BB&N 403(b) Summary Plan Description 2022

150127 150128 BUCKINGHAM BROWNE & NICHOLS SCHOOL DC RE TIREMENT PLAN SUMMARY PLAN DESCRIPTION

i TABLE OF CONTENTS INTRODUCTION TO YOUR PLAN How do I participate in the Plan? ................................ ................................ ................................ ................................ ............................... 1 What happens if I'm a Participant, terminate employment and then I' m rehired? ................................ ................................ ............... 2 ARTICLE II EMPLOYEE CONTRIBUTIONS What are elective deferrals and how do I contribute them to the Plan? ................................ ................................ ............................... 2 What are rollover contributions? ................................ ................................ ................................ ................................ ................................ 3 ARTICLE III EMPLOYER CONTRIBUTIONS What is the Employer match ing contribution and how is it allocated? ................................ ................................ ................................ .. 3 What is the Employer nonelective contribution and how is it allocated? ................................ ................................ .............................. 3 ARTICLE IV COMPENSATION AND ACCOUNT BALANCE What compensation is used to determine my Plan benefits? ................................ ................................ ................................ ................ 4 Is there a limit on the amount of compensation which can be considered? ................................ ................................ ........................ 4 Is there a limit on how much can be contributed to my account each year? ................................ ................................ ....................... 4 How is the money in the Plan invested? ................................ ................................ ................................ ................................ ................... 4 Will Plan expenses be deducted from my ac count balance? ................................ ................................ ................................ ................ 5 ARTICLE V VESTING What is my vested interest in my account? ................................ ................................ ................................ ................................ .............. 5 ARTICLE VI DISTRIBUTIONS PRIOR TO TERMINATION OF EMPLOYMENT Can I withdraw money from my account while working? ................................ ................................ ................................ ........................ 6 Can I withdraw money from my account in the event of financial hardship? ................................ ................................ ....................... 6 ARTICLE VII DISTRIBUTIONS UPON TERMINATION OF EMPLOYMENT When can I g et money out of the Plan? ................................ ................................ ................................ ................................ .................... 7 What is Normal Retirement Age and what is the significance of reaching Normal Retirement Age? ................................ .............. 7 When am I considered to be disabled under the Plan? ................................ ................................ ................................ .......................... 7 How will my benefits be paid to me? ................................ ................................ ................................ ................................ ......................... 8 May I elect another distribution method? ................................ ................................ ................................ ................................ .................. 8 ARTICLE VIII DISTRIBUTIONS UPON DEATH What happens if I die while working for the Employer? ................................ ................................ ................................ .......................... 8 Who is the beneficiary of my death benefit? ................................ ................................ ................................ ................................ ............ 8 How will the death benefit be paid to my beneficiary? ................................ ................................ ................................ ............................ 9 When must payments be made to my benefici ary (required minimum distributions)? ................................ ................................ ....... 9

ii What happens if I terminate employment, commence required minimum distribution payments and then die before receiving all of my benefits? ................................ ................................ ................................ ................................ ........................... 9 ARTICLE IX TAX TREATMENT OF DISTRIBUTIONS What are my tax consequences when I receive a distribution from the Plan? ................................ ................................ .................... 10 Can I elect a rollover to reduce or defer tax on my distribution? ................................ ................................ ................................ ........... 10 ARTICLE X LOANS Is it possible to borrow money from the Plan? ................................ ................................ ................................ ................................ ......... 10 ARTICLE XI PROTECTED BENEFITS AND CLAIMS PROCEDURES Are my benefits protected? ................................ ................................ ................................ ................................ ................................ ......... 10 Are there any exceptions to the general rule? ................................ ................................ ................................ ................................ ......... 10 Can the Employer amend the Plan? ................................ ................................ ................................ ................................ ......................... 11 What happens if the Plan is discontinued or terminated? ................................ ................................ ................................ ...................... 1 1 How do I submit a claim for Plan benefits? ................................ ................................ ................................ ................................ .............. 11 What if my benefits are denied? ................................ ................................ ................................ ................................ ................................ 11 What is the claims review procedure? ................................ ................................ ................................ ................................ ...................... 12 What are my rights as a Plan Participant? ................................ ................................ ................................ ................................ ............... 14 What can I do if I have questions or my rights are violated? ................................ ................................ ................................ ................. 14 ARTICLE XII GENERAL INFORMATION ABOUT THE PLAN Plan Name ................................ ................................ ................................ ................................ ................................ ................................ .... 15 Plan Number ................................ ................................ ................................ ................................ ................................ ................................ . 15 Plan Effective Dates ................................ ................................ ................................ ................................ ................................ .................... 15 Other Plan Information ................................ ................................ ................................ ................................ ................................ ................ 15 Employer Information ................................ ................................ ................................ ................................ ................................ .................. 15 Plan Administrator Information ................................ ................................ ................................ ................................ ................................ ... 15

1 BUCKINGHAM BROWNE & NICHOLS SCHOOL DC RE TIREMENT PLAN SUMMARY PLAN DESCRIPTION INTRODUCTION TO YOUR PLAN Buckingham Browne & Nichols School DC Retirement Plan ("Plan") has been adopted to provide you with the opportunity to save for retirement on a tax advantaged basis . This Plan is a type of retirement plan known as a 403(b) plan. This Summary Plan Description ("SPD") contains information regarding when you may become eligible to participate in the Plan, your Plan benefits, your distribution options, and many other features of the Plan. You should take the time to read this SPD to understand the fea tures of the Plan. This SPD addresses t he most common questions you might have regarding the Plan. If this SPD does not answer all of your questions, please contact the Plan Administrator or other Plan representative. The Plan Administrator is generally r esponsible for responding to questions and making determinations related to the administration, interpretation, and application of the Plan, unless those responsibilities have been delegated to other parties. The Employer is t he Plan Administrator . The Business Office, which includes Human Resources Human Resources , acts for the Plan A dministrator for many of the administrative tasks . More information can be found at the end of this SPD in the Article entitled "General Information abo ut the Plan." This SPD describes the Plan's benefits and obligations as contained in the legal Plan document, which governs the operation of the Plan. The Plan document is written in much more technical and precise language and is designed to comply with applicable legal requirements. If the non - technical language in this SPD and the technical, legal language of the Plan document conflict, the Plan document always governs. If you wish to receive a copy of the legal Plan document, please contact the Plan Ad ministrator. This SPD describes the current provisions of the Plan. The Plan is subject to federal laws , such as ERISA (the Employee Retirement Income Security Act), the Internal Revenue Code and other federal and state laws which might affect your rights. The provisions of the Plan are subject to revision due to a change in laws or due to pronouncements by the Internal Revenue Service (IRS) or Department of Labor . Your Employer may also amend or terminate this Plan. The Plan Administrat or will notify you if the provisions of the Plan that are described in this SPD change. Investment arrangement. The investment products you select (known as investment arrangements) may also affect the provisions of the Plan. Investment arrangements are p rovided through TIAA. In some cases the investment arrangements may limit your options under the Plan. This SPD does not address the provisions of the various investment arrangements. You should contact the Plan Administrator or the investment provider if you have questions about the provisions of your specific investment arrangements. Types of contributions. The following types of contributions are allowed under this Plan:  Employee elective deferrals  Employer Matching Contribution s  Employer Nonelective Contribution s  Employee rollover contributions Two Classes of Participation. Effective June 1, 2022 , w e amended the Plan so that all employees will now be able to participate. This is great news for our part - time and temporary employees who previously were excluded from participation. These employees now have Limited Participation rights which will allow them to save for retirement from their own compensa tion. They do not receive Employer contributions except in circumstances where hours of service are so significant as to be close to full - time status and special service requirements are satisfied , as described later in this SPD. Full Participants are th ose employees in regularly scheduled positions with service requirements of at least 1,000 hours per year. Full Participants may save for retirement from their compensation and are also eligible for Employer contributions. If first hired on or after June 1, 2022, a minimum age requirement of 21 also applies for employer contributions, but not the right to save. Limited Participants are those with lesser schedules, such as temporary, seasonal, or part - time. Employees in these job categories are Limited Participants and are not Full Participants : - Seasonal Coaches (regardless of scheduled hours) - Summer Counsellors (regardless of scheduled hours) - Substitute Teachers paid on a per diem basis (regardles s of scheduled hours) - Any other Temporary or Seasonal employee, if scheduled to work at a rate that would regularly be less than 20 hours per week with an expectation of less than 1,000 Hours of Service in an Eligibility Computation Period. ARTIC LE I PARTICIPATION IN THE PLAN How do I participate in the Plan? You must open an account with TIAA. If you want to save from your own compensation, you also must complete a Salary Reduction Form and return to the Employer. You may use this e - mail: jpagounes@bbns.org or deliver to Human Resources . If you have questions regarding the enrollment process please contact the Employer or a TIAA representative at 1 - 800 - 842 - 2888.

