The document outlines Constellation Energy Group's policy and procedures for reviewing and approving related person transactions. It defines related persons and related person transactions. It establishes procedures for identifying related persons, disseminating a master list of related persons, approving transactions, ratifying past transactions, reviewing ongoing transactions, reporting to committees, and disclosing transactions as required. The policy aims to identify potential conflicts and ensure related person transactions are fair to the company.
Group Employee Benefits-Providing Individuals, Families, Employees and Companies the best Legal and Identity Theft Protection in America -"Equal Justice Under Law"!
Group Employee Benefits-Providing Individuals, Families, Employees and Companies the best Legal and Identity Theft Protection in America -"Equal Justice Under Law"!
14 general principles (Highlighted)
from the
Office of Government Ethics
https://www.oge.gov/
https://www.oge.gov/Web/OGE.nsf/0/73636C89FB0928DB8525804B005605A5/$FILE/14%20General%20Priniciples.pdf
Research for Election 2020
$26/month Pre-Paid Legal, Identity Theft Shield Family Planstanley kania
It’s no secret. Identity Theft is a major problem in America. Think you’re not at risk?
Unfortunately you are. Do you hand your credit cards to servers at restaurants? Do you sign
your credit cards? Do you supply personal information over the internet? If you can answer
yes to one of these questions, contact (Stan Kania), Independent Associate, at
(724-840-1876) to find out how our Identity Theft Shield can help you!
The Pre Paid Legal Business Presentation -- Improves Your Business Bottom Line by protecting Employee Groups, at no cost to the Employer. We also have Small Business Legal Plans, as well as Family & Individual Legal Plans NATIONWIDE U.S. & Canada.
14 general principles (Highlighted)
from the
Office of Government Ethics
https://www.oge.gov/
https://www.oge.gov/Web/OGE.nsf/0/73636C89FB0928DB8525804B005605A5/$FILE/14%20General%20Priniciples.pdf
Research for Election 2020
$26/month Pre-Paid Legal, Identity Theft Shield Family Planstanley kania
It’s no secret. Identity Theft is a major problem in America. Think you’re not at risk?
Unfortunately you are. Do you hand your credit cards to servers at restaurants? Do you sign
your credit cards? Do you supply personal information over the internet? If you can answer
yes to one of these questions, contact (Stan Kania), Independent Associate, at
(724-840-1876) to find out how our Identity Theft Shield can help you!
The Pre Paid Legal Business Presentation -- Improves Your Business Bottom Line by protecting Employee Groups, at no cost to the Employer. We also have Small Business Legal Plans, as well as Family & Individual Legal Plans NATIONWIDE U.S. & Canada.
Edelman digital + sxsw 2016 lançamentoDaniel Rimoli
Lançamento da Edelman Digital no Brasil com a visão que tivemos do evento #SXSW2016: inteligência artificial, realidade virtual, machine learning, big data e muito mais.
Presentation of the webinar on 10-21-13 by the Ohio Environmental Council about the proposed legislation (Ohio Senate Bill 58) that would weaken Ohio's clean energy laws.
Appointment and Qualification of directors along with relevant rules.Dipendra Prasad Poudel
In this presentation you can find the provisions regarding appointment of directors and their qualifications as per companies act 2013 and relevant rules of Appointment and qualification of directors rules. Due care has been taken to make presentation simple and attractive. Any suggestions, feedback and queries are openly accepted.
Petróleo Brasileiro S.A. – Petrobras Agrees to Pay More Than $850 Million for FCPA Violations
Reaches Agreement with Brazilian Authorities in Related Investigation
Related Party Transaction as per Companies Act and SEBI(LODR)CS Bhuwan Taragi
This PPT is on Related Party Transaction as per companies Act, 2013 and SEBI(LODR) 2015. you will company know who are related parties and what are approval required for related parties transactions.
You can visit my you tube channel "CS Bhuwan Taragi- The Law Talks " for more clearity on this topic.
CTB - Key Individuals - Roles and Responsibilties.pdfKotive
“Key individual”, in relation to an authorised financial services provider, or a representative, carrying on business as a
corporate or unincorporated body, a trust or a partnership
USDA Loans in California: A Comprehensive Overview.pptxmarketing367770
USDA Loans in California: A Comprehensive Overview
If you're dreaming of owning a home in California's rural or suburban areas, a USDA loan might be the perfect solution. The U.S. Department of Agriculture (USDA) offers these loans to help low-to-moderate-income individuals and families achieve homeownership.
