3-RFQ Sec4b. ACT Investment Policy 2025.pdf

Exhibit 1

403(b) Retirement Plan Investment Policy Statement

February 26, 2025

(I) INTRODUCTION

The Agency for Community Transit 403(b) Retirement Plan (“Plan”) was established for the benefit of eligible employees of Agency for Community Transit. The purpose of the Plan is to provide retirement benefits to participants and their beneficiaries, through employer and participant contributions and earnings thereon. OneAmerica is the Third-Party Administrator (TPA) of the plan.

The Agency for Community Transit Investment Committee (“Committee”) is empowered to establish guidelines and make decisions concerning the investment choices offered in the Plan.

(II) PURPOSE OF INVESTMENT POLICY STATEMENT

The purpose of this Investment Policy Statement (“Statement”) is to establish objectives for management of the assets of the Plan. This Statement:

(1) Provides written documentation of the Committee’s expectations regarding the Plan’s total investment program.

(2) Establishes objectives and guidelines for selecting the asset classes and investment options available in the Plan.

(3) Outlines criteria and procedures for the ongoing evaluation of the investment options and the total investment program.

This Statement is intended to be dynamic in nature and will be updated and revised as circumstances change. The Statement has been established by the Committee to guide its decisions with respect to assets held in the trust established pursuant to the Plan to comply with the Committee’s responsibility under the Plan to act with prudence and solely in the interest of participants and their beneficiaries as required by ERISA. The Committee will, absent circumstances deemed appropriate by the Committee for a deviation from the guidelines of the Statement, follow the guidelines of the Statement with respect to the investment of Plan assets.

In deviating from the guidelines of the Statement, the Committee will not be required to take formal action, but it will document the reasons for its deviation from the Statement guidelines in a particular instance.

(III) INVESTMENT OBJECTIVES AND GUIDELINES

A) ERISA Section 404(c)

The Plan is an ERISA Section 404(c) plan, which provides Plan participants with the ability to exercise control over the investment of the Plan assets allocated to their own accounts. The Committee is charged with the responsibility of selecting the investment funds offered to participants and establishing investment procedures. In general, the investments must be prudent, diversified to minimize the risk of large losses, and for the exclusive benefit of the Plan’s participants. Accordingly, to the extent that procedures consistent with Section 404(c) of ERISA are established and followed, the fiduciaries will be partially relieved of fiduciary responsibility under Section 404(c) of ERISA, including responsibility for investment decisions made by Plan participants.

Specifically, the Plan intends to:

(1) offer at least 3 investment options, each of which is diversified and has materially different risk and return characteristics.

(2) provide participants (and, as applicable, beneficiaries) the opportunity to direct the investment of their account balances in and between the investment options on at least a quarterly basis and more frequently to the extent necessary to comply with ERISA Section 404(c); and

(3) provide participants (and, as applicable, beneficiaries) sufficient information, without providing "investment advice," to allow them to make informed decisions regarding investment of their account balances in the options provided, consistent with their personal risk and return criteria.

The Committee recognizes its responsibility to select and monitor, in a reasonable manner, the asset classes and the related investment options made available to participants and beneficiaries. Consequently, the Committee hereby establishes investment objectives and other criteria as guidelines for selecting and monitoring these classes and options.

B) Criteria for Selection of Asset Classes

The Committee may retain an Investment Consultant to assist it in carrying out its responsibilities regarding selection of asset classes for investment options under the Plan.

Cook Street Consulting is the Investment Consultant under this Investment Policy. The Committee will consider and select classes of investment options (the “asset classes”) and the specific option or options (the “investment options”) within each asset class, to be offered to participants and beneficiaries.

In selecting the asset classes, the Committee will consider asset classes reasonably designed to further the purposes of the Plan, taking into account:

(1) The risk of loss and opportunity for gain associated with the asset classes, both objectively and in light of the range of risk tolerance participants (and, as applicable, beneficiaries) are likely to want or need, taking into account the correlation of the various asset classes and the time horizon over which participants (and, as applicable, beneficiaries) are likely to have their account balances invested; and appropriate for participants at various ages;

(2) The composition of the available asset classes with regard to participants' (and, as applicable, beneficiaries') opportunity to meet their investment objectives without exceeding their risk tolerance; and

(3) The composition of the available asset classes with regard to participants' (and, as applicable, beneficiaries') opportunity to achieve diversification (with respect to asset class and investment style).