2 Elective Deferrals An Elective Deferral is a tec h nical name for the process where you agree to make a Plan contribution which comes out of your compensation . As described in Article II, an Elective Deferral is taxed currently only for Social Security purposes. At a later date, when you actually receive the money you pay income taxes, based on whatever your tax bracket is at the time and the law of the state where you permanently reside at the time . Saving for your retirement should be a key part of most everyone’s financial plan, even (or especially) if you are very young. There is no minimum age or waiting period if you want to save from your own compensation. Matching Contribution s Full Participants are immediately eligi ble for Matching Contribution s. If first hired on or after June 1, 2022, Matching Contribution s may not start until after the Entry D ate in which you are at least age 21. Entry Dates are January 1 and July 1 and deferrals prior to that Entry Date are not matched. Limited Participants will generally not be eligible for Matching Contribution s except for Plan Years when they satisfy the special service conditions described at the end of this Article I II . If they do qualify, the age 21 rule described above also applies if first hired on or after June 1, 2022. Nonelective Contribution s Full Participants are immediately eligible for Employer Nonelective Contribution s. If first hired on or after June 1, 2022, Nonelective Contribution s may not start until after the Entry Date in which you are at least age 21. Entry Dates are January 1 and July 1 and compensation prior to that Entry Date is not credited . Limited Particip ants will generally not be eligible for Nonelective Contribution s except for Plan Years when they satisfy the special service conditions described at the end of this Article II I . If they do qualify, the age 21 rule described above also applies if first hired on or after June 1, 2022. Reclassified Employee s The Plan is only for Employees , not independent contractors or employees of temporary help agencies. If it is determined that your Employer erroneously classified you as a non - Employee and you should have been treated as an Employee, you are not entitled to participate in the Plan except for Elective Deferrals. Military Service. If you are a veteran and are reemployed under the Uniformed Services Employment and Reemployment Rights Act of 1994, you r qualified military service might be considered servi ce with the Employer. If you might be affected by this law, ask the Plan Administrator for further details. What happens if I'm a Participant, termina te employment and then I'm rehired? If you are no longer a Participant because of a termination of employment, and you are rehired, then you will be able to part icip ate in the Plan on the date on which you are rehired if you are otherwise eligible to participate in the Plan. ARTICLE II EMPLOYEE CONTRIBUTIONS What are elective deferrals and how do I contribute them to the Plan? Elective Deferrals. As a Participant under the Plan, you may elect to reduce your compensation by a specific percentage and have that amount con tributed to the Plan on a pre - tax basis as an elective deferral. Your taxable income is reduced by the elective deferral contribution so you pay less in federal income taxes (however, the amount you defer is still counted as compensation for purp oses of So cial Security taxes). Later, when the Plan distributes the elective deferrals and earnings, you will pay the taxes on those e lective deferrals and the earnings. Therefore, federal income taxes on the elective deferral contributions and on the earnings are only postponed. Eventually, you will have to pay taxes on these amounts. You will always be 100% vested in your elective deferrals (see the Article in this SPD entitled "Vesting"). Elective Deferral procedure. The amount you elect to defer will be deduc ted from your pay in accordance with a procedure established by the Plan Administrator. If you wish to defer, the procedure will require that you enter into a Salary Reduction Agreement. You may elect to defer a portion of your compensation payable on or after your Entry Date. Such election will become effective as soon as administratively feasible after it is received by the Plan Administrator. Your election will generally remain in effe ct until you modify or terminate it. Elective Deferral modifications. You may revoke or make modifications to your salary deferral election in accordance with procedures that the Employer provides. See the Plan Administrator for further information. Elec tive Deferral Limit. As a Participant, you may elect to defer a percentage of your compensation each year instead of receiving that amount in cash. Your total elective deferrals in any taxable year can not exceed a dollar limit which is set by law. The limi t for 2022 is $ 20,500 . After 2022 , the dollar limit may increase for cost - of - living adjustments. See the paragraph below on Annual dollar limit.

3 Age 50 Catch - Up Deferrals. If you are at least age 50 or will attain age 50 before the end of a calendar year, then you may elect to defer additional amounts (called Age 50 Catch - Up Deferrals) to the Plan as of the January 1st of that year. You can defer t he additional amounts regardless of any other limitations on the amount you can defer to the Plan. The maximum Age 50 Catch - Up Deferrals that you can make in 2022 is $ 6,500 . After 2022, the maximum might increase for cost - of - living adjustments. Any Age 50 Catch - Up Deferrals that you make will be taken into account in determining any Employer M atching Contribution made to the Plan. Annual dollar limit. You should also be aware that each separately stated annual dollar limit on the amount you may defer (the annual deferral limit and the "catch - up contribution" limit) is a separate aggregate limit that applies to all such similar salary deferral amounts and "catch - up contributions" you may make under this Plan and any other cash or deferred arrangements (including other tax - sheltered 403(b) annuity contracts, simpli fied employee pensions or 40 1(k) plans) in which you may be participating. Generally, if an annual dollar limit is exceeded, then the excess must be returned to you in order to avoid adverse tax consequences. For t his reason, it is desirable to request in writing that any such excess salary deferral amounts and "catch - up contributions" be returned to you. If you are in more than one plan, you must decide which plan or arrangement you would like to return the excess. If you decid e that the excess should be distributed from this Plan, you must communicate this in writing to the Plan Administrator no later than the March 1st following the close of the calendar year in which such excess deferrals were made. However, if the entire dollar li mit is exceeded in this Plan or any other plan the Employer maintains, then you will be deemed to have notified the Plan Administrator of the excess. The Plan Administrator will then return the excess deferral and any earnings to you by April 15th. What are rollover contributions? Rollover contributions. Subject to the provisions of your investment arrangements and at the discretion of the Plan Administrator, if you are a Participant in the Plan, you might be permitted to deposit into the Plan distributions you have received from other plans and certain IRAs . Such a deposit is called a "rollover" contribution and might result in tax savings to you. You may ask the Plan Administrator of the other plan or the trustee or custodian of the IRA to directly transfer (a "direct rollover") to this Plan all or a portion of any amount that you are entitled to receive as a distribution from such plan. Alternatively, you may elect to deposit any amount eligible to be rol led over within 60 days of your receipt of the distribution. You should consult qualified counsel to determine if a rollover is in your best interest. Rollover account. Your rollover contribution will be accounted for in a "rollover account." You will alw ays be 100% vested in your "rollover account" (see the Article in this SPD entitled "Vesting"). Rollover contributions will be affected by any investment gains or losses. Withdrawal of rollover contributions. You may withdraw the amounts in your "rollover account" at any time. ARTICLE III EMPLOYER CONTRIBUTIONS This Article describes Employer contributions that will be made to the Plan and how your share of the contributions is determined. What is the Employer Matching Contribution and how is it allocated? Matching Contribution . Your Employer will make a Matching Contribution equal to 2% of your compensation provided your elective deferrals equal or exceed 2% of your compensation . Full Participants are immediately eligible and Matching Contribution s will generally be made for them within a reasonable period following your deferral (although the Plan permits contributions to be made at a later date). Important Notes : 1. Matches are made on a payroll period basis . To obtain the maximum match, defer at least 2% in every payroll period . There are no carryover credits if you skip deferring in one payroll period and contribute more in another. For example, If you contribute more than 2% in one payroll period and nothing in a later payroll period, you will only get a 2% match for the period when you contributed. T here is no carryover match for the period when you did not contribute . 2. Limited Participants would only receive a Match for a Plan Year if all the conditions described later in this A r ticle III are satisfied. Because of part - time and temporary schedules, it is unlikely that Limited Participants would receive Matches. What is the Employer Nonelective Contribution and how is it allocated? Nonelective Contribution . Each Plan Year , the Employer will make a N onelective C ontribution equal to 8 % of your compensation , even if you do not defer. Full Participants are immediately eligible and Nonelective Contribution s for them will generally be made within a reasonable period following each payroll period (although the Plan permits contributions to be made at a later dat e). Important Note: Limited Participants receive a Nonelective Contribution for a Plan Year if all the conditions described later in this Article III are satisfied. Because of part - time and temporary schedules, it is unlikely that Limited Participants w ill receive Nonelective Contribution s .