Key Features of USDA Loans:
Zero Down Payment: USDA loans require no down payment, making homeownership more accessible.
Competitive Interest Rates: These loans often come with lower interest rates compared to conventional loans.
Flexible Credit Requirements: USDA loans have more lenient credit score requirements, helping those with less-than-perfect credit.
Guaranteed Loan Program: The USDA guarantees a portion of the loan, reducing risk for lenders and expanding borrowing options.
Eligibility Criteria:
Location: The property must be located in a USDA-designated rural or suburban area. Many areas in California qualify.
Income Limits: Applicants must meet income guidelines, which vary by region and household size.
Primary Residence: The home must be used as the borrower's primary residence.
Application Process:
Find a USDA-Approved Lender: Not all lenders offer USDA loans, so it's essential to choose one approved by the USDA.
Pre-Qualification: Determine your eligibility and the amount you can borrow.
Property Search: Look for properties in eligible rural or suburban areas.
Loan Application: Submit your application, including financial and personal information.
Processing and Approval: The lender and USDA will review your application. If approved, you can proceed to closing.
USDA loans are an excellent option for those looking to buy a home in California's rural and suburban areas. With no down payment and flexible requirements, these loans make homeownership more attainable for many families. Explore your eligibility today and take the first step toward owning your dream home.
how to sell pi coins on Bitmart crypto exchangeDOT TECH
Yes. Pi network coins can be exchanged but not on bitmart exchange. Because pi network is still in the enclosed mainnet. The only way pioneers are able to trade pi coins is by reselling the pi coins to pi verified merchants.
A verified merchant is someone who buys pi network coins and resell it to exchanges looking forward to hold till mainnet launch.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
how to sell pi coins in all Africa Countries.DOT TECH
Yes. You can sell your pi network for other cryptocurrencies like Bitcoin, usdt , Ethereum and other currencies And this is done easily with the help from a pi merchant.
What is a pi merchant ?
Since pi is not launched yet in any exchange. The only way you can sell right now is through merchants.
A verified Pi merchant is someone who buys pi network coins from miners and resell them to investors looking forward to hold massive quantities of pi coins before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
What website can I sell pi coins securely.DOT TECH
Currently there are no website or exchange that allow buying or selling of pi coins..
But you can still easily sell pi coins, by reselling it to exchanges/crypto whales interested in holding thousands of pi coins before the mainnet launch.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and resell to these crypto whales and holders of pi..
This is because pi network is not doing any pre-sale. The only way exchanges can get pi is by buying from miners and pi merchants stands in between the miners and the exchanges.
How can I sell my pi coins?
Selling pi coins is really easy, but first you need to migrate to mainnet wallet before you can do that. I will leave the telegram contact of my personal pi merchant to trade with.
Tele-gram.
@Pi_vendor_247
The secret way to sell pi coins effortlessly.DOT TECH
Well as we all know pi isn't launched yet. But you can still sell your pi coins effortlessly because some whales in China are interested in holding massive pi coins. And they are willing to pay good money for it. If you are interested in selling I will leave a contact for you. Just telegram this number below. I sold about 3000 pi coins to him and he paid me immediately.
Telegram: @Pi_vendor_247
Poonawalla Fincorp and IndusInd Bank Introduce New Co-Branded Credit Cardnickysharmasucks
The unveiling of the IndusInd Bank Poonawalla Fincorp eLITE RuPay Platinum Credit Card marks a notable milestone in the Indian financial landscape, showcasing a successful partnership between two leading institutions, Poonawalla Fincorp and IndusInd Bank. This co-branded credit card not only offers users a plethora of benefits but also reflects a commitment to innovation and adaptation. With a focus on providing value-driven and customer-centric solutions, this launch represents more than just a new product—it signifies a step towards redefining the banking experience for millions. Promising convenience, rewards, and a touch of luxury in everyday financial transactions, this collaboration aims to cater to the evolving needs of customers and set new standards in the industry.
Currently pi network is not tradable on binance or any other exchange because we are still in the enclosed mainnet.
Right now the only way to sell pi coins is by trading with a verified merchant.
What is a pi merchant?
A pi merchant is someone verified by pi network team and allowed to barter pi coins for goods and services.
Since pi network is not doing any pre-sale The only way exchanges like binance/huobi or crypto whales can get pi is by buying from miners. And a merchant stands in between the exchanges and the miners.
