Emory University Post-Retirement Benefit Trust

“The northern trust company is the directed trustee of the emory university post-retirement benefit trust and is responsible for holding and managing assets of the trust. Emory university is governed by a board of trustees, which has delegated broad authority for oversight of the trust to the pension board, which is comprised of officers and employees of emory university and emory healthcare. The pension board is deemed to be the plan administrator of the trust and its oversight includes investment selection and performance management. This responsibility is further delegated to emory investment management, an operating division of emory university. Emory investment management is responsible for executing investment strategy and manager selection for the trust assets. There are no officers, directors, individual trustees or employees of the trust. Northern trust is reported as an institutional trustee in part vii of form 990.”

“An accounting firm experienced in the tax-exempt area has been engaged to prepare the 990. Once a draft has been prepared it is reviewed by senior management and presented to the emory pension board prior to being filed.”

“The code of business conduct and ethics applies to all directors of northern trust corporation, all directors of subsidiaries of northern trust corporation and all officers and employees of northern trust worldwide. More detailed northern trust policies and procedures that apply to all employees or certain groups are set forth in other documents, including risk management related policies and procedures. While these other policies and procedures are not part of this code, all northern trust employees are expected to conduct himself or herself consistently with this code and all other policies that address specific legal requirements imposed by laws and regulations in countries in which northern trust does business and other corporate standards. Northern trust expects all northern trust employees covered by the code to adhere to its overriding commitment to the highest standards of integrity, ethics, honesty and respect for all persons with whom it deals, within and outside northern trust. Compliance with the code, other northern trust policies, procedures and standards, and the laws and regulations referred to in those documents, is a vital part of that commitment. This code also helps northern trust enhance its relationships with its clients, each other, and all of the people that contribute to northern trust's success. The emory university conflict of interest policy requires certain individuals to disclose participation in activities or circumstances that may present a conflict of interest on an annual basis or if at any time such individual becomes aware of circumstances that may present a conflict of interest. These disclosures are reviewed by the executive compensation and trustees' conflict of interest committee of the emory university board of trustees ('conflict of interest committee'), as necessary. If the conflict of interest committee determines that a conflict of interest exists, the individual with the conflict of interest may make a presentation to the conflict of interest committee, but after such presentation, the individual must leave the meeting during the discussion of, and the vote on, the transaction or arrangement that resulted in the conflict of interest. During the fiscal year none of the trustees of emory university or directors of emory healthcare with related business interests voted on business decisions involving such companies.”

“The emory university post-retirement benefit trust does not have employees.”

“These documents are not made available to the public.”