Securities Trading Policy

4. When is the Information “Generally Available”?

Information is generally available if:

(a) It consists of readily observable matter;

(b) It has been made known in a manner likely to bring the information to the attention of people who commonly invest in Securities of a kind whose price or value might be affected by the information, and, since it was made known, a reasonable period for it to be disseminated among such persons has elapsed;

(c) It is derived from information which has been made public; or

(d) It consists of observations, deductions, conclusions or inferences made or drawn from other generally available information.