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Disclosure

Ethics

Doctors take the Hippocratic Oath and judges take a Constitutional Oath. We strive for accuracy and completeness in our research from unbiased diligence and investigation. Our opinions reflect our judgment at a particular time following a comprehensive examination of changes due to economic, industry and company specific factors. To ensure governance, disclosure and transparency standards, our recommendations, reviews, disclosures and stock rankings are written in plain English and updated quarterly. Our oath is professionalism demands uncompromising integrity and Scimitar is committed to uncompromising professionalism. Our equity research will not sacrifice quality for quantity.

Compliance with law, both in letter and in spirit, is the foundation of Scimitar's ethical standards. All personnel must respect and obey the laws and regulations of the places where we do business. Scimitar and its personnel are subject to all applicable governmental laws, rules, and regulations, including those of the U.S. Securities and Exchange Commission (SEC) and EU regulatory bodies. Compliance with the law does not, however, comprise our entire ethical responsibility; rather, it is a minimum and an essential condition for performance of our duties.

Our unwavering commitment is to our clients, their shareholders and each other. Trust, integrity and character are the foundation of our corporate existence.

Corporate Code of Ethics and Conduct