Kraft Heinz Company Group Benefit

“The Northern Trust Company is the directed trustee of the trust and pursuant to the trust agreement performs certain functions with respect to the trust. The investment subcommittee of the employee benefits administration board of the Kraft Heinz Company is responsible for directing the Northern Trust Company as trustee with respect to trust investments. The employee benefits administration board of the Kraft Heinz Company is responsible for administration of the benefit plan funded through the trust. The committee may delegate all or part of its authority to an individual or entity.”

“Each officer of the VEBA can be reached through the mailing address provided (the trustee's address). Each such officer works in a different location: The Kraft Heinz Company, 1 PPG Place, Suite 3100, Pittsburgh, PA 15222.”

“The governing trust committee delegates day to day responsibility for operating the trust to the trustee and to professionals in finance, benefits, and law of the trust sponsor. The trustee prepares a draft of Form 990 which is then reviewed by staff professionals on behalf of the governing trust committee. A copy is then provided to members of the committee.”

“Apart from the trustee, which is an institutional trustee and subject to fiduciary and contractual standards, each officer who is a member of the trust's governing committee is also a fiduciary under ERISA who is required to act in the exclusive benefit of benefit plan participants. Further, each officer, as an employee of the Kraft Heinz Company is subject to the Kraft Heinz Company conflicts of interest/ethics policy. Under this policy, an officer would be precluded from acting in a manner which would represent a conflict of interest with the Kraft Heinz Company or its benefit plans or trusts.”

“The trust provides copies of its governing documents to plan participants upon written request to the plan administrator. All Kraft Heinz employees have internet access to the Kraft Heinz Company conflicts of interest policies applying to the trust officers who are Kraft Heinz employees. The trust financial statements are available to all plan participants upon request; summary annual reports are distributed to plan participants and posted on an intranet site.”

“Change in accrued income = $853”