All employees sign a confidentiality agreement to not act upon or discuss any of the information or material they work on or see.

All employees must receive pre-approval from the CRP Compliance Director for any securities transactions for themselves, their immediate family (spouse and children), and anyone else for which they make investment decisions.

We keep a running record of securities the firm is working on in order to maintain a database upon which to pre-clear trades for employees of the firm.

We receive monthly trade confirmations directly from the brokerage firms where employees maintain accounts.

CRP maintains a conflict clearance data base to ensure that we are not preparing material for firms working on opposite sides of a deal.

Subject to the US Equity Research Settlement, we make no references to our clients research capabilities when preparing pitch material.