2013 sample transamerica investment policy statement

2013

SAMPLE TRANSAMERICA

INVESTMENT POLICY

STATEMENT

As the Fiduciaries (defined below) will determine the appropriateness of using and adopting this IPS, they

understand that Transamerica Retirement Solutions and its affiliates do not provide investment or

fiduciary advice.

Part I. THE PLAN

The Company (the “Sponsor”) sponsors the Plan (the “Plan”) for the benefit of its employees. It is

intended to provide eligible employees with the long-term accumulation of retirement savings through a

combination of employee and employer contributions to the individual participant accounts within the

Plan and to the earnings thereon.

The Plan is intended to comply with the Internal Revenue Code of 1986, as amended, and the Employee

Retirement Income Security Act of 1974 (ERISA), as amended.

The Plan is intended to comply with ERISA Section 404(c) and thereby to relieve the Fiduciaries of the

Plan of liability for any losses which are the direct and necessary result of investment instructions given

by participants and beneficiaries (collectively, the “Participants”). Accordingly, the Plan’s Fiduciaries

will make a good faith effort to satisfy the conditions in the Department of Labor’s (“DOL’s”) 404(c)

regulation under section 404(c).

The Plan’s participants are expected to have different investment objectives, time horizons, and risk

tolerances. To meet those varying investment needs, the Plan allows Participants to direct the investment

of their account balances among a broad range of investment choices in order to construct diversified

portfolios that reasonably span the risk/return spectrum.

Part II. THE PURPOSE OF THE INVESTMENT POLICY STATEMENT

This Investment Policy Statement (IPS) is intended to assist the Plan’s Fiduciaries in making investment-

related decisions in a prudent manner. That is, the IPS assists the Fiduciaries in engaging in the prudent

process required by the fiduciary standards of ERISA. To achieve that objective, the IPS outlines the

processes for the selection, monitoring and evaluation of the investments in the Plan, as well as the

monitoring of investment-related services. While this IPS describes specific acts and criteria, they are for

purposes of guidance only. The Fiduciaries are not bound by the literal terms of this IPS, but will instead

use considered judgment in making their decisions. Nonetheless, the guidance in this IPS is intended to be

helpful to the Fiduciaries to assist them in fulfilling their responsibilities under ERISA.

Specifically, this Investment Policy Statement:

Defines the Plan’s investment objectives.

Defines the roles of those responsible for the Plan’s investments and related services.

Establishes investment selection procedures and criteria, and monitoring procedures.

Describes procedures for handling investment choices that fail to satisfy established

objectives.

Provides for appropriate diversification within and among investment vehicles.

Provides for services to assist the participants in making investment decisions.

The Fiduciaries will review this Investment Policy Statement periodically, and it will be amended to reflect

changes made by the Fiduciaries from time to time.

Part III. INVESTMENT OBJECTIVES

The Plan’s investment choices will be selected with the goal of:

Providing the potential for reasonable returns (compared to appropriate peer groups and

indices) at prudent levels of risk.

Providing a broad range of investments in appropriate asset classes.

Providing diversified investment vehicles to reduce the risk of large losses.

Prudently managing administrative and investment management costs.

Part IV. ROLES AND RESPONSIBILITIES

The Sponsor is responsible for the roles and fiduciary responsibilities in this IPS. However, if permitted by

the Plan, it may appoint an Investment Committee (the “Committee”), in which case the Committee will

perform the roles and responsibilities described below. This IPS refers to the Sponsor and Committee, as

the case may be, as the “Fiduciaries” or the “Investment Fiduciaries.”

Those responsible for the management of the Plan’s investments include, but are not limited to:

The Sponsor is responsible for:

Selecting the trustee; and

Appointing and monitoring the members of the Investment Committee as the Investment

Fiduciaries, if applicable.

The Investment Fiduciaries are responsible for:

Establishing and maintaining the Investment Policy Statement;

Selecting the investment choices;

Periodically monitoring the performance of the investment choices offered by the Plan and

making investment changes;

Hiring the recordkeeper and/or investment advisory consultants;

Hiring and monitoring investment consultants, if appropriate; and

Overseeing participant investment education, communication, and other investment-related

services.

Part V. SELECTION OF INVESTMENTS

The selection of the Plan’s investment choices is among the Fiduciaries’ most important responsibilities.

This part discusses the considerations and guidelines for fulfilling that fiduciary duty.

Selection of Investment Categories

The Plan intends to provide an appropriate range of asset classes (or investment categories) that will

reasonably span the risk-and-return spectrum, that satisfies the “broad range” criteria of U.S. Department of

Labor Regulation § 2550.404c, and that is consistent with the investment needs and abilities of the

Participants. These investment categories, and the investment choices chosen to fill those categories, should

allow Participants to construct portfolios consistent with their individual circumstances, for example, their

goals, time horizons and tolerances for risk. To accomplish that goal, the Fiduciaries will select from among

the investment categories listed on Appendix A of this IPS. (However, where appropriate, the Fiduciaries

may include additional categories.)

