Last revised: March 23, 2009

TheSmallCapInvestor.com, is a publication of The Small Cap Investor LLC. The website is a news and information distribution service designed to act as a single, consolidated, meeting location for small cap stock research published by analysts and the investors who seek that research.

Our objective from inception has been that investors need a place where they can get professional equity research and the analysts need a distribution point. TheSmallCapInvestor.com believes that under this scenario, we can serve both the investor and the analyst without any conflicts of interest.

The ultimate goal of our site is to assist individual investors in the gathering of their due diligence on small cap stocks (market capitalizations under $2 billion). Investors need independent sources from which they can make investment decisions and our goal as a publisher of financial information is to provide a platform for investors to gather information in a consolidated location.

TheSmallCapInvestor.com’s Disclosure Policy has been designed to keep subscribers aware of any conflicts of interest in any security that may be owned by The Small Cap Investor, LLC, its Directors, Officers or Employees (including immediate family members) as well as the ownership and financial interests of the contributors who write stories for our web site publication.

TheSmallCapInvestor.com allows employees to invest in companies discussed on this forum, however, when an employee becomes aware of any material non-public information, he/she is prohibited from transactions in the affected security until the information has been released in a public press release by the company or via regulatory filing.

At the end of each and every article authored and published by our site, the contributors responsible for writing the article are required to disclose any financial interest they may have or had in the past 12 months regarding any companies in the article. Financial Interest include direct share ownership in an account controlled by the author of an article or an immediate family member, as well as any type of compensation they have received during the prior year by the company being discussed.

Our site also features Independent Stock Research. All analysts who submit research reports to our site must include a disclosure section in their report that clearly demonstrates if they have received any type of financial compensation for there coverage. Some of the analysts on this site write Sponsored Research, meaning they have received some level of compensation to provide the Issuer research coverage on its publicly traded stock. These analysts are required to disclose such compensation, as well as their stock position, if any, at the time of publication.

Our website also features analysts who write Proprietary Research material. In the case of Proprietary Research, the analyst, or his/her firm, has not received any compensation for the analyst coverage being maintained on an Issuer. In such case, the analyst, and his/her firm, may seek to offer their equity research for purchase by the investment community. TheSmallCapInvestor.com website has been designed to increase the awareness of an analysts research coverage and may offer the reports on our site for sale. The Small Cap Investor LLC has revenue sharing arrangements in place with analysts who sell proprietary research on our website as a form of our revenue generation process.

Regardless of whether a research report is Sponsored or Proprietary, the information included in such report is solely the independent thoughts and commentary of the analyst writing the report. Additionally, contributors to featured columns on the site also maintain their independence from our control or influence. As a matter of policy, The Small Cap Investor LLC nor TheSmallCapInvestor.com and their editorial staff, have no control or influence on the material submitted by analyst and editorial contributors in any section of website. The only control our editorial staff has in regards to any material submitted to the site by independent, outside contributors is whether to allow the material to be posted on the site or whether to decline the inclusion of the material in its entirety.

Our firm has 4 (four) primary sources of revenue generation.

First, we sell advertisements on our website to brokerage firms, web sites, and investment publications among others who seek to advertise on our network. TheSmallCapInvestor.com cannot make any warranties as to the compensation policies of these organizations, and in no way endorses their offers, services, or the content contained within their advertisements.

Our second form of revenue generation is in the sale of Premium Memberships. Free Subscribers can upgrade to a Premium Membership and receive certain features designed strictly for Premium Members. Such Premium features included real-time delivery of The Meehan Report, access to Proprietary Research Reports, special event invitations and more.

Our third form of revenue generation is via the sale of Proprietary Research Reports submitted to the website by Independent Research Firms for distribution across our network. The Small Cap Investor LLC maintains revenue sharing agreements with all analysts who have research featured on our website. When a Free Member selects to purchase a Proprietary Research Report, the member will select the report and pay for each report on a per download basis. Our company receives a percentage of this fee as compensation to cover the operational costs of running the website..

Lastly, The Small Cap Investor LLC may from time to time accept compensation from publicly traded companies, or third parties acting on the behalf of public companies, including cash, stock, and options or warrants for advertising services on TheSmallCapInvestor.com which are provided to those companies. Such advertisements include premium rotation in the Research Spotlight section, advertisements in locations within the site designed as advertisement locations, as well as special features and promotions that the Issuer may wish to communicate to investors.

The Small Cap Investor LLC, through its website TheSmallCapInvestor.com is an independent publisher of investment information. The company does not write research and does not receive compensation in exchange for coverage of publicly traded companies. The only compensation received in connection with research coverage of publicly traded companies that our company receives is in regards to the revenue share of research reports downloaded from out site on a per download basis to cover operational costs of running the website.

For questions or comments regarding this Disclosure Policy, please contact: editor@thesmallcapinvestor.com.