4 When can Limited Participants qualify for Employer Matching and Nonelective Contribution s? There may be occasional times when a Limited Participant works so many hours that it would be fair to credit Employer contrib utions. Foll owing each Plan Year, the Plan A dministrator will review the hours and service records of Limited Participants. For tho se who qualify, Employer Matching and Nonelective Contributions would be made af t er the Plan Y ear ends. To qualify for Employer contributions for a Plan Year, the Limited Participa nt must have satisfied ALL four of these conditions: : - completed one Year of Eligibility Service * on or before January 1 or July 1 of the Plan Year (a one - time requirement), and - credited with at least 1,000 hours in the Plan Year, and - employed on December 31 of the Plan Year , and - at least age 21 before a January 1 or July 1 entry date, if hired on or after June 1, 2022 . * For this purpose, a Year of Eligibility Service is an Eligibility Computation Period in which 1,000 Hours of Service is credited. Eligibility Computation Periods are the 12 months following the first Hour of Service and Plan Years starting after the first Hour of Service. Compensation and deferrals pri or to a qualifying Entry Date are not taken into account. If a Limited Participant qualifies for a Plan Year after meeting all these conditions, a Matching and Nonelective contributio n will be contributed to the A ccount , without interest, after the end of th e Plan Year. Important Note: If transferred from a Limited Participa n t Status position to a Full Participa n t position, or vice versa, the above requirements will continue to apply for but only with respect to periods when in Limited Participation Status. ARTICLE IV COMPENSATION AND ACCOUNT BALANCE What compensation is used to determine my Plan benefits? Compensation for calculating Elective D eferrals and Employer contributions is taxable base compensation only. Pay for overtime hours and bonuses is not taken into account. Stipends are disregarded, except for employees whose pay consists solely or most ly of stipends. Taxable non - cash compensation is disregarded. Adjustments to compensation. T he following adjustments to base compensation will be made : - Elective Deferrals to this Plan and to any other pre - tax plan or arrangement (such as salary reductions under a flexible benefits cafeteria plan or employee contributions for health insurance) will be included , even though not taxable . - C ompensation paid after you terminate is generally excluded . However, compensation that would have been considered compensation (like a final pay check) is counted, if paid within 2 1/2 months after you terminate employment, or if later, the last day of the Plan Year in which you terminate employment: Is there a limit on the amount of C ompensation which can be considered? The Plan, by law, cannot recognize annual compensation in excess of a certain dollar limit. The limit for the Plan Year begin ning in 2022 is $ 305,000 . After 2022, the dollar limit might increase for cost - of - living adjustments. Is there a limit on how much can be contributed to my account each year? The law imposes a limit on the amount of contributions (both Employer contributions and elective deferrals, but exclu ding Age 50 Catch - Up Deferrals) that may be made to your accounts during a year. For 2022, this total cannot exceed the lesser of $61,000 or 100% of your includible compensation (generally your compensation for the prior 12 - month period, as limited under t he previous question). After 2022, the dollar limit might increase for cost - of - living adjustments. The above limit may also need to be applied by taking into account contributions made to other retirement plans in which you are a participant. If you have more than 50% control of a corporation, partnership, and/or sole proprietorship, then the above limit is based on contributions made in this Plan as well as contributions made to any 403(b) or qualified plans maintained b y the businesses you c ontrol. If you control another business that maintains a plan in which you participate, then you are responsible for providing the Plan Administrator with information necessary to apply the annual contribution limits. If you fail to provide n ecessary and c orrect information to the Plan Administrator, it could result in adverse tax consequences to you, including the inability to exclude contributions to the Plan from your gross income for tax purposes. How is the money in the Plan invested? The Plan assets may be invested in mutual funds and Annuity Contracts. See the Plan Administrator for further details regarding permissible investments. You will be able to direct the investment of your Plan account , including your elective deferrals . The Plan Administrator will provide you with information on the investment choices available to you, the frequency with which you can change your investment choi ces and other information. If you do not direct the investme nt of your Plan account, then your account will be invested in accordance with

5 the default investment alternatives your Employer establishes under the Plan. These default investments will be made in accordance with specific rules under which the fiduciarie s of the Plan, including your Employer and the Plan Administrator, will be relieved of any legal liability for any losses resulting from the default investments. The Plan Administrator has or will provide you with a separate notice which details these defa ult investments and your right to switch out of the default investment if you so desire. The Plan is intended to comply with Section 404(c) of ERISA (the Employee Retirement Income Security Act). If the Plan compli es with this Section, then the fiduciarie s of the Plan, including your Employer and the Plan Administrator, will be relieved of any legal liability for any losses which are the direct and necessary result of the investment directions that you give. You must follo w procedures in giving investment directions. If you fail to do so, then your investment directions need not be followed. When you direct investments, your account is segregated for purposes of determining the earnings or losses on these investmen ts. Your account does not share in the inv estment performance for other Participants who have directed their own investments. You should remember that the amount of your benefits under the Plan will depend in part upon your choice of investments. Gain s as well as losses can occur and your Employe r and the Plan Administrator will not provide investment advice or guarantee the performance of any investment you choose. Periodically, you will receive a benefit statement that provides information on your account balance and your investment retu rns. It is your responsibility to notify the Plan Administrator of any errors you see on any statements within 30 days after the stateme nt is provided or made available to you. Will Plan expenses be deducted from my account balance? Expenses allocated to all accounts. Subject to the terms of the investment arrangements funding the plan, the Plan might pay some or all Plan related expenses except for a limited category of expenses which the law r equires your Employer to pay. The category of expenses which your Employer must pay are known as "settlor expenses." Generally, settlor expenses relate to the design, establishment or termination of the Plan. See the Plan Administrator for more details. Th e expenses charged to the Plan might be charged pro rata to each Participant in relation to the size of each Part icipant's account balance or might be charged equally to each Participant. In addi tion, some types of expenses might be charged only to some Pa rticipants based upon their use of a Plan feature or receipt of a Plan distributi on. Finally, the Plan might charge expenses in a different manner as to Participants who have terminated employment with your Employer versus those Participants who remain emp loyed with your Employer. Terminated employee. After you terminate employment, subject to the terms of the inves tment arrangements funding the P lan, your Employer reserves the right to charge your account for your pro rata share of the Plan's administration expenses, regardless of whether your Employer pays some of these expenses on behalf of current employees. Expenses allocated to individual accounts. There are certain other expenses that might be paid just from your account subject to the t erms of the investment arra ngements funding the P lan. These are expenses that are specifically incurred by, or attributable to, you. For example, if you are marrie d and get divorced, the Plan might incur additional expenses if a court mandates that a porti on of your account be paid to your ex - spous e. These additional expenses might be paid directly from your account (and not the accounts of other Participants) because they are directly attributable to you under the Plan. The Plan Administrator will inform y ou when there will be a charge (or charges) directly to your account. Your Employer might , from time to time, change the manner in which expenses are allocated. ARTICLE V VESTING What is my vested interest in my account? Most employees are 100% vested in their contributions and Employer contributions. “Vested” means that your account is not forfeitable. However, it remains subject to Plan rules and the poss ibility of investment loss. A special vesting rule has been added for Employees who are hired on or after June 1, 2022 . They will forfeit all Employer contribution accounts if they terminate employment prior to 15 months of employment and have a break in service. A break in service is 12 consecutive months of not bei ng an Employee . If a P articipant return s to service prior to 5 years of break in service (6 if a break was due to child birth or adoption) , forfeited amounts may be restored, but the rules for restoration are not included in this SPD. If you return to employment after a termination and forfeited amounts under this 15 month rule, be sure to ask the Plan Administrator for more information abou t the restoration rules and whether you qualify. Military Service. If you are a veteran and are reemployed under the Uniformed Services Employment and Reemployment Rights Act of 1994, your qualified military service might be considered service with your Employer. If you might be affected by this law, ask the Plan Administrator for further details.

6 A RTICLE VI DISTRIBUTIONS PRIOR TO TERMINATION OF EMPLOYMENT The Individual Agreements governing the investment options that you selected for your Plan contributions might contain additi onal limits on when you can take a distribution, the form of distribution that is avail able as well as your right to transfer among approved investment options . Please review both the following information in this Summary Plan Description and the terms of your annuity contracts or custodial agreements before requesting a distribution. Contact your Employer or the investment vendor if you hav e questions regarding your distribution options. Can I withdraw money from my account while working ? In - service distributions. You may be entitled to receive an in - service distribution. However, this distribution is not in addition to your other benefits and will therefore reduce the value of the benefits you will receive at retirement. This distribution is made at your election subject to possible administrative limitations on the frequency and actua l timing of such distributions. Conditions. Generally , you may receive a distribution from certain accounts , if vested, prior to termination of employment provided you satisfy any of the following conditions:  you have attained age 59 1/2. Satisfying this condition allows you to receive distributions from any of your accounts, whether from E lective D eferrals, Matching Contribution s, or Nonelective Contribution s .  you have incurred a financial hardship as described below , regardless of age. These withdrawals are only allowed from Elective Deferral Accounts. Restricted Amounts. There may be restrictions placed on distributions from certain account investments. Ask the Plan Administrator if you need further details. Qualified reservist distributions. If you: (i) are a reservist or National Guardsman; (ii) were/are called to active duty after September 11, 2001; and (iii) were/are called to duty for at least 180 days or for an indefinite period, you may take a distribu tion of your elective deferrals under the Plan while you are on active duty, regardless of your age. The 10% premature f ederal distribution penalty tax, normally applicable to Plan distributions made before you reach age 59 1/2, will not apply to the distr ibution. You also may repay the distribution to an IRA, without limiting amounts you otherwise could contribute to the IRA, provided you make the repayment w ithin 2 years following your completion of active duty. Distributions for deemed severance of empl oyment. If you are on active military duty for more than 30 days, then the Plan generally treats you as having severed employment for purposes of receiving a distribution from the Plan from elective deferrals . If you request a distribution on account of th is deemed severance of employment, then you are not permitted to make any contributions to the Plan for six (6) months after the date of the distribution. Withdrawal of rollover contributions . You may withdraw amounts in your "rollover account" at any time . Annuity waiver. If you wish to receive any in - service distribution from the Plan , you (and your spouse, if married) must first waive the annuity form of payment. If you are married, you must get written consent from your spouse to take a distribution from the Pl an in any form other than a qualified joint an d survivor annuity. Your spouse' s consent is also needed if you want to name someone other than your spouse as your beneficiary. The annuity would need to be structured to provide a benefit while you are both alive and th en to provide a survivor benefit that is equal to 50 percent of the a mount you received while you were both living. You can designate a different survivor percentage subject to certain limits under the qualified optional survivor annuity regulations. Your Emplo yer will provide you with more information regarding your annuit y options when it comes time for you to make a decision. Follow the procedures established by your E mployer to document your spouse' s consent to waive the annuity and take the payment in some other form permitted by the Plan. Your spouse must also consent to any Plan loans that you request. Can I withdraw money from my account in the event of financial hardship? Hardship distributions. You may withdraw money in your Elective Deferral Accounts (not your Employer Contribution accounts or Restricted Amounts ) due to financial hardship if you satisfy certain conditions , subject to any rules and conditions set forth in the investment arrangements . This hardship distribution is not in addition to your other benefits and will therefore reduce the value of the benefits you will receive upon termination of employment or other event entitling you to distribution of your account balance . Restricted Amounts. There are legal restrictions placed on hardship distributions from certain accounts (referred to as "Restricted Accounts"). Unless Congress changes the law , y ou can not take hardship distributions from earnings on E lective D eferrals. Qualifying expenses. A hardship distribution may be made to satisfy certain immediate and heavy financial needs that you have. A hardship distribution may only b e made for payment of the following:  Expenses for medical care (described in Section 213(d) of the Internal Revenue Code) for you, your spouse , your dependents or your beneficiary.  Costs directly related to the purchase of your principal residence (excluding mortgage payments).  Tuition, related educational fees, and room and board expenses for the next twelve (12) months of post - secondary education for you, your spouse, your children , your dependents or your beneficiary.

