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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