Securities Fraud and Insider Trading Policy


Summary

This policy against insider trading and securities fraud provides guidelines to the employees, officers, and directors of a publicly traded company with respect to transactions in the company's securities. Among other things, this policy prohibits directors, officers, employees, consultants and contractors from trading in the company's securities based on material nonpublic information regarding the company and imposes specific black-out periods and pre-clearance procedures for trading in the company's stock on directors and officers and their family members. This policy and related insider trading procedures should be disclosed annually, pursuant to Item 408 of Regulation S-K (17 C.F.R. § 229.408) of the Securities Exchange Act of 1934.