Selection of Investment Choices

After determining the investment categories to be used, the Fiduciaries will choose specific investment

choices for each of those categories.

As the Fiduciaries engage in the process of selecting the investment choices, they may consider various

third-party materials, including, but not limited to, the Transamerica Investment Monitor Methodology:

Fiduciary Support and Investment Selection Process, The Lipper Review Letter and conclusions concerning

that review, and the Investment Scorecards provided to the Fiduciaries.

Attached as Appendix B (section entitled “Transamerica Investment Monitor Methodology”) is a

description of the methodology and scoring of investment choices included in the Transamerica

package of investments and services. The Investment Fiduciaries have reviewed the methodology

and have determined that it is one tool that is suitable and appropriate for the Plan and the

Participants, and shall be adopted as one of the criteria utilized for their selection of investment

choices for this Plan.

Attached as Appendix C (entitled “Lipper”) is a review and evaluation by Lipper, Inc. of

investment processes used by Transamerica Retirement Solutions. The Lipper evaluation

concluded that Transamerica’s investment choice roster and the Transamerica’s due diligence

process for selecting and monitoring investment choices can help you build an investment line-up

to meet your participants varied needs.

If applicable, attached as Appendix D, Fiduciaries have listed any additional tools used for their

selection of investment choices for this Plan.

Part VI. INVESTMENT MONITORING AND REPORTING

The ongoing monitoring of investments involves a regular and disciplined process. It is the mechanism for

confirming that the selection process and its criteria continue to be satisfied and that an investment choice

continues to be suitable and appropriate for the Participants in this Plan.

While frequent change is neither expected nor desirable, the process of monitoring investment performance

relative to specified guidelines is an ongoing process.

Monitoring should occur on a regular basis and should generally utilize the same criteria that were the basis

of the investment selection decision. The investment choices will be monitored on a regular basis. It is

contemplated, but not mandated, that a formal review will be done at least annually. Further, the Investment

Fiduciaries should consider any unusual, notable or extraordinary events on a current basis. Examples of

such events may include portfolio manager departure, material litigation against the investment

management firm, violation of securities laws, or material changes in firm ownership structure.

If, upon evaluation, an investment choice continues to be acceptable, no further action is required. If the

initial evaluation of an investment choice is not conclusive, the Investment Fiduciaries may, in their

discretion, take steps to further study and/or remedy the deficiency. If over a reasonable period the provider

is unable to resolve the issue, termination may result, which decision shall be solely in the discretion of the

Investment Fiduciaries (see Part VII).

Attached as Appendix B (section entitled “Transamerica Investment Monitor Methodology”) is a

description of the process used by Transamerica for determining whether an investment choice

has underperformed. The Investment Fiduciaries have reviewed that process (as well as an

Investment Scorecard) and have determined that it is suitable and appropriate for this Plan and its

Participants, and shall be adopted as one of the criteria utilized for purposes of monitoring the

investment choices.

For monitoring purposes, the Investment Fiduciaries also adopt the Transamerica Investment

Monitor Methodology and Scoring Process described in Appendix B as one of the monitoring

criteria.

Part VII. INVESTMENT CHOICE TERMINATION

The Investment Fiduciaries will give consideration to terminating an investment choice if:

The investment choice significantly underperforms without a justifiable rationale.

The investment choice fails to achieve performance and risk objectives.

The investment choice fails to maintain a consistent investment style.

There are no hard and fast rules for investment choice termination. However, if the investment has

consistently failed to adhere to one or more of the above conditions, it is reasonable to presume a lack of

adherence going forward. Failure to remedy the circumstances of unsatisfactory performance, within a

reasonable time, is a basis for termination.

In addition to those above, other factors may include investment manager turnover, or material change to

investment processes. Of course, the Fiduciaries may also remove any investment choice at any time and

for whatever reason they deem appropriate, including a determination that the investment is no longer

suitable for the participants.

An investment choice to be terminated shall be removed using one of the following approaches:

Remove and replace (map assets) to an alternative investment choice.

Continue the investment choice, but add a competing investment choice.

Remove the investment choice and do not provide a replacement investment choice.

Replacement of a terminated investment choice would follow the criteria outlined in Part V, Selection of

Investments.

The guidelines in this IPS, and in this Part VII, are to assist, but not bind, the Fiduciaries. Ultimately, all

decisions relating to investment choices, including termination, are solely within the discretion of the

Investment Fiduciaries.

Part VIII. PARTICIPANT EDUCATION AND COMMUNICATION

The Plan will communicate to employees that they direct their own investments; permit investment changes

at least quarterly; and provide educational materials allowing employees to make informed decisions.

To assist participants who lack investment knowledge or who prefer to use professionally allocated

investments, the Plan may offer investment choices that allocate accounts among various investment

categories and that balance risk, reward and other factors. If such investment choices are made available,

the purposes and benefits of these vehicles will be communicated to the Participants.

