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CORRESP
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CORRESP

 February 25, 2026

 Kim
McManus

 Division of Investment Management

 Securities and
Exchange Commission

 100 F Street, N.E.

 Washington, D.C.
20549

Re:
 Prospectuses and Statements of Additional Information (“SAI”) contained in Post-Effective Amendment
No. 277 to the Registration Statement of Russell Investment Company (filed on December 10, 2025)

 Dear Ms. McManus:

This letter responds to comments you provided to me in a telephonic discussion on February 20, 2026, regarding Post-Effective Amendment No. 277 to
the Russell Investment Company (“RIC” or the “Registrant”) Registration Statement (the “Registration Statement”) filed with the Securities and Exchange Commission (the “SEC” or
“Commission”) on December 10, 2025 (the “RIC Filing”). Summaries of the comments, and Registrant’s responses thereto, are provided below.

Responses to Comments

 Capitalized terms have the
same meaning as defined in the Prospectuses and SAI unless otherwise indicated.

1.

Comment:

In the “Proxy Voting Policies and Procedures” section of the SAI, please disclose, where appropriate, how the Sustainable Aware Equity Fund will approach ESG proxy voting issues. Alternatively, please explain in
correspondence why the Registrant believes such disclosure is not required. See, e.g., “Disclosure of Proxy Voting Policies and Proxy Voting Records by Registered Management Investment Companies,” SEC Rel. No. IC-25922 (Apr. 14, 2003).

Response:

 Registrant confirms that the Proxy Voting Policies and Procedures (the “P&P”) and Engagement Policy, collectively referred to
as the “Guidelines” in the Registration Statement, will be included in a new Appendix B to the SAI for the 485(b) filing. The Registrant has revised the last paragraph of the above-referenced section of the SAI as follows:

 Information on how the Funds voted proxies relating to portfolio securities during the
most recent 12-month period ended June 30 is available, without charge, upon request by contacting the Funds at 1-800-787-7354, at https://connect.rightprospectus.com/russellinvestments and on the SEC’s website at http://www.sec.gov. Please refer to Appendix B at the end of this SAI for the Guidelines
effective March 1, 2026. Current The Guidelines are available, without charge, at https://russellinvestments.com.”

 

The Guidelines are contained in Appendix I hereto and reference is made to Section I of the P&P which specifically discusses proxy voting in relation to environmental and social issues.

Sincerely,

 /s/ Jennifer O’Brien

 cc:

 Mary Beth
Albaneze

 Jessica Gates

 John
V. O’Hanlon

 Stephanie Capistron

 Appendix I – Guidelines

 PROXY VOTING POLICIES AND GUIDELINES 2026

 As adopted by:

Russell Investments Capital, LLC

 Russell Investments Funds
Management, LLC

 Russell Investments Implementation Services, LLC

Russell Investment Management, LLC

 Russell Investments Trust
Company

 Russell Investments Canada Limited

 Russell
Investments Korea Limited

 Russell Investment Management Ltd

Russell Investment Group Limited

 Russell Investments France
SAS

 Russell Investments Ireland Limited

 Russell
Investments Limited

 Russell Investments Group Japan Co., Ltd.

(the foregoing collectively referred to herein as “Russell Investments”)

CONFIDENTIAL

 Copyright © 2026 Russell Investments Group, LLC. All rights reserved. This material is proprietary and may not be reproduced, transferred, or distributed in any form without prior written permission from
Russell Investments. It is delivered on an “as is” basis without warranty.

PROXY VOTING POLICIES AND GUIDELINES / 2

 Proxy administration procedures

For over 30 years, Russell Investments has executed a robust, global proxy voting programme that is a foundation of our stewardship efforts. Our documented
Proxy Voting Policies and Procedures, along with custom Proxy Voting Guidelines, form the basis of this program. These guidelines, crafted based on industry best practices and regulations, dictate our approach to voting on specific topics. Carefully
drafted to uphold our clients’ best interests, our guidelines undergo annual review and updates to align with shareholders’ interests.

 While
the Proxy Voting Policy and Guidelines comprehensively address most proxy issues with detailed specificity, the Active Ownership Committee (the Committee) acknowledges that certain matters necessitate deeper scrutiny and a non-prescriptive approach. In such cases, the guidelines refer the votes to the Committee for review, as explained in the below.

