Is this speculation feasible?

Possible explanation: if management is negotiating a material deal and certain trading restrictions are in force.

INSIDER TRADING POLICY

This Policy applies to all transactions in the Company’s securities, ----.

It applies to all officers of the Company, all members of the Company’s Board of Directors, and to any person who possesses Material Non-public Information regarding the Company.

To ensure compliance with this Policy and applicable securities laws, all directors, officers and employees having access to the Company’s Material Non-public Information shall refrain from conducting transactions (Black-out Period) involving the purchase or sale of the Company’s securities during the period.

Examples of material information include, but are not limited to:

· major acquisitions or dispositions by the Company;

· the signing of important contracts involving the Company or the loss of important contracts;

· exploration, mining, permitting, environmental or financial matters; or

· significant changes in management at senior levels or on the board of directors.