Research at Guzman & Company is conducted along the Best Practices Guidelines recommended by the Securities Industry Association, and ongoing and revised NYSE and NASD regulations. While the brokerage industry has been shaken by revelations of compromised research integrity, Guzman & Company policy has always required analyst objectivity. The firm supports analysts' conclusions, even if contrary to the short-term interests of Guzman's investment banking advisory or trading businesses, or to those of its buy-side and corporate buyback clients. Guzman & Company prizes thoroughness and integrity, and fosters these qualities by maintaining a Research environment free of inappropriate influence on recommendations, earnings estimates and price targets.

Guzman policy includes, but is not limited to:

A) Any report to be reviewed by a subject company for factual accuracy prior to publication is sent without an investment rating or summary thesis in its text, ensuring confidentiality regarding intended rating and price target.

B) Equity analyst compensation is based on a salary and bonus system, which is determined by a combination of:

• Success in effectively rating stocks, projecting earnings, and creating value for clients
• Overall productivity
• Sales and trading support, and
• Institutional research votes

Compensation is evaluated in accordance with SEC, NYSE and NASD regulations and principles of investor ethics.

C) Research does not report to Investment Banking at Guzman & Company. The Investment Banking division has neither direct nor indirect approval of or influence over the investment opinions, earnings estimates and/or price targets of any company covered, whether it is an investment banking client or not. All parties are made to understand that analyst independence and the interests of his or her investing clients are his or her foremost priorities.

D) To avoid potential conflicts of interest, analysts may not own securities of the firms they cover, and thus cannot trade against their recommendations, or ahead of planned publication of a relevant report. Furthermore, relevant private investments and outside business interests must similarly not conflict with analyst recommendations, and must be disclosed. Guzman analysts may not cover securities of companies of which they or members of their household or immediate family are officers, directors, or advisory board members. At all times, Guzman analysts must put customers first.