As part of our process, an external service provider, Glass Lewis, acts as our proxy administrator and is responsible for aggregating proxy ballots received
directly from Russell Investments’ custodians and applying our custom guidelines when executing proxy votes. Our internal proxy coordinator monitors voting activity through Glass Lewis’ online platform. Proposals requiring case-by-case review are directed to internal analysts. These analysts conduct individual research and collaborate with the proxy coordinator to provide recommendations to the
Committee.

 To ensure alignment with our guidelines, the Committee oversees an annual internal audit process, verifying the accuracy of vote execution by
Glass Lewis.

1.
 Any Proxy Administrator retained by Russell Investments shall vote all proxies as instructed in the guidelines
attached hereto. The Proxy Administrator is currently Glass Lewis & Co (“Glass Lewis”). In the event (a) a voting matter is to be determined on a
case-by-case basis or (b) the Proxy Administrator raises a question regarding a particular matter, the Proxy Administrator shall request direction from Russell
Investments’ Active Ownership Committee. The Active Ownership Committee may instruct the Proxy Administrator “not to vote” on any proposal.

2.
 The Proxy Administrator shall maintain a system allowing Russell Investments access to all solicitations for
vote received by the Proxy Administrator.

3.
 The Proxy Administrator shall vote each proxy pursuant to the guidelines, unless directed otherwise by Russell
Investments’ Active Ownership Committee.

4.
 The Proxy Administrator shall maintain a record of all votes received, all votes cast and any other relevant
information pursuant to the Proxy Administrator’s normal policies and as directed by Russell Investments.

5.
 The Proxy Administrator will use the attached guidelines until such guidelines are superseded by subsequent
guidelines. The guidelines may be changed at any time in Russell Investments’ sole discretion.

PROXY VOTING POLICIES AND GUIDELINES / 3

 Contents

 PROXY VOTING POLICIES AND GUIDELINES

1

 A.

General considerations

5

 B.

Audit and reporting

5

 C.

Board

6

 D.

Capital

10

 E.

Corporate transactions

11

 F.

Shareholder rights and governing documents

12

 G.

Remuneration

14

 H.

Mutual fund proxies

17

 I.

Environmental and Social Issues

18

 J.

Appendix

21

PROXY VOTING POLICIES AND GUIDELINES / 4

 A. General considerations

Proxy voting is a fundamental tool that allows shareholders to express support or concern regarding aspects of corporate governance, operations, or
disclosures. As stewards of our clients’ capital, we have an obligation to vote responsibly and hold companies accountable on their behalf. These guidelines describe our approach to corporate governance, environmental and social topics, when
exercising our voting rights on behalf of our clients.

 We apply these guidelines globally, and across all asset classes as required. However, they are
designed to accommodate the nuances of specific market requirements, expectations, and local regulations, rather than providing discretion. This ensures that we remain compliant while considering the diverse nature of our capabilities.

While we strive to vote on all our clients’ holdings in all markets, there are instances where this may not be possible due to a practice known as share
blocking, which could prevent us from trading for a certain period if we were to vote these shares.

 Companies should act transparently and disclose
information to shareholders to the fullest extent possible. Therefore, we expect companies to disclose any relevant materials ahead of a General Meeting, providing sufficient time for shareholders to review, analyse and engage upon the information
disclosed. In certain instances, when we consider the level of information is inadequate to apply these guidelines, we may choose to vote against a particular proposal.

B. Audit and reporting

 1. Transparency and
reporting

 The strength of financial controls and the integrity of financial statements form the cornerstone for the healthy operation of the companies we
invest in. The board should release a report from an external auditor, offering an impartial and objective assessment of whether the company’s accounts accurately represent its financial position and future prospects.

As a general practice, we tend to support proposals seeking to acknowledge Reports and Accounts signed off as complete by a qualified auditor ahead of the
Annual General Meeting (“AGM”). In the event of a qualified opinion, we expect the company to provide a full, comprehensive explanation. In markets where it’s mandatory for companies to present
non-financial information statements/reports, we will typically endorse their approval. Yet, we reserve the right to vote against management if the independent assurance service provider raises substantial
concerns about the information provided, or if the disclosed information is not sufficient for shareholders to make informed voting decisions.

 2.
External auditor

 The independence of the external auditor holds significant importance for ensuring the integrity of financial assessments. Excessive non-audit fees could potentially compromise an auditor’s independence, impacting the quality of their audit work. Consequently, it is our expectation that companies provide a transparent breakdown of both
audit and non-audit services. In cases where the total non-audit fees surpass the fees paid for audit-related services, we might consider voting against re-electing the external auditor.

