This document is about the policies and procedures that Alpha Investment Consulting Group, LLC agrees to apply whenever it serves as trustee or other fiduciary of an employee stock ownership plan (ESOP) subject to ERISA that is purchasing, selling, or receiving an offer to purchase or sell employer securities that are not publicly traded. It covers the selection and use of a valuation advisor, oversight of the valuation advisor, financial statements, the fiduciary review process, debt and fair market value, control, consideration of claw-back arrangements, and the use of other professional service providers.