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Trading Restriction Compliance and Full Disclosure

The Company has a robust and enforceable trading restriction policy that applies and is agreed to by all editors, analysts, and traders for publications or any other content produced by the Company, whether for content that is purchase or freely available, and that applies to other individuals identified by the Company in its sole discretion. These individuals shall be referred to as “covered persons.”

Our trading restrictions apply to all covered persons and apply to the initial coverage of all stocks within newsletters and services published by the Company, with the exception of the stocks in automatically generated reports in the Investors Alley Stock Ratings service.

When an editor or analyst has decided to begin coverage of a stock for inclusion in a paid subscription newsletter or service that stock will be placed on a Restricted Trades List which will be maintained by a designated trading compliance officer within the Company. Covered persons will be barred from initiating any transactions with such security immediately upon such stock being placed on the Restricted Trades List for seven full trading days after the date on which the paid subscription newsletter or service is published with content about such stock.

Covered persons must immediately disclose any personal holdings in stocks placed on the Restricted Trades List.

Covered persons cannot buy or sell shares for seven full trading days after the publication of any initial report in any paid subscription newsletter or service on a stock. As many stocks are mentioned in update issues and alerts, the buy and sell restriction applies only to the initial research to recommend a transaction with the stock as part of a paid subscription newsletter or service.

Providing advance notice of inclusion or initiation of coverage of a stock to non-employees of or contractors working on the behalf of the Company is forbidden.

The Company will make every reasonable effort to inform subscribers of paid subscription newsletters and services of any positions in stocks held by covered persons that are recommended in said paid subscription newsletters and services. In the case where it is the editor or analyst of that paid subscription newsletter or service this person will be identified as holding a position in the stock mentioned. In the case where is another covered person or persons other than the editor or analyst of said paid subscription newsletter or service such position shall be disclosed without providing personally identifiable information about that person or persons.

Updated on December 11, 2019

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