Conflicts of Interest Policy

As a fiduciary to your organization’s assets, we believe the only way to operate is by being objective in reality and appearance. To crystallize our firm belief in these principles, we created and adhere to a Code of Ethics and Conflicts of Interest Policy.

The premise of our Code of Ethics and Conflicts of Interest Policy is that each PlanPilot associate has a fundamental obligation to act in the best interests of our clients and avoid conflicts of interest that would undermine our unbiased independent advice.

A snapshot of Our Conflicts of Interest Policy follows:

• We do not provide research or consulting services to any investment managers, mutual fund    companies or recordkeepers. While these firms have retirement plans and need assistance on plan    design, fee benchmarking, or other services, we do not believe it is appropriate for PlanPilot to    provide services to these firms.

• We do not host conferences or conduct surveys that are subsidized by investment managers, mutual fund companies or recordkeepers.

• We do not charge investment managers a fee to be included in our research database or to meet    with our investment analysts.

• We do not receive any direct or indirect compensation from investment managers, mutual fund    companies or recordkeepers.

• We do not accept gifts from any investment managers, mutual fund companies or recordkeepers.

To help plan sponsors better understand whether their investment consultants face potential conflicts of interest, the SEC and the Department of Labor (DOL) developed a set of “ten questions” for reference. Please refer to the SEC’s web site:
http://www.sec.gov/investor/pubs/sponsortips.htm


Conflicts of Interest Policy

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