7  Amounts necessary to p revent your eviction from your principal residence or foreclosure on the mortgage of your principal residence.  Payments for burial or funeral expenses for your deceased parent, spouse, children , your dependents or your beneficiary.  Expenses for the r epair of damage to your principal residence (that would qualify for the casualty loss deduction under Internal Revenue Code ) without regard to the limit on casualty losses that are deductible for income tax purposes under IRC 165(h) .  Expenses for disast ers arising from federally declared disasters, such as your expenses and losses (including loss of income) attributable to that disaster, provided your principal residence or place of employment was in an area FEMA designate s as qualifying for individual a ssistance. Beneficiary Hardship. A beneficiary is someone you designate under the Plan to receive your death benefit who is not otherwise your spouse or dependent. Conditions. If you have any of the above expenses, a hardship distribution can only be mad e if you certify and agree that all of the following conditions are satisfied: (a) The distribution is not in excess of the amount of your immediate and heavy financial need. The amount of your immediate and heavy financial need may include any amounts necessary to pay any federal, state, or local income taxes or penalties reasonably anticipated to result from the distribution; and (b) You have obtained all distributions, other than hardship distributions , currently available under all plans that your E mployer maintains; and (c) You certify (via a form for that purpose) that you have insufficient cash or other liquid assets reasonably available to sati sfy the need. . Annuity waiver. If you wish to receive a hardship distribution from the Plan , you (and your spouse, if you are married) must first waive the annuity form of payment. (See the Article entitled "Benefits and Distributions Upon Terminat ion of Employment" for a further explanation of how benefits are paid from the Plan.) ARTICLE VII DISTRIBUTIONS UPON TERMINATION OF EMPLOYMENT To the extent permitted in the investment arrangements, the provisions in this Article apply to distributions from the Plan following termination of employment. When can I get money out of the Plan? You might be able to receive a distribution of the vested portion of some or all of your accounts in the Plan when you terminate employment with your Employer. The rules regarding the payment of death benefits to your beneficiary are described in the Art icle in this SPD entitl ed "Distributions upon Death." If you terminate employment, you will be entitled to a distribution within a reasonable time after your termination . You must consent to this distribution. (See the question "How will my benefits be paid?" for a further expl anation of how benefits are paid from the Plan.) Military Service. If you are a veteran and are reemployed under the Uniformed Services Employment and Reemployment Rights Act of 1994, your qualified military service may be considered service with your Emp loyer. There might also be benefits for employees who die or become disabled while on active duty. Employees who receive wage continuation payments while in the military may benefit from various changes in the law. If you think you may be affected by these rules, ask the Plan Administrator for further details. What is Normal Retirement Age and what is the significance of reaching Normal Retirement Age? Normal Retirement Age. Your Normal Retirement Age is the date you reach age 65 . Payment of benefits. You will become 100% vested in all of your accounts under the Plan (assuming you are not already fully vested) if you are employed on or after your Norm al Retirement Age. However, the actual payment of benefits generally will not begin until you have terminated employment. In such event, a distribution will be made, at your election, as soon as administrative ly feasible. If you remain employed past your N ormal Retirement Age, you may generally defer the receipt of benefits until you actually terminate employment. In such event, benefit payments will begin as soon as feasible at your request, but generally not later than age 70 1/2 . (See the question entitl ed "How will my benefits be paid to me?" for an explanation of how these benefits will be paid.) When am I considered to be disabled under the Plan ? Definition of disability. Under the Plan, disability is defined as the inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment that can be expected to result in death or which has lasted or can b e

8 expected to la st for a continuous period of not less than twelve months. The permanence and degree of such impairment must be supported by medical evidence . The Plan Administrator may require that your disability be determined by a licensed physician. How will my benef its be paid to me? The following provisions apply to the extent permitted under the i nvestment arrangements in which the plan assets are invested. Lump - sum distributions. If you terminate employment and your vested account balance does not exceed $5,000, then your vested account balance might only be distributed to you in a single lump - sum payment. Distribution methods. If you terminate employment and your vested account balance exceeds $5,000 (or another amount as provided in your investment arrangement) , then your vested account balance might be distributed to you under the following methods provided they are permitted under your investment arrangements :  a single lump - sum payment  instal lments over a period of not more than your assumed life expectancy (or the assumed life expectancies of you and your beneficiary)  an annuity contract that the Vendor provides or purchases with your vested account balance  ad - hoc distributions. You may request a distribution of some or all of your Plan accounts, at any time following your termination of employment, subject to any reasonable limits regarding timing and amounts as the Plan Administrator or your investment arrangements may impose. Require d beginning date. There are rules that require that certain minimum distributions be made from the Plan. Distributions are required to begin not later than the April 1st following the end of the year in which you reach age 70 1/2 or terminate employment, w hichever is later. You should see the Plan Ad ministrator if you think you might be affected by these rules. Mandatory annuity distribution (subject to waiver). Subject to the provisions of your investment arrangements, if you are married on the date your benefits are to begin, you will automatically receive a joint and 50% survivor annuity, unless you and your spouse waive the annuity and elect an alternative form of payment. This means that you will receive payments for your life, and afte r your death, yo ur surviving spouse will receive a monthly benefit for the remainder of his or her life equal to 50% of the benefit you were receiving at the time of your death. You may elect a joint and 75% survivor annuity instead of the standard joint and 50% survivor annuity. You should consult an advisor before making such election. If you are not married on the date your benefits are to begin, you will automatically receive a life annuity, unless you waiv e the qualified annuity and elect an alternative form of payme nt. This means you will receive payments for as long as you live. However, regardless of your marital status, if your vested account balance does not exceed $5,000, then, depending on the ter ms of your investment arrangement, your vested account balance might be distributed to you in a single lump - sum payment and you might not receive the qualified annuity. May I elect another distribution method? Waiver of annuity. If your vested benefit in the Plan exceeds $5,000, then when you are about to receive any distribution, the Plan Administrator will explain the joint and survivor annuity or the life annuity to you in greater detail. You will be given the option of waiving the joint and survivor annuity or the life annuity form of payment during the 180 - day period before the annuity is to begin. IF YOU ARE MARRIED , YOUR SPOUSE MUST IRREVOCABLY CONSENT IN WRITING TO THE WAIVER IN THE PRESENCE OF A NOTARY OR A PLAN REPRESENTATIVE. You may revoke any waiver. Th e Plan Administrator will provide you with forms to make these elections. Since your spouse participates in these elections, you must immediately inform the Plan Administrator of any change in your marital status. Other distribution method. If your vested account balance exceeds $5,000 and if you and your spouse elect not to take a joint and survivor annuity, or if you are not married when your benefits are scheduled to begin and have elected not to take a life ann uity, you may elect to rece ive distribution of your account balance under any alternative distribution method as described above. ARTICLE VIII DISTRIBUTIONS UPON DEATH What happens if I die while working for the Employer? If you die while still employed by the Employer, then your vested account balance will be used to provide your beneficiary with a death benefit. Who is the beneficiary of my deat h benefit? Married Participant. If you are married at the time of your death, your spouse will be the beneficiary of 50% of the death benefit distributed as a qualified annuity. Any remaining amount of your death benefit which is not payable to your spouse as a qualified

