COE-BROWN NORTHWOOD ACADEMY TAX-DEFERRED ANNUITY PLAN

This plan or any part of it is intended to meet the conditions of 29 CFR 2550.404c-1 (shifting investment responsibility to participants).

Participants have the opportunity to direct the investment of all of the assets allocated to their individual accounts regardless of whether 29 CFR 2550.404c-1 is intended to be met.

Employee contributions are allocated to separate accounts under the plan or employer contributions are based in whole or in part on employee deferrals or contributions to the plan. Not applicable to 401(k) plans with only QNECs and/or QMACs or to 403(b)(1) 403(b)(7) or 408 arrangements.

Plan uses a Code section 403(b)(1) annuity contract as a funding vehicle.

Plan uses Code section 403(b)(7) custodial accounts as a funding vehicle.

Total or partial participant-directed account plan where plan uses a default investment account for participants who fail to direct assets in their account.