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Disclosure

Date Issued: May 20, 2009

Global Commodity Investing, published by Business Financial Publishing LLC, is an investment newsletter advisory that is built on the premise of assisting individual investors in learning about growth stocks. Our goal as publishers of financial information and individual investors is to be as independent as possible, and to put the interests of our subscribers above all else.

We strive to find the best possible investments for our subscribers, and in no way want that to be tarnished. For this reason, we have decided to issue a formal disclosure policy.

Global Commodity Investing encourages its employees to invest in individual stocks. We believe that in doing so, we are better able to understand the stock market and share this knowledge and our experiences with subscribers. After all, who would want to join an investment newsletter where the employees never made their own investments?

Further, Global Commodity Investing does permit its employees to invest in companies discussed within the newsletter. We have however put in place strict restrictions and disclosure policies in order to put the interests of our subscribers first and foremost.

Below you will find the details of this policy.

Disclosure

Our full disclosure policy is designed to keep you fully aware of any stocks that are owned by employees of Global Commodity Investing and also discussed within the newsletter.

When we mention a company within an issue of the newsletter and an employee or writer owns the stock in an investment account they control (directly or indirectly), that position is fully disclosed.

All companies covered within the newsletter that are also owned by employees are listed at the bottom of each issue or article in the Disclaimer, whether the issue is sent by email or posted on the web site.

Trading Restrictions

In addition to full disclosure, we have also developed trading restrictions which apply to all personnel. These restrictions apply to stocks covered within Global Commodity Investing and held within the Global Commodity Investing Portfolio.

  1. Once the Editor or writers have decided to begin coverage of a new company, that company is placed on a "Restricted List" which bars trading in a company effectively immediately, and further bans trading for thirty days after the date of the publishing of that article. Employees must disclose any positions in companies on the Restricted List immediately.
  2. In the event that BFP Personnel do own shares, BFP will not publish an initial report that company until five business days have passed from the date of the most recent transaction.
  3. BFP Personnel cannot buy or sell shares for thirty days after the issuance of an initial report on a company. Since many companies are mentioned on a weekly basis in the Portfolio Update issues, this restriction only applies to initial research reports.

  4. No "tipping" non-employees of a report which will be written about a specific company in advance.

Compensation

Our main source of compensation comes from subscribers who pay a subscription fee for Global Commodity Investing. Thus our core interest is to work toward the benefit of our growing base of members.

Global Commodity Investing is an independent newsletter service, and is does not receive compensation in exchange for coverage of publicly traded companies.

We do sell advertising to other companies including brokerage firms, web sites, and investment publications among others. Global Commodity Investing makes no warranty as to the compensation policies of these organizations, and in no way endorses their offers, services, or the content contained within their advertisements.

 

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