W. W. GRAINGER, INC. RETIREMENT SAVINGS PLAN

Age/service weighted plan where allocations are based on age service or age and service; or new comparability or similar plan where allocations are based on participant classifications consisting entirely or predominantly of highly compensated employees or the plan provides an additional allocation rate on compensation above a specified threshold that exceeds the permitted disparity limits of Code section 401(l).

Profit-sharing 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.

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

Plan sponsor(s) received services of leased employees as defined in Code section 414(n) during the plan year.

Plan sponsor(s) is (are) a member(s) of a controlled group (Code sections 414(b) (c) or (m)).

U.S.-based plan that covers residents of Puerto Rico and is qualified under both Code section 401 and section 1165 of the Internal Revenue Code of Puerto Rico.