The Company prohibits trading in its securities based on material, nonpublic information regarding the Company ("Inside Information"). The Policy covers officers, directors and all other employees of the Company, as well as family members of such persons, and others, in each case where such persons have or may have access to Inside Information.

It is the policy of the Company to oppose the unauthorized disclosure of any nonpublic information acquired in the work-place and the misuse of Material Nonpublic Information in trading in its securities.