Part IX. COORDINATION WITH THE PLAN DOCUMENT

If any term or condition of this investment policy conflicts with the Plan, the terms and conditions of the

Plan shall control.

Part X. FURTHER GUIDELINES

Advice

Investment Managers

As named fiduciary, the Investment Fiduciaries may retain the services of an Investment

Manager(s) as defined in Section 3(38) of ERISA to assume all or part of the Investment

Fiduciaries' duties under this Investment Policy Statement. The duties and responsibilities of

the Plan's Investment Manager(s) will be set forth in a written agreement between the

Investment Fiduciaries and the Investment Manager and may include:

communicating with and reporting to the Investment Fiduciaries on a regular basis

(at least annually and more frequently upon the Investment Fiduciaries' request);

notifying the Investment Fiduciaries of any issue that may impact the investment of Plan

assets (e.g., change in ownership, professional staff, investment philosophy and/or

process);

investing Plan assets with the care, skill, prudence and diligence that a prudent

investment professional would exercise in the investment of those assets; and meeting

as requested with the Investment Fiduciaries to discuss investment strategy and

review past performance.

Investment Consultants and Advisors

The Investment Fiduciaries may retain the services of an investment consultant(s) to provide

advice to the Investment Fiduciaries regarding the investment fund options offered under the

Plan. The Investment Fiduciaries may also, in their discretion, retain the services of an

investment advisor who acts as a fiduciary as defined in Section 3(21)(A)(ii) of ERISA. The

duties and responsibilities of an investment consultant may include:

preparing periodic performance evaluation reports;

assisting the Investment Fiduciaries with the analysis of the performance review;

assisting the Investment Fiduciaries in developing and reviewing Plan

investment strategies and fund selection.

As with any designation of a service provider to the Plan, the designation of a company or individual to

provide investment advice to plan participants and beneficiaries is a fiduciary act. Therefore, the Investment

Fiduciaries will act prudently and solely in the interest of the Participants both in making such

designation(s) and in continuing such designation(s).

At a minimum, the investment advice by the selected provider should be unbiased and be based on sound

asset allocation theory and in-depth investment analysis. Monitoring will ordinarily occur on an annual

basis and will generally utilize the same criteria that were the basis for the selection of the investment

adviser, and will also include a review of the performance of the advice and the service to the participants.

Self-directed Brokerage Window

In an effort to provide total investment flexibility, a self-directed brokerage option may be offered in the

Plan. The Plan’s self-directed brokerage option, if available, may allow participants to invest in any

publicly-traded security, including stocks, bonds and mutual funds, with the following exceptions: short

sales, options, futures, limited partnerships, currency trading and trading on margin. In developing and

maintaining the Plan’s self-directed brokerage option, the Sponsor will evaluate the self-directed option

provider for reasonable cost, competitive service capability and participant satisfaction. There will be an

annual review to confirm competitiveness.

Company Stock

Company stock may be offered as an investment option pursuant to the terms of the Plan. Plan Fiduciaries

will be responsible for managing the investment of Plan assets in company stock according to the Plan

document. The Plan Sponsor will monitor the performance of the Company stock but not for the purpose of

recommending levels of company stock investment in the Plan or the elimination of company stock as a

Plan investment as they may have access to inside information.

APPENDIX A

Investment Categories

Cash Equivalents:

Cash Management Fund or Stable Value Fund

Bond:

Bond Fund

High Yield Bond

Hybrid:

Balanced Fund

Asset Allocation Group and/or Target Maturity Group

Domestic Equity:

Value

Blend

Growth

Large Cap Value

Large Cap Blend

Large Cap Growth

Large

Mid Cap Value

Mid Cap Blend

Mid Cap Growth

Mid

Small Cap Value

Small Cap Blend

Small Cap Growth

Small

(Categorized by: Investment Style & Market Capitalization)

International:

International Equity

Global

Global Equity

Specialty:

Real Estate

TRSC 5185-0113

60%

10% 10%

10%

10%

PerformanceMeasurement

Investment Process &Portfolio Composition

ManagementTenure

StyleConsistency

Fees &Expenses

QUALITATIVE ANALYSIS

QUANTITATIVE ANALYSIS

Performance Measurement** — 60% Weight

Performance Measurement** (Trailing Returns) — 50% weighting

Performance Measurement** (Risk-Adjusted Returns) — 50% weighting

Weighting of Scores Based on Track Record

Performance 10-Years 5-Years 3-Years10-Years 33.3%

5-Years 33.3% 50%

3-Years 33.3% 50% 100%

Weighting of Scores Based on Track Record

Performance 10-Years 5-Years 3-Years10-Years 33.3%

5-Years 33.3% 50%

3-Years 33.3% 50% 100%

Scoring Breakdown

Score - 5.0 Investment choice’s return outperformed the peer group average by at least 30% of the peer group average for the applicable periodScore - 4.0 Investment choice’s return outperformed the peer group average by less than 30% but at least 10% of the peer group average for the applicable periodScore - 3.0 Investment choice’s return outperformed the peer group average by less than 10% of the peer group average or investment choice’s return underperformed the peer group average by at most 10% of the peer group average for the applicable periodScore - 2.0 Investment choice’s return underperformed the peer group average by more than 10% but at most 30% of the peer group average for the applicable periodScore - 1.0 Investment choice’s return underperformed the peer group average by more than 30% of the peer group average for the applicable period

