in any other action to take advantage of, or pass on to others, that information. Policy on Hedging and Pledging of NW Holdings Securities NW Holdings has adopted a Policy on Hedging and Pledging of Securities which prohibits the directors and executive officers of the Company and its subsidiaries from engaging in any short sales, zero-cost collars, or forward sale contracts with respect to the Company’s securities, or purchasing or selling puts, calls, options, or other derivatives securities based on the Company’s securities.