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assistance, to manage their own investments with assistance or to have their
investments managed entirely by a designated Provider of services to the plan.
• The Plan will regularly, at least annually, review its educational policies,
educational curriculum, performance standards and procedures to assure that
strong and effective strategies for plan participants are represented.

2.3 Duties and Responsibilities

The Plan Sponsor must identify individuals responsible for carrying out Plan duties.
Typically, the Plan Sponsor will appoint a Deferred Compensation Committee
(“Committee”), whose general duties and responsibilities for Plan participant
education are as follows:

• Establish educational services offered by providers to plan participants.
• Require Provider adherence to this Education Policy.
• Develop education-specific Provider performance standards based on goals and
financial guarantees that will be part of ongoing Provider evaluation.
• Review this Policy at least annually and recommend amendments to the Policy at
any time to reflect changes in the procedures or to incorporate requirements
based on new regulations and / or best practices.
• Approve annual educational topics, establish the schedule of on-site educational
programs targeted to both current employees and retiree participants and assure
that the programs are easily accessible by all plan participants.
• Identify multi-channel (i.e., electronic, one-to-one, printed, etc.) educational
programs which are made available to participants.
• Provide input and approve ongoing communication / marketing of educational
programs.

• Promote plan participant use of guidance and investment advice services.
• Encourage coordination of defined benefit and defined contribution information
as well as other participant assets in order to achieve the most comprehensive
development of asset allocation strategies.
• Establish and monitor, at least annually, the impact of educational programs on
participant behavior including, but not limited to, the number of participants in the
plan, total and average plan contributions, number of fund selections per
participant, frequency of re-balancing by participants, and participant usage of
different components of the educational program. Wherever possible, the
identified information will be distinguished by gender, age and department /
occupation.
• Assure that the Education Policy Statement is easily accessible by plan
participants as appropriate.
• Although the Employee Retirement Income Security Act of 1974 (ERISA) does
not apply to the Plan, the Committee intends to operate the Plan generally in
conformance with ERISA 404(c).
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