1. Ethical precepts are an essential element of professional independent research, establishing the credibility necessary to understanding and accepting the research Provider's analytical output. Thus:

a. These Standards incorporate by reference the Analyst "Standards and Ethics" of the CFA Institute, the "Issuer / Analyst Guidelines" jointly adopted by the CFA Institute and National Investor Relations Institute, and the appropriate language in NASD Rule 2711, Regulation AC, as well as other recognized industry guides; and

b. Once a company has enrolled for coverage, the responsibility of the fee-based independent research Provider and its assigned Analyst(s) is to the public and to a company's shareholders and investors, and not to any company or to management.

    2. Qualified Analysts are fundamental to the production of valid analytics. Thus:

a. Only Analysts credentialed by professional peer-reviewed organizations, or otherwise qualified by several years of supervised or supervisory research reporting for recognized financial institutions, and only adherents to the "Standards and Ethics" of the CFA Institute should be allowed to produce research published by fee-based independent research Providers;

b. The names and credentials of Analysts producing the research shall be included in reports published by independent research Providers, along with an attestment thereto that the Analyst's work product is purely his or her own without influence or interference; and

c. Only qualified Analysts shall determine what to publish and when to publish. Independent research Providers are obligated to distribute the qualified Analyst's report upon publication.

3. Transparency is vital to the publication and dissemination of investment data and fundamental analysis, and is an ethical responsibility of the fee-based independent research Provider. Thus:

a. Fee-based independent research Providers shall disclose all amounts of compensation received or to be received for the preparation, publication and dissemination of research, research summaries or other announcements not only in the reports but also in whatever form such material is disseminated;

b. All such communications shall include the names and identities of the payers, and if a third-party or third-parties, their names and identities, as well as their relationship(s) to the issuer;

c. All such communications shall also meet both the letter and the spirit of U.S. Securities and Exchange Commission Regulation 17(b);

d. If communications come from the issuer, it is the responsibility of the Provider to advise the issuer that its reports or summaries may not be issued without the inclusion of these full disclosures, and if the Provider is ignored, it is the responsibility of the Provider to so inform the public; and further,

e. Ratings and targets shall not be issued as recommendations or stock price predictors, and should not be issued or published in the absence of a full, publicly-accessible report. Where a report has been issued previous to a public announcement, the research Provider has a responsibility to notice the investing public as to the date the report was previously issued, as well as who received the report.

4. Conflicts are inimical to credible professional research. Shareholders and investors need to feel comfortable that research is produced and published in an environment that is as free of Analyst influences as possible. Thus:

a. Analysts shall not own a stake in their ratings. Neither they nor principals of independent research Providers shall own or trade any form of equities of companies under coverage;

b. Analysts should be paid for their initial reports in advance, or if salaried, the Analysts' incomes shall not be dependent on the outcome of their reports; and

c. Independent research should not be under the control of an investment banking department, investor relations or promotional firm or department or executive, and shall not be produced or published under the auspices of an investment bank, investor relations or promotional firm or brokerage.

5. The Mission of the Standards-based independent research Provider is to provide the investing public with an ethical, qualified, transparent and conflict-lessened fundamental analysis of public companies and their equities. Thus:

a. Adopters of these "Standards for Independent Research Providers" agree to review by the FIRST Research Consortium Independent Research Standards Task Force, and agree that the Consortium may, at its sole determination, suspend, terminate or expel a Provider found to be in violation of these Standards.