Report of Independent Registered Public Accounting Firm
To the Board of Trustees of Vanguard International Equity Index Funds and Shareholders of
Vanguard Global ex-U.S. Real Estate Index Fund
In planning and performing our audit of the financial statements of Vanguard Global ex-U.S. Real Estate
Index Fund (one of the funds constituting Vanguard International Equity Index Funds, hereafter referred
to as the “Fund”) as of and for the year ended October 31, 2019, in accordance with the standards of the
Public Company Accounting Oversight Board (United States) (“PCAOB”), we considered the Fund’s
internal control over financial reporting, including controls over safeguarding securities, as a basis for
designing our auditing procedures for the purpose of expressing our opinion on the financial statements
and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on
the effectiveness of the Fund’s internal control over financial reporting. Accordingly, we do not express an
opinion on the effectiveness of the Fund's internal control over financial reporting.
The management of the Fund is responsible for establishing and maintaining effective internal control over
financial reporting. In fulfilling this responsibility, estimates and judgments by management are required
to assess the expected benefits and related costs of controls. A company’s internal control over financial
reporting is a process designed 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. A company’s internal control over financial reporting includes those
policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately
and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable
assurance that transactions are recorded as necessary to permit preparation of financial statements in
accordance with generally accepted accounting principles, and that receipts and expenditures of the
company are being made only in accordance with authorizations of management and directors of the
company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized
acquisition, use or disposition of a company’s assets that could have a material effect on the financial
statements.
Because of its inherent limitations, internal control over financial reporting may not prevent or detect
misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk
that controls may become inadequate because of changes in conditions, or that the degree of compliance
with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists when the design or operation of a control
does not allow management or employees, in the normal course of performing their assigned functions, to
prevent or detect misstatements on a timely basis. A material weakness is a deficiency, or a combination of
deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a
material misstatement of the company’s annual or interim financial statements will not be prevented or
detected on a timely basis.
Our consideration of the Fund’s internal control over financial reporting was for the limited purpose
described in the first paragraph and would not necessarily disclose all deficiencies in internal control over
financial reporting that might be material weaknesses under standards established by the PCAOB.
However, we noted no deficiencies in the Fund’s internal control over financial reporting and its operation,
including controls over safeguarding securities, that we consider to be a material weakness as defined
above as of October 31, 2019.
PricewaterhouseCoopers LLP, Two Commerce Square, Suite 1800, 2001 Market Street, Philadelphia, PA 19103-7045
T: (267) 330 3000, F: (267) 330 3300, www.pwc.com/us
This report is intended solely for the information and use of the Board of Trustees of Vanguard
International Equity Index Funds and the Securities and Exchange Commission and is not intended to be
and should not be used by anyone other than these specified parties.
