Massachusetts Mutual Life Insurance Companyand affiliates, Springfield, MA 01111-0001

www.massmutual.com

Massachusetts Mutual Life Insurance Company and affiliates1295 State Street, Springfield, MA 01111-0001

Massachusetts Mutual Life Insurance Companyand affiliates, Springfield, MA 01111-0001

www.massmutual.com

Massachusetts Mutual Life Insurance Company and affiliates1295 State Street, Springfield, MA 01111-0001

Massachusetts Mutual Life Insurance Companyand affiliates, Springfield, MA 01111-0001

www.massmutual.com

Massachusetts Mutual Life Insurance Company and affiliates1295 State Street, Springfield, MA 01111-0001

Position correct sizeand version ofMassMutual logoin this position.DO NOT SCALE LOGOS!

© 2013 Massachusetts Mutual Life Insurance Company, Springfield, MA 01111-0001. All rights reserved. www.massmutual.com. MassMutual Financial Group is a marketing name for Massachusetts Mutual Life Insurance Company (MassMutual) [of which Retirement  Services  is a division] and its affiliated companies and sales representatives.

RS1958 1013 C02212-05

Investment Policy Statement for <Name of Plan>

Solutionsfor Plan Sponsors

Retirement Strategies

For The [Name of Plan]

[Company Name]

[Date]

Massachusetts Mutual Life Insurance Companyand affiliates, Springfield, MA 01111-0001

www.massmutual.com

Massachusetts Mutual Life Insurance Company and affiliates1295 State Street, Springfield, MA 01111-0001

Massachusetts Mutual Life Insurance Companyand affiliates, Springfield, MA 01111-0001

www.massmutual.com

Massachusetts Mutual Life Insurance Company and affiliates1295 State Street, Springfield, MA 01111-0001

Massachusetts Mutual Life Insurance Companyand affiliates, Springfield, MA 01111-0001

www.massmutual.com

Massachusetts Mutual Life Insurance Company and affiliates1295 State Street, Springfield, MA 01111-0001

Position correct sizeand version ofMassMutual logoin this position.DO NOT SCALE LOGOS!

Providing you the tools…Sample investment policy statement

This is a sample investment policy statement template for your plan. MassMutual believes all plans should have an Investment Policy Statement (IPS) and the terms of the IPS should be closely followed. We have provided this sample statement free of charge as a service to our valued clients. The only request we have is that you not share our sample IPS template with third parties. Please contact your MassMutual Retirement Services professional if you have any questions or comments.

Contents 1 | Plan information

1 | Responsible parties

2 | Purpose of this investment policy statement

2 | Plan objectives and purpose

2 | Roles and responsibilities

3 | Selecting and monitoring the investment options

3 | Investment selection

4 | Investment monitoring and reporting

5 | Investment option termination

5 | Administrative review procedures

6 | Communication policies

5

[PlanSponsor/InvestmentCommittee]willterminatean

investment option upon losing confidence in the investment

option’s potential to:

• Achieveperformanceandriskobjectives,

• Maintainaconsistentinvestmentstyle.

There are no hard and fast rules for investment option

termination.However,iftheinvestmentconsistentlyfailsto

adhere to one or more of the above conditions, it is reason-

able to presume a lack of adherence going forward. Failure

to remedy the circumstances of unsatisfactory performance,

within a reasonable time, shall be grounds for termination.

Any recommendation to terminate an investment option

will be treated on an individual basis, and will not be made

solely based on quantitative data. In addition to those above,

other factors may include investment option manager

turnover, or material change to investment processes.

Considerable judgment will be exercised in the termination

decision process.

An investment option to be terminated shall be removed

using one of the following approaches:

• Removeandreplace(mapassets)toanalternative

investment option.

• Continuetheinvestmentoption,butaddacompeting

investment option.

Replacement of a terminated option would follow the crite-

ria outlined in the Selection of Investments and Managers

section of this Investment Policy Statement template.

Administrative review proceduresThe plan sponsor is accountable for monitoring and evaluat-

ing the investment options chosen for the plan. All chosen

investment options will be reviewed at least annually for

acceptability, under the guidelines outlined above.

Communication policiesAt enrollment and on an ongoing basis the recordkeeper

provides participant communication materials that include

sufficient information for participants to make

informed decisions.

