Agreement Concerning Fiduciary Engagements and Process Requirements for Employer Stock Transactions

This document is about an agreement between the US Department of Labor and GreatBanc Trust Company regarding the policies and procedures that GreatBanc Trust Company must follow when serving as a trustee or fiduciary of an ESOP in transactions involving the purchase or sale of employer securities that are not publicly traded. It covers requirements for selecting and overseeing a valuation advisor, analyzing financial statements and projections, documenting the fiduciary review process, and ensuring that transactions are at fair market value.