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Privacy Policy

Introduction

Habitat for Humanity of Summit County respects each individual’s right to personal privacy. We will collect and use information through our Web site only in the ways disclosed in this statement. This statement applies solely to information collected at the Habitat for Humanity of Summit County Web site.

Part I. Information Collection

Habitat for Humanity of Summit County collects information through our Web site at several points. We collect the following information about primary visitors: full name, address and email.

We collect this information through registration forms and donation forms. Information collected includes person’s full name, address and email. The information is collected voluntarily. To receive our products and services, contact information is mandatory in order to reach persons. Other information we request is optional.

We do not employ cookies.

Part II. Information Usage

The information collected by Habitat for Humanity of Summit County will be used for contact purposes and mailing lists. Users who provide information will receive email newsletters and print materials. Registered users will receive additional announcements from us about products, services, special deals, and a newsletter. Out of respect for the privacy of our users we present the option to not receive these types of communications.

We offer links to other Web sites. Please note: When you click on links to other Web sites, we encourage you to read their privacy policies. Their standards may differ from ours.

If our policy on information collection or uses changes, will advise you by email within 48 hours.

Part III. Problem Resolution

If problems arise, users may contact Habitat for Humanity of Summit County by phone at 330-745-7734 or email habitat@hfhsummitcounty.org. We are committed to resolving disputes within 48 hours.

Part V. Data Storage and Security

Habitat for Humanity of Summit County protects user information with the following security measures: SSL encryption.

Habitat for Humanity of Summit County, Inc.

Whistleblower/Anti-Retaliation Policy

This Whistleblower/Anti-Retaliation Policy of Habitat for Humanity of Summit County, Inc. (“Habitat”): (1) encourages staff and volunteers to come forward with credible information on Prohibited Practices or Violations of Law; (2) specifies that Habitat will protect the person from retaliation; and (3) identifies where such information can be reported.

1. Encouragement of reporting.

Habitat encourages complaints, reports or inquiries about Prohibited Practices or Violations of Law, including illegal or improper conduct by Habitat itself, by its leadership, or by others on its behalf. For purposes of this policy, “Violations of Law” means a violation of any state, federal or local law that Habitat has the authority to correct and the staff member or volunteer reasonably believes that the violation is: (i) a criminal offense that is likely to cause an imminent risk of physical harm to persons, (ii) a hazard to public health or safety, or (iii) a felony. For purposes of this policy, “Prohibited Practices” means conduct that a staff member or volunteer reasonably believes constitutes a serious violation of the policies and practices established by Habitat and that would financially or detrimentally impact Habitat, such as incorrect financial reporting, financial improprieties, accounting or audit matters, or detrimentally impact the reputation of Habitat, such as ethical violations, fraudulent conduct, or other similar improper practices or policies.

Other subjects on which Habitat has existing complaint mechanisms should be addressed under those mechanisms, such as raising matters of alleged discrimination or harassment via Habitat’s human resources channels, unless those channels are themselves implicated in the wrongdoing. This policy is not intended to provide a means of appeal from outcomes in those other mechanisms.

2. Protection from retaliation.

Habitat prohibits retaliation by or on behalf of Habitat against staff or volunteers for making good faith complaints, reports or inquiries under this policy or for participating in a review or investigation under this policy. This includes retaliation in the form of an adverse employment action such as termination, decrease in compensation, or the threat of physical harm. Every effort will be made to protect the confidentiality of the staff member or volunteer making the report. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law, and to provide accused individuals their legal rights of defense.

This protection extends to those whose allegations are made in good faith but prove to be mistaken. Habitat reserves the right to discipline persons who make bad faith, knowingly false, or vexatious complaints, reports or inquiries or who otherwise abuse this policy. Any staff member or volunteer who makes a report under this policy who believes he or she is being retaliated against must immediately contact Habitat’s President and Chief Executive Officer or President of the Board of Trustees; if both of those persons are implicated in the complaint, report or inquiry, it should be directed to any member of the Board of Trustees not so implicated.

