Prohibition of Insider Trading

We adhere to a uniform Insider Trading Policy in all securities dealings. This means that directors, officers and employees who are considered to have knowledge of material facts or changes in the affairs of CHI that have not been disclosed to the public—including any information likely to affect the market price of the securities of the company—are prohibited from buying or selling the company’s securities during trading blackout periods.

Trading blackouts are required covering 5 calendar trading days before, and 2 calendar trading days after, the disclosure of quarterly and annual financial reports. CHI’s shares of stocks, options to purchase stocks, bonds and other evidence of indebtedness are all covered under this policy, as are all members of the Board of Directors, key officers (including their immediate families), consultants, advisers and employees who are made aware of undisclosed material information.

In 2019, our company required all directors and officers to disclose their transactions in shares of the company within three business days from the date of the transaction. Our company also requires employees to accomplish an annual disclosure statement. We were in full compliance with all laws and regulations, and thus no case was found of any violation of the company’s policy in 2019.