I will leave the telegram contact of my personal pi merchant. I and my friends has traded more than 6000pi coins successfully
Tele-gram
@Pi_vendor_247
what is the future of Pi Network currency.DOT TECH
The future of the Pi cryptocurrency is uncertain, and its success will depend on several factors. Pi is a relatively new cryptocurrency that aims to be user-friendly and accessible to a wide audience. Here are a few key considerations for its future:
Message: @Pi_vendor_247 on telegram if u want to sell PI COINS.
1. Mainnet Launch: As of my last knowledge update in January 2022, Pi was still in the testnet phase. Its success will depend on a successful transition to a mainnet, where actual transactions can take place.
2. User Adoption: Pi's success will be closely tied to user adoption. The more users who join the network and actively participate, the stronger the ecosystem can become.
3. Utility and Use Cases: For a cryptocurrency to thrive, it must offer utility and practical use cases. The Pi team has talked about various applications, including peer-to-peer transactions, smart contracts, and more. The development and implementation of these features will be essential.
4. Regulatory Environment: The regulatory environment for cryptocurrencies is evolving globally. How Pi navigates and complies with regulations in various jurisdictions will significantly impact its future.
5. Technology Development: The Pi network must continue to develop and improve its technology, security, and scalability to compete with established cryptocurrencies.
6. Community Engagement: The Pi community plays a critical role in its future. Engaged users can help build trust and grow the network.
7. Monetization and Sustainability: The Pi team's monetization strategy, such as fees, partnerships, or other revenue sources, will affect its long-term sustainability.
It's essential to approach Pi or any new cryptocurrency with caution and conduct due diligence. Cryptocurrency investments involve risks, and potential rewards can be uncertain. The success and future of Pi will depend on the collective efforts of its team, community, and the broader cryptocurrency market dynamics. It's advisable to stay updated on Pi's development and follow any updates from the official Pi Network website or announcements from the team.
how to sell pi coins effectively (from 50 - 100k pi)DOT TECH
Anywhere in the world, including Africa, America, and Europe, you can sell Pi Network Coins online and receive cash through online payment options.
Pi has not yet been launched on any exchange because we are currently using the confined Mainnet. The planned launch date for Pi is June 28, 2026.
Reselling to investors who want to hold until the mainnet launch in 2026 is currently the sole way to sell.
Consequently, right now. All you need to do is select the right pi network provider.
Who is a pi merchant?
An individual who buys coins from miners on the pi network and resells them to investors hoping to hang onto them until the mainnet is launched is known as a pi merchant.
debuts.
I'll provide you the Telegram username
@Pi_vendor_247
how to swap pi coins to foreign currency withdrawable.DOT TECH
As of my last update, Pi is still in the testing phase and is not tradable on any exchanges.
However, Pi Network has announced plans to launch its Testnet and Mainnet in the future, which may include listing Pi on exchanges.
The current method for selling pi coins involves exchanging them with a pi vendor who purchases pi coins for investment reasons.
If you want to sell your pi coins, reach out to a pi vendor and sell them to anyone looking to sell pi coins from any country around the globe.
Below is the contact information for my personal pi vendor.
Telegram: @Pi_vendor_247
how can I sell pi coins after successfully completing KYCDOT TECH
Pi coins is not launched yet in any exchange 💱 this means it's not swappable, the current pi displaying on coin market cap is the iou version of pi. And you can learn all about that on my previous post.
RIGHT NOW THE ONLY WAY you can sell pi coins is through verified pi merchants. A pi merchant is someone who buys pi coins and resell them to exchanges and crypto whales. Looking forward to hold massive quantities of pi coins before the mainnet launch.
This is because pi network is not doing any pre-sale or ico offerings, the only way to get my coins is from buying from miners. So a merchant facilitates the transactions between the miners and these exchanges holding pi.
I and my friends has sold more than 6000 pi coins successfully with this method. I will be happy to share the contact of my personal pi merchant. The one i trade with, if you have your own merchant you can trade with them. For those who are new.
Message: @Pi_vendor_247 on telegram.
I wouldn't advise you selling all percentage of the pi coins. Leave at least a before so its a win win during open mainnet. Have a nice day pioneers ♥️
#kyc #mainnet #picoins #pi #sellpi #piwallet
#pinetwork
Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
Turin Startup Ecosystem 2024
Una ricerca de il Club degli Investitori, in collaborazione con ToTeM Torino Tech Map e con il supporto della ESCP Business School e di Growth Capital
Introduction to Indian Financial System ()Avanish Goel
The financial system of a country is an important tool for economic development of the country, as it helps in creation of wealth by linking savings with investments.
