Page 26 - NovDefComp
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In executing its responsibilities, the Committee will make decisions solely in the interest of Plan participants and
        beneficiaries, for the exclusive purpose of  providing Plan benefits and defraying reasonable administrative costs. All
        investments selected by the Committee are intended to meet concepts of ERISA  section 404(c) as a best practice.

        Part V. MONITORING OF SERVICE PROVIDERS
        Service providers should be monitored on a regular basis or more frequently if applicable. Administrative and/or
        recordkeeping service providers may be  benchmarked against, but not limited to, industry averages and/or other
        provider quotes. Monitoring for these service providers should include, but not be  limited to, the provider’s:

                •  Investment offerings and services
                •  Recordkeeping technology and services
                •  Compliance services and support
                •  Technology
                •  Participant access and communications
                •  Total Plan costs

        The monitoring of the plan provider(s) is to ensure that total plan costs and services are competitive and reasonable.

        Investment consultant service providers (plan and participant level) should be monitored regularly and should include,
        but not be limited to, the provider’s:

                •  Investment Due Diligence processes
                •  Fiduciary guidance and services
                •  RPF/Benchmarking scope and services
                •  Technology
                •  Participant level access, communications and advice (if applicable)
                •  Cost

        Part VI. SELECTION OF INVESTMENT OPTIONS
        The selection of investment options offered under the Plan is among the Committee’s most important responsibilities.
        Set forth below are the considerations  and guidelines employed in fulfilling this fiduciary responsibility.


        The Plan intends to provide an appropriate range of investment options that may span the risk/return spectrum.
        Further, the Plan’s investment options are  intended to allow Plan participants to construct portfolios consistent with
        their  unique  individual  circumstances,  goals,  time  horizons  and  tolerance  for  risk.  Major  asset  classes  to  be
        considered may include, but are not limited to:

        Conservative Investments
        Cash and liquid investments including, but not limited to, money market, stable value, and guaranteed interest
        accounts.
        Income Investments
        Income oriented investments including, but not limited to, low, medium, and high quality bond funds, with short,
        intermediate, and/or long term duration.  Management styles may be indexed and actively managed international,
        global, and domestic styles.

        Equity Investments
        Funds that invest in equity securities, both domestic and foreign, including, but not limited to, small, medium, and large
        market capitalization, with value, blend,  and growth investment objectives, which may be actively managed or indexed.

        Asset Allocation Investments
        Funds or accounts that invest in a combination of conservative, income, and equity investments, “fund of funds” accounts
        combining several of the above  investments into one or a series of investments, and “manager of managers” accounts
        combining several different investment styles and fund managers into  one account or a series of accounts.
        Other Investments
        Other appropriate investments in other styles or asset classes offered through vehicles such as commingled trusts,
        insurance Company separate accounts  through a group annuity contract, and mutual funds.  Notwithstanding the
        foregoing, the Committee may consider, but is not required, to include in the  investment menu any specific investment
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