Seeking Alpha Conduct & Investment Policy

Seeking Alpha expects the highest ethical standards from our employees. For this reason, we've established the following policies governing our employees' behavior and personal investing:

Rule #1: No short-term trading: You must hold positions in stocks, options, bonds, and ETFs for a minimum of 90 days. You may request a waiver of this rule under extenuating circumstances. (Note: As of April 1, 2020, we have suspended this rule due to rapidly changing market dynamics.)

Rule #2: No front-running: You may not buy/sell stocks, options, bonds and ETFs if you have knowledge of a yet-to-be-published article discussing that security.

Rule #3: Don't abuse your position: You may not abuse your position at Seeking Alpha (knowledge, access, authority, etc.) for personal gain.

For purposes of clarification:

• Your investments include the investments of any person or entity whose investment activity could reasonably be attributed to you.

• Investment activity does not include the purchase/sale of stocks made by investment managers in managed funds, collective investment schemes or other vehicles where you have no control over the decisions or timing of investments made.

You agree, upon request, to provide Seeking Alpha with brokerage statements related to your investments. Such information will be used solely for the purpose of complying with this policy.

Note: These policies are internal policies for Seeking Alpha employees. They do not apply to authors not employed by Seeking Alpha who publish on the Seeking Alpha website.