Media Policy

Piper Jaffray is committed to establishing and maintaining effective, ongoing and mutually beneficial relationships with the media. Working with the media can help build awareness of the Piper Jaffray brand among clients and the general public and enhance the Company’s reputation as a client-focused securities firm dedicated to delivering superior financial advice, investment products and transaction execution to middle market companies, government, non-profit entities, and institutional and private investors.

The Piper Jaffray media relations team is dedicated to working in concert with business line partners to conduct media outreach which best positions Piper Jaffray and its employees as experts to clients, potential clients, shareholders and the public. This is accomplished by pitching and participating in stories specifically related to Piper Jaffray’s areas of expertise with select media outlets. These outlets include: select national and local print publications including trade publications, broadcast outlets and Internet outlets.

Additionally, the media relations team manages crisis communication events with a view toward reducing negative coverage and works to ensure that no material, non-public information is inadvertently disclosed during an interview.

In order to ensure the effectiveness of our media relations efforts and the consistency of our external brand and reputation, the following policy has been adopted to clearly define the process by which Piper Jaffray and its employees will work with the media.

Media Contact Generally

The Piper Jaffray media relations team is here to serve as your conduit to the media. In an effort to bolster Piper Jaffray’s interactions with the media and to ensure compliance with the Piper Jaffray Disclosure Policy, all media interview requests received by employees must be submitted to the media relations team for approval prior to the interview taking place. Employees are prohibited from contacting members of the media or otherwise pitching a story to the media regarding Piper Jaffray without prior approval from one of the media relations contacts.

Employees who communicate with the media without prior authorization may face disciplinary action.

Spokesperson Guidelines

The media relations team will use the following general guidelines when determining the appropriate spokesperson for a given topic:

Business Line Heads and Management Committee Members:

Division-wide announcements and initiatives, competitive position and broader market activity.

Senior Research Analysts:

Broader stock market commentary; trends and performance of a covered sector; investment outlook, competitive position and financial results of companies under coverage.

Investment Bankers:

Trends within a specific sector and M&A outlook.

Interviews Regarding Individual Companies Covered by Research:

The only employees authorized to discuss a company covered by a senior research analyst is that analyst. Only senior research analysts can make buy, sell or hold recommendations to the media (after being approved by Compliance and published).

Interviews Regarding Stock Market Performance:

In order to ensure consistency of the Company’s public stock market commentary, only designated spokespeople will be authorized to provide market commentary that airs on national broadcast and in national print outlets.

Interview Protocols

When communicating with the media, employees must comply with the following rules:

·  All employees must comply with the rules outlined in the Piper Jaffray Companies Disclosure Policy. Employees are prohibited from leaking or disseminating sensitive or non-public information to the media.

·  Research analysts also must comply with the policy outlined in the current version of the Piper Jaffray & Co. Investment Research manual.

·  Employees participating in media interviews speak for the Company as a whole, the Piper Jaffray brand and its Guiding Principles, not for themselves. Accordingly, employees who represent the Company in media interviews may not voice personal opinions that are not consistent with the Company’s views.

·  Employees may not comment on corporate issues, litigation, regulatory matters or political matters without prior approval from the media relations team, which will first obtain approval from the General Counsel department.

Press Releases

Press releases may be issued only through the media and investor relations teams. Business groups and individual employees are prohibited from writing and issuing their own press releases. As a general rule, Piper Jaffray will not participate in joint press releases with vendors. With prior approval from the Piper Jaffray Media Relations and General Counsel departments, the firm may permit press releases by third parties that mention the firm name as a new client with a description paragraph of the company.

Contributed Articles

Employees who are contacted or who wish to write a contributed or by-lined article for a publication, must bring the request to media relations. Media relations will work with employees to ensure that the firm’s overall messages are conveyed when appropriate and gain proper legal and compliance approvals.

Media in Piper Jaffray Offices

When members of the media come onto Piper Jaffray premises, they must be accompanied by a Piper Jaffray media relations professional or an employee designated by the media relations team at all times. This rule applies to all photographers, television-camera persons and reporters. Employees who suspect that a member of the media is in our offices without authorization should contact a member of the media relations team immediately. Contact information is available on Trading Post phone directory, select the Media Relations department.