Investment Policy Statement for <Name of Plan>

4

Optional:

[Investors who wish to follow a disciplined asset alloca-

tion strategy require options that stay consistent to their

stated investment style. Several style-focused core options,

representing the primary asset classes (e.g., stocks, bonds

and cash) allow participants to implement and maintain

theintegrityoftheirowncustomizedinvestmentstrategy.

Becausetheplanfiduciaryrecognizessomeplanpartici-

pants desire assistance in making investment decisions, the

planalsooffersassetallocation/balancedstrategies.These

options offer a simple means to implement an asset alloca-

tion policy by having investment professionals implement

and monitor the asset mix. A participant only chooses one

balanced/assetallocationoptiontoimplementachosen

investment strategy.]

Optional:

[To satisfy the needs of active investors, the plan offers a

self-directed brokerage account.]

The[Plansponsor/investmentcommittee]afterdetermining

the asset classes to be used, evaluates investment providers

and chooses a provider to manage the investment options.

Each investment provider must meet certain

minimum criteria:

1. Beaninsurancecompany,bank,investment

management company or an investment adviser

under the Registered Investment Advisers

Act of 1940.

2. Beoperatingingoodstandingwithregulatorsand

clients, with no material pending or concluded

legal actions.

3. Should provide detailed information on its history,

investment philosophy and approach, and its

principals, clients, locations, fee schedules and other

relevant information.

The particular investments should pursue the

following standards:

1. Performance equal to or greater than the median

return for an appropriate, style-specific benchmark

and peer group over a specified time period.

2. Specific risk and risk-adjusted return measures

should be established and agreed to by [Plan

Sponsor/investmentcommittee]andbewithina

reasonable range relative to an appropriate,

style-specific benchmark and peer group.

3. Demonstrated adherence to the stated

investment objective.

4. Competitive fees compared to similar investments.

5. An investment manager that provides all

performance, holdings, and other relevant

information in a timely fashion, with

specified frequency.

Investment monitoring and reportingThe ongoing monitoring of each investment option must

be a regular and disciplined process. Monitoring will occur

onaregularbasisandutilizethesamecriteriathatwerethe

basis of the investment selection. Monitoring is the mecha-

nism for revisiting the investment.

Investment option termination

Investment Policy Statement for <Name of Plan> 1

Plan informationPlan name:

Type of plan:

Plan adoption date:

Plan year-end date:

Plan number:

Trust ID number:

Responsible partiesThe parties responsible for managing and operating the plan include but

are not limited to:

Plan Fiduciary (Sponsor): [NAME and contact information]

Trustee: [NAME and contact information]

Investment Provider: MassMutual

Investment Committee: [NAME and contact information]

Recordkeeper: [NAME and contact information]

Investment Policy Statement for <Name of Plan>

2

Purpose of this investment policy statementThe Investment Policy Statement establishes investment

principles and a framework for selecting, monitoring and

evaluating investment options under the Plan.

Annually we will review this Investment Policy Statement,

and if appropriate, amend it to reflect changes in the market,

Plan participant objectives, or other factors relevant to

the Plan.

The Investment Policy Statement defines the Plan’s

investment objective as well as defines the roles of those

responsible for the Plan’s investments. It also establishes

investment procedures, measurement standards and

monitoring procedures.

If this Investment Policy Statement conflicts with the Plan

Document, the provisions of the Plan Document will prevail.

Plan objectives and purpose[Name of Company] sponsors a [Plan Name] plan to provide

employees with a vehicle for saving for their retirement. Plan

participants direct their individual account balances among

the investment options selected by the plan fiduciary. The

plan provides participants with the opportunity to make their

own investment choices and permits them to make changes to

their allocation instructions [frequency: such as “daily”]. The

plan fiduciary strives to provide a range of investment options

that will enable all participants to invest in the way that they

feel best suits their long-term investment objectives.

This Plan is a qualified employee benefit plan intended to

comply with all federal laws and regulations. This Plan is

designed to comply with the provisions of ERISA

Section 404(c).

Roles and responsibilities The responsibilities of the Plan Sponsor include:

• SelectingtheTrustee;

• HiringtheInvestmentProviderand/orRecordkeeper

• Appointingthemember(s)oftheinvestment

committee (if one exists).