3. Where to report.

Subject to disclosure that may be necessary as described in Section 2 above, complaints, reports or inquiries may be made under this policy on a confidential or 2 anonymous basis. They should describe in detail the specific facts demonstrating the basis for the complaints, reports or inquiries. They should be directed to Habitat’s President and Chief Executive Officer or President of the Board of Trustees; if both of those persons are implicated in the complaint, report or inquiry, it should be directed to any member of the Board of Trustees not so implicated. Habitat will conduct a prompt, discreet, and objective review or investigation. Staff or volunteers must recognize that Habitat may be unable to fully evaluate a vague or general complaint, report or inquiry that is made anonymously.

Red Flag Reporting

Habitat for Humanity of Summit County is a client of Red Flag Reporting, an independent business unit where volunteers, customers, donors, employees or anyone witnessing or wishing to report an incident, safety concern or impropriety relative to Habitat for Humanity of Summit County or the Habitat ReStore in Summit County can call anonymously. If you feel you have something to report to this independent party for investigation, please call 1-877-64-RedFlag (1-877-647-3335) or visit www.redflagreporting.com

Our client code for reporting is 3307457734. We appreciate you helping to protect our organization and our community.

Policy 31

Non-Proselytizing

Adoption Date: JUNE 2012

1.0 Purpose

This policy applies to Habitat for Humanity International and its affiliated organizations (Habitat for Humanity).

The purpose of this policy is:

To provide internal and external clarity regarding Habitat for Humanity’s approach to humanitarian aid and development assistance as a Christian ministry.
To ensure alignment with back and I said international standards unacceptable humanitarian aid and development assistant practices.

2.0 Policy

Habitat for Humanity international and its affiliated organizations (Habitat for Humanity) will not proselytize nor will Habitat for Humanity work with entities or individuals who insist on proselytizing as part of their work with Habitat for Humanity. This means that Habitat for Humanity will not offer assistance on the expressed or implied condition that people must (i) adhere to or convert to a particular faith or (ii) listen and respond to messaging designed to induce conversion to a particular faith.

3.0 Rationale

Habitat for Humanity is a Christian ministry dedicated to a vision of a world where everyone has a decent place to live. Habitat for Humanity conducts its programs in a way that are sensitive and respectful to the cultural context and the local faith community and reflect our belief that all or created in God’s image and deserve to be treated without discrimination.

Globally, faith based organizations from all religions approach their work with a range of motivations that inform their development approach. This policy is intended to ensure that Habitat for Humanity conforms to recognized global standards that clearly state that agencies may not conditioned the receipt of assistance or participation and their work on any requirement that people listen and respond to a message intended to induce people to join a religious movement, political party, or other cause or organization.

Habitat for Humanity International’s motivation is to unite people around the concept of “putting God’s love into action” along with others from all faiths or with no faith convictions who are interested in helping those in need of improved shelter.

Investment Policy Statement

Initial Adoption – August 31, 2022, Revision 1 Board Approved – August 22, 2023

Table of Contents

Organizational Overview
Statement of Purpose
Operating and Control Procedures
Investment Responsibility
Authorization
Delegation
Roles and Responsivities
Standard of Conduct
Investment Policy Review
Funds Investment Objectives
Asset Allocation Guidelines
Rebalancing Guidelines
Allocation of New Capital
Risk Expectation/Guidelines
Guidelines for Transactions
Prohibited Transactions
Equity Guidelines
Fixed Income/Cash Equivalent Guidelines
Alternative Investing Guidelines
Selection of Investments/Active Investment Managers
Watch/Termination of Investment Managers
Investment Manager Restrictions
Performance Measurement

Organizational Overview

Habitat for Humanity of Summit County was organized as an affiliate in 1986. We have been building homes with families in Summit County for over 30 years. Families partner with Habitat to achieve the strength, stability and self-reliance they need to build a better future. To date, Habitat for Humanity of Summit County has built over 200 homes and has housed more than 300 adults and 500 children.

Statement of Purpose

The purpose of this investment policy is to establish a clear understanding of the investment objectives and procedures for the Board of Trustees for Habitat for Humanity of Summit County Inc. (“Trustees”), the Investment Committee (“Committee”) to fulfill their fiduciary responsibilities pertaining to the investments of the Mid-Range Program Pool and Long-Term Program Pool (“Funds”). It will be used as the primary guideline for the members of the Trustees and any investment professionals retained. The guidelines apply to unrestricted and restricted investable assets.

