Green Markets Rebar Employee Code of Ethics

This Code of Ethics reflects the key policies and principles governing Green Markets Rebar employees’ work

These policies, are attested to and confirmed by any person including interns, temporary, contract and permanent workers, or any other person having access to Green Markets Rebar pricing or data prior to publication. They are designed to ensure that all employees understand and conduct our business in a highly ethical, responsible and honest manner, and in compliance with all applicable policies, laws and regulations.

As an Employee, I understand that I have an obligation to conduct myself and our business with the highest ethical standards, with integrity and within guidelines that prohibit actual or potential conflicts of interest or the perception of impropriety. By executing this document, I attest that:

a) I will adhere to all applicable policies, laws regulations, and the methodology and standards publicly available at https://green-markets.com/Steel/methodology/;

b) I will not engage in any new content production or product development activities, or other such interactions without the prior approval of Compliance and management;

c) I am unaware of any potential or actual conflict of interest that may impair my ability to abide by the Code or my ability to ethically meet my Green Markets responsibilities;

d) I understand that I am prohibited from transacting (whether directly or indirectly) in any individual equities, bonds or other financial instruments (including commodities, industry-specific mutual funds or any other targeted investment) in or issued by companies or industries Green Markets covers, other than through broad-based funds or managed accounts where I have no knowledge of, or input into, holdings and/or investment decisions;

e) I will not short sell securities, sell securities for a profit within 30 days of purchasing them, or trade in derivative instruments;

f) I will avoid activities that may violate laws and regulations, such as tipping or trading on confidential information of material non-public information;

g) I will not disclose confidential information or material non-public information obtained in connection with my employment to anyone outside of Green Markets (including, but not limited to, my parents, siblings, spouse, partner or roommates) for any purpose other than one that is related to my specific role with Green Markets;

h) I understand that I cannot provide or communicate (i) investment advice, (ii) data or analysis customized or tailored for certain customers or groups of customers or (iii) data or analysis that has not yet been released to all customers;

i) I will submit all marketing materials to Compliance for approval. Marketing materials are meant to promote the business or an individual analyst and include any broadly disseminated e-mails (this includes e-mails that are sent to a large group of people at once and also form e-mails that are sent individually to one person at a time) or other written communications subject to any level of client dissemination;

j) I may not give or accept any form of remuneration, gift or compensation from companies that are the subject of, or may be materially affected by, my work for Green Markets;

k) I have and will promptly disclose to Compliance and management all Outside Business Activities (defined below) in Exhibit A to this document;

If I do not understand a concept discussed here, or am unsure of any course of action that they address, I will seek the guidance of Compliance.

It is the Employee’s responsibility to report any suspected violations of policies, laws and regulations to Management, Compliance, or Human Resources, or to contact the company’s Anonymous Ethics Hotline.

Questions regarding the methodology or compliance thereto should be directed to:

Green Markets Rebar
attn: Daniel Houder, Managing Director
P.O. Box 190
Sullivan, NH 03445
USA