
Unit Investment Trusts Yes Yes Yes Yes Yes
UCITs Funds (non-Vanguard) Yes No No No No
Vanguard Annuities and Insurance Products Yes No No No Yes
Vanguard ETFs Yes Yes No Yes Yes
Vanguard Funds Yes Novii No Noviii Yes
Warrants Yes Yes Yes Yes Yes

 

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APPENDICES ENDNOTES

 

Clarifications and explanations to the content within the appendices

 

 

i Accounts you share ownership with will need to be disclosed, e.g., a joint account

ii Fully managed accounts can be maintained outside of Vanguard with review and approval from the Code team. Please provide one of the following documents for review:

·A signed discretionary/advisory agreement from the outside firm, or
·A signed letter from your advisor on their firm's letterhead.

 

This documentation should include the following information:

·The account number(s) for any account considered fully managed
·The name of your advisor or the name of the program in which the account is enrolled
·A statement that you have no discretion/trading authority over your managed account(s)

 

iii Reportable on Initial Holdings Report or when acquired. All Crew and Contingent Workers deemed Associated Persons must report their accounts, holdings, and transactions through My Compliance Office (MCO).

 

iv Options on Covered Securities include trades that are exercised or assigned involuntarily by the crew member.

 

v Prohibited from acquiring Securities in a Private Placement without prior approval from Compliance.

 

vi Permitted to sell stock with a market cap above US $5 billion, so long as, over a rolling 30 day period, their total value aggregate sales of the stock does not exceed $10,000.

 

vii Vanguard ETFs require preclearance.

 

viii Vanguard ETFs require a 60 day hold.

 

Page 37 of 37

 

 

 

Exhibit 99.CERT

 

CERTIFICATIONS

 

I, Mortimer J. Buckley, certify that:

 

1. I have reviewed this report on Form N-CSR of Vanguard Trustees’ Equity Fund;

 

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

 

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

 

4. The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

 

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

 

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

 

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

 

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

 

5. The registrant’s other certifying officer(s) and I have disclosed to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

 

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize, and report financial information; and

 

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.

 

Date: December 19, 2022

 

  /s/ Mortimer J. Buckley
  Mortimer J. Buckley
  Chief Executive Officer

 

 

 

 

CERTIFICATIONS

 

I, Christine Buchanan, certify that:

 

1. I have reviewed this report on Form N-CSR of Vanguard Trustees’ Equity;

 

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

 

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

 

4. The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

 

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

 

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

 

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

 

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

 

5. The registrant’s other certifying officer(s) and I have disclosed to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

 

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize, and report financial information; and

 

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.

 

Date: December 19, 2022

 

  /s/ Christine Buchanan
  Christine Buchanan
  Chief Financial Officer

 

 

 

 

Exhibit 99.906CERT

 

Certification Pursuant to 18 U.S.C. Section 1350,

As Adopted Pursuant to

Section 906 of the Sarbanes-Oxley Act of 2002

 

Name of Issuer: Vanguard Trustees’ Equity Fund

 

In connection with the Report on Form N-CSR of the above-named issuer that is accompanied by this certification, the undersigned hereby certifies, to his knowledge, that:

 

1.The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

 

2.The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the issuer.

 

Date:   December 19, 2022

 

  /s/ Mortimer J. Buckley
  Mortimer J. Buckley
  Chief Executive Officer

 

 

 

 

Certification Pursuant to 18 U.S.C. Section 1350,

As Adopted Pursuant to

Section 906 of the Sarbanes-Oxley Act of 2002

 

Name of Issuer: Vanguard Trustees’ Equity

 

In connection with the Report on Form N-CSR of the above-named issuer that is accompanied by this certification, the undersigned hereby certifies, to her knowledge, that:

 

1.The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

 

2.The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the issuer.

 

Date:    December 19, 2022

 

  /s/ Christine Buchanan
  Christine Buchanan
  Chief Financial Officer