Investment Policy Statement

Last Updated: June 5, 2025

Last Reviewed: June 5, 2025

Purpose

The purpose of the Investment Policy Statement (“IPS”) is to assist the entity that has established and maintains the Plan for the benefit of its employees and their beneficiaries and any committee appointed by it as a “named fiduciary” for investments (collectively referred to as “Plan Sponsor”) in supervising, monitoring and evaluating the investments available to participants in the Plan Sponsor’s defined contribution plan (“Plan”). The Plan Sponsor is authorized to oversee the investment of Plan assets. The Plan Sponsor will discharge its responsibilities under the Plan in accordance with Section 404(a) of the Employee Retirement Income Security Act (“ERISA”) and solely in the interests of Plan participants.

The Plan’s investment program is defined in the IPS by:

  • Stating in a written document the Plan Sponsor’s objectives and guidelines for the investment of the Plan’s assets.

  • Establishing the duties and responsibilities of the parties involved with the Plan.

  • Establishing criteria to regularly select, monitor, evaluate and compare and, when appropriate, replace investment options.

  • Complying with all ERISA, fiduciary, prudence and due diligence requirements, and with all other applicable state and federal laws, rules and regulations that may impact the Plan assets. 

The purpose of the Plan is to encourage additional tax-advantaged retirement savings by employees, and to provide a vehicle for these savings. The Plan is designed to meet the applicable requirements of the Internal Revenue Code of 1986, as amended. And the requirements of ERISA section 404(c) and the Department of Labor regulations thereunder. As a participant-directed Plan, participants' accounts will bear the gains and losses associated with their decisions.  The Plan Sponsor or other Plan fiduciary will not be liable for any loss (or reduced gain) a participant incurs as a direct and necessary consequence of the participant’s exercise of investment discretion.

This Statement is not intended to be a Plan document. It is designed to provide guidance to the Plan Sponsor in carrying out its fiduciary functions with respect to the Plan. If any term or condition of this Statement conflicts with any term or condition of the Plan, the terms and conditions of the Plan will control.

Objectives

The purpose of the Plan is to encourage eligible employees to accumulate funds for retirement by providing them with a convenient way to save on a regular and long-term basis.

The Investment Objectives of the Plan are to:

  • Make available to participants and beneficiaries a prudent and diversified menu of investment choices appropriate at different ages and with different risk tolerances;

  • Control costs of administering the Plan and managing the investments, including reviewing and evaluating the fees associated with investment options, to ensure that fees are reasonable in relation to the services provided;

  • Make available to participants general investment information to help them make more informed investment choices;

  • Follow ERISA 404(c) “Safe Harbor” requirements; and

  • Provide a qualified default investment alternative for participants who do not or cannot make their own investment decisions.

Investment Policy Review

The Plan Sponsor will periodically review the IPS to assess whether its stated investment objectives remain relevant and the continued feasibility of achieving those objectives has not materially changed. The Plan Sponsor does not anticipate that its IPS will materially change frequently, but it will be amended when appropriate. In particular, short-term changes in the financial markets should not require adjustments to the IPS. 

Duties and Responsibilities

Plan Sponsor

As the Plan’s fiduciary, the primary responsibilities of the Plan Sponsor are to:

  • Establish and maintain an Investment Policy Statement.

  • Make available sufficient asset classes with different and distinct risk profiles under the Plan so that each participant has the opportunity to prudently diversify his/her account given his/her investment circumstances.

  • Unless delegated to a 3(38) Investment Manager, prudently select investment options.

  • Unless delegated to a 3(38) Investment Manager, monitor investment options as to fund levels, returns, manager performance relative to established benchmarks, and manager tenure.

  • Review the reasonableness of each investment alternative's fees and expenses when compared to similar alternatives in the marketplace.  

  • Unless delegated to HIA as 3(38) Investment Manager, remove investment options and terminate managers that are not performing at acceptable levels.

  • Monitor and supervise service vendors.

  • Avoid prohibited transactions and conflicts of interest.

Role of Outside Investment Professionals

The Plan Sponsor may appoint a third-party investment adviser as described in Section 3(21) of ERISA or an investment manager as defined in Section 3(38) of ERISA to assist in fulfilling these responsibilities. For purposes of this Investment Policy Statement, Human Interest Advisors (“HIA”), an SEC-registered investment adviser, shall be considered as the investment adviser or investment manager, if appointed by the Plan Sponsor to serve in one of those capacities.

If HIA is appointed to be a co-fiduciary for investments (i.e., 3(21)), HIA is responsible for making investment recommendations in regard to the Plan’s fund lineup, while the Plan Sponsor is responsible for selecting and monitoring investment options. If HIA is appointed as a fiduciary investment manager (i.e., 3(38)), HIA is responsible for selecting and monitoring investment options. 

The Plan Sponsor may also arrange for the provision of general investment education services or individual investment advice for participants.

Custodian/Trustee

The Plan’s custody services are provided by Matrix Trust Company (“Matrix”). The Plan Sponsor has appointed Matrix to hold the plan’s assets in a non-fiduciary capacity, effect transactions, and provide account reporting. Matrix is responsible for safekeeping the Plan’s assets.

The primary duties and responsibilities of the custodian are to:

  • Value the Plan’s holdings.

  • Collect income and dividends owed to the Plan.

  • Settle transactions (e.g., buy and sell orders).

  • Provide not less than quarterly reports that detail transactions, cash flows, securities held and their current value, and change in value of each security and the overall plan since the previous report; and

  • Maintain separate accounts by legal registration.

