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Generally, three to five years of performance history is needed before results alone can play a substantial role in

judging an investment option. In the short run, other factors can and will be given significantly more weight than

investment results. These factors include, but are not limited to:

Consistency of investment style

Organizational and personnel stability

Fundamental risk

Concentration risk

The

Committee

recognizes the long-term nature of retirement plan investments. Loss of principal is only one risk for a

long-term investor. Opportunity costs and inflation also warrant considerations. The

Committee

will review the

retirement plan vendor platform periodically to ensure that broadly diversified investment options are available to

participants.

Finally, the

Committee

does not have a symmetrical risk tolerance, meaning decisions which result in large gains are

not as good as decisions that prevent large losses.

IV.

INVESTMENT OPTIONS

The investment options which have been selected for the plan are well-diversified; professionally managed; charge fees

that are reasonable for the asset class and/or investment approach taken; and provide, in the aggregate, the participant

with the opportunity to structure a portfolio with risk and return characteristics suitable to long-term investment

programs. The current investment options of the

ABC Company Plan

are named in the periodic Investment Review

which is prepared by the

Registered Investment Advisor (RIA)

.

The

Committee

will apply the following due diligence criteria in selecting each mutual fund investment option:

Regulatory oversight: Each investment manager should be a regulated bank, an insurance company,

a mutual fund organization, or a registered investment advisor.

Correlation to style or peer group: The investment option should be highly correlated to the asset

class of the investment option. For example, a small cap equity investment option’s performance

should be highly correlated with small cap equities in general over time.

Performance relative to a peer group: The investment option’s performance should be evaluated

against the peer group.

Performance relative to assumed risk: The investment option’s risk-adjusted performance should be

evaluated against the peer group.

Minimum track record: The inception date should be greater than three years unless relevant

circumstances support a shorter time frame.

Holdings consistent with style: The investment option’s individual stock and/or bond holdings

should be consistent with its stated style.

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