Operating and Control Procedures

The Funds are ultimately overseen by the Trustees. As such, only those individuals who have been appropriately appointed by the Trustees may act on behalf of the Funds. Appointed individuals should refer to this Investment Policy Statement’s operating and control procedures when making decisions on behalf of the Funds.

The Trustees are responsible for overseeing the management of the Funds. The Trustees, with the assistance of any outsourced investment professionals, have the responsibility to oversee the investments of the Funds, to establish broad guidelines for the Fund’s portfolios, select investments, determine or approve asset allocation and monitor performance of all investments on a regular basis.

Investment Responsibility

The Trustees have the following authority:

	Investment Consultants	Board of Trustees	Investment Committee
Policies and Authorities	Provide Input and Recommend	Select and Approve	Recommend to Trustees
Investment Manager & Consultant Selection	Provide Input and Recommend	Select, Approve and Implement	Recommend to Board of Trustees
Asset Allocation Within Sectors	Provide Input and Recommend	–	Select, Approve and Implement

The Trustees, through their investment consultant, will conduct reviews with major investment managers. Additional on-site reviews with these managers will be scheduled if market conditions or performance warrant. Index funds do not require reviews and will be reported on quarterly.

Investment performance reports will be consolidated and distributed by the investment consultant to Trustees reporting total return performance compared to relevant benchmarks net of fees.

Authorization

Through due process and prior approval of the Trustees, the Chief Financial Officer may act upon instructions rendered to him/her. Furthermore, the Chief Financial Officer may request or execute withdrawals from the Funds upon approval of the Trustees. All withdrawals or transactions associated with the Funds should be requested in writing.

Delegation

The Trustees may select and engage investment professionals, including investment managers (professional money management), investment consultants (professional investment advice providers) and custodians (professional investment domicile agents) to help manage and domicile the Funds.

The Trustees may delegate to external investment professionals the management and investment of all or part of the Funds to the extent that can be prudently done under the circumstances. The Trustees shall act in good faith, with the care that an ordinary, prudent person in a like position would exercise under similar circumstances in:

Selecting investment professionals
Establishing the scope and terms of the delegation, consistent with the scope and purposes of the Funds
Periodically reviewing the investment professional’s actions in order to monitor performance and compliance with the scope and terms of the delegation

In this regard, the Trustees shall engage investment professionals that have demonstrated competence in their respective responsibilities and investment strategies. These investment professionals have discretion and authority for determining investment strategy, security selection and timing of purchases and sales of assets subject to the guidelines for which they have been approved within the guidelines of the approved Investment Policy Statement.

Roles and Responsibilities

Trustees of Habitat for Humanity of Summit County Inc.:

Oversee the management of assets.
Act solely in the best interest of the Funds and its mission.
Select qualified members to serve on the Committee.
Review Committee’s proposed changes to investment policy statement and approve.
Ratify Committee’s proposed changes to the IPS before any changes are implemented.
Select consultants, investment managers, custodians, and any other vendors required to administer and manage the Funds.
Periodically request a performance summary from the Committee.
Avoid prohibited transactions and conflicts of interest.
Approve any distribution of investment funds

Investment Committee:

Oversee the management of assets.
Act solely in the best interest of the Funds and its mission.
Determine investment objectives, develop investment (and asset allocation) strategies, and create performance guidelines.
Set and revise the investment policies and receive Trustees approval before IPS implementation.
Recommend to Trustees the selection of consultants, investment managers, custodians, and any other vendors required to administer and manage the Funds.
Periodically review all funds-related expenses to ensure they are competitive and appropriate.
Review and evaluate investment results and make changes as needed.
Provide periodic performance reports to the Trustees.
Avoid prohibited transactions and conflicts of interest.

