Conflicts and Disclosure Policies

Editorial Staffers

To avoid any appearance that our reporting is driven by personal interest, TheStreet, Inc. does not permit any employees on its editorial staff to individually hold positions in individual stocks, though they are permitted to own stock in TheStreet, Inc. ( TST: Nasdaq). The restriction is, to our knowledge, among the most stringent in financial journalism.

Editorial staffers are permitted to own mutual funds. However, if a staffer writes about a mutual fund in which he or she holds shares, appropriate disclosure is made. Furthermore, editorial staff reporters whose beat covers a particular industry are not permitted to hold shares in closed-end or exchange-traded mutual funds that are primarily focused on that industry.

Board Members and Business Staffers

Similarly, restrictions have been placed upon the involvement of the board members and business staffers of TheStreet, Inc., including columnist and board member James J. Cramer, in the editorial content of the magazine. Board members and business staffers are not permitted to discuss individual stocks with editorial staffers of TheStreet or RealMoney. Moreover, as a general matter, neither board members nor business staffers — nor anyone else outside of editorial staff of and contributors to TheStreet or RealMoney — are informed of the contents of any of our stories prior to their being posted on the sites.

Outside Columnists

Outside contributing columnists for TheStreet and, including Mr. Cramer, may from time to time write about stocks in which they or their firms have a position. In such cases, appropriate disclosure is made.

Neither Mr. Cramer nor any other contributing columnist who owns stocks will respond to questions received via TheStreet for any individual investment advice or money management assistance. Nor will they respond to any email requests for guidance with regard to securities, except possibly to refer the writer to our publications and to this statement.

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