INVESTMENT POLICY STATEMENT Effective as of July 31, 2023 Investment Adviser: Betterment LLC 1 INTRODUCTION This Investment Policy Statement (“Investment Policy”) has been developed by Betterment LLC (“Betterment”) and describes the processes for the selection, monitoring, and management of investments for Client’s 401(k) plan (“Plan”) assets for which Betterment serves as a 3(38) fiduciary. Client approves this Investment Policy as set forth in the Services Agreement executed between Client, Betterment, and certain of Betterment’s affiliates. The Services Agreement serves as evidence of the Client’s decision to use Betterment’s managed account services for Plan participants and for Betterment to serve as a 3(38) investment manager. Client agrees that by continuing to participate in Betterment's managed account offering, Client approves of the terms of the Investment Policy. This Investment Policy supersedes any previously adopted investment policy statement. This Investment Policy assumes that the Plan intends to comply with ERISA § 404(c) and the Department of Labor Regulations § 2550.404c established thereunder (collectively, “§ 404(c)”), and Plan has concluded that this Investment Policy is an appropriate policy for achieving this objective. Plan participants have the ability to exercise independent control over their investments by providing Betterment with investment instructions, including by selecting their desired portfolio strategy and asset allocation, and Betterment manages participant portfolios based on those instructions. Participants’ exercise of control allows them to affect the potential returns in their account and control their degree of risk. This includes selecting a portfolio strategy and asset allocation, as well as establishing a separate retail relationship with Betterment and directing Betterment to manage a participant’s 401(k) account holistically with participant’s other Betterment accounts (as described below). Betterment’s core portfolio strategy (“Core”), described below, serves as the qualified default investment alternative (“QDIA”) if a participant does not provide any instruction to Betterment. SERVICES AND RESPONSIBILITIES Betterment is responsible for: 1. Serving as an investment manager within the meaning of ERISA § 3(38) to the Plan. 2. Selecting, managing, and overseeing the Plan’s investment options, including constructing portfolio strategies, providing ongoing monitoring of portfolio strategies, and updating and/or developing new portfolio strategies as appropriate. 3. Managing participant account balances pursuant to their chosen investment strategy or goal, and offering participants guidance on how to reach their retirement goals. 4. Managing the QDIA for the investment of a participant’s assets when the participant otherwise fails to provide investment direction. 5. Providing periodic reports to the Plan to enable it to monitor Betterment in its role as investment manager. 2 6. Maintaining and periodically updating this Investment Policy. MANAGED ACCOUNT OFFERING Betterment provides investment management and related services primarily over the Internet, which includes discretionary investment services, portfolio strategy construction, and retirement planning tools. Participants input information about themselves and their retirement goals through Betterment’s online interface, and Betterment’s software generates recommendations and constructs and manages participant portfolios based on the information they provide. If participants do not input any information, Betterment manages their accounts with the Plan’s QDIA. Portfolio Strategies Participants may select from among several different portfolio strategies based on their preferences. Portfolio strategies are typically implemented through investments in publicly traded exchange-traded funds (“ETFs”). Portfolio strategy options include Betterment constructed portfolios, such as Betterment Core, Betterment Innovative Technology, several socially responsible portfolio strategies, and a flexible portfolio strategy that allows participants to build their own portfolio by adjusting weights of asset classes and/or adding exposure to additional asset classes relative to Betterment Core. For portfolio strategies that Betterment constructs, Betterment selects the underlying securities, and provides asset class mappings, allocations, weights, and capital markets assumptions for the portfolio. In the future, Betterment may construct additional portfolio strategies to provide more investment options to participants. Betterment also makes available several third-party constructed portfolio strategies to participants. For third-party constructed portfolio strategies, Betterment receives allocation updates from the third-party provider. Betterment conducts a limited review of the allocations as it relates to the portfolio strategies’ investment objective and then interpolates the allocations into Betterment’s portfolio management software. Third-party constructed portfolio strategies typically offer complementary approaches to Betterment’s constructed portfolios, such as a factor-based “smart beta” portfolio strategy and an all-bond portfolio strategy. As a 3(38) investment manager to Plans, Betterment manages the QDIA using its Core portfolio strategy. If plan participants do not select an investment strategy, their contributions will be invested pursuant to the Core portfolio strategy. The Core portfolio strategy is a globally diversified portfolio of low-fee stock and bond ETFs that includes stock investments in developed and emerging markets and bond investments in governments, agencies and corporations around the world. Through incorporating multiple asset classes, Betterment’s 3 construction process seeks to maximize expected return per unit of risk, achieved through diversification. Asset class exposures are obtained through the usage of ETFs that are selected using Betterment’s proprietary security selection methodology as described below. The QDIA’s target allocation (as defined below) takes into account the participant’s age and anticipated retirement age, and becomes more conservative over time (following a “glide path”) as a participant approaches retirement. If a participant has a separate independent advisory relationship with a third-party investment advisor that utilizes the Betterment for Advisors (B4A) platform, the participant may also designate the third-party advisor as a fiduciary with discretion to manage their 401k account, and may elect from additional custom portfolio strategies constructed by the third-party investment advisor. Such delegation is documented between Betterment, the participant, and the third-party investment advisor. Betterment will manage a participant’s account assets in accordance with the portfolio strategy that the participant designates for such