Scoring Breakdown

Score - 5.0 Investment choice’s Sharpe Ratio is at least 0.30 higher than the peer group average for the applicable periodScore - 4.0 Investment choice’s Sharpe Ratio is 0.16 to 0.29 higher than the peer group average for the applicable periodScore - 3.0 Investment choice’s Sharpe Ratio is plus or minus 0.15 of the peer group average for the applicable periodScore - 2.0 Investment choice’s Sharpe Ratio is 0.16 to 0.29 lower than the peer group average for the applicable periodScore - 1.0 Investment choice’s Sharpe Ratio is at least 0.30 lower than the peer group average for the applicable period

Note: For the Performance Measurement scoring, an investment choice’s 3, 5 and 10-year returns and Sharpe Ratios will be included. If an investment choice has a 10-year record, the average of the 3, 5, and 10-year return scores will be used (33.3%/33.3%/33.3% weightings, respectively). If an investment choice has a 5-year record, the average of the 3 and 5-year return scores will be used (50%/50% weightings, respectively). If an investment choice only has a 3-year record, 100% weight will be applied to the 3-year return score. If an investment choice has less than a 3-year record, “N/A” will be shown.

Transamerica Investment Monitor

Methodology*

* The Transamerica Investment Monitor provides investment selection and monitoring due diligence related to the investment choices on Transamerica’s platform as a normal part of its business. Transamerica makes certain of this due diligence available to clients so they may leverage it as they select and monitor the investments for their own plan. Clients and other interested parties must consult and rely solely upon their own independent advisors regarding their particular situation. All investments involve risk, including loss of principal and there is no guarantee of profits. Investors should carefully consider their objectives, risk tolerance, and time horizon before investing. This is not meant to be construed as investment advice. Transamerica is not a fiduciary with respect to the plan as defined by ERISA including sections 3(21), 3(38) or 3(16), nor it is responsible for a plan’s selection, monitoring or de-selection of investments. Although the investment choices may meet the “significantly exceeds,” “meets/exceeds,” or “below” criteria, there are no guarantees of a profit and it is still possible to lose money from that investment choice. The methodology and criteria used may be changed at any time. Transamerica Retirement Solutions does not provide investment advice. Nothing presented herein should be construed as a recommendation to purchase or sell a particular investment, product or follow any investment technique or strategy. Transamerica Retirement Solutions does not act as a fiduciary.

** See the additional notes section of this report for a description of how the investment choices expense class may affect the performance measurement rating. Transamerica may close an investment choice to new investors: (1) If the mutual fund or underlying investment continuously fails to meet scoring criteria; (2) If the current investment manager of the mutual fund or underlying investment places a restriction on the investment where no new investors are allowed due to capacity issues; (3) To offer a more competitive alternative; (4) If the mutual fund or underlying investment completely closes; (5) If there is a lack of participant interest; (6) To streamline investment choices across product offerings; or (7) For other reasons as determined by Transamerica. Participants in plans which already included the investment choice are not treated as new investors.

Transamerica may close an investment choice to new investors: (1) If the mutual fund or underlying investment continuously fails to meet scoring criteria; (2) If the current investment manager of the mutual fund or underlying investment places a restriction on the investment where no new investors are allowed due to capacity issues; (3) To offer a more competitive alternative; (4) If the mutual fund or underlying investment completely closes; (5) If there is a lack of participant interest; (6) To streamline investment choices across product offerings; or (7) For other reasons as determined by Transamerica. Participants in plans which already included the investment choice are not treated as new investors.

Monitoring Scorecard Rankings

Scoring Ranges

5.00 to 4.00 Significantly Exceeds Criteria

3.99 to 3.00 Meets/Exceeds Criteria

2.99 to 1.00 Below Criteria

1

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APPENDIX B

Style Consistency (R-Squared) – 10% Weight

Scoring Breakdown

Score - 5.0 Investment choice has a 3-year R2 of 85.0 or higher with respect to a relevant category or style specific index

Score - 4.0 Investment choice has a 3-year R2 of at least 75.0 but less than 85.0 with respect to a relevant category or style specific index



Score - 1.0 Investment choice has a 3-year R2 of less than 55.0 with respect to a relevant category or style specific index

Note: If an investment choice has less than 3-years of performance, “N/A” will be shown.

