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This Policy is incorporated by reference into the main Terms of Service for Porter & Company, LLC (referred to as the “Publisher” or “Porter & Co.”). By accessing and using the comment sections (“Forum”) associated with our financial publications, you explicitly agree to these terms. Failure to comply will result in the immediate removal of your content and may lead to the suspension or termination of your subscription without refund.

Section 1: Legal Disclaimer and Publisher’s Exemption

CRITICAL NOTICE: The content published by Porter & Co. (including, but not limited to, newsletters, articles, and reports) is produced in reliance upon the statutory exclusion from the definition of “investment adviser” under Section 202(a)(11)(D) of the Investment Advisers Act of 1940 (the “Publisher’s Exclusion”).

1. NO PERSONALIZED ADVICE: This Forum is intended only for the impersonal discussion of general financial and economic topics, market trends, and information published in our newsletters. PORTER & CO. DOES NOT PROVIDE PERSONALIZED INVESTMENT ADVICE.

2. NO FIDUCIARY DUTY: Your use of this Forum, or any communication with our staff or other subscribers within this Forum, does not create an investment advisory relationship or any fiduciary duty between you and Porter & Co. or its affiliates.

3. INFORMATIONAL USE ONLY: All information, recommendations, or opinions posted by the publisher and by other subscribers are for informational and educational purposes only. You must consult your own qualified financial professional before making any investment decisions.

Section 2: Prohibited Content and Activity

To protect the integrity of the Publisher’s Exclusion and comply with securities laws, the following activities are strictly prohibited in the Forum:

A. Prohibition on Personalized Investment Advice

1. Soliciting Advice: You may not ask the Publisher or any other subscriber for specific advice tailored to your personal financial circumstances, investment objectives, or specific portfolio holdings. Prohibited questions include, but are not limited to: “Should I buy more of stock X right now?” or “Given my age and risk tolerance, what should I do with my position in Y?”

2. Providing Advice: You may not post comments that constitute personalized investment recommendations to any specific individual subscriber.

3. Portfolio Discussion: You may not disclose or solicit information regarding specific individual portfolio values, asset allocations, account balances, or transaction histories.

B. Prohibited Market Practices

1. Manipulation: You are strictly prohibited from posting false or misleading information, engaging in “pump and dump” schemes, or any activity intended to manipulate the price or trading volume of any security.

2. Insider Information: You may not post any material, non-public information about a security or company.

3. Fraudulent Statements: You may not post content that is fraudulent, libelous, or defamatory.

C. Publisher Employee Contact

1. Employees of Porter & Co. may participate in the Forum for general discussion and to answer administrative questions. However, they are strictly prohibited from answering any question that solicits personalized investment advice. Any attempt to contact a staff member outside the Forum regarding your personal portfolio will be disregarded.

Section 3: Transparency and Disclosure Requirements

1. Required Disclosure of Financial Interest: You are required to disclose any financial interest (e.g., direct ownership, options, short positions) in a security or company if you post content that recommends, promotes, or expresses strong enthusiasm or negative sentiment regarding that security.

Example Disclosure: “I own 500 shares of $XYZ$.”

2. Affiliation Disclosure: If you are an investment adviser, broker-dealer, or other financial professional, you must disclose your professional status when posting.

Section 4: Moderation and Enforcement

1. Right to Moderate: Porter & Co. reserves the unqualified right, but not the duty, to review, edit, and remove any comment or content at its sole discretion, without warning or explanation, if the content is deemed to violate this Policy, any law or regulation, or the spirit of the Publisher’s Exclusion.

2. Enforcement: Violations of this Policy, particularly those related to personalized advice or market manipulation, may result in:

Immediate deletion of the offensive content.
Issuance of a formal warning.
Immediate and permanent termination of your subscription and access to the Forum, without a refund.

3. No Guarantee of Monitoring: While we actively monitor the Forum, we cannot guarantee that all unlawful or prohibited content will be identified or removed immediately. Users are solely responsible for their posts.

Section 5: Indemnification

You agree to indemnify, defend, and hold harmless Porter & Co. and its officers, directors, employees, and agents from and against any claims, liabilities, damages, losses, and expenses, including reasonable attorneys’ fees, arising out of or in any way connected with your violation of this Policy.

Last Updated: December 5, 2025

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