Insider Trading Policy

Insider Trading Policy. Federal securities laws, including the Securities Exchange Act of 1934, prohibit the purchase or sale of securities by any person who is in possession of material, nonpublic information (MNPI) about the issuer of such securities. It is the policy of the Company that no director, officer, employee, or any other person who has access to MNPI about the Company or any other company with which the Company has a business relationship shall: (a) buy, sell, gift, or otherwise trade in the securities of the Company (or such other company) while in possession of MNPI; (b) communicate ("tip") MNPI to any other person who may trade on the basis of that information; or (c) recommend the purchase or sale of securities on the basis of MNPI. For purposes of this policy, "material" information is any information that a reasonable investor would consider important in deciding whether to buy, sell, or hold a security, including but not limited to: financial results, earnings forecasts, mergers and acquisitions, significant contracts, changes in senior management, FDA approvals or denials, and material litigation. All covered persons are subject to a trading blackout period beginning fourteen (14) days before the end of each fiscal quarter and ending two (2) full business days after the public release of quarterly or annual financial results. Pre-clearance from the General Counsel is required for all trades by directors, officers, and other designated insiders.