Fee & Expenses** – 10% Weight

Scoring Breakdown

Score - 5.0 Investment choice’s expense ratio is at most 80.0% of the relevant peer group average

Score - 4.0 Investment choice’s expense ratio is greater than 80.0% but at most 90.0% of the relevant peer group average



Score - 1.0 Investment choice’s expense ratio is greater than 120.0% of the relevant peer group average

Investment Process & Portfolio Composition – 10% Weight

Scoring Breakdown

Score - 5.0 Meets all criteria

Score - 4.0 Meets majority of the criteria

Score - 3.0 Meets more than half of the criteria

Score - 2.0 Meets few of the criteria

Score - 1.0 Meets none of the criteria

Note: Each investment choice is classified into major asset categories and sectors of the market. Since the majority of the investment choice’s assets should generally be fully invested within the applicable investment strategy, a high cash position will result in a lower score. Equity, Bond, and Hybrid investment choices are rated on separate scales as each investment choice type has a unique set of criteria.

Management Tenure – 10% Weight

Scoring Breakdown

Score - 5.0 Investment manager tenure is 5 years or more

Score - 4.0 Investment manager tenure is at least 3-1/2 but less than 5 years

Score - 3.0 Investment manager tenure is at least 1-1/2 years but less than 3-1/2 years

Score - 2.0 Investment manager tenure is at least 6 months but less than 1-1/2 years

Score - 1.0 Investment manager tenure is less than 6 months

Note: Management tenure will be determined using the longest tenure of any individual providing investment management to the portfolio.

This chart is for illustrative purposes only and your investment choices’ scores may differ from this example.* The Transamerica Scorecard Methodology is Transamerica Retirement Solutions’ (“Transamerica”) proprietary rating methodology. Transamerica reserves the right to modify, eliminate or add criteria at any time.** See the additional notes section of this report for a description of how the investment choices expense class may affect the fees and expenses.

Example (Investment Choice)

60% Weight 10% Weight 10% Weight 10% Weight 10% Weight Total Score

Performance Measurement

Style Consistency Fees & Expenses Management Tenure Investment Process & Portfolio Composition

ABC Investment Choice 4.00 5.00 3.00 4.00 5.00 Significantly Exceeds Criteria

4.10

Methodology*

Transamerica Investment Monitor

2

TRSC 5483(R2)-0412 For Plan Sponsor and Professional Use Only. Page 1 of 6

April 1, 2013 Dear Transamerica Retirement Solutions: Except as noted, the entire roster of investment choices provided in each of the Transamerica Retirement Solutions1 products2 has been reviewed by Lipper, Inc. This review is limited to an evaluation of the investment choices offered on Transamerica’s retirement platform. The review consisted of an analysis of the investment choices presented in the products as of December 31, 2011, and the degree to which the roster presents a set of investment choices that are appropriate for a defined contribution plan. The results will help plan sponsors make more informed investment choice selections for plan participants.

Analysis: Lipper has reviewed the individual product offerings utilizing two major components: 1) Product/Investment Choice Evaluation: a) Investment Choice Level Screening, b) Product Level Diversity, c) Diversity within Style; and 2) Investment Choice Selection and Monitoring Review.

Each investment choice is analyzed for performance and risk measures, style consistency, costs, and manager tenure. Additional analysis is performed to review the investment choices as they pertain to diversity of investment choice offerings across the product and within various style categories.

Summary of Results: Lipper believes Transamerica’s investment choice roster in each product meets the criteria set by Lipper and Transamerica. The evaluation results are listed below.

Criteria (as of 12/31/11)

Measure

Evaluation (Pass/Fail)

PRODUCT/INVESTMENT CHOICE EVALUATION – BOTTOM-UP Investment Choice Level Screening

At least 70% of the product’s investment choices must pass Lipper’s investment choice level criteria.

Pass

Product Level Diversity At least one investment choice must be present in each applicable style.

Pass

Diversity within Style Category

At least one investment choice must have different characteristics from another within the style category.

Pass

INVESTMENT CHOICE SELECTION AND MONITORING REVIEW – TOP-DOWN EVALUATION Transamerica Investment Monitor (TIM) 3

Provider maintains and follows specific disciplines for selection and monitoring for investment choices on the Transamerica platform.

Pass

An evaluation summary of the investment criteria used by Lipper can be found in the Criteria Document (page 4). In addition, certain investment choices were excluded from the analysis due to insufficient performance data.4

The analysis has been specially prepared by Lipper, Inc., a Thomson Reuters Company ("Lipper") for Transamerica Retirement Solutions, who provides this to the plan sponsor. This analysis may be distributed to Transamerica's clients (plan sponsors), but may not be distributed to its clients' plan participants. "Lipper" is a trademark of