9 annuity will be paid to your beneficiary (which may be your spouse). You may designate a non - spouse beneficiary as to the portion of your account not payable as a qualified annuity wi thout your spouse's consent. IF YOU WISH TO WAIVE THE QUALIFIED ANNUITY BENEFIT, YOUR SPOUSE MUST IRREVOCABLY CONSENT TO WAIVE THE ANNUITY AND TO YOUR DESIGNATION OF ANY NON - SPOUSE BENEFICIARY. YOUR SPOUSE'S CONSENT MUST BE IN WRITING, BE WITNESSED BY A NO TARY OR A PLAN REPRESENTATIVE AND ACKNOWLEDGE THE SPECIFIC NON - SPOUSE BENEFICIARY. If you are married and you change your designation, then your spouse must again consent to the change. In addition, you may e lect a beneficiary other than your spouse witho ut your spouse's consent if your spouse cannot be located. Unmarried Participant. If you are not married, you may designate a beneficiary of your choosing. Divorce. If you have designated your spouse as your beneficiary for all or a part of your death be nefit, then upon your divorce, the designation is no longer valid. This means that if you do not select a new beneficiary after your divorce, then you are treat ed as not having a beneficiary for that portion of the death benefit (unless you have remarried, in which case the prior provisions of this section apply to your new spouse) . No beneficiary designation. Subject to the terms of the investment a rrangements, at the time of your death, if you have not designated a beneficiary or your beneficiary is not alive, then 50% of your death benefit will be paid to your surviving spouse and 50% will be paid to your estate. If you are unmarried or have no sur viving spouse, your entire death benefit will be paid to your estate. How will the death benefit be paid to my beneficiary? Mandatory annuity distribution (subject to waiver). If the death benefit does not exceed $5,000, then the benefit may only be paid as a lump - sum. If you are married at the time of your death and the death benefit exceeds $5,000, then the death benefit will be paid to your spouse in the form of a qualified annuity as described above under "Who is the beneficiary of my death benefit?", unless you and your spouse waive the qualified annuity. If the qualified annuity applies, the Plan will purchase, using 50% of your account, an annuity contract providing for p ayments over the life of your spouse. The size of the monthly payments will depend on the value of your vested account at the time of your death. Waiver of annuity. You and your spouse may waive the qualified annuity form of distribution. Generally, the p eriod during which you and your spouse may waive the annuity begins as of the first day of the Plan Year in which you reach age 35 and ends when you die. The Plan Administrator must provide you with a detailed explanation of the annuity. This explanation m ust generally be given to you during the period of time beginning on the first day of the Plan Year in which you will reach age 32 and ending on the first day of the Plan Year in which you reach age 35. It is important that you inform the Plan Administrato r when you reach age 32 so that you may receive this information. Under a special rule, you and your spouse may waive the survivor annuity form of payment any time before you turn age 35. However, any waiver will become invalid at the beginning of the Pla n Year in which you turn age 35, and you and your spouse will be required to make another waiver. Distribution method/annuity waived. If you and your spouse waive the qualified annuity, and the death benefit exceeds $5,000, the benefit may be paid to your spouse in the methods described above under "How will my benefits be paid to me?" provided the methods are permitted under your investment arrangements . When must payment s be made to my beneficiary (required minimum distributions)? If your designated beneficiary is a person (other than your estate or most trusts) then minimum distributions of your death b enefit must generally begin within one year of your death and must be paid over a period not extending beyond your beneficiary's life expectancy. If your spouse is the beneficiary, the start of payments may be delayed until the year in which you would have attained age 7 0 1/2. Generally, if you die before you are re quired to begin minimum distributions (which for most people is shortly after the later of age 70 1/2 or retirement) and your beneficiary is not a person, then your entire death benefit must be paid within five years after your death. Some investment produ cts may allow a person to use this five - year rule. See the Plan Administrator for further details. Since a spouse has certain rights in the death benefit, you should immediately report any change in your marital status to th e Plan Administrator. What hap pens if I terminate employment, commence required minimum distribution payments and then die before receiving all of my benefits? If you are married at the time of death, the form of payment will be a life annuity to your surviving spouse as described abo ve under "Mandatory annuity distribution (subject to waiver)," unless you and your spouse had waived the q ualified annuity. In the event you had waived the qualified annuity, your beneficiary will be entitled to your remaining vested interest in the Plan at the time of your death. See the Plan Administrator for more information regarding the timing and method of payments that apply to your beneficiary.

10 ARTICLE IX TAX TREATMENT OF DISTRIBUTIONS What are my tax consequences when I receive a distribution from the Plan? Generally, you must include any Plan distribution in your taxable income in the year in which you receive the distribution. T he tax treatment may also depend on your age when you receive th e distribution. Certain distributions made to you when you are under age 59 1/2 cou ld be subject to an additional f ederal 10% penalty tax. Qualified reservist distributions. If you: (i) are a reservist or National Guardsman; (ii) were/are called to active duty after September 11, 2001; and (iii) were/are called to duty for at least 180 days or for an indefinite period, you may take a distribution of your elective deferrals under the Plan while you are on active duty, regardless of your age. The 10% prematu re distribution f ederal penalty tax, normally applicable to Plan distributions made before you reach age 59 1/2, will not apply to the distribution. You also may repay the distribution to an IRA, without limiting amounts you otherwise could contribute to t he IRA, provided you make the repayment within 2 years following your completion of active duty. Can I elect a rollover to reduce or defer tax on my distribution? Rollover or D irect Transfer. You may reduce, or defer entirely, the tax due on your distribution through use of one of the following methods: (a) 60 - day rollover. You may roll over all or a portion of the distribution to an Individual Retirement Account or Annuity (IRA) or another employer retirement plan willing to accept the rollover. This will result in no tax being due until you begin withdra wing funds from the IRA or other qualified employer plan. The rollover of the distribution, however, MUST be made within strict time frames (normally, within 60 days after you receive your distribution). Under certain circumstances, all or a portion of a dis tribution (such a s a hardship distribution) may not qualify for this rollover treatment. In addition, most distributions will be subject to mandatory federal income tax withholding at a rate of 20%. This will reduce the amount you actually receive. For this reason, if you wish to roll over all or a portion of your distribution amount, then the direct rollover option described in paragraph (b) be low would be the better choice. (b) Direct rollover. For most distributions, you may request that a direct transfer (sometimes ref erred to as a direct rollover) of all or a portion of a distribution be made to either an Individual Retirement Account or Annuity (IRA) or another employer retirement plan willing to accept the transfer. A direct transfer will result in no tax being due u ntil you withdraw funds from the IRA or other employer plan. Like the 60 - day rollover, under certain circumstances all or a portion of the amount to be distributed may not qualify for this direct transfer. If you elect to actually receive the distribution rather than request a direct transfer, then in most cases 20% of the distribution amount will be withheld for federal income tax purposes. If you decide to directly transfer all or a portion of a distribution, you (and your spouse, if you are married) must first waive the qualified annuity form of payment. (See the question entitled "How will my benefits be paid to me?" for a further explanation of this waiver requirement.) Tax Notice. WHENEVER YOU RECEIVE A DISTRIBUTION THAT IS AN ELIGIBLE ROLLOVER DISTRI BUTION, THE PLAN ADMINISTRATOR WILL DELIVER TO YOU A MORE DETAILED EXPLANATION OF THESE OPTIONS. HOWEVER, THE RULES WHICH DETERMINE WHETHER YOU QUALIFY FOR FAVORABLE TAX TREATMENT ARE VERY COMPLEX. YOU SHOULD CONSULT WITH QUALIFIED TAX COUNSEL BEFORE MAKIN G A CHOICE. ARTICLE X LOANS Is it possible to borrow money from the Plan? Yes, it is possible to borrow money from the Plan. Loans are permitted in accordance with the Plan Loan Policy attached to this SPD and subject to the limitations o f your investment arrangements. ARTICLE XI PROTECTED BENEFITS AND CLAIMS PROCEDURES Are my benefits protected? As a general rule, your interest in your account, including your "vested interest," may not be alienated. This means that you r interest may not be sold, used as collateral for a loan (other than for a Plan loan) , given away or otherwise transferred (except at death to your beneficiary). In addition, your creditors (other than the IRS) may not attach, garnish or otherwise interfere with your benef its under the Plan. Are there any exceptions to the general rule? There are three exceptions to this general rule. The Plan Administrator must honor a qualified domestic relations order (QDRO ). A QDRO is defined as a decree or order issued by a court that obligates you to pay child support or alimony, or otherwise allocates a portion of your assets in the Plan to your spouse, former spouse, children or other dependents (referred to as alternate payees) . If a QDRO is received by the Plan Admini strator, all or a portion of your benefits may be used to satisfy that obligation. The Plan Administrator will determine the validity of any domestic relations order received. You and your beneficiaries can obtain fro m the Plan

