408(b)(2) Compensation Disclosure — Covered Service Provider

This disclosure is issued by TrueNorth Fiduciary Risk Advisors, LLC (the “Covered Service Provider” or “TrueNorth”), a corporate benefits consultancy registered to do business in the United States. TrueNorth's principal place of business is on file with each plan sponsor in Schedule A of the engagement letter.

TrueNorth provides the following services to the Plan, as further specified in Schedule A of the engagement letter:

1. Fiduciary co-pilot services, including chairmanship of the plan-governance committee on a quarterly cadence, maintenance of the audit-readiness file, and annual fiduciary training for committee members;
2. Stop-loss procurement, including net-of-commission RFP, multi-year and no-laser term negotiation, policy-wording review, and quarterly large-claim watch;
3. Pharmacy benefits procurement and oversight, including PBM contract structure, rebate reconciliation, and annual independent pharmacy audit coordination;
4. Plan-design services, including claims-distribution analysis, network strategy, cost-share modeling, and documentation of the prudent process to ERISA §404(a) standard;
5. Such additional services as are specified in writing in Schedule A.

TrueNorth acknowledges that it is a fiduciary under ERISA §3(21)(A) with respect to the Plan, and accepts named co-fiduciary status as of the effective date of the engagement letter. Where Schedule A so provides, TrueNorth additionally accepts §3(38) investment-manager status and the discretionary authority associated with it.

TrueNorth's compensation is paid directly by the Plan Sponsor in the form of a flat annual retainer or a PEPM (Per-Employee-Per-Month) fee, in each case specified in writing in Schedule A of the engagement letter. The dollar amount, payment cadence, and any applicable performance offset are disclosed in Schedule A prior to engagement and are not contingent on the placement, renewal, or retention of any insurance product, vendor service, or plan arrangement.

TrueNorth does not accept, and will not accept during the term of any engagement, any of the following forms of compensation from any insurance carrier, third-party administrator, pharmacy benefit manager, broker general agent, captive manager, network, reinsurance broker, or other vendor whose services it evaluates or recommends:

• Commissions (base, override, or contingent)
• Performance bonuses tied to placement or retention volume
• Finder's fees, placement fees, or referral payments
• Marketing, conference sponsorship, or educational reimbursements
• Non-monetary compensation of any kind, including paid travel and entertainment

Indirect compensation received by TrueNorth in respect of the Plan for the current attestation period is, and is hereby disclosed to be, $0.00.

TrueNorth does not maintain a related-party arrangement under which compensation is paid among affiliates, subsidiaries, or commonly owned entities in respect of Plan services. TrueNorth is a stand-alone consultancy and does not operate a commission line of business under common ownership.

Compensation due upon termination of the engagement is limited to the pro-rata share of the retainer or PEPM fee earned through the effective termination date. TrueNorth does not assess a termination penalty, a non-refundable engagement fee, or a wind-down fee. Prepaid amounts are refunded on a pro-rata basis within thirty (30) days of termination.

TrueNorth represents that, as of the effective date of this disclosure, it maintains no conflicts of interest with respect to the Plan or the services identified in Section 2. Any conflict that may arise during the engagement will be disclosed to the Plan Sponsor in writing within five (5) business days of TrueNorth's knowledge of it, together with TrueNorth's proposed remediation.

This disclosure is refreshed and re-attested on a quarterly cadence and on the occurrence of any material change in TrueNorth's compensation arrangement. The current public copy supersedes any prior published version and is available at the URL identified on this filing at all times.

This disclosure is effective as of the date set forth in the document banner above. It has been reviewed by counsel of record and is issued by a duly authorized officer of TrueNorth.