Compliance

Terrapin Research and Management Company (“Terrapin.”), Inc. is a California corporation and provider of independent research services Terrapin has not received compensation, nor does it plan to solicit business from the companies that are the subjects of its research commentary. Terrapin is not a broker-dealer, nor a member of FINRA. Terrapin observes strict guidelines in the acquisition and dissemination of information regarding its covered companies and business sectors. In compliance with our internal policies and procedure, we carefully avoid the release of material non-public information. The Terrapin research analysts responsible for the provision of the opinions expressed in the company’s research product that analyzes a company or business sector certifies that the views expressed accurately reflect the personal views of the research analyst and that the analysts compensation is not directly or indirectly, related to the specific recommendations or views expressed by the analyst’s research report or product. No direct, or indirect, conflicts of interest arise from Terrapin’s research product findings.   All Terrapin employees must consent to and agree with our firm policies and procedures, in writing; including but not limited to Insider Trading Prohibition, Client Privacy Policy, Confidentiality Policy, Non-Disclosure Policy, and Certification Regarding Material Non-Public Information.