11 Administrator, without charg e, a copy of the procedure used by the Plan Administrator to determine whether a qualified domestic relations order is valid. The second exception applies if you are involved with the Plan's operation. If you are found liable for any action that adver sely affects the Plan, the Plan Administrator can offset your benefits by the amount that you are ordered or required by a court to pay th e Plan. All or a portion of your benefits may be used to satisfy any such obligation to the Plan. The last exception appl ies to f ederal tax levies and judgments. The f ederal government is able to use your int erest in the Plan to enforce a f ederal tax levy and to collect a judgment resulting from an unpaid tax assessment. Can the Employer amend the Plan? Your Employer has the right to amend the Plan at any time. In no event, however, will any amendment authorize or permit any p art of the Plan assets to be used for purposes other than the exclusive benefit of Participants or their beneficiaries. Additionally, no amendment will cause any reduction in the amount credited to your account. What happens if the Plan is discontinued or terminated? Although your Employer intends to maintain the Plan indefinitely, your Employer reserves the right to terminate the Plan at any time. Upon termination, no further contributions will be made to the Plan and all amounts credited to your accounts will become 100% vested. Your Emplo yer will direct the distribution of your accounts in a manner permitted by the Plan as soon as practicable. You will be notified if the Plan is terminated. How do I submit a claim for Plan benefits? You may file a claim for benefits by submitting a written request for benefits to the Plan Administrator. You should contact the Plan Administrator to see if there is an applicable distribution form that must be used. If no specific form is required or ava ilable, then your written request for a distribution will be considered a claim for benefits. In the case of a claim for disability benefits, i f disability is determined by the Plan Administrator (rather than by a third party such as the Social Security Ad ministration), then you must also include with your claim sufficient evidence to enable the Plan Administrator to make a determination on whether you are disab led. Decisions on the claim will be made within a reasonable period of time appropriate to the c ircumstances. "Days" means calendar days. If the Plan Administrator determines the claim is valid, then you will receive a statement describing the amount of ben efit, the method or methods of payment, the timing of distributions and other information relev ant to the payment of the benefit. For purposes of the clai ms procedures described below, "you" refers to you, your authorized representative, or anyone else entitled to benefits under the Plan (such as a beneficiary). A document, record, or other informa tion will be considered relevant to a claim if it:  was relied upon in making the benefit determination;  was submitted, considered, or generated in the course of making the benefit determination, without regard to whether it was relied upon in making the benefit determination;  demonstrated compliance with the administrative processes and safeguards designed to ensure and to verify that benefit determinations are made in accordance with Plan documents and Plan provisions have been applied consistently with respect to all claimants; or  constituted a statement of policy or guidance with respect to the Plan concerning the denied treatment option or benefit. The Plan may offer additional voluntary appeal and/or mandatory arbitration procedu res other than those described below. If applicable, the Plan will not assert that you failed to exhaust administrative remedies for failure to use the voluntary proc edures, any statute of limitations or other defense based on timeliness is tolled during t he time a voluntary appeal is pending; and the voluntary process is available only after exhaustion of the appeals process described in this section. If mandatory arbitration is offe red by the Plan, the arbitration must be conducted instead of the appeal p rocess described in this section, and you are not precluded from challenging the decision under ERISA §501(a) or other applicable law. What if my benefits are denied? Your request for Plan benefits will be cons idered a claim for Plan benefits, and it will be subject to a full and fair review. If your claim is wholly or partially denied, the Plan Administrator will provide you with a written or electronic notification of the Plan's a dverse determination. This wri tten or electronic notification must be provided to you within a reasonable period of time, but not later than 90 days ( except as provided below for disability claims) after the receipt of your claim by the Plan Administrator, unless the Plan Administrator determines that special circumstances require an extension of time for processing your claim. If the Plan Administrator determines that an extension of time for processing is required, written notice of the extension will be furnished to you pri or to the termination of the initial 90 - day period. In no event will such extension exceed a period of 90 days from the end of such initial period. The extension notice will indicate the special circumstances requiring an extension of time and the date by which the Plan expects to render the benefit determination. In the case of a claim for disability benefits, if disability is determined by the Plan Administrator (rather than a third pa rty such as the Social Security Administration), then instead of the above, the initial claim must be resolved within 45 days of receipt by the Plan. A Plan may, however, extend this decision - making period for an additional 30 days for reasons beyond the control of the Plan. The Plan

12 will notify you of the extension prior to the end o f the 45 - day period. If, after extending the time period for a first period of 30 days, the Plan Administrator determines that it will still be unable, for reasons beyond the control of the Plan, to make a decision wi thin the extension period, the Plan may extend decision making for a second 30 - day period. Appropriate notice will be provided to you before the end of the first 45 days and again before the end of each succeeding 30 - day period. This notice will explain the circumstances requiring the extension and the date the Plan Administrator expects to render a decision. It will explain the standards on which entitlement to the benefits is based, the unresolved issues that prevent a decision, the additional issues that prevent a dec ision, and the additional information needed to resolve the issues. You will have 45 days from the date of receipt of the Plan Administrator’s notice to provide the information required. If the Plan Administrator determines that all or part of the claim should be denie d (an "adverse benefit determination" ), it will provide a notice of its decision in written or electronic form explaining your appeal rights. An “adverse benefit determination” also i ncludes a rescission, which is a retroactive cancellation or termination of ent itlement to disability benefits. The notice will be provided in a culturally and linguistically appropriate manner and will state: (a) The specific reason or reasons for the adverse determination. (b) Reference to the specific Plan provisions on which the determination is based. (c) A description of any additional material or information necessary for you to perfect the claim and an explanation of why such material or information is necessary. (d) A description of the Plan's review procedures and the time limits applicable to such procedures. This will include a statement of your right to bring a civil action under section 502(a) of ERISA following an adverse benefit determination on review. (e) In the case of a claim for disability benefits, if disab ility is determined by the Plan Administrator (rather than a third party such as the Social Security Administration, then the following additional information will be provided: (i) A discussion of the decision, including an explanation of the basis for di sagreeing with or not following:  The views you presented to the Plan of health care professionals treating the claimant and vocational professionals who evaluated you;  The views of medical or vocational experts whose advice was obtained on behalf of the Plan in connection with an adverse benefit determination, without regard to whether the advice was relied upon in making the benefit determination; or  A disability determination made by the Social Security Administration and presented by you to the Plan. (ii) Either the internal rules, guidelines, protocols, or other similar criteria relied up on to make a determination, or a statement that such rules, guidelines, protocols, or other criteria do not exist. (iii) If the adverse benefit determination is based on a medical necessity or experimental treatment and/or investigational treatment or similar exclusion or limit, an explanation of the scientific or clinical judgment for the determination, applyin g the terms of the Plan to your medical circumsta nces. If this is not practical, a statement will be included that such explanation will be provided to you free of charge, upon request. (iv) A statement that you are entitled to receive, upon request and free of charge, reasonable access to, and copies o f, all documents, records, and other information relevant to the claim. If your claim has been denied, and you want to submit your claim for review, you must follow the claims review procedure in t he next question. What is the claims review procedure? Upon the denial of your claim for benefits, you may file your claim for review, in writing, with the Plan Administrator. (a) YOU MUST FILE THE CLAIM FOR REVIEW NO LATER THAN 60 DAYS (EXCEPT AS PROVIDED BELOW FOR DISABILITY CLAIMS) AFTER YOU HAVE RECEIVED WRITTEN NOTIFICATION OF THE DENIAL OF YOUR CLAIM FOR BENEFITS. HOWEVER, IF YOUR CLAIM IS FOR DISABILITY BENEFITS AND DISABILITY IS DETERMINED BY THE PLAN ADMINISTRATOR (RATHER THAN A THIRD PARTY SUCH AS THE SOCIAL SECURITY ADMINISTRATION), THEN INSTEAD OF THE ABOVE, YOU MUST FILE THE CLAIM FOR REVIEW NOT LATER THAN 180 DAYS FOLLOWING RECEIPT OF NOTIFICATION OF AN ADVERSE BENEFIT DETERMINATION. IN THE CASE OF AN AD VERSE BENEFIT DETERMIN ATION REGARDING A RE SCISSION OF COVERAGE , YOU MUST REQUEST A REVIEW WITHIN 90 DA YS OF THE NOTICE. (b) You may submit written comments, documents, records, and other information relating to your claim for benefits. (c) You will be provided, upon request a nd free of charge, reasonable access to, and copies of, all documents, records, and other information relevant to your claim for benefits.

