New Disclosures Policy

This New Disclosures Policy is intended to facilitate the early detection and disclosure of reportable items to the SEC and to improve the efficiency and effectiveness of compliance efforts. It applies to all corporate and subsidiary locations, with particular emphasis on parties responsible for financial reporting and disclosure of related events.

Under this policy, new disclosable items are identified with sufficient lead time to allow for proper assignment of responsibility, efficient and effective data gathering and processing, and streamlined companywide comprehension and consensus. This is intended to enhance the completeness and accuracy of information reported in quarterly SEC filings.