Investment Consultant:

Assist with all aspects of development, review and maintenance of the Investment Policy Statement
Meet with the Committee at least annually and provide a quarterly performance monitor

Conduct all necessary investment searches
Make sure all applicable active managers are complying with the Investment Policy Statement
Perform on-going asset allocation studies
Perform an annual fee review of all portfolio costs
Help the Trustees and Committee negotiate and reduce costs
Complete any specific projects the committee may wish to review
Perform an Annual Fiduciary Review

Standard of Conduct

The Trustees recognize that Ohio has formally adopted the UPMIFA (Uniform Prudent Management of Institutional Funds Act) legislation which pertains to these Funds. As such, in managing and investing the Funds assets, the Trustees shall:

Act in good faith and with the care an ordinary prudent person in a like position would exercise under similar circumstances
Incur only costs that are appropriate and reasonable in relation to the assets, the purposes of the Funds and the skills available
Make a reasonable effort to verify facts relevant to the management and investment of the Funds
Make management and investment decisions about an individual asset not in isolation, but rather in the context of the Fund’s portfolio of investments as a whole and as a part of the overall investment strategy including risk and return parameters set forth in this Investment Policy Statement

Consider the following factors if relevant:

– General economic conditions

– The possible impact of inflation or deflation

– The expected tax consequences, if any, of investment decisions or strategies

– The role that each investment or course of action plays within the overall investment portfolio or Funds

– The expected total return from income and appreciation of investments

– Other resources of the Funds

– The needs of the Funds to make distributions and to preserve capital

– An asset’s special relationship or special value, if any, to the Funds or mission

Investment Policy Review

The Trustees and Committee will review the Investment Policy Statement and corresponding objectives annually for their continued pertinence. The current Policy should remain in effect until such time as it is formally modified by the Trustees through a formal process.

Funds Investment Objectives

The primary objective for the investments of the Funds is the preservation of capital while providing for the long-term growth of principal without undue exposure to risk. Specifically, the Funds objectives are as follows:

Maintain the real purchasing power of the Funds after inflation, costs and spending
Provide a stable source of liquidity and financial support for the mission of the Funds

While acknowledging the importance of preserving capital, the stewards of the Funds also recognize the necessity of accepting risk if the Funds is to be able to achieve its long-term investment goals. It is the view of the Trustees that choices made with respect to asset allocation will be among the major determinants of investment performance. The Trustees shall seek to ensure that the risks taken are appropriate and commensurate with Fund’s objectives. The Long-Term Program Pool has a long-term investment horizon, while the Mid-Range Program Pool has a time horizon that is meant to have a life not to exceed FY 2025-2026 to meet program investments that have been approved by the Board of Trustees.

The objectives shall be accomplished by utilizing a strategy of equities, fixed income, alternative investments, and cash equivalents in an allocation which is conducive to participation in a rising market while allowing for adequate protection in a falling market. Due to the inevitability of short-term market fluctuations, which may cause variations in the investment performance, it is intended that the foregoing objectives will be achieved over rolling three- and five-year periods.

The investment performance objective of the Funds shall, net of investment advisory/investment fees, strive to exceed the spending rate plus CPI over time.

Asset Allocation Guidelines

The total Portfolio shall be diversified both by asset class (e.g., equities, fixed income, alternative investments and cash equivalents), and by economic sector, industry, quality, size, investment style, geographic location, etc. The purpose of diversification is to provide reasonable assurance that no single security or class of securities will have a disproportionate impact on the total Portfolio and the portfolio is positioned to maximize risk-adjusted returns.

The asset allocation shall be implemented using the policy portfolio with the target allocations and ranges approved for each investment strategy. The asset allocation may be implemented using active and/or passive investment vehicles. Due to the need for diversification and the longer funding periods for certain investment strategies, the Trustees recognize that an extended period of time may be required to fully implement the asset allocation plan. It is expected that market value fluctuations will cause deviations from the target allocations and may need to be periodically rebalanced. The Trustees will review the asset allocation quarterly and will, within a reasonable period of time, re-allocate within the guidelines below when significant differences occur (see Guidelines on following page):

Mid-Range Program Pool:

	Minimum	Target	Maximum	Benchmark

Equity Strategies	8%	18%	28%	MSCI All Country
Domestic Equities	6%	16%	26%	Russell 3000
Large Growth	2%	6%	10%	Russell 1000 Growth
Large Value	2%	6%	10%	Russell 1000 Value
Small/Mid Cap	0%	4%	8%	Russell 2500 Growth
International Equities	0%	2%	5%	MSCI All Country ex US
Developed Markets	0%	2%	5%	MSCI EAFA Growth


