INVESTMENT PHILOSOPHY

Freedom One Investment Advisors serves as a co-fiduciary to retirement plans with respect to plan investments.  As such, we are subject to the guidelines established by ERISA in carrying out our fiduciary duties.  We serve plan sponsors by accepting certain fiduciary responsibilities that will ensure they they will meet these fiduciary responsibilities.  We make every effort to ensure that this is done in a  transparent manner emphasizing a regular, thorough, and well-documented due diligence process.  In this way, plan sponsors can maintain a level of comfort they they are acting in accordance with the Department of Labor's standards, as spelled out in the department's publication, "Meeting Your Fiduciary Responsibilities."

We also have an obligation to each plan participant, which is summarized as follows:

Our goal is to create an opportunity for plan participants to make well informed and suitable investment decisions that will enable them to meet their retirement objectives.

To accomplish the objective stated above, we believe that it is fundamental to have a well established investment strategy that is well documented and subject to ongoing review to ensure a high level of confidence that the following guidelines will be met:

• Diversification of asset classes so as to minimize the risk of substantial losses
• Valuation of various investment categories in a consistent manner to increase the probability of optimal allocation across alternative investment categories
• Implementation of risk management controls to reduce the possibility of negative surprises within the investment groups or the money managers who are responsible for the investments
• Availability of suitable investment options for investors with different levels of risk tolerance