Insider Trading Compliance Policy

Summary

This Insider Trading Compliance Policy (the “Policy”) 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 event-specific restricted periods and pre-notification 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, as amended (Exchange Act).