To have the ability to pay all benefits obligations when requested.

INVESTMENT POLICY STATEMENT FOR: Alliance Benefit Group Health Savings Account Program I. GENERAL Purpose and Overview The Alliance Benefit Group Health Savings Account Program ( Program ) was established for the exclusive benefit of Eligible Individuals under Section 223(d) of the Internal Revenue Code ("IRC"). The purpose of this Investment Policy Statement is to establish prudent criteria and due diligence processes with respect to the selection of investment options offered within the Program. The methodology used to select and review the Program s investment alternatives is detailed in this document. The Program offers a number of investment alternatives that have been selected in accord with the criteria set forth within this Investment Policy Statement. Alliance Benefit Group will conduct a periodic review of the performance of these investment alternatives to determine whether to modify the alternatives. II. STATEMENT OF OBJECTIVES This Investment Policy Statement has been developed by the Alliance Benefit Group of Illinois, Inc. ( ABG ) and describes the prudent investment process that it deems appropriate. This process includes offering investment alternatives with various styles that, in total, are intended to offer Eligible Individuals a sufficient level of diversification and the ability to vary individual exposure to risk and investment return opportunity. The objectives are: To comply with prudent provisions and due diligence procedures that experienced investment professionals would utilize. To establish procedures for providing Eligible Individuals with sufficient information so that each individual can make an informed decision about his or her selection of investment alternatives and permitting Eligible Individuals to change investment alternatives on a daily basis. To have the ability to pay all benefits obligations when requested. To control and account for all costs of administering the program and managing the investment alternatives. HSA - 2014 1

III. DUTIES AND RESPONSIBILITIES Alliance Benefit Group (ABG) The primary responsibilities of the ABG Investment Committee ( Investment Committee ) are to: Prepare and maintain an investment policy statement. Provide sufficient investment alternatives with different and distinct risk/return profiles and styles so that each Participant can prudently diversify his/her account. Prudently select investment alternatives among which Participants can choose. Control and account for all investment, record keeping and administrative expenses associated with the Program.. Monitor and supervise all service vendors and investment options. Avoid prohibited transactions and conflicts of interest. Refrain from giving what could be construed as investment advice. Investment Managers Investment managers are co-fiduciaries responsible for making investment decisions (security selection and price decisions) within the mutual fund. The specific duties and responsibilities of each investment manager are: To manage the assets under their supervision in accordance with the guidelines and objectives outlined in their respective Prospectus or Trust Agreement. To exercise full investment discretion with regards to buying, managing, and selling assets held in the portfolios. To vote promptly all proxies and related actions in a manner consistent with the longterm interest and objectives of the mutual fund. Each investment manager shall keep detailed records of the voting of proxies and related actions and will comply with all applicable regulatory obligations. To use the same care, skill, prudence, and due diligence under the circumstances then prevailing that experienced investment professionals acting in a like capacity and fully familiar with such matters would use in like activities in compliance with all applicable laws, rules, and regulations. Custodian Custodians are responsible for the safekeeping of the Program s assets. The specific duties and responsibilities of the custodian are: To maintain separate accounts by legal registration. HSA - 2014 2

To value the holdings. To collect all income and dividends owed to the Program. To settle all transactions (buy-sell orders). To provide monthly reports that detail transactions, cash flows, securities held and their current value, and change in value of each security and the overall portfolio since the previous report. Eligible Individuals Each Eligible Individual is responsible for: Deciding whether to participate in the Program by opening a Health Savings Account to receive contributions from the Employee and/or Employer Determining how much to contribute under the Program each year, subject to the allowable limits. The selection of where their own contributions and the Employer contributions should be invested. Eligible Individuals shall have full responsibility for individual choices among the investment alternatives offered through the Program. IV. ASSET CLASS GUIDELINES Long-term investment performance, in large part, is primarily a function of asset class mix. The long-term performance characteristics of the following broad asset classes have been reviewed, focusing on balancing the risks and rewards. 1) Money Market or Ultrashort Bond. 2) Short, Intermediate and Long-Term Bond. 3) Short, Intermediate and Long-Term Government. 4) Small, Mid and Large Cap Value 5) Small, Mid and Large Cap Blend 6) Small, Mid and Large Cap Growth. 7) Domestic Hybrid. 8) Emerging Market, Foreign and World Stock or Bond. 9) Real Estate. 10) Commodities HSA - 2014 3