Fixed Income	66%	76%	86%	Barclays U.S. Aggregate
Cash & Equivalents	2%	5%	20%	3 Month T-Bill
Core Bonds	60%	66%	72%	Barclays U.S. Aggregate
Global Bonds	0%	3%	6%	World Gov’t Bond Index
High Yield Bonds	0%	2%	5%	Merrill Lynch High Yield

Absolute Return / Alternative	2%	6%	10%	HFRI FOF Composite
Global Hedge Funds– Alternative	2%	6%	10%	HFRI FOF Composite

Long-Term Program Pool:

	Minimum	Target	Maximum	Benchmark

Equity Strategies	41%	51%	61%	MSCI All Country
Domestic Equities	35%	40%	45%	Russell 3000
Large Growth	9%	14%	19%	Russell 1000 Growth
Large Value	9%	14%	19%	Russell 1000 Value
Small/Mid Cap	7%	12%	17%	Russell 2500
International Equities	4%	11%	18%	MSCI All Country ex US
Developed Markets	4%	8%	12%	MSCI EAFA Growth
Emerging Markets	0%	3%	6%	MSCI Emerging Markets


Fixed Income	33%	43%	53%	Barclays U.S. Aggregate
Cash & Equivalents	0%	3%	6%	3 Month T-Bill
Core Bonds	30%	35%	40%	Barclays U.S. Aggregate
Global Bonds	0%	3%	6%	World Gov’t Bond Index
High Yield Bonds	0%	2%	4%	Merrill Lynch High Yield

Absolute Return / Alternative	2%	6%	10%	HFRI FOF Composite
Global Hedge Funds– Alternative	2%	6%	10%	HFRI FOF Composite

Rebalancing Guidelines

The purpose of rebalancing is to maintain the Fund’s policy asset allocation within the Policy’s ranges, thereby ensuring that the Funds does not incur additional risks as a result of having deviated from the policy portfolio. More frequent tactical rebalancing of asset classes within their ranges will also be permitted in order to take advantage of shorter-term market conditions, as long as such changes or allocations do not, in the opinion of the Trustees, cause undue risk or expense to the Funds. The Trustees will review the asset allocation at least quarterly for rebalancing purposes.

Allocation of New Capital

Funds gifts will be commingled for the purpose of investing with the exception of restricted gifts or gifts accepted with special instruction. Additions to principal shall be allocated by the Committee in accordance to the guidelines established in the Investment Policy Statement.

Risk Expectations/Guidelines

It is recognized by the Trustees that a certain amount of volatility will be incurred in order to meet the objective of long-term growth of capital. However, the annualized standard deviation of the total portfolio shall not exceed 10% for the Mid-Range Program Pool and 15% for the Long-Term Program Pool of the appropriately blended benchmark(s). Additionally, each underlying investment will be reviewed for its individual risk profile as measured by Modern Portfolio Theory risk statistics.

Guidelines for Transactions

The following are specific guidelines to be used by the Trustees, active separate account investment managers and custodians:

The custodian will provide a monthly transaction journal and investment position for each investment manager.
The custodian will sweep daily, all cash in the sub accounts of the Funds. The cash should be invested at competitive rates in the custodian’s money market for future investments by the managers.

Prohibited Transactions

The following transactions will be prohibited unless otherwise deemed permissible by prior approval of the Trustees:

There shall be no short selling, securities lending, financial futures, margins, options or other specialized investments without the prior approval of the Trustees.
There shall be no investments in non-marketable securities, commodities, crypto/bitcoin, or speculative real estate without the prior approval of the Trustees.
There shall be no investments in private placements or letter stock without the prior approval of the Trustees.

Equity Guidelines

The purpose of the equity portion is to provide a total return that will simultaneously provide for growth in principal and current income sufficient to support the Fund’s minimum distribution requirement, while at the same time preserve the purchasing power of the portfolio’s assets. It is recognized that the equity portfolio entails the assumption of greater market variability and risk.

