Only authorized persons are permitted to conduct corporate communications with investment analysts, investors, and other market professionals. These activities include email communications, telephone conversations, one-on-one meetings, presentations, and other communications. The persons authorized to make such communications are the Company’s CEO, CFO, CMO and Investor Relations staff.

In the interest of fair disclosure and to mitigate the risk of inadvertent disclosure of material information, or the appearance of doing so, the Company will observe “Quiet Periods” and “Silent Periods” prior to its issuance of earnings releases, during which company personnel will be limited in conducting corporate communications. The “Quiet Period” begins two weeks prior to the end of the quarter and continues until the commencement of the “Silent Period.” The “Silent Period” is the two weeks preceding the Company’s issuance of an earnings release.

During the “Quiet Period” only the CMO and Director of Investor Relations (and not other senior management) will provide any corporate communications including responding to unsolicited correspondence from, engaging in one-on-one meetings and discussions with, or otherwise having private communications regarding the Company with, analysts, investors and other market professionals. However, an exception to this rule during the Quiet Period may be utilized for the CEO for communications regarding the Company with analysts, investors and other market professionals as long as at least one of the CFO, CMO or Director of Investor Relations is also in attendance. In all such cases, only otherwise publicly available historic information will be disclosed. During the Silent Period, no Company personnel will engage in any such corporate communications.

This Policy does not apply to public disclosures in accordance with Regulation FD that are authorized by the CEO or CFO.

Revised as of January 2019