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APPENDIX C


Thomson Reuters and has been licensed for use by Transamerica. None of the information provided to Transamerica by Lipper is intended to constitute investment advice or a recommendation to make (or refrain from making) any kind of investment decision and may not be relied on as such. Lipper makes no representation or warranty, express or implied, to Transamerica's clients, investors, or any member of the public regarding the advisability of, or the results that may be obtained from, investing in securities generally or in any product, retirement plan, hedge fund, or mutual fund particularly. Past performance is not necessarily a guide to future performance and investors should remember that past performance is not a guarantee of future results. Neither Lipper nor any member of the Thomson Reuters Group shall be acting, or deemed to be acting, as a "fiduciary" (as defined under the Employee Retirement Income Security Act of 1974) to any of Transamerica's clients or any of Transamerica's clients' plan participants. There is no agreement or understanding whatsoever that Lipper will provide individualized advice to any of Transamerica's clients or any of Transamerica's clients' plan participants. LIPPER AND EACH INFORMATION PROVIDER OR OTHER THIRD PARTY SUPPLIER EXPRESSLY DISCLAIMS ANY CONDITION OF QUALITY AND ANY IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. ALTHOUGH LIPPER MAKES REASONABLE EFFORTS TO ENSURE THE ACCURACY AND RELIABILITY OF THE INFORMATION PROVIDED TO TRANSAMERICA, NEITHER LIPPER NOR ANY INFORMATION PROVIDER OR OTHER THIRD PARTY SUPPLIER GUARANTEES SUCH ACCURACY OR RELIABILITY. LIPPER, ITS EMPLOYEES, AGENTS, CONTRACTORS, SUB-CONTRACTORS, INFORMATION PROVIDERS, AND OTHER THIRD PARTY SUPPLIERS WILL NOT BE HELD LIABLE FOR ANY DAMAGES OF ANY KIND IN CONNECTION WITH THE INFORMATION CONTAINED IN THIS DOCUMENT, INCLUDING LOST PROFITS, REGARDLESS OF WHETHER SUCH DAMAGES COULD HAVE BEEN FORESEEN OR PREVENTED.

1Plan-related recordkeeping services are provided by Transamerica Retirement Solutions Corporation (“Transamerica” or “Transamerica Retirement Solutions”). The investment choices are available through a contract issued by Transamerica Financial Life Insurance Company (“TFLIC”), TA-AP- 2001-CONT, or Transamerica Life Insurance Company (“TLIC”), CNT-TLIC 10-05. Transamerica is an affiliate of TFLIC and TLIC. TFLIC is not authorized and does not do business in the following jurisdictions: Guam, Puerto Rico, and the U .S. V irgin Islands. TLIC is not authorized in New Y ork and does not do business in New York. Contract form and number may vary, and these investment choices may not be available in all jurisdictions. Fees and charges may apply. For complete information, contact your Transamerica representative.

Securities offered through Transamerica Investors Securities Corporation (TISC), 440 Mamaroneck Avenue, Harrison, NY 10528. Transamerica Retirement Solutions and TISC are affiliated companies. Transamerica Financial Life Insurance Company and Transamerica Life Insurance Company are affiliates of Transamerica Investors

Securities Corporation (TISC). Securities are offered by TISC, 440 Mamaroneck Avenue, Harrison, NY 10528.

Regarding the Transamerica Director Series Product, the separate account investment choices offered are exempt from registration with the SEC; therefore, no prospectuses are filed for them. However, certain of the separate account investment choices, other than stable value investment choice(s), invest in mutual funds which are subject to SEC registration. Investors should consider the investment objectives, risks, charges and expenses of the fund carefully before investing. The prospectus for each fund contains this and other important information about that fund. In addition, comprehensive information on all the investment choices is available on the investment fact sheets. Prospectuses for these mutual funds can be ordered directly from the fund company. If you are a participant in the plan, please contact the participant call center at (800) 401-8726 Monday-Friday 8:00 a.m. to 8:00 p.m. Eastern Time. If you are the plan sponsor, please contact SponsorConnectSM at (866) 498-4557 Monday-Friday 9:00 a.m. to 8:00 p.m. Eastern Time. Read each prospectus carefully before investing. The Transamerica Advisor Series plan administration services are provided by Transamerica Retirement Solutions and funds are distributed by Transamerica Investors Securities Corporation (TISC), a registered broker-dealer and an affiliate of Transamerica Retirement Solutions. Transamerica specializes in the promotion of retirement plan products and services. Investors should carefully consider the risk, charges, and expenses of the funds before investing. The prospectus for each fund (other than for Stable Value investment choices, which are not mutual funds) contains this and other information about that fund. Prospectuses for these mutual funds can be ordered directly from the fund company or for more information, please contact us at (888) 498-4557 Monday through Friday 9:00 a.m. to 8:00 p.m. Eastern Time. Read each prospectus carefully before investing.