13 (d) Your claim for review must be given a full and fair review. This review will take into account all comments, doc uments, records, and other information submitted by you relating to your claim, without regard to whether such information was submit ted or considered in the initial benefit determination. In addition to the claims review procedure above, if your claim is for disability benefits and disability is determined by the Plan Administrator (rather than a third party such as the Social Security Administration), then: (a) Your claim will be reviewed without deference to the initial adverse benefit determination an d the review will be conducted by an appropriate named fiduciary of the Plan who is neither the individual who made the adverse benefit determination that i s the subject of the appeal, nor the subordinate of such individual. (b) If the initial adverse ben efit determination was based on a medical judgment, including determinations with regard to whether a particular treatment, drug, or other item is experimental, investigational, or not medically necessary or appropria te, the fiduciary will consult with a h ealth care professional who was neither involved in or subordinate to the person who made the original benefit determination. This health care professional will have appropriate training and experience in the field of m edicine involved in the medical judgm ent. Additionally, medical or vocational experts whose advice was obtained on behalf of the Plan in connection with the initial determination will be identified. (c) Any medical or vocational experts whose advice was obtained on behalf of the Plan in conn ection with your adverse benefit determination will be identified, without regard to whether the advice was relied upon in making the benefit determination. (d) If the Plan considers, relies upon or creates any new or additional evidence during the review of the adverse benefit determination, the Plan will provide such new or additional evidence to you, free of charge, as soon as possible and sufficie ntly in advance of the time within which a determination on review is required to allow you time to respond . (e) Before the Plan issues an adverse benefit determination on review that is based on a new or additional rationale, the Plan Administrator must provide you with a copy of the rationale at no cost to you. The rationale must be provided as soon as poss i ble and sufficiently in advance of the time within which a final determination on appeal is required to allow you time to respond . The Plan Administrator will provide you with written or electronic notification of the Plan's benefit determination on revie w. The Plan Administrator must provide you with notification of this denial within 60 days (45 days with respect to claims relating to th e determination of disability benefits) after the Plan Administrator's receipt of your written claim for review, unless the Plan Administrator determines that special circumstances require an extension of time for processing your claim. In such a case, you will be not ified, before the end of the initial review period, of the special circumstances requiring the extension an d the date a decision is expected. If an extension is provided, the Plan Administrator must notify you of the determination on review no later than 120 days (or 90 days with respect to claims relating to the determination of disability benefits) . The Plan Administrator will provide written or electronic notification to you in a culturally and linguistically appropriate manner. I f the initial adverse benefit determination is upheld on review, the notice will include: (a) The specific reason or reasons for the adverse determination. (b) Reference to the specific Plan provisions on which the benefit determination was based. (c) A statement that you are entitled to receive, upon request and free of charge, reasonable access to, and copies of, all documents, records, and other information relevant to your claim for benefits. (d) In the case of a claim for disability benefits, if disability is determined by the Plan Administrator (rather than a third pa rty such as the Social Security Administration): (i) Either the specific internal rules, guidelines, protocols, or other similar criteria relied upon to make the determination, o r a statement that such rules, guidelines, protocols, or criteria do not exist. (ii) If the adverse benefit determination is based on a medical necessity or experimental treatment and/or investigational treatment or similar exclusion or limit, an explanation of the scientific or clinical judgment for the determination, applyin g the terms of the Plan to your medical circumstances. If this is not practical, a statement will be included that such explanation will be provided to you free of charge, upon request. (iii) A statement of your right to bring a civil action under section 502(a) of ERISA and, if the Plan imposes a contractual limitations period that applies to your right to bring such an action, a statement to that effect which includes the calendar date on which such limitation expires on the claim. If the Plan offers voluntary appeal procedures, a description of those proced ures and your right to obtain sufficient information about those procedures upon request to enable you to make an informed decision about whether to submit to such voluntary appeal. These procedures will include a description of your right to representatio n, the process for selecting the decision maker and the circumstances, if any, that may affect the impartiality of the decision maker. No fees or costs wi ll be imposed on you as part of the voluntary appeal. A decision whether to use the voluntary appeal p rocess will have no effect on your rights to any other Plan benefits.

14 (iv) A discussion of the decision, including an explanation of the basis for disagreeing with or not following:  the views presented by the claimant to the Plan of health care profess ionals treating you and vocational professionals who evaluated you;  the views of medical or vocational experts whose advice was obtained on behalf of the Plan in connection with an adverse benefit determination, without regard to whether the advice was relied upon in making the benefit determination; or  a disability determination made by the Social Security Administration and presented by you to the Plan. If you have a claim for benefits which is denied, then you may file suit in a state or federal c ourt. However, in order to do so, you must file the suit no later than 180 days after the date of the Plan Administrator's final determination denying your claim. What are my rights as a Plan Participant? As a Participant in the Plan you are entitled to certain rights and protections under the Employee Retirement Income Security Act of 1974 (ERISA). ERISA provides that all Plan Participants are entitled to: (a) Examine, without charge, at the Plan Adm inistrator's office and at other specified locations, all documents governing the Plan, including collective bargaining agreements and insurance contracts, if any, and a copy of the latest annual report (For m 5500 Series) filed by the Plan with the U.S. De partment of Labor and available at the Public Disclosure Room of the Employee Benefits Security Administration. (b) Obtain, upon written request to the Plan Administrator, copies of documents governing the operation of the Plan, including collective bargaining agreements and insurance contracts, if any, and copies of the latest annual report (Form 5500 Series) and updated Summary Plan Description. The Plan Administrator may make a reasonable charge for the copies. (c) Receive a summary of the Plan's annual financial report. The Plan Administrator is required by law to furnish each Participant with a copy of this summary annual report. In addition to creating rights for Plan Participants, ERISA imposes duties upon the people who are responsible for th e operation of the Plan. The people who operate your Plan, called "fiduciaries" of the Plan, have a duty to do so prudently and in the interest of you and other Plan Participants and beneficiaries. No one, including your Employer or any other person, may f ire you or otherwise discriminate against you in any way to prevent you from obtaining a pension benefit or exercising your rights under ERISA. If your claim for a pension benefit is denied or ignored, in whole or in part, you have a right to know why thi s was done, to obtain copies of documents relating to the decision without charge, and to appeal any denial, all within certain time schedules. Under ERISA, there are steps you can take to enforce the above rights. For instance, if you request a copy of Plan documents or the latest annual report from the Plan and do not receive them within 3 0 days, you may file suit in a f ederal court. In such a case, the court may require the Plan Administrator to provide the materials and pay you up to $110 a day until you receive the materials, unless the materials were not sent because of reasons beyond the control of the Plan Administrator. If you have a claim for benefits which is denied or ignored, in whole or in part, y ou may file suit in a state or f ederal court. In addition, if you disagree with the Plan's decision or lack thereof concerning the qualified status of a domestic relations order or a medi cal child suppo rt order, you may file suit in f ederal court. You and your beneficiaries can obtain, without charge , a copy of the Plan's QDRO procedures from the Plan Administrator. If it should happen that the Plan's fiduciaries misuse the Plan's money, or if you are discriminated against for asserting yo ur rights, you may seek assistance from the U.S. Department of La bor, or you may file suit in a f ederal court. The court will decide who should pay court costs and legal fees. If you are successful, the court may order the person you have sued to pay these costs and fe es. If you lose, the court may order you to pay t hese costs and fees, for example, it finds your claim is frivolous. What can I do if I have questions or my rights are violated? If you have any questions about the Plan, you should contact the Plan Administrator. If you have any questions about this statement or about your rights under ERISA, or if you need assistance in obtaining documents from the Plan Administrator, you should co ntact the nearest office of the Employee Benefits S ecurity Administration, U.S. Department of Labor, listed in the telephone directory or the Division of Technical Assistance and Inquiries, Employee Benefits Security Administration, U.S. Department of Labor, 200 Constitution Avenue, N.W., Washington, D.C. 20210. You may also obtain certain publications about your rights and responsibilities under ERISA by calling the publications hotline of the Employee Benefits Security Administration. ARTICLE XII GENERAL INFORMATION ABOUT THE PLAN There is certain general information which you may need to know about the Plan. This information has been summarized for you in this Article.