The current asset classes and corresponding investment options selected by the Committee are attached as Appendix A. The Committee may add, delete or change asset classes and investment options at any time, in its discretion. However, in no event will the following asset classes be selected: precious metals funds, illiquid funds, funds that primarily use commodities or futures contracts, sector funds, or any other asset class not deemed appropriate by the Committee. Notwithstanding the foregoing, appropriately limited amounts of these securities may, where appropriate, be held by investment funds selected as investment options under one or more asset classes.

C) Criteria For Selection of Investment Options

The Committee may evaluate Investment Options based on a range of criteria. Examples of criteria it may consider include:

(1) regulatory oversight: is the Investment Option a regulated bank, an insurance company, a mutual fund organization, a registered investment advisor, or something else?

(2) longevity: when was the Investment Option’s composite inception date?

(3) assets under management: what are the Investment Option’s composite assets under management?

(4) correlation to asset class and/or peer group: is the Investment Option correlated to the asset class with respect to which it is designated?

(5) performance relative to a peer group: how does the Investment Option’s performance compare against the peer group’s median fund manager return for appropriate trailing periods?

(6) performance relative to exhibited risk: how does the Investment Option’s risk-adjusted performance (Alpha and/or Sharpe Ratio) compare to the peer group’s risk-adjusted performance?

(7) tracking error: if an Investment Option’s primary purpose is to track an index (i.e. a "passive" investment), how does its tracking error compare over appropriate trailing periods?

(8) holdings consistent with style: for Investment Options other than multiple asset class options like balanced funds, managed accounts, or target retirement funds, what percent of the assets are allocated to unrelated asset class securities?

(9) expense ratios/fees: what is the Investment Option’s expense ratio and performance net of fees (as compared to peer investments)?

(10) stability of the organization and respective management team: are there substantive organizational concerns of any kind?

(11) administrative constraints: are there any recordkeeping administration concerns?

In addition, in selecting investment options, such funds shall be compared with appropriate market indexes and peer groups, with respect to one or more of the considerations listed above (e.g., returns over specified periods of time, expense ratios and other fees, etc.). The

Committee may select one or more investment options with respect to each asset class and will not be required to select the same number of investment options with respect to any two or more asset classes.

The Committee may select an investment or multiple investments within an asset class (such as target retirement funds, asset allocation funds, and/or managed accounts) based on pertinent criteria (which may include the factors described above) and any other factors, including, but not limited to, generally accepted investment theories and prevailing investment industry practices.

The Committee may consider any applicable revenue sharing fees (12b-1, sub-TA, etc.)

generated by each Investment Option and the availability of alternative share classes and/or investment vehicles (collective investment trusts, etc.) as part of its selection process.

D) Default Investment Option for Participants’ Contributions

The specific mutual fund used as an Investment Option for the Age-Appropriate Target Date Fund as shown in Appendix A will be the Qualified Default Investment Alternative “QDIA” for participants who fail to make an investment election.

(IV) ASSET CLASS AND INVESTMENT OPTION MONITORING

No less frequently than annually, the Committee will review the continued suitability of the classes, and the overall performance of the investment options. As part of this review process, the Committee shall prepare or cause to be prepared a Performance Monitoring Report, which shall review the performance of the investment options in light of the criteria set out in this Statement. The purpose of this report is to satisfy the Committee's obligation to continually perform due diligence on the Plan's investments.

The Committee shall also review the suitability of an investment option upon a change in the fund's management or a perceived or announced change in investment style.

Watchlist status may be considered relative to the aforementioned Investment Option selection criteria detailed in Section III.

The Committee shall have the right to eliminate and, as appropriate, replace any investment option that ceases to be suitable based upon the criteria set out in this Statement. The Committee may add additional investment options, as it deems appropriate in its discretion.

(V) DISSEMINATION OF INFORMATION AND INVESTMENT EDUCATION

The Committee intends to provide or cause to be provided to participants and beneficiaries information to enable them to make informed decisions regarding investment of their account balances in the investment options provided, consistent with their personal risk and return criteria. However, the ultimate investment decision shall be made by the participants. Stifel is the financial advisor to participants in the plan under this Investment Policy.

(VI) CONFLICTS OF INTEREST

A member of the Committee shall disclose, to the extent the member has, or reasonably may be expected to be aware of, any relationship involving the member, the member’s family or a business or work relationship, that directly or indirectly may constitute a conflict or potential conflict of interest or prohibited transaction in connection with a matter pending before the Committee, or within the scope of its authority, including:

(1) appointing or renewing the appointment of an investment option or other vendor providing fiduciary or other services to the Plan;

(2) a matter involving a Plan account or a benefit under the Plan; or

(3) the selection and continuation of an investment option.

