Idea Events Rules of Conduct

Last updated December 16, 2010

Track.com is pleased to have you participate in our Idea Events. An Idea Event is a gathering of Track.com subscriber participants and/or contributors, either in person, by telephone conference call, or through webinar, to discuss important ideas or current developments in our economic, financial, or political world or in particular industries or specialties, and to share insights, thoughts and experiences with each other in these areas. We welcome your participation in our Idea Events and trust you will benefit from them.

Set forth below are the specific Rules of Conduct which govern your participation in our Idea Events. Participation in our Idea Events is subject to these Rules of Conduct as well as our Terms of Use and, if you are a contributor to the Site, our Author Agreement. The terms of such documents are hereby incorporated as part of these Rules.

Upon signing up for an Idea Event, you will be reminded of your obligation to comply with these Rules of Conduct. Track.com will not be held liable or responsible for any violations of these Rules of Conduct.

I. Subscriber Participants and Contributors

You shall not do any of the following at any time in connection with your participation in our Idea Events:

• Disclose material, nonpublic information about a public company (material, non-public information is defined as any non-public information that would influence an investor’s decision to buy or sell securities);
• Disclose information that you have a duty or have agreed to keep confidential or for which there is an expectation of confidentiality (e.g., by agreement, employer policy, fiduciary duty, etc.);
• Participate in the Idea Event if doing so would violate applicable law or any agreement with, or other obligation to, any person, employer, former employer or other entity;
• Disclose any trade secrets or other proprietary information not owned solely by you;
• Tout or hype stock;
• Use inappropriate, unethical or misleading language in your discussions;
• Participate in the Event should it present any conflict of interest for you or other person or entity with whom you may be affiliated or for whom you perform services;
• Discuss any entity which is paying you to provide coverage for that entity’s stock or business; and
• Use for your own purposes or personally benefit from any confidential information that is disclosed and known by you to be confidential as a result of your participation in the Idea Events, at least until such time as the confidential information has been publicly disseminated and is publicly available.

II. Employees, Directors, or Consultants of a Company

If you are an employee or director of a company, you must obtain the consent of your company prior to your participation in the Idea Event. You should be conversant with any restrictions imposed on you by any employment agreements, employee manuals, codes of conduct, consulting agreements, company policies or similar materials which govern your employment relationship. Track.com will not be responsible to your employer or any third party for breaches by you of any such restrictions or prohibitions.

You shall not do any of the following at any time in connection with your participation in an Idea Event:

• Participate in an event the topic of which is your company, such as its performance, strategy, or products, without the express consent of the company, or discuss or disclose material non-public information about that company;
• Discuss accounting, financial, or other material issues relating to the company if you have worked in the accounting or finance department of a company, or consulted with that area of the company, within the last year;
• Speak on behalf of the company without its express written consent;
• Engage in an Event should it present, or has the appearance of presenting, a conflict of interest with you or the company.
• If you are an accountant or a lawyer, speak about a company which you have audited within the last three years or to which you have given legal advice within the last year; and
• Address pending planned or pending securities offerings of, or transactions involving, the company.

We look forward to your participation in our Idea Event.