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Investment Guidelines

Compliance

The Murdock Trust requires that outside investment managers comply with all applicable laws, rules, and regulations. Compliance with the Investment Advisory Agreement, Mutual Fund Prospectus, Limited Partnership Agreement, Limited Liability Company Agreement, or other governing instruments, and this Investment Policy is essential and will be monitored regularly by the Trust.

Consistency

Investment philosophy, style, and strategy shall remain consistent and any changes will require immediate written notification to the Trust.

Performance Evaluation

Performance will be evaluated over meaningful long-term periods against return expectations used in the strategic asset allocation process. Individual manager or product performance will be compared against risk/return expectations, other managers of a similar style, and various market indices as a frame of reference. Overall, Trust performance shall be compared against institutions with similar objectives and of a similar nature.

Performance comparisons on a short-term basis will be made for purposes of gaining a better understanding of outside managers, controlling and understanding risk/volatility, and refining expectations. It should be noted that all performance will be evaluated net of related investment management fees, custody costs, unrelated business income tax, and other such applicable costs, if any.

Controlling Expenses - Transaction Costs

Investment management fees shall be reasonable for the services provided. Transactions shall be executed at competitive rates on a “best execution basis” and will be monitored periodically by the Trust.

Commission Recapture

The Trust will attempt to recapture those commissions managers feel can be directed on a “best execution basis.”

Securities Lending

The Trust uses Mellon Trust's securities lending program when it is deemed prudent and beneficial to do so.

Periodic Meetings/Monitoring

On an as deemed necessary basis, investment managers will make a formal report to the Trust of their performance, in light of their risk/return expectations, and their outlook for the future in their style of investing. In addition, Trustees and/or staff will periodically visit managers in their offices.