CAE USA, Inc.

NOMINATOR COMMENTS

CAE is a global leader in training for the civil aviation, defense and health care sectors. Its workforce is unique, with many employees enjoying second careers after serving in the military and civil aviation. CAE has consistently demonstrated a profound dedication to the financial wellness and retirement security of its employees.

Its comprehensive financial wellness program includes personalized financial planning services, educational workshops and access to financial advisers. CAE employees take good advantage of the plan features—e.g., 81% invest in a professionally managed allocation, compared with a 69% average for plans managed at Vanguard. CAE excels in participant communication by providing clear, concise and regular updates about the retirement plan through a range of communication channels; its resources are tailored to the various generational demographics.

PLANSPONSOR: Please cite any noteworthy initiatives you have taken in the past 24 to 36 months that have produced results to improve your plan, and describe the results.

CAE USA: We added the Candidly student loan service in November 2024. While most of our employees are on their second career, we felt that their children might benefit from the support. In the short time since, 23 employees have engaged, with an additional debt reduction of $9,760.

The committee considered all SECURE [Setting Every Community Up for Retirement Enhancement] 2.0 Act provisions, and we implemented automatic portability and qualified disaster distribution; added eligibility and benefits for all students and co-ops; and increased the automatic cash-out limit to $7,000. Other committee-approved items are pending Vanguard’s build-out for the pertinent voluntary provisions—hardship withdrawal self-certification and distributions for domestic abuse victims’ emergency expense withdrawals.

The committee has been debating the nonunion match. We decided the first step was to make the match clearer, and thereby more valuable, to participants by simplifying it. We moved the nonunion plan match to 100% up to 4%—it had been 100% up to 3% and 50% of the next 2%. We plan to increase the match incrementally in subsequent years. We enhanced the loan policy to allow repayment after termination.

We had several adjustments to the fund lineup per the committee investment policy and with advice from our co-fiduciaries at Cook Street, which benchmarked recordkeeper fees and negotiated a reduction of $10 per participant per year as of January 1, 2023.

PLANSPONSOR: Please explain the ongoing governance efforts of those involved with the plan meant to ensure its compliance and effective operation.

CAE USA: We have a fantastic committee composed of human resource and finance leaders from our various business lines. The committee meets at least three times per year, but quarterly if possible. It selected Cook Street Consulting after a request for proposals as its investment adviser and co-fiduciary.

Every quarter, we review investment results against the investment policy statement; we update the IPS regularly. Our committee has a committee charter that outlines governance, roles and responsibilities. Cook Street assists with plan administration by benchmarking or running an RFP for recordkeeper fees and services every three years.

The HR benefits team—the plan administrator—contracts with an outside audit firm to conduct the annual audit. Hill Ward Henderson, our ERISA attorneys, help us with plan document updates, amendments, etc. Our Vanguard partners share market developments, account analysis and compliance news with the committee to help it make informed decisions.

This year, for our Plan Sponsor of the Year profiles, we are publishing Q&As based on the finalists’ applications and nominator comments. Responses are edited and may be paraphrased. In cases where the finalist self-nominated or, on its application, referred judges to the nomination for the answer, we have attributed those nominator answers to the plan sponsor.