The Transamerica Advisor Series is available in all states. For all states except New York, Transamerica stable value investment choices are available under contract form

number CNT-TLIC 10-05, a group variable annuity contract issued by Transamerica Life Insurance Company (“TLIC”), Cedar Rapids, Iowa, and plan recordkeeping services are

provided by Transamerica Retirement Solutions Corporation (“Transamerica” or “Transamerica Retirement Solutions”). Contract form and number may vary, and may not be

available in all jurisdictions. In the state of New York, Transamerica stable value investment choices are available under contract form number TA-AP-2001-CONT, a group

variable annuity contract issued by Transamerica Financial Life Insurance Company (“TFLIC”), Harrison, New York and plan recordkeeping services are provided by Transamerica

Retirement Solutions. For all states except New York, Transamerica stable value investment choices are investments in the TLIC general account. In the state of New York,

Transamerica stable value investment choices are investments in the TFLIC general account.

2The following products have been reviewed by Lipper: Transamerica Director Series and Transamerica Advisor Series. 3Transamerica performs investment selection and monitoring due diligence related to the investment choices on Transamerica’s platform as a normal part of its business. Clients and other interested parties must consult and rely solely upon their own independent advisors regarding their particular situation. All investments involve risk, including loss of principal and there is no guarantee of profits. Investors should carefully consider their objectives, risk tolerance, and time horizon before investing. This is not meant to be construed as investment advice. Transamerica is not a fiduciary with respect to the plan as defined by ERISA including sections 3(21), 3(38) or 3(16), nor it is responsible for a plan’s selection, monitoring or de-selection of investments. Although the investment choices may meet the “significantly exceeds,” “meets/exceeds,” or “below” criteria, there are no guarantees of a profit and it is still possible to lose money from that investment choice.

Transamerica does not provide investment advice. Nothing presented herein should be construed as a recommendation to purchase or sell a particular investment or follow

any investment technique or strategy. Transamerica Retirement Solutions does not act as a fiduciary to any plan.

4The following investments were excluded from the review because they have less than 3 years of performance: SSgA Small Cap Value Index, Transamerica Stable Value Core, Transamerica Stable Value Strategy, Transamerica Stable Value Focus, Transamerica Multi-Managed Balanced Fund, Manning & Napier Pro-Blend Conservative Term Fund, Manning & Napier Pro-Blend Extended Term Fund, Manning & Napier Pro-Blend Moderate Term Fund, Manning & Napier Pro-Blend Maximum Term Fund, Transamerica


Morgan Stanley Growth Opportunities Fund, Transamerica WMC Diversified Growth Fund, Eaton Vance Large-Cap Growth Fund, Goldman Sachs Government Income Fund, and Transamerica Multi-Managed Balanced Fund.


Criteria Document — Transamerica Retirement Solutions The objective of this evaluation is to determine if Transamerica Retirement Solutions product meets criteria agreed upon by Lipper and Transamerica for performance and diversity. This is to be ascertained in three steps:

Determine if the investment choices offered in the Transamerica Retirement Solutions product pass the agreed-upon investment choice-level screen.

Establish if the product is diversified in its offering of investment choices. Where multiple investment choices are offered within a style, ascertain whether they are complementary in their

investment process and management.

This objective is to be met by the processes described hereafter.

INVESTMENT CHOICE/PRODUCT SCREENS

Lipper will perform three screens – first at the investment choice level, second at the product level, and third by style within the product. At the investment choice level, Lipper incorporates several main areas of focus for the screens – performance results, style consistency, management tenure, and costs. Each factor is to be based on a number of points, totaling 100 (see below).

For an investment choice to pass the overall screening process, it must achieve a score of at least 70 points.

Points

Screening Factors – Investment Choice Level

30 1.) 3-YEAR LIPPER LEADER FOR CONSISTENT RETURN

In order to pass, each investment choice’s Lipper Leader for Consistent Return Measure must be 2 or greater within its respective style group over the most recent 3-year period. (If an investment choice does not have at least 3-years of history, we will then look at relevant performance on a case-by-case basis.) Qualitative exceptions, as determined by Lipper, were made in the event that a manager demonstrated a superior previous track record.

10 2.) 3-YEAR ALPHA

In order to pass, an investment choice’s Alpha must be within 75% the respective style group’s Alpha over the most recent 3-year period. This measure can be helpful in determining the manager’s ability to contribute to an investment choice’s performance.

20 3.) STYLE CONSISTENCY – 3 YEAR R2

In order to pass, an investment choice must have a 3-year R2 of 0.80 or higher against the relevant Lipper chosen style

benchmark index or category benchmark index. An investment choice that is maintaining its principal investment strategies should consistently and persistently maintain its style classification. Lipper is looking for those investment choices that are “style consistent.”

25 4.) MANAGEMENT

In order to pass, the portfolio manager must have minimum 3-year tenure with the investment choice. Qualitative exceptions to the 3-year minimum can be made in the event that a manager demonstrated a superior previous track record within the same style.

15 5.) EXPENSE RATIO

In order to pass, an investment choice must maintain a competitive expense ratio, which is defined as not more than 10 basis points higher than 66 percent of the respective classification averages.