The responsibilities of the Plan’s Trustee(s) include:

• InvestingplanassetsinaccordancewiththeTermsof

the Trust Agreement.

Investment Policy Statement for <Name of Plan> 3

The responsibilities of the Investment Provider include:

• Providingfinancialinformationonaregularbasisas

determinedbythePlan;

• Makingreasonableinvestmentdecisionsconsistent

withthestatedapproach;and

• Providinginformationtoassisttheplanfiduciary.

The responsibilities of the Investment Committee (if no

investment committee exists, the Plan Sponsor) include:

• Developingasoundandconsistentinvestmentpolicy;

• Selectingasuitableinvestmentprovider;

• Selectingdiversifiedinvestmentoptionswithvarying

objectivesandrisk/returncharacteristics;

• Monitoringandevaluatingperformanceresultsand

recommendinginvestmentoptionchanges;

• Providingemployeeswithinvestmenteducationto

help them be informed investors.

The responsibilities of the Recordkeeper include:

• Maintainingandupdatingindividualaccount

balances;

• Updatingplancontributionsaswellaswithdrawals

and distributions.

Selecting and monitoring the investment options[NameofPlan/InvestmentCommittee]recognizesdiffer-

ent investors have different investment objectives. The Plan

strives to provide participants with an appropriate range of

investment options to meet the various risk profiles of

its participants.

Investment selectionThe Plan intends to provide an appropriate range of invest-

mentoptionsthatwillspantherisk/returnspectrumand

allow Plan participants to construct portfolios consistent

with their unique individual circumstances, goals, time hori-

zonsandtoleranceforrisk.Majorassetclassestobeoffered

may include:

• StableValue

• FixedIncome(multiplecategories)

• AssetAllocation(lifestyleandbalanced)

• AssetAllocation(lifecycle)

• LargeCapEquity(multiplestyles)

• MultiCapEquity(multiplestyles)

• MidCapEquity(multiplestyles)

• SmallCapEquity(multiplestyles)

• International/Global(multiplestylesandcategories)

• Specialty(sectorandothernarrowlydefinedoptions)

• Self-DirectedBrokerageAccount

Investment Policy Statement for <Name of Plan>

2

Purpose of this investment policy statementThe Investment Policy Statement establishes investment

principles and a framework for selecting, monitoring and

evaluating investment options under the Plan.

Annually we will review this Investment Policy Statement,

and if appropriate, amend it to reflect changes in the market,

Plan participant objectives, or other factors relevant to

the Plan.

The Investment Policy Statement defines the Plan’s

investment objective as well as defines the roles of those

responsible for the Plan’s investments. It also establishes

investment procedures, measurement standards and

monitoring procedures.

If this Investment Policy Statement conflicts with the Plan

Document, the provisions of the Plan Document will prevail.

Plan objectives and purpose[Name of Company] sponsors a [Plan Name] plan to provide

employees with a vehicle for saving for their retirement. Plan

participants direct their individual account balances among

the investment options selected by the plan fiduciary. The

plan provides participants with the opportunity to make their

own investment choices and permits them to make changes to

their allocation instructions [frequency: such as “daily”]. The

plan fiduciary strives to provide a range of investment options

that will enable all participants to invest in the way that they

feel best suits their long-term investment objectives.

This Plan is a qualified employee benefit plan intended to

comply with all federal laws and regulations. This Plan is

designed to comply with the provisions of ERISA

Section 404(c).

Roles and responsibilities The responsibilities of the Plan Sponsor include:

• SelectingtheTrustee;

• HiringtheInvestmentProviderand/orRecordkeeper

• Appointingthemember(s)oftheinvestment

committee (if one exists).

The responsibilities of the Plan’s Trustee(s) include:

• InvestingplanassetsinaccordancewiththeTermsof

the Trust Agreement.

Investment Policy Statement for <Name of Plan> 3

The responsibilities of the Investment Provider include:

• Providingfinancialinformationonaregularbasisas

determinedbythePlan;

• Makingreasonableinvestmentdecisionsconsistent

withthestatedapproach;and

• Providinginformationtoassisttheplanfiduciary.