Specific Equity guidelines are as follows:

The objective for the domestic equity portfolio is to outperform the S&P 500 and the Russell 3000 Stock Index over a full market cycle. The objective of the international equity portfolio is to outperform the ACWI-EXUS. Performance will be monitored on a quarterly basis and evaluated over rolling three- and five-year periods.
The equity portfolio will be broadly diversified according to economic sector, industry, number of holdings, style and other investment characteristics. However, it is recognized that in order to achieve its investment objective, the components of the equity portfolio must be actively monitored. Several complementary investment styles will be used to reduce portfolio risk.
Equity investment style is expected to be a criterion for investment selection within the context of a diversified investment structure. Decisions as to individual security selection, security size and quality, number of industries and holdings, turnover and other tools employed by active investment managers and mutual funds are the responsibility of the investment managers and are subject to the usual standards of fiduciary prudence. However, active investment managers are expected to invest consistently in the style for which they were hired.
Unless otherwise instructed, an equity manager may, at their discretion, hold investment reserves of cash equivalents, but with the understanding that performance will be measured against stock indexes described in their investment guidelines.
Each equity investment manager shall vote proxies for those securities under management absent any specific directive to the contrary by the Trustees.

Fixed Income/Cash Equivalent Guidelines

The purpose of the fixed income portfolio (bonds and cash equivalents) is to provide a deflation hedge, to reduce the overall volatility of the portfolio, and to produce current income in support of the needs of the Funds.

Specific Fixed Income guidelines are as follows:

The objective of the fixed income portfolio is to outperform the Barclays Capital Aggregate Bond Index. Performance will be monitored on a quarterly basis and evaluated over rolling three- and five-year periods.
A portion of the fixed income portfolio may be allocated to non-core fixed income strategies with the prior consent of the Trustees. These strategies may include, but are not limited to international fixed income, emerging market fixed income, high-yield fixed income, global currencies, and preferred securities. The purpose of including non-core fixed income in the portfolio is to enhance the overall risk-return characteristics of the portfolio.
Fixed income separate account investment managers are expected to employ active management techniques, but changes in average maturity should be moderate and incremental. Significant changes in overall average maturity should be communicated to the Trustees unless an index funds or mutual funds is used.
In general, the portfolio shall be well diversified with respect to type, industry and issuer in order to minimize risk exposure. However, obligations carrying the full faith and credit of the U.S. Government or Government Agency may be held without limitation. Generally, other than investments in the U.S. Government or Government Agency, no single debt issue will be allowed to exceed 5% market value of the debt portfolio unless an index funds or mutual funds is used.

Alternative Investment Guidelines

Alternative investments may provide an investment portfolio improved risk-return characteristics. Alternative investments may have limited liquidity, less transparency, and higher fees. As such, the committee may use alternative investments as a tool to improve portfolio positioning.

Specific alternative investments Investment guidelines are as follows:

The Trustees recognize that alternative investments often have low correlation to more traditional investments.
The Trustees recognize that alternative investments may be used for their offensive and defensive characteristics.
The Trustees accept, by their nature and structure, alternative investments have several risks above and beyond those associated with traditional investments. Risks may include limited liquidity, less transparency and higher fees.
The Trustees may consider, but are not limited to, the following alternative investments investment asset classes: private equity, real estate, managed futures, commodities, hedge portfolios and other categories outside of traditional investments. The alternative investment portfolio will be well diversified among a number of strategies at all times.

Selection of Investments/Active Investment Managers

When considering the appointment of a new money manager, the Trustees will utilize a documented manager search process by which a manager’s performance, history, risk posture, fee structure, professionals and similar attributes can be carefully scrutinized. This information will be used to determine if the manager is appropriate for appointment of Funds. The following are factors that should be considered:

Validity of Strategy
Quality of Investment Process
Depth of Professional Resources
Organizational Depth & Stability
Risk Management
Historical Performance
Asset Capacity
Vehicle Quality
Client Service

Watch/Termination of Investment Managers

The Trustees recognize the importance of a formal watch and termination process for investment managers. The watch process is established to evaluate investment managers over a typical full-market cycle (est. 5 years). A manager may be placed on watch or may be terminated for the following reasons:

Failure to follow the Funds Investment Policy Statement may be grounds for removal. Furthermore, the Trustees, at their discretion, reserve the right to terminate any investment manager, at any time, for any reason they deem necessary.
Failure to consistently meet investment benchmarks, as established within a reconciled performance monitor, over an extended period of time may result in a manager being placed on “watch” and may eventually lead to termination. Specifically, if a manager trails their respective index or bogey by 200 basis points over 3 years and the manager is in the 50% percentile ranking or below of a comparable manager universe then the manager is immediately placed on “watch”.
Failure to comply with investment restrictions as provided by the Trustees may be grounds for removal.
Substantive changes in an investment manager’s philosophy, process, people or fees may result in that manager being placed on “watch” and may result in termination.