100 TOTAL POINTS POSSIBLE


Criteria Document — Transamerica Retirement Solutions (cont’d)

DIVERSITY SCREEN — PRODUCT LEVEL

For a product to be considered diversified in its offerings, it must have at least one investment choice in each of the following applicable style categories:

LARGE CAP GROWTH LARGE CAP BLEND*

LARGE CAP VALUE

MULTI CAP GROWTH MULTI CAP BLEND* MULTI CAP VALUE

MID CAP GROWTH MID CAP BLEND* MID CAP VALUE

SMALL CAP GROWTH SMALL CAP BLEND* SMALL CAP VALUE

GLOBAL/INTERNATIONAL EQUITY

SPECIALTY/SECTOR

HYBRID/MIXED-ASSET

FIXED INCOME – LONG/INTERMEDIATE

FIXED INCOME – SHORT/CASH EQUIVALENTS**

*Note: Large Cap Blend, Multi Cap Blend, Mid Cap Blend and Small Cap Blend style categories listed above are defined as “Core” by Lipper.

**This category seeks to protect against loss of principal while providing returns comparable to money market funds and short-term Treasury instruments. An investment in a

cash equivalent investment choice is not insured or guaranteed by the FDIC or any other government agency. Although the investment seeks to preserve the value of your

principal, it is possible to lose money by investing in the investment choice. These investment choices have generally provided a dependable level of stability and liquidity;

nevertheless, the investment is still subject to credit risk and to liquidity risk.

DIVERSITY SCREEN — STYLE CATEGORY LEVEL

Within each style category where more than one investment choice is offered, additional screening will be performed to discover if the investment choices are complementary by differing in their investment approach and management. Three factors will be considered in determining diversity within a style:

1. Number of Holdings 2. 3-Year Standard Deviation of Returns 3. 3-Year Beta

For an investment choice to pass, it must not have similar results in these three criteria as another investment choice within the same style category. At least one investment choice must be different from another for Lipper to determine that complementary investment choices are offered within style categories.

The Transamerica Retirement Solutions product must meet the criteria agreed upon by Lipper and Transamerica for performance and diversity according the following parameters:

1. At least 70% of the product’s investment choices must pass the quantitative screening process (70 points or higher). 2. The product is diversified per the Diversity Screen at the product level (at least one investment choice in each

applicable style). 3. The product must offer complementary investment choices within each applicable style where more than one

investment choice is offered, in order to be qualified as diverse within the style category.


The analysis has been specially prepared by Lipper, Inc., a Thomson Reuters Company ("Lipper") for Transamerica Retirement Solutions, who provides this to the plan sponsor. This analysis may be distributed to Transamerica's clients (plan sponsors), but may not be distributed to its clients' plan participants. "Lipper" is a trademark of Thomson Reuters and has been licensed for use by Transamerica. None of the information provided to Transamerica by Lipper is intended to constitute investment advice or a recommendation to make (or refrain from making) any kind of investment decision and may not be relied on as such. Lipper makes no representation or warranty, express or implied, to Transamerica's clients, investors, or any member of the public regarding the advisability of, or the results that may be obtained from, investing in securities generally or in any product, retirement plan, hedge fund, or mutual fund particularly. Past performance is not necessarily a guide to future performance and investors should remember that past performance is not a guarantee of future results. Neither Lipper nor any member of the Thomson Reuters Group shall be acting, or deemed to be acting, as a "fiduciary" (as defined under the Employee Retirement Income Security Act of 1974) to any of Transamerica's clients or any of Transamerica's clients' plan participants. There is no agreement or understanding whatsoever that Lipper will provide individualized advice to any of Transamerica's clients or any of Transamerica's clients' plan participants. LIPPER AND EACH INFORMATION PROVIDER OR OTHER THIRD PARTY SUPPLIER EXPRESSLY DISCLAIMS ANY CONDITION OF QUALITY AND ANY IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. ALTHOUGH LIPPER MAKES REASONABLE EFFORTS TO ENSURE THE ACCURACY AND RELIABILITY OF THE INFORMATION PROVIDED TO TRANSAMERICA, NEITHER LIPPER NOR ANY INFORMATION PROVIDER OR OTHER THIRD PARTY SUPPLIER GUARANTEES SUCH ACCURACY OR RELIABILITY. LIPPER, ITS EMPLOYEES, AGENTS, CONTRACTORS, SUB-CONTRACTORS, INFORMATION PROVIDERS, AND OTHER THIRD PARTY SUPPLIERS WILL NOT BE HELD LIABLE FOR ANY DAMAGES OF ANY KIND IN CONNECTION WITH THE INFORMATION CONTAINED IN THIS DOCUMENT, INCLUDING LOST PROFITS, REGARDLESS OF WHETHER SUCH DAMAGES COULD HAVE BEEN FORESEEN OR PREVENTED.

APPENDIX D

Fiduciaries to list additional tools used for their selection or investment choices for

this Plan.

2013 sample transamerica investment policy statement

Documents