The responsibilities of the Investment Committee (if no

investment committee exists, the Plan Sponsor) include:

• Developingasoundandconsistentinvestmentpolicy;

• Selectingasuitableinvestmentprovider;

• Selectingdiversifiedinvestmentoptionswithvarying

objectivesandrisk/returncharacteristics;

• Monitoringandevaluatingperformanceresultsand

recommendinginvestmentoptionchanges;

• Providingemployeeswithinvestmenteducationto

help them be informed investors.

The responsibilities of the Recordkeeper include:

• Maintainingandupdatingindividualaccount

balances;

• Updatingplancontributionsaswellaswithdrawals

and distributions.

Selecting and monitoring the investment options[NameofPlan/InvestmentCommittee]recognizesdiffer-

ent investors have different investment objectives. The Plan

strives to provide participants with an appropriate range of

investment options to meet the various risk profiles of

its participants.

Investment selectionThe Plan intends to provide an appropriate range of invest-

mentoptionsthatwillspantherisk/returnspectrumand

allow Plan participants to construct portfolios consistent

with their unique individual circumstances, goals, time hori-

zonsandtoleranceforrisk.Majorassetclassestobeoffered

may include:

• StableValue

• FixedIncome(multiplecategories)

• AssetAllocation(lifestyleandbalanced)

• AssetAllocation(lifecycle)

• LargeCapEquity(multiplestyles)

• MultiCapEquity(multiplestyles)

• MidCapEquity(multiplestyles)

• SmallCapEquity(multiplestyles)

• International/Global(multiplestylesandcategories)

• Specialty(sectorandothernarrowlydefinedoptions)

• Self-DirectedBrokerageAccount

Investment Policy Statement for <Name of Plan>

4

Optional:

[Investors who wish to follow a disciplined asset alloca-

tion strategy require options that stay consistent to their

stated investment style. Several style-focused core options,

representing the primary asset classes (e.g., stocks, bonds

and cash) allow participants to implement and maintain

theintegrityoftheirowncustomizedinvestmentstrategy.

Becausetheplanfiduciaryrecognizessomeplanpartici-

pants desire assistance in making investment decisions, the

planalsooffersassetallocation/balancedstrategies.These

options offer a simple means to implement an asset alloca-

tion policy by having investment professionals implement

and monitor the asset mix. A participant only chooses one

balanced/assetallocationoptiontoimplementachosen

investment strategy.]

Optional:

[To satisfy the needs of active investors, the plan offers a

self-directed brokerage account.]

The[Plansponsor/investmentcommittee]afterdetermining

the asset classes to be used, evaluates investment providers

and chooses a provider to manage the investment options.

Each investment provider must meet certain

minimum criteria:

1. Beaninsurancecompany,bank,investment

management company or an investment adviser

under the Registered Investment Advisers

Act of 1940.

2. Beoperatingingoodstandingwithregulatorsand

clients, with no material pending or concluded

legal actions.

3. Should provide detailed information on its history,

investment philosophy and approach, and its

principals, clients, locations, fee schedules and other

relevant information.

The particular investments should pursue the

following standards:

1. Performance equal to or greater than the median

return for an appropriate, style-specific benchmark

and peer group over a specified time period.

2. Specific risk and risk-adjusted return measures

should be established and agreed to by [Plan

Sponsor/investmentcommittee]andbewithina

reasonable range relative to an appropriate,

style-specific benchmark and peer group.

3. Demonstrated adherence to the stated

investment objective.

4. Competitive fees compared to similar investments.

5. An investment manager that provides all

performance, holdings, and other relevant

information in a timely fashion, with

specified frequency.

Investment monitoring and reportingThe ongoing monitoring of each investment option must

be a regular and disciplined process. Monitoring will occur

onaregularbasisandutilizethesamecriteriathatwerethe

basis of the investment selection. Monitoring is the mecha-

nism for revisiting the investment.

Investment option termination

Investment Policy Statement for <Name of Plan> 1

Plan informationPlan name:

Type of plan:

Plan adoption date:

Plan year-end date:

Plan number:

Trust ID number:

Responsible partiesThe parties responsible for managing and operating the plan include but

are not limited to:

Plan Fiduciary (Sponsor): [NAME and contact information]

Trustee: [NAME and contact information]

Investment Provider: MassMutual

Investment Committee: [NAME and contact information]

Recordkeeper: [NAME and contact information]

Investment Policy Statement for <Name of Plan>

This is a sample investment policy statement template for your plan. MassMutual believes all plans should have an Investment Policy Statement (IPS) and the terms of the IPS should be closely followed. We have provided this sample statement free of charge as a service to our valued clients. The only request we have is that you not share our sample IPS template with third parties. Please contact your MassMutual Retirement Services professional if you have any questions or comments.

