Introduction
Carbon360 is committed to conducting our business to the highest standards of business practices, and to preserving the integrity of our brand. We expect every Carbon360 associate to work with integrity and professionalism.

This Carbon360 Principles of Ethical Conduct represents our attempt to define Carbon360's expectations of how each of us conducts ourselves every day. We cannot anticipate or define standards of behavior for every situation that might arise. We must use our best judgment and moral sense to perform our job responsibilities in an ethical manner within both the letter and spirit of this Policy and Carbon360's other policies. This Policy is not intended as a substitute for Carbon360's other more detailed policies that relate to standards of conduct.

Comply With Applicable Laws
Carbon360 takes seriously our collective obligation to adhere to all laws that govern our personal and professional actions. Analysts must strictly comply with all applicable laws and regulations of the jurisdictions where Carbon360 does business. While not an exhaustive list, this includes complying with laws and regulations concerning Financial Reporting, Insider Trading, Antitrust, Copyright, Foreign Corrupt Practices and Data Protection.

Provide Objectivity
Carbon360 is an independent, privately owned research and consulting firm that provides technology and business strategy resources to the financial services industry. Carbon360 provides unbiased insight to industry trends, competitors in the market, and market sizes. Carbon360' research reports are written by in-house analysts with extensive experience at a variety of top global financial services firms, technology vendors, and consultancies.

Carbon360's research clients include financial institutions, vendors, and consulting firms. Occasionally, these solution providers will be evaluated in our reports, along with providers with whom Carbon360 does not have a relationship. Carbon360 evaluates all vendors using the same criteria, whether or not they use our research and advisory services.

Vendors and financial institutions profiled in our reports are given the opportunity to correct factual errors prior to publication, but cannot influence Carbon360's analysis or opinions of the products, solutions, or strategies that we are evaluating. Firms may not purchase or influence positive exposure.

Avoid Conflicts Of Interest
Analysts avoid situations where actual conflict of interest exist with Carbon360, or where the appearance of a conflict of interest may be perceived. This includes not engaging in any outside employment without the prior written permission of senior management, not having a financial interest in, or affiliation with, competitors of Carbon360, not serving on outside Boards of Directors without senior management approval, not accepting valuable gifts from business contacts, and not engaging in political activities with Carbon360 funds, equipment, facilities or supplies. Additional restrictions may apply to analysts depending on position and job responsibilities at Carbon360. For example, Analysts must not have a financial interest in companies that do business or seek to do business with Carbon360 if analysts are in a position to influence decisions affecting that business.

Methodology
The findings and analyses in Carbon360's reports reflect our analysts' opinion and research of market trends, sizes and participants. When citing third party data or opinions Carbon360 provides sources of information. When citing formal survey results Carbon360 provides as much information as possible about the survey methodology and participants, within the limits of confidentiality. All other material appearing in Carbon360s reports is created by the analyst and is derived of from the Carbon360’s analysis.

Protect Carbon360's and Our Clients' Confidential Information
Carbon360 considers all of its business information, whether about Carbon360 or others, to be confidential and important business assets. All analysts comply strictly with signed confidentiality agreement with Carbon360, Company policy and the law, and protect the confidentiality of both Carbon360's business information and the business information of our clients. Even if analysts leave Carbon360 they carefully protect information provided by clients who have been promised confidentiality. In addition, analysts never use improper means to obtain the confidential information of any other person or business.

Act Ethically In the Handling and Reporting of Data
Carbon360 relies on each Analyst to use the highest degree of personal integrity in reporting any kind of data or information to the Company, to our clients, and to the financial community. It is our analysts' responsibility to provide complete and accurate information when it is requested, and to input only accurate information into the Company's books and records. Any records, expense reports, financial reports and other data presented to Carbon360, our clients, and other appropriate parties must be complete and accurate. These obligations have a special significance for Carbon360's financial management associates, who are uniquely capable and empowered to ensure that the interests of all those who have a stake in Carbon360's financial integrity are appropriately balanced, protected and preserved.