 Companies ought to furnish comprehensive disclosures regarding resolutions for
electing or ratifying an external auditor. Specifically, we look for explanations regarding any changes in the external auditor and details about the competitive tender process used to select a new external auditor.

Should it be determined that the effectiveness of the auditor has been compromised, we might opt not to support their
re-appointment. Furthermore, we might oppose the re-appointment of an audit company if its lengthy tenure could potentially challenge its independence.

PROXY VOTING POLICIES AND GUIDELINES / 5

 C. Board

1. Size

 The board of directors is the focal point of corporate
governance. Directors represent the shareholders, and they are charged with safeguarding investors’ interests. Directors should provide corporate leadership but refrain from interfering in day-to-day company operations which are properly the province of the CEO and other senior executive officers. Holding executives accountable for their actions is a critical responsibility of the board.

Ensuring that a company’s board is suitable for the size and nature of the business is paramount. It is crucial that the size of the board does not
compromise the dynamics of the board and an efficient decision-making process.

 2. Board effectiveness

The effectiveness of the board relies heavily on how it is structured and composed. We support strong boards that demonstrate a commitment to creating
shareholder value. While director candidates and other board-related issues must be evaluated on a case-by-case basis considering the company’s performance and
total governance structure, we prefer to see mechanisms that promote:

•

 Independence: A board free from management influence is better equipped to oversee strategy and assess
performance and executive compensation objectively.

•

 Accountability: Directors must be accountable to shareholders. Policies that promote accountability would include
annual elections and shareholders’ ability to fill vacancies or to remove directors without cause.

•

 Responsiveness: Directors should be responsive to shareholders, particularly in regard to shareholder proposals
that receive a majority vote and tender offers where a majority of shares are tendered.

•

 Competence: Companies should seek directors whose skills and expertise add value to the board.

 In contested elections, where shareholders nominate alternate directors in opposition to management’s choices, we consider
various factors:

•

 Long-term financial performance of the target company relative to its industry;

•

 Management’s track record;

•

 Background to the proxy contest;

•

 Qualifications of director nominees (both slates);

•

 Evaluation of what each side is offering shareholders as well as the likelihood that the proposed objectives and
goals can be met; and

•

 Stock ownership positions of the proponents.

We prefer directors to be elected to the board on an annual basis and be accountable to shareholders by approval of a majority of shares voted in favour on
each resolution.

PROXY VOTING POLICIES AND GUIDELINES / 6

 3. Leadership

In advocating for effective corporate governance, there is a recognition of the importance of separating the roles of the Chair and Chief Executive Officer
(CEO) within a company. This separation, particularly in controlled companies where either the chair or CEO holds substantial shares, ensures a clearer division of responsibilities at the highest level.

When the chair and CEO roles are consolidated, there is an expectation for companies to provide comprehensive explanations regarding why this combination
serves the best interests of the company. Regular reviews of this structure are also encouraged.

 There is a distinct preference for an independent non-executive Chair of the Board, and it is recommended that companies appoint a Lead Independent Director, even in cases where the chair is already independent.

When assessing proposals that would require the positions of chairman and CEO to be held by different persons, we will consider:

•

 Whether a designated lead director has been elected by and from the independent board members with clearly
delineated duties. At a minimum these include:

•

 Presides at all meetings of the board at which the chairman is not present, including executive sessions of the
independent directors;

•

 Serves as liaison between the chairman and the independent directors;

•

 Approves information sent to the board;

•

 Approves meeting agendas for the board;

•

 Approves meeting schedules to assure that there is sufficient time for discussion of all agenda items;

•

 Has the authority to call meetings of the independent directors; and

•

 If requested by major shareholders, assurance that they are available for consultation and direct communication

•

 Level of independence of the board and the key committees.

•

 Whether the company publicly discloses a sufficient explanation of why it chooses not to give the position of
chairman to the independent lead director, and instead to combine the chairman and CEO positions.

•

 Established governance guidelines.

While it may be appropriate in certain cases for CEOs to simultaneously serve as chair of the board, we may decide to vote against the chair of the governance
or nominations committee if the company lacks both an independent chair and an independent lead director.

PROXY VOTING POLICIES AND GUIDELINES / 7

 4. Independence

In evaluating board composition, the emphasis lies on fostering an optimal blend of directors with appropriate, relevant and diverse industry backgrounds.
Additionally, the inclusion of a substantial number of independent directors within boar