Page 25 - NovDefComp

MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
Defined Benefit and Defined Contribution Recordkeeping

Investment Service Operations System

with regular assessments. Training reports are also distributed available to managers to track employee
progress towards development goals. Focus is also placed on protecting the investment in strategic portfolio
initiatives by ensuring appropriate training and readiness of employees. It is MassMutual management’s
responsibility to determine that all MassMutual associates have received appropriate training.
Department managers also encourage training and development that continues to qualify personnel for
their functional responsibilities.
The associate performance evaluation process is an ongoing performance review and part of the employee
development process. All associates receive feedback on their overall responsibilities, including internal
controls, on a regular basis or at least twice a year. Associates identify their specific performance and
development goals designed to enhance their knowledge of and ability to best service the retirement plans.
During the evaluation and feedback process, any areas requiring improvement are identified and associates
are coached on the ways they can improve their performance and meet their development objectives.
MassMutual policies, procedures, and controls are subject to regular reviews by corporate governance,
risk, and control functions. Corporate Audit, Compliance and Ethics, Enterprise Risk Management,
Financial Reporting Risk, Corporate Law and Enterprise Information Risk Management functions are
designed to evaluate compliance with Company policies in addition to governmental regulations that govern
retirement service operations. Formal reports documenting the scope and results of reviews performed by
the governance, risk and control functions are prepared and submitted to Company management as well
as the Audit Committee of the Board of Directors as applicable.
A summary of the Company’s policies and procedures is incorporated in its Code of Conduct (the Code).
All associates must certify that they have read the Code and agree to follow the Company’s Code of
Conduct and the underlying policies and practices. The Company has a formal conflict-of-interest policy,
which establishes rules of conduct for associates. Specifically, associates are prohibited from divulging
confidential information regarding Plan Sponsor affairs, trading in securities of the Plan Sponsors or
affiliates or taking any action that’s in conflict with the best interests of the plan. In addition, associates
(access persons) who have access to non-public information about securities holdings of our mutual funds
and separate investment accounts (SIAs) must provide periodic brokerage statements to a compliance
officer for review if they have an outside brokerage account.
Risk Assessment

MassMutual’s Enterprise Risk Management group (ERM) has a dedicated business risk management
function that collaborates with various corporate governance risk and control functions to regularly assess
the risk that could impede MassMutual’s ability to service DB and DC plans. The business risk management
function works with MassMutual management to identify the services that meet the common needs of its
user constituencies and to help assess the risks that result in the appropriate controls being put in place.
Periodic risk management meetings are held to ensure that risk assessment is a continuous process
throughout the year. In addition to the risk assessment performed by the business risk management
function, ERM and other Corporate entities perform additional risk assessments that are intended to provide
perspective on relevant MassMutual risks.
Enterprise Information Risk Management and Third Party Risk Management facilitate regular risk
assessments of subservice providers utilized by MassMutual.

Financial Reporting Risk facilitates annual risk assessments which include the potential for fraud
over operations that support the generation of MassMutual Financial Reporting.
Corporate Audit performs regular risk assessments to select MassMutual operations to be
audited.

MassMutual Defined Benefit and Defined Description of the System Provided by
Contribution Investment Service Operations MassMutual
System
14