Integrity, ethical behavior, and professional excellence are the core principles guiding our research process. These principles are built on explicit trust between Blue Heron and our clients. Blue Heron maintains and administers a rigorous compliance policy, which is part of an overall strategic training system we have implemented to protect our clients, our company and our sources. Blue Heron has policies in place that should prevent our company from providing clients any material non-public information that could lead to improper insider trading. We:

• train our team to understand ethical and legal issues relevant to our industry
• vet our sources through diligent analysis of each source based on relevancy, ethics and legality
• tell the source we do not want any material non-public information
• tell the source we will not conduct the interview if the source has any executed confidentiality agreement in full force and effect

Company culture goes a long way with issues like this, and Blue Heron has established a culture that encourages communication and compliance.