purpose, or, in the case of a participant who does not designate a portfolio strategy, in accordance with the QDIA. Betterment monitors its portfolio strategies consistent with its policies and procedures and the stated portfolio objective. More information about all the available portfolio strategies is available at https://www.betterment.com/work/investments. Asset Allocation and Risk Tolerance For each portfolio strategy, Betterment will recommend an asset allocation, which is the relative percentage of asset classes (i.e. stocks, bonds, and if applicable, other asset classes) in which a participant’s account will be invested. Betterment’s recommended allocation is based on participants’ current age and anticipated retirement age. Participants can either accept the recommended allocation or elect a different allocation based on their own risk tolerance. For certain investment strategies, including the QDIA, participants have the option to enable a feature to automatically adjust their allocation in accordance with the glide path as their retirement date approaches. As described above, for participants who are invested in the QDIA by default, their default asset allocation will automatically follow the glide path as they approach retirement. If a participant chooses to deviate from Betterment’s recommended asset allocation, creates a custom portfolio, or disables this feature, their allocation will not automatically adjust over time. The investment objectives of each portfolio strategy offered to participants can only be achieved by incurring a certain amount of principal volatility and risk. Each investment strategy will be managed in a manner (a) intended to minimize principal fluctuations at the established time horizon and (b) consistent with the investment strategy’s stated objective. 4 Security Selection Each available portfolio strategy seeks to provide participants with exposure to various asset classes in line with the portfolio’s stated objective. The selection process for portfolio strategies is intended to satisfy a broad set of potential participant financial goals, including but not limited to: attempting to maximize returns, minimize investment costs, limit volatility, and diversify investments. Betterment’s constructed portfolio strategies consider diversification across geography and asset class, as well as costs associated with the particular investments within the asset class. For third-party constructed portfolio strategies, Betterment seeks to incorporate strategies that offer complementary approaches to Betterment’s constructed portfolios. Betterment does not select the underlying securities in third-party constructed portfolios. In evaluating particular securities for inclusion in a Betterment constructed portfolio strategy, Betterment analyzes a universe of available ETFs that satisfy key metrics including expense ratio, tracking difference, liquidity, and bid-ask spread. Betterment investment personnel also consider whether the security satisfies a particular investment objective, such as sustainability, exposure to a novel asset class, or focus on a particular geographic region, among others. Considering these factors, securities are ranked by quantitative and qualitative metrics to narrow down to a list of finalists. Betterment then constructs portfolios of finalist ETFs that satisfy the portfolio strategy’s stated objectives. If a Participant establishes a retail relationship with Betterment and elects certain tax optimization features (e.g., Tax Coordination or Tax Loss Harvesting+), Betterment will manage that participant’s 401(k) account holistically with other Betterment accounts. This may cause Betterment to purchase certain securities in such a participant’s 401(k) account than Betterment typically purchases for participants with only a Betterment 401(k) account. Any security purchased for a participant’s account is subject to the same security selection process and ongoing monitoring and review. For third-party constructed portfolios, the third-party provider/ asset manager/advisor may alternatively select and monitor these securities in place of Betterment. Additional information about Betterment’s Tax Coordination feature is available at https://www.betterment.com/resources/asset-location-methodology and additional information about Betterment’s Tax Loss Harvesting+ feature is available at https://www.betterment.com/resources/tax-loss-harvesting-methodology Performance Expectations Over the long-term, the investment objectives for each portfolio strategy available to participants is to achieve an average total annual rate of return consistent with the range of capital market expectations for each portfolio strategy at the selected allocation. Returns may vary within these ranges, year by year and by portfolio strategy. 5 Participant Direction Participants are unable to select the underlying ETFs for particular asset classes, which are selected by Betterment for Betterment constructed portfolios or selected by third-parties and implemented by Betterment for third-party constructed portfolios. Plan acknowledges this limitation is prudent and beneficial to the Plan and its participants by agreeing to use Betterment’s services. Participants provide direction to Betterment by the selection of portfolio strategies, asset allocation, and enabling certain portfolio management tools, such as the glide path, or if they have other Betterment accounts, tax loss harvesting, and tax coordinated portfolios. Proxy Voting Plan delegates to Betterment the authority to receive and vote all proxies and related materials for any security held in by the Plan. Betterment accordingly will vote on matters requiring a proxy vote for the securities held by the Plan in Betterment Constructed Portfolios and will do so in a way that is reasonably expected to ensure that proxy matters are conducted in the best interest of participants. Plan also delegates to Betterment the authority to vote on other corporate actions, like tender offers, which do not require a proxy or are not solicited via proxy. You may request information regarding how Betterment voted your proxies. Betterment will vote only on proxies and respond to corporate actions associated with securities that Betterment currently selects for Betterment Constructed Portfolios and will abstain from voting on other securities, including but not limited to those securities only present in third-party portfolios. If a security is present in both Betterment Constructed Portfolios and third-party portfolios, it is considered a recommended security and Betterment will vote on proxies associated with that security in all portfolios in which it is held. Betterment is not responsible for voting proxies or participating in corporate actions for any security until the security is in the possession and control of Betterment Securities. 6
