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Mr. Grugeon serves in a similar capacity with Nationwide Fund Advisors ("NFA"), an affiliate registered <br /> investment adviser providing advisory services to the mutual funds within Nationwide Funds Group, the <br /> mutual fund arm of Nationwide Financial. Mr. Grugeon is a member of the Nationwide Investment <br /> Management Group ("IMG") Leadership Team which supports and participates in strategic initiatives and <br /> implements plans for the IMG lines of business, including the review and approval of investment-related <br /> matters affecting NFA and the Nationwide mutual funds. <br /> To help mitigate potential conflicts of interest arising from Mr. Grugeon's multiple roles and responsibilities, <br /> NIA maintains separate policies and procedures governing its investment process and the operation of its <br /> Investment Committee. Additional mitigating steps for NIA Advisory Programs are described below. <br /> To mitigate conflicts with respect to Nationwide ProAccount®, NIA has retained an Independent Financial <br /> Expert ("IFE"), which has sole control and discretion over the development and ongoing maintenance of the <br /> Nationwide ProAccount portfolios, including periodic rebalancing and changes to asset allocation and fund <br /> selection. The IFE's fees for services provided under Nationwide ProAccount are not related to the mutual <br /> funds it selects or otherwise influenced by the revenue NIA or its affiliates may receive from such mutual <br /> funds. <br /> To mitigate conflicts with respect to the Advice Program for Plan Sponsors of Trustee Directed Retirement <br /> Plans (the "Advice Program"), NIA offers the Advice Program through Nationwide Retirement Clear Advantage. <br /> The standard asset fee that Nationwide charges in connection with Nationwide Retirement Clear Advantage is <br /> reduced by a discount, expressed in terms of basis points, that reflects the amount of mutual fund payments <br /> made to Nationwide as indicated in the Fund Selection Schedule of the applicable retirement program <br /> agreement. As a result, payments that Nationwide receives from mutual funds or their affiliates selected <br /> through the Advice Program will not increase Nationwide's overall compensation. To further mitigate these <br /> conflicts, the Portfolio Strategist that NIA has hired for the Advice Program will not consider mutual funds <br /> affiliated with Nationwide. Moreover, the Portfolio Strategist's fees for services provided under the Advice <br /> Program are not related to the mutual funds it selects or otherwise influenced by the revenue NIA or its <br /> affiliated companies may receive from these mutual funds. Please note, however, that NIA has discretion to <br /> terminate its relationship with the Portfolio Strategist at any time, upon notice to clients, and may either <br /> engage a suitable replacement or operate the Advice Program without a Portfolio Strategist. <br /> NIA uses qualitative and quantitative factors in selecting sub-advisers to the Nationwide Large Cap Growth <br /> Portfolio. NIA may recommend or have a bias towards sub-advisers who also manage assets for NFA, due to <br /> NFA's greater access to and knowledge of these sub-advisers' investment processes, investment philosophies <br /> and portfolio managers. As a result, qualitative factors and analysis may play a greater role than quantitative <br /> factors and analysis in the selection and monitoring of these sub-advisers rather than sub-advisers who do not <br /> provide services for NFA. <br /> Item 5 Additional Compensation <br /> Mr. Grugeon does not receive additional compensation for providing advisory services. <br /> 4 <br />