Other investment alternatives in the Program that do not meet the specified inclusion criteria set forth above, but that fall into the categories below: Fixed Rate investment(s) Sector or specialty fund(s) V. INVESTMENT MANAGER SELECTION The following due diligence criteria is applied and reviewed in selecting each individual investment option. Regulatory oversight: Each investment manager should be a regulated bank, an insurance company, a mutual fund organization, or a registered investment adviser. Correlation to style or peer group: The product should be highly correlated to the asset class of the investment option. This is a critical part of the analysis since most of the remaining due diligence involves comparisons of the manager to the appropriate peer group. The monitoring criteria assesses consistency of fund s investment style characteristics over a period of time. Style Drift examines the behavior of a manager over multiple rolling periods of time to ensure consistency. R-squared measures the portion of an investment s return that can be explained by movements in the benchmark. Performance relative to a peer group: The product s performance should be evaluated against its style group peers. Performance relative to assumed risk: Risk/Return is reviewed to determine if risk was less than the benchmark or performance was greater than the benchmark. Up/Down Capture Analysis measures the behavior of the fund in both up markets and down markets. Information Ratio attempts to measure the relative risk/return consistency of the manager. Minimum track record: The product s inception date should be three years or more. Assets under management: The product should have at least $200 million under management. Expense ratios/fees: This due diligence item measures the rank of the fund s operating expenses among its style group peers. Fund expenses are reviewed to ensure that the fund s expense ratio is competitive with other available offerings. Stability of the organization: The Manager Tenure is reviewed to determine if there have been any recent changes to the fund s management. There should be no perceived organizational problems -the same portfolio management team should be in place for at least two years. VI. MONITORING AND REVIEW Performance Objectives Fluctuating rates of return characterize the securities markets, particularly during short-term time periods. Recognizing that short-term fluctuations may cause variations in performance, fund manager performance is, therefore, evaluated from a long-term perspective. HSA - 2014 4

On a timely basis, but not less than annually, the Committee will review whether each fund manager continues to conform to the search criteria outlined in the previous section; specifically: The fund manager's adherence to the Program s investment guidelines; Material changes in the fund manager's organization, investment philosophy and/or personnel; and, Any legal, SEC and/or other regulatory agency proceedings affecting the fund manager. It has been determined that it is in the best interest of the Eligible Individuals that performance objectives be established for each fund manager. Each fund s performance will be evaluated against the fund s peers (category) and the manager performance will be evaluated in terms of an appropriate market index. Listed below are the asset classes and indexes that will be used as a benchmark for each investment option: Asset Class/ Peer Group Index Peer Group Universe Large Cap Equity Large Cap Value Russell 1000 Value TR Large Cap Value Large Cap Blend Russell 1000 TR Large Cap Core Large Cap Growth Russell 1000 Growth TR Large Cap Growth Mid Cap Equities Mid-Cap Value Russell MidCap Value TR Mid-Cap Value Mid-Cap Blend Russell MidCap TR Mid-Cap Core Mid-Cap Growth Russell MidCap Growth TR Mid-Cap Growth Small Cap Equities Small Cap Value Russell 2000 Value TR Small Cap Value Small Cap Blend Russell 2000 TR Small Cap Core Small Cap Growth Russell 2000 Growth TR Small Cap Growth Foreign Large Blend Morningstar Developed ex US Index Foreign Lrg Blend Real Estate Morningstar Real Estate Category Avg Real Estate Diversified Emerging Mkts Morningstar Emerging Markets Index Emerging Markets Commodities Broad Bskt. Morningstar Long-Only Commodities Idx Commodities Fixed Income Intermediate Bond Mstar Intermed US Govt/Corp Bond Idx Intermed.-Term Bond Short Bond Mstar Short-Term US Govt/Corp Bond Idx Short-Term Bond High Yield Bond Credit Suisse High Yield Bond Index High Yield Bond Inflation-Protected Bond Morningstar TIPS Index TIPS World Bond Morningstar Global Govt Bond Index World Bond Money Market Morningstar Cash Index Money Market Database HSA - 2014 5