It facilitates the flow of funds form the households (savers) to business firms (investors) to aid in wealth creation and development of both the parties
what is the best method to sell pi coins in 2024DOT TECH
The best way to sell your pi coins safely is trading with an exchange..but since pi is not launched in any exchange, and second option is through a VERIFIED pi merchant.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and pioneers and resell them to Investors looking forward to hold massive amounts before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade pi coins with.
@Pi_vendor_247
constellation energy Policy and Procedures With Respect to Related Person Transactions
1. Policy and Procedures With Respect to Related Person Transactions
A. Policy Statement
Constellation Energy Group, Inc. (the quot;Companyquot;) recognizes that Related Person Transactions (as defined below) can present potential or
actual conflicts of interest and create the appearance that Company decisions are based on considerations other than the best interests of
the Company and its stockholders. Accordingly, as a general matter, it is the Company's preference to avoid Related Person Transactions.
Nevertheless, the Company also recognizes that there are situations where Related Person Transactions may be in, or may not be
inconsistent with, the best interests of the Company and its stockholders, including but not limited to situations where the Company may
obtain products or services of a nature, quantity or quality, or on other terms, that are not readily available from alternative sources or when
the Company provides products or services to Related Persons (as defined below) on an arm's length basis on terms comparable to those
provided to unrelated third parties or on terms comparable to those provided to employees generally. Therefore, the Company has adopted
the procedures set forth below for the review, approval or ratification of Related Person Transactions. The Company will review and may
amend this policy from time to time.
B. Related Person Transactions
For purposes of this policy, a quot;Related Person Transactionquot; is a transaction, arrangement or relationship (or any series of similar
transactions, arrangements or relationships) in which the Company (including any of its subsidiaries) was, is or will be a participant, and in
which any Related Person had, has or will have a direct or indirect interest, other than:
transactions available to all employees generally (e.g., non-discretionary contributions made pursuant to the Company's matching
q
contribution program);
transactions involving the provision of electric or gas services by Baltimore Gas and Electric Company at rates fixed by tariff; or
q
charitable contributions involving less than $10,000 when aggregated with all similar charitable contributions.
q
For purposes of this Policy, a quot;Related Personquot; means:
1. any person who is, or at any time since the beginning of the Company's last fiscal year was, an officer of the Company or any of its
subsidiaries subject to Section 16 of the Securities Exchange Act of 1934 (an quot;executive officerquot;);
2. any person who is an employee of the Company or any of its subsidiaries who receives at least one executive-level benefit as
determined by Human Resources (a quot;management employeequot;)
3. any other employee of the Company or any of its subsidiaries;
4. any person who is, or at any time since the beginning of the Company's last fiscal year was, a member of the Board of Directors of
the Company or a nominee to become a member of the Board of Directors of the Company;
5. any person who is known to be the beneficial owner of more than 5% of any class of the Company's voting securities;
6. any immediate family member of any of the foregoing persons, which means any child, stepchild, parent, stepparent, spouse, sibling,
mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law of the employee, executive officer, Board
member, Board member nominee or more than 5% beneficial owner, and any person (other than a tenant or employee) sharing the
household of such employee, executive officer, Board member, Board member nominee or more than 5% beneficial owner (each, an
quot;immediate family memberquot;); and
7. any firm, corporation or other entity in which any of the foregoing persons is a director, executive officer, general partner or principal
or in a similar position or in which such person has a 10% or greater beneficial ownership interest.
C. Identification of Certain Related Persons
1. Board Members, Executive Officers, and Nominees. On an annual basis, each Board member and executive officer shall submit to the
legal department the following information: (a) a list of his or her immediate family members (as defined above); (b) in the case of a
Board member, the Board member's employer and job title or brief job description; and (c) for the Board member or executive officer,
and to the knowledge of such Board member or executive officer, for each of his or her immediate family members, each firm,
corporation or other entity in which such person is a general partner, principal, executive officer, director or trustee or in a similar
position or in which such person has a 10% or greater beneficial ownership interest.
2. Management Employees. On an annual basis, each management employee shall submit to the legal department the following
information: (a) a list of Related Person Transactions entered into in the past year identifying the Related Person and a statement on
whether the transactions were approved in accordance with this policy; and (b) for the management employee and his or her spouse
and children, each firm, corporation or other entity in which such person is a general partner, principal, executive officer, director or
trustee or in a similar position or in which such person has a 10% or greater beneficial ownership interest.
