Stock Ownership by Officers

To more closely align the interests of the Corporation’s officers and shareowners, the Corporation’s officers are expected to own a significant equity interest in the Corporation, in the form of common stock and within a reasonable time after initial election to office, in accordance with the following guidelines:

Shares of common stock or common stock share units held in the Corporation’s employee benefit and deferred compensation plans are credited toward meeting these guidelines.

Ordinarily, three years will be deemed a reasonable time to meet these guidelines.

Absent special circumstances and unless approved by the Chief Executive Officer of the Corporation, an officer is expected to maintain ownership of the Corporation’s common stock in accordance with these guidelines for so long as he or she remains an officer.