The manager may remain on watch for up to eight quarters. If performance has not improved as measured by the standards established in this Investment Policy Statement, the manager may be terminated.

A manager may avoid being placed on watch if they can statistically demonstrate they are adding value by limiting risk in the portfolio. (For example, the manager trails its respective index but does so with substantially less beta, standard deviation, downside capture, etc.) It may then be concluded the manager is still adding value in a given market cycle.

Investment Manager Restrictions

The following investment manager restrictions will remain in force unless otherwise deemed permissible by prior approval of the Trustees. The Trustees recognize these Investment Policy restrictions will not apply to any mutual funds or pooled investment vehicles. Additionally, there may be exceptions permitted for alternative investments. If an investment manager believes that one or more Investment Policy guidelines will inhibit their performance, it is their responsibility to communicate their views to the Trustees. This may be communicated through the retained investment consultant.

There shall be no short selling, securities lending, financial futures, margins, options or other specialized investments without the prior approval of the Trustees.
There shall be no investments in non-marketable securities, commodities or speculative real estate without the prior approval of the Trustees.
The market value of any one issue shall not exceed 10% of the manager’s total portfolio, with the exception of securities issued by the U.S. Government and its agencies or mutual funds without prior permission of the Trustees.
No equity manager shall purchase any security when that manager’s overall current position exceeds 6% of the total shares outstanding in any security without prior permission of the Trustees.
If any major management or personnel changes occur within the investment manager’s firm, the Trustees are to be immediately notified.

All separate account managers will receive a copy of the Fund’s Investment Policy Statement. If, for any reason, a separate account investment manager does not believe they are in compliance or will be able to comply with this Investment Policy Statement, it is incumbent upon them to promptly communicate such issues to the Trustees.

Performance Measurement

The Fund’s portfolios will be monitored on a continual basis for consistency in investment philosophy, return relative to objectives and investment risk as measured by asset concentrations, exposure to extreme economic conditions and market volatility. Portfolios will be reviewed by the Trustees on a quarterly basis, but results will be evaluated over rolling three- and five-year periods. The Trustees, with the assistance of their investment consultants, will regularly review each investment manager to confirm that factors underlying performance expectations remain in place. At a minimum, the following performance and risk characteristics should be reviewed quarterly:

Aggregated portfolio performance
Individual asset class performance
Individual investment manager/investment performance
Overall risk posture
Individual investment manager/investment risk posture

The Trustees will review quarterly the performance and risk characteristics of the overall portfolio as well as the individual managers and asset classes. The portfolio should be measured against the overall market as compared to the asset allocation and represented in a custom Blended Benchmark. The custom Blended Benchmark should consist of:

Mid-Range Program Pool:

6% Russell 1000 Growth 6% Russell 1000 Value

4% Russell 2500 5% T Bills

2% MSCI ACWI-EX US 6% HFRI Funds of Funds

2% Merrill Lynch High Yield 66% Barclays Aggregate Bond Index

3% Bloomberg Barclays Global Aggregate Hedged Bond Index

Long-Term Program Pool:

14% Russell 1000 Growth 14% Russell 1000 Value

12% Russell 2500 3% T Bills

11% MSCI ACWI-EX US 6% HFRI Funds of Funds

2% Merrill Lynch High Yield 35% Barclays Aggregate Bond Index

3% Bloomberg Barclays Global Aggregate Hedged Bond Index

The Fund’s asset allocation should be measured against a like universe to determine overall performance compared to similar allocations. Additionally, each manager should be individually compared to their appropriate index as well as corresponding Manager Universe to determine performance. Individual managers/investments should be measured against, but not limited to, the appropriate indexes as defined by the asset allocation table established in this Investment Policy Statement.