15 Plan Name The full name of the Plan is Buckingham Browne & Nichols School DC Retirement Plan . Plan Number The Employer has assigned Plan Number 001 to your Plan. Plan Effective Dates This Plan was originally effective on January 1, 1976 . The amended and restated provisions of the Plan become effective on June 1, 2022. Other Plan Information Plan Year. The Plan's records are maintained on a twelve - month period of time. This is known as the Plan Year. The Plan Year ends on December 31st . The Plan will be governed by the laws of the state of the Employer's principal place of business to the extent not governed by federal law. Benefits provided by th e Plan are NOT insured by the Pension Benefit Guaranty Corporation (PBGC) under Title IV of the Employee Retirement Income Security Act of 1974 because the insurance provisions under ERISA are not applicable to this type of Plan. Service of legal process may be made upon the Employer. Service of legal process may also be made upon the Employer's chief executive officer or Plan Administrator. Employer Information The Employer's name, address , business telephone number and identification number are: Buckingham Browne & Nichols School 80 Gerrys Landing Road Cambridge , Massachusetts 02138 - 5595 617 - 800 - 2781 04 - 2103751 Plan Administrator Information The Plan Administrator is responsible for the day - to - day administration and operation of the Plan. For example, the Plan Administrator maintains the Plan records, including your account information, provides you with the forms you need to complete for Plan participation, and direct s the payment of your account at the appropriate time. The Plan Administrator will also allow you to review the formal Plan document and certain other materials related to the Plan. If you have any questions about the Plan or your participation, you should contact the Plan Administrator. The Plan Administrator may designate other parties to perform some duties of the Plan Administrator, and some duties are the responsibility of the investment provider(s) to the Plan. The Plan Administrator has the complete power, in its sole discretion, to determine all questions arising in connection with the administration, interpretation, and application of the Plan (and any related documents and underlying policies). Any such determination by the Plan Administrator is c onclusive and binding upon all persons. The name , address and business telephone number of the Plan's Administrator are: Contact: Buckingham Browne & Nichols School Address: 80 Gerrys Landing Road Cambridge, Massachusetts 02138 - 5595 Telephone: 617 - 800 - 2781

1 APPENDIX PLAN LOAN POLICY To the extent permitted by the Investment Arrangements in which the Plan assets are invested, Buckingham Browne & Nichols School DC Retirement Plan permits loans to be made to Participants pursuant to a written loan policy. All references to Participants in this loan policy include Participants and their Beneficiaries or any alternate payee with respect to the Plan provided that t he borrower must qua lify as a "party in interest" as defined by ERISA Section 3(14). All current employees of the Employer and certain former Employees qualify as parties in interest. The Individual Agreements governing the investment options that you selected for your Plan c ontributions may contain additional limits on when you can take a loan. Please review both the following information in this Loan Policy and your annuity contracts or custodial agreements before requesting a loan. Contact your Employer or the investment v e ndor if you have questions regarding your loan options. The Plan Administrator is authorized to administer the Participant loan policy. All applications for loans will be made by a Participant to the Plan Administrator (or the Plan Administrator's delegat e) on forms which the Plan Administrator will make available for such purpose. 1 . LOAN APPLICATION/BORROWER QUALIFICATION  Loans are available to Participants on a reasonably equivalent basis. However, if you terminate employment, you will generally not be entitled to obtain a loan. A Participant must apply for each loan with an application which specifies the amount of the loan desired and the requested duration for the loan. The Plan Administrator may request additional information before approving a l oan.  All loan applications will be considered by the Plan Administrator within a reasonable time after the Participant makes forma l application.  The loan will be treated as a directed investment of the borrower's Account. 2 . LOAN LIMITATIONS. With regard to any loan made pursuant to this loan policy, the following rule(s) and limitation(s) will apply, in addition to such other requirements set forth in the Plan:  Loans to a Participant will not be approved in an amount which exceeds 50% of his or her nonforfeitable account balance. The maximum aggregate dollar amount of loans outstanding to any Participant may not exceed $50,000, reduced by the excess of the Participant's highest outstanding Participant loan balance during the 12 - month period endin g on the date of the loan over the Participant's current outstanding Participant loan balance on the date of the loan. Loans from a TIAA Annuity other than an RPL loan are further limited to: (a) 45% of the combined accumulation s attributable to the fund ing vehicle(s) under your retirement p lan; or (b) 90% of the CREF and TIAA Real Estate accumulation attributable to participation under this Plan for Retirement Loan (RL) loans, or (c) 90% of your TIAA Annuity accumulation attributable to participation u nder this Plan for a Group Supplemental Retirement Annuity (GSRA) loan.  No loan in an amount less than $1,000 will be granted to any Participant for any single loan.  A Participant can have 3 loan(s) currently outstanding from the Plan. However, if this loan limitation exceeds three, and your loan is an RPL loan, you may not have more than three loans at any one time.  Loan refinancing is not permitted. 3 . ACCOUNT RESTRICTIONS. With regard to loans made pursuant to this loan policy (s ubject to the investment arrangements), the following rules apply:  Loans may only be made from accounts attributable to:  Pre - tax Elective Deferrals  Rollovers from other plans 4 . EVIDENCE AND TERMS OF LOAN. The Plan Administrator will document every loan in the form of a promissory note signed by the Participant for the face amount of the loan, according to the following:  Any loan granted or renewed under this policy will bear a reasonable rate of interest.

2 The interest rate will be fixed fo r the duration of the loan. However, with respect to amounts invested with TIAA, the interest rate for your loan will vary, as described below, depending upon how your retirement balance is invested.  Group Supplemental Retirement Unit - Annuity (GSRA) contract - The interest rate is variable and can increase or decrease every three months. The interest rate you pay initially will be the higher of (1) the Moody's Corporate Bond Yield Average for the calendar month ending two months before your loan is is sued; or (2) the interest rate credited before your annuity starting date, as stated in the applicable rate schedule, plus 1 percent. Thereafter, the rate may change quarterly, but only if the new rate differs from your current rate by at least 1/2 percent .  Retirement Loan (RL) contract - For all Employers except those located in Arkansas, Hawaii, or New Jersey, the interest rate you pay initially will be the higher of (1) the Moody's Corporate Bond Yield Average for the calendar month ending two months before your loan is issued; or (2) the interest credited before your annuity starting date, as stated in the applicable rate schedule, plus 1 percent. Thereafter the rate will change annually, but only if the Moody's Corporate Bond Yield Average for the ca lendar month ending two months before the anniversary of your loan differs from your current rate by at least a 1/2 percent. If the latest average differs by less, your interest rate will remain the same for the next year. For Employers located in Arkansas , Hawaii, or New Jersey, the interest rate will be a fixed rate of 8 percent.  Retirement Plan Loans from mutual funds or annuity contract (RPL) - The interest rate will be fixed for the term of the loan and will be equal to the Federal Reserve Board Ban k prime loan rate plus 1 percent at the time of the loan origination.  The loan must provide at least quarterly payments under a level amortization schedule. If you are currently employed by the Employer, the Plan Administrator will require you to enter into either a payroll deduction or an ACH agreement or other repayment method agreed to by the investment arrangement to repay the loan.  The Plan Administrator will fix the term for rep ayment of any loan; however, in no instance may the term of repaymen t be greater than five years , unless the loan qualifies as a home loan . A "home loan" is a loan used to acquire a dwelling unit which, within a reasonable time, you will use as a principal residence. The term for a home loan will be no more than 10 years.  There might be a charge to your Account for expenses, if any, directly related to the loan set up, annual maintenance, administrative charges, and collection of the note.  A loan, if not otherwise due and payable , might be due and payable on your date of termination of employment with the Employer as stated in the promissory note unless directly rolled over (if otherwise permitt ed) to another employer's plan.  A loan, if not otherwise due and payable, is due and payable on termination of the Plan, notwithstanding any contrary provision in the promissory note. Nothing in this loan policy restricts your Employer's right to terminate the Plan at any ti me. You should note that the law treats the amount of any loan (other than a "home loan") not repaid five years after the date of the loan as a taxable distribution on the last da y of the five - year period or, if sooner, at the time the loan is in default. 5 . SECURITY FOR LOAN. The Plan will require that you provide security before a loan is granted. For this purpose, the Plan will consider your interest under the Plan (account balances) to be adequate security. However, in no event will more than 50% of your vested interest in the Plan (determined immediately after origination of the loan) be used as secu rity for the loan. Generally, it will be the policy of the Plan not to make loans which require security other than your vested interest in the Plan. However, if addi tional security is necessary to adequately secure the loan, then the Plan Administrator wi ll require that such security be provided before the loan will be granted. 6 . FORM OF PLEDGE. The pledge and assignment of your account balances will be in the form prescribed by the Plan Administrator. 7 . LEAVE OF ABSENCE/SUSPENSION OF PAYMENT. The Plan Administrator will suspend loan repayments for the period of a military leave of absence. 8 . PAYMENTS AFTER LEAVE OF ABSENCE. When payments resume following a payment suspension in connection with a leave of absence authorized above , if applicable, you m ust select one of the following methods to repay the loan, to the extent permitted by the investment provider, plus accumulated interest :  You will increase the amount of the required installments to an amount sufficient to amortize the remaining balance of the loan, plus accrued interest, over the remaining term of the loan.  You will pay a balloon payment of the remaining unpaid principal and interest, at the conclusion of the term of the loan as determined in the promissory note.  You may extend th e maturity of the loan and re - amortize the payments over the remaining term of the loan. In no event will the amount of the adjusted installment payment be less than the amount of the installment payment provided under the promissory note. The revised term of the loan will not exceed the maximum term permitted above, augmented by the time you were in United States military service.

3 9 . DEFAULT. The Plan Administrator will treat a loan as in default if:  any scheduled payment remains unpaid beyond the last day of the calendar quarter following the calendar quarter in which the Participant missed the scheduled payment Upon default, you will have the opportunity to repay the loan, resume current status of the loan by paying any missed payment plus interest o r, if distribution is available under the Plan and investment arrangements, request distribution of the note. If the loan rem ains in default, the Plan Administrator will offset your vested account balances by the outstanding balance of the loan to the ext e nt permitted by law. The Plan Administrator will treat the note as repaid to the extent of any permissible offset. Pending final disposition of the note, you remain obligated for any unpaid principal and accrued interest.