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Committee Responsibilities

As fiduciaries under the Plan, the primary responsibilities of the

Committee

are:

Prepare and maintain this investment policy statement.

Provide sufficient asset classes with different and distinct risk/return profiles so each participant can

prudently diversify his/her account.

Prudently select investment options.

Control and account for all investment, record keeping and administrative expenses associated with

the Plan.

Monitor and supervise all service vendors and investment options.

Avoid prohibited transactions and conflicts of interest.

The

Committee

will periodically review the plan vendor/custodian to ensure that the overall plan offering is

competitive relative to the marketplace for comparable plans.

The Department of Labor has stated that if statutes and trust provisions permit, the fiduciary may delegate certain

decisions to money managers, trustees, investment consultants, and/or

Registered Investment Advisor (RIA)

. The

Committee

understands that even when Fiduciary duties are delegated they are unable to fully abdicate his/her

fiduciary responsibility.

Registered Investment Advisor (RIA) Responsibilities

The

Committee

will retain an objective, third-party Consultant/RIA to assist the

Committee

in managing the overall

investment process.

The Consultant/RIA will be responsible for guiding the

Committee

through a disciplined and rigorous investment

process to enable the

Committee

to meet the fiduciary responsibilities outlined above. The Consultant/RIA will

exercise its responsibilities in the best interest of the Plan’s participants and beneficiaries. The Consultant/RIA will

employ generally accepted analytics-based or data-based software in developing investment research for the Plan’s

investment options.

Custodial Responsibilities

The plan vendor serves as custodian and is responsible for the safekeeping of the Plan’s assets. The specific custodial

duties and responsibilities of the plan vendor are:

Maintain separate accounts by legal registration.

Value the holdings.

Collect all income and dividends owed to the Plan.

Settle all transactions (buy-sell orders).

Provide monthly reports that detail transactions, cash flows, securities held and their current value,

and change in value of each security and the overall portfolio since the previous report.

III.

INVESTMENT POLICY GUIDELINES & OBJECTIVES

While the

Committee

believes it is their responsibility to frequently review the results achieved by each investment

option, judgments regarding an option’s suitability will not be made based solely on short-term performance.

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