Monitoring of Investment Options The Investment Options shall be monitored using Standards and Criteria. These standards and criteria are based upon rankings (i.e. returns and statistics for each fund ranked relative to the returns and statistics for all other funds within each fund s investment category). Rankings may be measured within the following categories: Relative Return Standards may include: Returns/Performance Rank: The product s performance ranked against its peers for 1, 3, 5, and 10-year cumulative periods. Quantitative Analysis may include: Alpha Rank Alpha is the measure of the difference between a fund s actual returns and its expected performance, given its level of risk as measured by beta. Beta Rank Beta is a measure of a fund s sensitivity to market movements. It compares a fund s volatility with that of a benchmark. R-squared Rank R-squared measures the relationship between the fund and its benchmark index the correlation of the fund s returns to its benchmark s returns. Sharpe Ratio Rank Sharpe Ratio is a risk-adjusted measure developed by Nobel Laureate William Sharpe. It is calculated by using standard deviation and excess return to determine reward per unit of risk. Sortino Ratio Rank Sortino Ratio is similar to the Sharpe Ratio except it differentiates harmful volatility from volatility in general by using a value for downside deviation. Information Ratio Rank Information Ratio is a risk-adjusted performance measure and excess return and risk relative to a specific benchmark index. Standard Deviation Rank Standard Deviation is the statistical measurement of how far a fund s performance can stray from its expected (i.e. average) return over a period of time to assess the level of volatility. Qualitative Review may include: Manager Tenure Manager Tenure indicates the period of time the lead manager has been managing the fund s portfolio. Net Expense Ratio Rank Expense Ratio is the percentage of fund assets paid for operating expenses and management fees of that fund. Watch/Pass Score: A score of Pass or Watch shall be assigned to each fund based on weightings assigned each of the prior 8 quarterly reporting periods. The score is a percentage calculated using the sum of the weights of the standards that meet the specified criteria over the total sum of all the weights assigned. For some standards/periods, data may not be available. The analysis shall treat these items as passing in the calculation of the score. Each available fund will be classified as follows: 0 to 64 Watch 65 or greater Pass The Committee may review additional information that it deems appropriate in its review of each fund such as historical performance and performance comparison with performance of investment HSA - 2014 6

peer groups and appropriate benchmark indices and other pertinent research provided by the Investment Consultant. Probation, Suspension or Removal of a Fund The decision to retain, suspend or terminate a fund cannot be made by a formula. It is the Committee s confidence in the fund manager s ability to perform in the future that ultimately determines the removal or retention of a fund manager. A fund may be removed, if review of monitoring standards and supporting data shows a level of negative factors which, in turn, gives the Committee little confidence in the fund s ability to improve to an acceptable level within the near future (i.e. typically by the next annual review). During the Committee s consideration for the removal of a fund, the Investment Consultant should provide replacement fund considerations within the same Style category of the fund being removed. If the Committee is not comfortable with an immediate removal for any reason (i.e. a high number of Participants or large portion of assets in a particular fund), a fund can be Suspended (no new money allowed into it, but existing balances can remain). This would allow for adequate Participant communication and a potentially longer transition to eventual removal, if appropriate. The fund would remain on the QMR, but would not remain on the Program s Investment Election form. The minutes and monitoring decisions would reflect the decision to suspend the fund citing the date or period that further action might be determined. At least annually the Committee should meet to review all funds. At that time Special Scrutiny should be paid to funds as indicated per the Standards described in the Section above Monitoring of a Fund. This can be done with the participation of the Investment Consultant or not. At the annual meeting, the Committee, in addition to the monitoring criteria, will review the supporting data provided within the QMR. VII. MEASURING COSTS The funds will be reviewed at least annually all costs associated with the management of the Program s investment program, including: Expense ratios of each investment option against the appropriate peer group. Custody fees: The holding of the assets, collection of the income and disbursement of payments. Whether the fund manager is demonstrating attention to best execution in trading securities Administrative Fees: Costs to administer the Program, including record keeping, account settlement (participant balance with that of fund), and allocation of assets and earnings, and (when applicable) the proper use of 12-b-1 fees to offset these fees. HSA - 2014 7

VIII. PROGRAM PROVISIONS GOVERN These procedures are not meant to interpret, extend or change the provisions of the Program in any way. The provisions of the Program may only be determined accurately by reading the actual Program document. If these procedures are inconsistent with the Program, the Program shall govern in every case. IX. CHANGE IN LAW If these procedures are inconsistent with a change in the law, regulations or rulings affecting such programs; the new law, regulations or rulings will control the operation of the program.. X. AMENDMENT This Investment Policy Statement may be amended by Alliance Benefit Group from time-to-time if deemed advisable. HSA - 2014 8