An interested member shall be recused from the Committee meeting while such a matter is discussed and voted upon. He or she may not vote on the issue to which a conflict of interest relates but may be counted in determining the presence of a quorum for purposes of the vote.

(VII) PROXY VOTING AND EXERCISING SHAREHOLDER RIGHTS

The Committee delegates to the designated Investment Option manager the authority to cast proxy votes and exercise all rights appurtenant to individual securities within an Investment Option, in accordance with ERISA. If the Plan participates in pooled investment vehicles ("Pools") that have specific proxy voting guidelines, the Committee maintains its fiduciary duty to understand and monitor how these Pools exercise shareholder rights. In those instances, the designated Investment Option manager’s adherence to its requirements under ERISA will be periodically assessed. If the Committee is solicited to cast proxy votes for reasons outside the aforementioned scope, such actions will be evaluated in accordance with the Committee's fiduciary responsibilities.

(VIII) COORDINATION WITH THE PLAN DOCUMENT

If any term or condition of this Statement conflicts with any term or condition of the Plan Document, the terms and condition of the Plan Document shall control so long as they are consistent with the law.

(IX) OPERATIONS

The Committee will review this Statement at least annually to make sure it remains in the best interest of the Plan participants and beneficiaries. It may be amended or modified by the Committee at any time.

Adopted this 26th day of February 2025.

Agency for Community Transit

By Steven J. Morrison Executive Director

ASSET CLASSES AND INVESTMENT OPTIONS

As of ________________, 2025

Fund Name Ticker Asset Class Peer Group

Active Tier

One America Stable Value n/a –Stable Value –Stable Value Vanguard Short-Term Investment-Grade Adm VFSUX Short-Term Bond Short-Term Bond

Baird Core Plus Bond Inst BCOIX Intermediate Core-Plus Bond

Intermediate Core-Plus Bond

American Funds Global Balanced R6 RGBGX World Allocation World Allocation Vanguard Equity-Income Adm VEIRX Large Value Large Value T. Rowe Price Growth Stock I PRUFX Large Growth Large Growth American Century Mid Cap Value R6 AMDVX Mid-Cap Value Mid-Cap Value Vanguard Mid Cap Growth Inv VMGRX Mid-Cap Growth Mid-Cap Growth DFA US Small Cap I DFSTX Small Blend Small Blend American Funds Capital World Gr&Inc R6 RWIGX World Large Stock World Large Stock American Funds Intl Gr and Inc R6 RIGGX Foreign Large Blend Foreign Large Blend

Passive Tier

Vanguard Total Bond Market Index Adm VBTLX Intermediate Core Bond Intermediate Core Bond

Fidelity Inflation-Prot Bd Index FIPDX Inflation-Protected Bond Inflation-Protected Bond

Vanguard Total Stock Mkt Idx Adm VTSAX Large Blend Large Blend Vanguard Total Intl Stock Index Admiral VTIAX Foreign Large Blend Foreign Large Blend

Target Retirement Funds

American Funds 2010 Trgt Date Retire R6 RFTTX Target-Date 2000-2010 Target-Date 2000-2010 American Funds 2025 Trgt Date Retire R6 RFDTX Target-Date 2025 Target-Date 2025 American Funds 2030 Trgt Date Retire R6 RFETX Target-Date 2030 Target-Date 2030 American Funds 2035 Trgt Date Retire R6 RFFTX Target-Date 2035 Target-Date 2035 American Funds 2040 Trgt Date Retire R6 RFGTX Target-Date 2040 Target-Date 2040 American Funds 2045 Trgt Date Retire R6 RFHTX Target-Date 2045 Target-Date 2045 American Funds 2050 Trgt Date Retire R6 RFITX Target-Date 2050 Target-Date 2050 American Funds 2055 Trgt Date Retire R6 RFKTX Target-Date 2055 Target-Date 2055 American Funds 2060 Trgt Date Retire R6 RFUTX Target-Date 2060 Target-Date 2060 American Funds 2065 Trgt Date Retire R6 RFVTX Target-Date 2065+ Target-Date 2065+ American Funds 2070 Trgt Date Retire R6 RFBFX Target-Date 2065+ Target-Date 2065+