Feltl and Company

Investment Protection Principles

Feltl and Company has adopted principles to eliminate the potential conflicts of interest that may arise out of a relationship between Investment Banking and Research Departments. In adopting these principles, Feltl announces:

• There is no direct link between compensation for analysts and investment banking and analysts are not compensated for a specific investment banking services transaction;
• Investment banking has no input into analyst compensation;
• A committee approves all recommendations;
• Discontinuation of coverage is disclosed as well as the rationale for such termination;
• Research reports disclose whether the firm has received or is entitled to receive compensation from a covered company over the past 12 months; and
• This process is monitored to ensure compliance with the principles.