Contents 1 | Plan information

1 | Responsible parties

2 | Purpose of this investment policy statement

2 | Plan objectives and purpose

2 | Roles and responsibilities

3 | Selecting and monitoring the investment options

3 | Investment selection

4 | Investment monitoring and reporting

5 | Investment option termination

5 | Administrative review procedures

6 | Communication policies

5

[PlanSponsor/InvestmentCommittee]willterminatean

investment option upon losing confidence in the investment

option’s potential to:

• Achieveperformanceandriskobjectives,

• Maintainaconsistentinvestmentstyle.

There are no hard and fast rules for investment option

termination.However,iftheinvestmentconsistentlyfailsto

adhere to one or more of the above conditions, it is reason-

able to presume a lack of adherence going forward. Failure

to remedy the circumstances of unsatisfactory performance,

within a reasonable time, shall be grounds for termination.

Any recommendation to terminate an investment option

will be treated on an individual basis, and will not be made

solely based on quantitative data. In addition to those above,

other factors may include investment option manager

turnover, or material change to investment processes.

Considerable judgment will be exercised in the termination

decision process.

An investment option to be terminated shall be removed

using one of the following approaches:

• Removeandreplace(mapassets)toanalternative

investment option.

• Continuetheinvestmentoption,butaddacompeting

investment option.

Replacement of a terminated option would follow the crite-

ria outlined in the Selection of Investments and Managers

section of this Investment Policy Statement template.

Administrative review proceduresThe plan sponsor is accountable for monitoring and evaluat-

ing the investment options chosen for the plan. All chosen

investment options will be reviewed at least annually for

acceptability, under the guidelines outlined above.

Communication policiesAt enrollment and on an ongoing basis the recordkeeper

provides participant communication materials that include

sufficient information for participants to make

informed decisions.

Investment Policy Statement for <Name of Plan>

Massachusetts Mutual Life Insurance Companyand affiliates, Springfield, MA 01111-0001

www.massmutual.com

Massachusetts Mutual Life Insurance Company and affiliates1295 State Street, Springfield, MA 01111-0001

Massachusetts Mutual Life Insurance Companyand affiliates, Springfield, MA 01111-0001

www.massmutual.com

Massachusetts Mutual Life Insurance Company and affiliates1295 State Street, Springfield, MA 01111-0001

Massachusetts Mutual Life Insurance Companyand affiliates, Springfield, MA 01111-0001

www.massmutual.com

Massachusetts Mutual Life Insurance Company and affiliates1295 State Street, Springfield, MA 01111-0001

Position correct sizeand version ofMassMutual logoin this position.DO NOT SCALE LOGOS!

© 2013 Massachusetts Mutual Life Insurance Company, Springfield, MA 01111-0001. All rights reserved. www.massmutual.com. MassMutual Financial Group is a marketing name for Massachusetts Mutual Life Insurance Company (MassMutual) [of which Retirement  Services  is a division] and its affiliated companies and sales representatives.

RS1958 1013 C02212-05

Investment Policy Statement for <Name of Plan>

Solutionsfor Plan Sponsors

Retirement Strategies

For The [Name of Plan]

[Company Name]

[Date]

Massachusetts Mutual Life Insurance Companyand affiliates, Springfield, MA 01111-0001

www.massmutual.com

Massachusetts Mutual Life Insurance Company and affiliates1295 State Street, Springfield, MA 01111-0001

Massachusetts Mutual Life Insurance Companyand affiliates, Springfield, MA 01111-0001

www.massmutual.com

Massachusetts Mutual Life Insurance Company and affiliates1295 State Street, Springfield, MA 01111-0001

Massachusetts Mutual Life Insurance Companyand affiliates, Springfield, MA 01111-0001

www.massmutual.com

Massachusetts Mutual Life Insurance Company and affiliates1295 State Street, Springfield, MA 01111-0001

Position correct sizeand version ofMassMutual logoin this position.DO NOT SCALE LOGOS!

Providing you the tools…Sample investment policy statement