3. Five Percent Owners. At the time the Company becomes aware of a person's status as a beneficial owner of more than 5% of any
class of the Company's voting securities, the legal department, by examining SEC filings and through the use of Internet search
2. engines and a review of applicable websites, shall create a list, to the extent the information is readily available, of (a) if the person is
an individual, the same information as is requested of Board members and executive officers under this policy and (b) if the person is
a firm, corporation or other entity, a list of principals or executive officers of the firm, corporation or entity, and shall update the list on
an annual basis.
4. Any person nominated to stand for election as a Board member shall submit to the Chief Compliance Officer the information
described above no later than the date of his or her nomination.
5. Any person who is appointed as a Board member or an executive officer shall submit to the Chief Compliance Officer the information
described above prior to such person's appointment as a Board member or executive officer, except in the case of an executive
officer where due to the circumstances it is not practicable to submit the information in advance, in which case the information shall be
submitted as soon as reasonably practicable following the appointment.
6. Board members and executive officers are expected to notify the Chief Compliance Officer of any updates to the information provided
pursuant to Section C.1 or C.2. Generally this would include notification of the marriage of the Board member, executive officer or
management employee, or the marriage of his or her sibling or child.
D. Dissemination of Related Person Master List
The legal department shall compile the information collected pursuant to the procedures described in Section C above and create a master
list of Related Persons (not including employees and the Related Persons of employees who are not executive officers or management
employees). The legal department shall distribute the master list to (a) the chief legal officers of the Company's business units and staff
groups and (b) the heads of accounts payable and accounts receivable of the Company's business units and staff groups. In addition, the
legal department shall distribute the portion of the master list containing the names of charitable and non-profit organizations to the person
(s) responsible for administering the Company's charitable contributions. The recipients of the master list shall utilize and distribute the
information contained therein, in connection with their respective business units and staff groups, to effectuate this policy.
E. Approval Procedures
Proposed transactions that involve Related Persons shall be completed only if the following steps are taken:
1. Prior to entering into the Related Person Transaction (a) the Related Person, (b) the employee or Board member who is an
immediate family member or a partner, shareholder or executive officer of the Related Person, or (c) a member of the business unit or
staff group responsible for the potential Related Person Transaction shall provide notice to the Chief Compliance Officer of the facts
and circumstances of the proposed Related Person Transaction, including:
i. the Related Person's relationship to the Company and interest in the transaction;
ii. the material facts of the proposed Related Person Transaction, including the proposed aggregate value of such transaction or,
in the case of indebtedness, the amount of principal that would be involved;
iii. the benefits to the Company of the proposed Related Person Transaction;
iv. if applicable, the availability of other sources of comparable products or services; and
v. an assessment of whether the proposed Related Person Transaction is on terms that are comparable to the terms available to
an unrelated third party or to employees generally.
2. To the extent necessary, a member of the legal department shall meet with the relevant business unit or staff group to confirm and
supplement the information provided in the original notice. The Chief Compliance Officer will assess whether the proposed
transaction is a Related Person Transaction for purposes of this policy.
3. If the Chief Compliance Officer determines that the proposed transaction is a Related Person Transaction, the proposed Related
Person Transaction shall be reported to the persons set forth below for their consideration:
Individual Participating in Related Person Transaction Transaction Reported to
Management employee or other employee (other than head of Head of business unit or staff group
business unit or staff group)
Head of business unit or staff group who is not an Executive Officer Chief Administrative Officer/General Counsel
Executive Officer or nominee (other than Chief Executive Officer and Chief Executive Officer
amount involved is $120,000 or less)
Chief Executive Officer or nominee (and amount involved is Chair of Nominating and Corporate Governance Committee
$120,000 or less)
Board member or nominee (and amount involved is $120,000 or Chair of Nominating and Corporate Governance Committee
less)
4. The person receiving the report of the Related Person Transaction, in consultation with the Chief Compliance Officer and members of
the legal department, shall consider all of the relevant facts and circumstances available to him or her, including (if applicable) but not
limited to: the benefits to the Company; the impact on a Board member's independence in the event the Related Person is a Board
member, an immediate family member of a Board member or an entity in which a Board member is a partner, director, shareholder or
3. executive officer; the availability of other sources for comparable products or services; the terms of the transaction; and the terms
available to unrelated third parties or to employees generally. Such person shall approve only those Related Person Transactions
that are in, or are not inconsistent with, the best interests of the Company and its stockholders, as such person determines in good
faith. The person receiving the report of the Related Person Transaction shall document his or her decision in writing and shall
convey the decision to the Chief Compliance Officer, who shall convey the decision to the individual or to such individual's supervisor.