In accordance with the Plan’s agreement with Matrix, the Plan receives monthly and/or quarterly account statements directly from Matrix.

Asset Class Guidelines

The Plan Sponsor believes long-term investment performance is, in large part, primarily a function of asset class mix. The Plan will offer a broad range of investment alternatives that provide participants with a reasonable opportunity to:

  • Materially affect the potential return on amounts in their individual Plan account and vary the degree of risk to which such amounts are subject

  • Choose from at least three investment alternatives that:

  • Are diversified

  • Have materially different risk and return characteristics

  • In aggregate, enable them to achieve a portfolio with aggregate risk and return characteristics at any point within the range normally appropriate for them

  • Offer the ability to diversify their investments in their portfolio so as to minimize the risk of large losses.  

Implementation/Option Selection

Investment options should be managed by either: (a) a bank; (b) an insurance company; (c) a registered investment company (e.g., mutual fund); or (d) a registered investment adviser. 

The selection of investment alternatives is generally based on the long-term performance of the investment. Accordingly, short-term results may be examined, but will not be the sole determinant in the selection/elimination process. For these purposes, “long-term” performance means the performance evaluated over a full-market cycle. The Plan Sponsor and HIA may select investment alternatives by utilizing qualitative and quantitative factors.  The following criteria will determine selection or elimination of the Plan’s investment options:

  • Model Portfolios: The following criteria will guide HIA in the selection and retention of the model portfolios:

  • Qualitative measures including asset allocation assessment, glide path draw down, diversification of assets, and the total number, complementary nature, and appropriateness of the underlying funds.  

  • Quantitative measures including quality of the underlying funds and the costs associated with them.

  • Model portfolios will be evaluated on a periodic basis over a full market cycle.  

  • Index Investment Options: The index investment alternatives will be evaluated on the basis of their performance relative to their benchmark indices.  

  • Actively Managed Investment Options: The performance of each actively managed investment options shall be compared with the performance of portfolios of other similarly managed investment products (peer groups) and a passive index, as reviewed by the Plan Sponsor and/or HIA from time to time.  Over a full-market cycle, all of the investment options’ annualized returns should meet or exceed the median returns of their respective peer groups.

  • Investment options selected should have demonstrated a reasonable risk/return profile. The Plan Sponsor and HIA recognize that risk and volatility are present to some degree in all investment alternatives. While high levels of risk are to be avoided, the assumption of some risk is warranted to allow participants the opportunity to achieve satisfactory long-term results consistent with this IPS.

  • When evaluating an investment option, the Plan Sponsor and HIA may, among other things, consider fees charged by a particular investment alternative, the qualifications, reputation, and tenure of the investment alternative’s principal employees, and the role the particular investment alternative has in the Plan’s overall investment portfolio, taking into account such factors as diversification, liquidity, and risk/return characteristics.

There are certain circumstances in which HIA’s trading algorithm intentionally deviates from target weights specified in model portfolios to prevent trade rejection by the custodian, Matrix. Specifically, when preparing dollar certain buy trades for small amounts of money where an asset cannot be purchased due to fractional share limitations, the algorithm will seek to instead purchase another fund in the participant’s model or otherwise invest the amount into a cash fund. In these circumstances, it is possible to see a variance from target model portfolio weights; however, HIA believes the degree is not material to participant accounts and is consistent with HIA’s fulfillment of its fiduciary duties to its clients.

Monitoring Responsibilities

The Plan Sponsor and if applicable HIA will monitor the performance of each investment manager and investment option on a periodic basis. ​​The Plan Sponsor and HIA will review whether each investment manager and option continues to conform to the criteria outlined in the previous section.  Where the Plan Sponsor designates HIA as the 3(38) investment manager, HIA is responsible for monitoring the performance of investment options.

The Plan Sponsor and HIA have the discretion to place or remove investment options from a “Watch List” at any time that they determine that such placement or removal from a “Watch List” is appropriate in light of relevant monitoring considerations and conduct a review and analysis of an investment option if, and when, any of the following occurs:

  • An investment options’s investment performance and risk levels over various periods (e.g., a three-year period and a five-year period), in light of the stated policies and objectives, does not meet the established monitoring criteria

  • An investment option appears to no longer adhere to its stated strategy and style; or

  • There is a significant change in the investment option’s organization and/or portfolio management.

An investment alternative will remain on the Watch List until the Plan Sponsor or HIA is satisfied that it no longer requires special monitoring. 

There are no hard rules for terminating investment options from a Plan. An investment option should be given a full market cycle to achieve the above-stated performance thresholds, and therefore, greater weight shall be given to market-cycle performance than performance in a given year.  Failure to meet performance thresholds may be a factor taken into account by the Plan Sponsor or HIA, together with other relevant factors and the totality of the circumstances, in assessing the continued propriety of the retention of an investment alternative.

The Plan Sponsor and HIA recognize that other conditions may occur, requiring action by the Plan Sponsor or HIA sooner than a full-market cycle. Other conditions could include, but are not limited to, a change in management of an investment option, style drift of an investment alternative, risk and return profile, capital outlook provided by the investment alternative, or regulatory issues relating to the fund management of the investment option, as well as any changes in the characteristics of the Plan. In the event that an investment option is replaced, it may be closed to future investment, eliminated from the investment menu, or replaced by a similar fund in the same asset class, as determined in the reasonable judgment of the Plan Sponsor or HIA.