Research Procedures & Ethics

1. Analysts are independent contractors not employed by CCM.

2. Analysts are pre-qualified, primarily by their level of expertise, as established by the CFA Institute or a similar overseas program, or by several years of experience providing analytics for recognized Wall/Bay Street institutions.

3. The analyst is responsible for providing research under stated procedures and is not responsible to the company in any way.

4. Analysts are paid in advance of their initial reports to avoid any pecuniary interest in the outcome.

5. Regardless of the outcome of the report, if it is professionally produced- and on time, and the analyst engages in timely communication with their covered companies, the analyst remains on the queue for future assignments.

6. Definitions of ratings are available to the public and to the analysts. No rating is to be issued that is labeled a recommendation. No analyst may recommend the purchase or the sale of any equity.

7. Analysts are asked to professionally arrive at an expected fair value of the company six, 12, 18 months out, and then to divide that by the number of shares calculated or reasonably expected to be outstanding on that future date. That number, no matter what it is, is the target valuation. (NOT ALL REPORTS HAVE TARGET VALUATION)

8. Reports must be publicly-accessible, at no charge, and a link provided to the public for any summaries or announcements published and distributed via any means.

9. Full disclosures regarding potential conflicts must accompany every communication.

10. Once the analyst has completed his or her report, and he or she affirms that the report is his or her sole work product, it is sent to the company with any and all ratings and target valuations extracted for errors and omissions review, then subsequently released for publication and distribution.