5. If a proposed Related Person Transaction involves (a) an executive officer, Board member or nominee and (b) an amount in excess
of $120,000, the proposed Related Person Transaction shall be submitted to the Nominating and Corporate Governance Committee
for consideration at the next Committee meeting or, in those instances in which the Chief Compliance Officer, in consultation with the
Chief Executive Officer or the Chief Financial Officer, determines that it is not practicable or desirable for the Company to wait until
the next Nominating and Corporate Governance Committee meeting, to the Chair of the Nominating and Corporate Governance
Committee (who will possess delegated authority to act between Committee meetings).
6. The Nominating and Corporate Governance Committee, or where submitted to the Chair, the Chair, shall consider all of the relevant
facts and circumstances available to the Committee or the Chair, including (if applicable) but not limited to, those set forth in Section
E.4 above. No member of the Committee shall participate in any review, consideration or approval of any Related Person Transaction
with respect to which such member or any of his or her immediate family members is the Related Person. The Nominating and
Corporate Governance Committee (or the Chair) shall approve only those Related Person Transactions that are in, or are not
inconsistent with, the best interests of the Company and its stockholders, as the Committee (or the Chair) determines in good faith.
The Nominating and Corporate Governance Committee or Chair, as applicable, shall convey the decision to the Chief Compliance
Officer, who shall convey the decision to the appropriate persons within the Company.
7. The Chair of the Nominating and Corporate Governance Committee shall report to the Nominating and Corporate Governance
Committee at the next Committee meeting any approval made by him or her pursuant to Section E.3 or E.5. Management of the
Company shall report to the Nominating and Corporate Governance Committee at the next Committee meeting any approval of a
Related Person Transaction involving an executive officer made by the Chief Executive Officer pursuant to Section E.3. The
Nominating and Corporate Governance Committee shall periodically report on its activities pursuant to this policy to the Board of
Directors.
8. To enable the Audit Committee to carry out its responsibilities with respect to accounting and financial reporting, the Chief
Compliance Officer shall report to the Audit Committee at least quarterly any approvals made by the Nominating and Corporate
Governance Committee, the Chair of the Nominating and Corporate Governance Committee or the Chief Executive Officer pursuant
to this policy.
F. Ratification Procedures
The legal department shall request from the accounts payable and accounts receivable departments of the business units and staff groups
annual reports of any amounts paid or payable to, or received or receivable from, any Related Person, and the legal department shall
determine if there are any Related Person Transactions that were not previously approved or previously ratified under this policy.
In the event the legal department becomes aware, as a result of the accounts payable/accounts receivable reports described above or
otherwise, of a Related Person Transaction that has not been previously approved or previously ratified under this policy:
1. If the transaction is pending or ongoing, it will be submitted for consideration in accordance with Section E above. Based on the
conclusions reached, the person receiving the report shall evaluate all options, including but not limited to ratification, amendment or
termination of the Related Person Transaction; and
2. If the transaction is completed, the person receiving the report shall evaluate the transaction, taking into account the same factors
described in Section E above, to determine if rescission of the transaction and/or any disciplinary action is appropriate, and shall
request that the Chief Compliance Officer evaluate the Company's controls and procedures to ascertain the reason the transaction
was not submitted for prior approval and whether any changes to these procedures are recommended.
G. Review of Ongoing Transactions
Annually, the Nominating and Corporate Governance Committee shall review any previously approved or ratified Related Person
Transactions involving executive officers or Board members that remain ongoing. Based on all relevant facts and circumstances, taking into
consideration the Company's contractual obligations, the Nominating and Corporate Governance Committee shall determine if it is in the
best interests of the Company and its stockholders to continue, modify or terminate the Related Person Transaction.
H. Reporting
A summary of all Related Person Transactions involving the Company's Board members and executive officers shall be provided annually to
the Nominating and Corporate Governance Committee.
I. Disclosure
All Related Person Transactions that are required to be disclosed in the Company's filings with the Securities and Exchange Commission, as
required by the Securities Act of 1933 and the Securities Exchange Act of 1934 and related rules and regulations, shall be so disclosed in
accordance with such laws, rules and regulations.
4. The material features of this policy shall be disclosed in the Company's annual report on Form 10-K or in the Company's proxy statement,
as required by applicable laws, rules and regulations. In addition, the Company shall post this policy on its website and update it as
necessary.