Steven Hall & Partners | Independent Executive Compensation Consultants

OUR INDEPENDENCE
Our independence is critical to our reputation and our livelihood, and we guard it vigilantly.  Our founding partners have long held the belief that regardless of whether we are retained by the Compensation Committee or management, our advice and viewpoint should always be driven by what is in the best interests of shareholders.  This recognition that our positions, views and recommendations are driven by our commitment to shareholders assures that we will always act in a manner that is independent and unbiased.

We carefully follow the actions of the SEC as they draft guidance regarding the Dodd-Frank requirement that the Compensation Committee consider independence factors when selecting independent advisors.  We have reviewed the five factors proposed on March 30, 2011 by the SEC and expect to have no difficulties in complying with these standards.  We will continue to monitor this issue throughout the SEC comment period and through implementation by the listing exchanges to ensure that we remain in compliance.