Page 423 - DCAC February 2024 Files
P. 423

The Committee believes that Environmental, Social and Governance (ESG) factors may have a material impact
      on the long-term financial success of its investments. The Committee may consider ESG as part of the decision-
      making process and evaluation of managers.

      Details on  the  current  investment  lineup  and  benchmarks  for  the  Plan  are  contained  in  the  Plan’s  regular   Deleted: Exhibit B details
      meeting materials.                                                                  Deleted: Plans

      B. Self-Directed Brokerage Accounts

      The self-directed brokerage option is intended to give sophisticated, experienced and knowledgeable investors   Deleted: designed
      access to additional investment options. The Plans, Committee, Investment Management Consultant and its   Deleted: for a
      recordkeeper have no expressed or implied responsibility for the evaluation, selection and/or monitoring of the
      investment options in any self-directed brokerage account program by the Plans, including no duty to supervise   Deleted: continued offering of the
      or  monitor  the  Participants'  or  Beneficiaries' investment  experience  in  the  self-directed brokerage  account
      program(s).

      C. Performance Expectations

      Over  time,  each  active  investment  option's  overall  annualized  total  return  should  perform  above  their
      benchmark and at or above the median of portfolios of similar style and passive options should  track their
      respective index.  The Committee will continually monitor and review funds against this expectation.

      D. Selection of Fund Managers and Options

      The Committee, with the assistance of the Investment Management Consultant, will select appropriate fund
      managers to manage Plan assets.  The following minimum criteria must be met:

           1.  The fund options will be managed by a bank, insurance company, investment management company
              or investment adviser as defined by the Registered Investment Advisers Act of 1940.

           2.  Historical  quarterly  performance  numbers,  calculated  on  a  time-weighted  basis  based  on  a
              composite  of  all  fully  discretionary  accounts  of  similar  investment  style,  will  be  utilized  for
              performance screening.

           3.  Performance evaluation reports that illustrate the risk/return profile of the manager relative to other
              managers of like investment style will be utilized.

           4.  Detailed information on the history of the fund management firm, its key personnel, and associated
              costs will be analyzed.

           5.  Each fund's investment strategy must be described, and successful adherence to that strategy over
              time must be documented.

           6.  Fund managers must compare favorably against a comparable peer group for selection.


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