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di Giancarlo Nicoli

Giancarlo Nicoli adheres to

Seeking Alpha’s Gold Standard Compliance

 1. Author qualification
* Authors attest that they have never been prosecuted on any securities-related issue, that they have never been barred from the securities industry, or convicted of a felony. (If you cannot agree to point 1 above but would still like to become a Seeking Alpha contributor, please contact us at contributors@seekingalpha.com).

 2. Disclosure of positions and intention to purchase securities
* Authors agree to disclose the existence at the time of writing of a long or short position (including stocks, options or other instruments) in any stock mentioned in an article. The suggested form of disclosure is to add the disclosure in the following format to the bottom of articles: “Disclosure: Long GOOG at time of writing”. If the author has no position in stocks mentioned, that should be indicated in the following format: “Disclosure: No position in stocks mentioned’
* Authors may not write about a stock with the intention to boost or reduce the stock’s price and sell (or buy) the stock into the resulting strength or weakness.
* If the author intends at the time of writing to sell or buy a stock within three days of publication of an article that discusses that stock, the author must disclose this.

 3. Disclosure of business relationships and conflicts of interest; no Investor Relations professionals
* Authors agree to disclose in the footer of posts any and all personal, material relationships with companies whose stocks they write about, or personal, material relationships with parties that stand to gain from the viewpoint they are outlining. Examples: authors must disclose if they are employed by a company whose stock they are writing about; perform consulting for a company they write about; receive paid advertising revenue or any other form of sponsorship fee from a company they write about. This applies to narrow asset classes as well. For example, if an author is paid to promote a gold dealer, that must be disclosed in any article about gold.
* Authors may not work in the field of investor relations. We will not accept articles from authors who work in the field of investor relations, even if the article focuses on companies with which the author has no business relationship.

4. Non-Infringement of Copyright

* Authors attest that any articles submitted for publication to Seeking Alpha do not infringe upon the rights of any other party. If other sources are quoted, the source must be clearly cited (and linked to when possible) and the quote must be within the parameters of Fair Use.

 5. Commitment to Accuracy
* Authors certify that all facts in articles submitted to Seeking Alpha are accurate to the best of his/her knowledge.

6. Author’s websites, promotion and other material

* Authors’ web sites, which Seeking Alpha will be asked to link to, may not contain any illegal material, racism or pornography.
* Authors must substantiate publicly any claims regarding their investment track records that are stated on their web sites, if such a claims are made.
* Authors may not make any guarantees or explicit predictions regarding the market performance that subscribers to their paid newsletters or other services can expect.
* Authors’ web sites must not contain sensationalist language about stocks, e.g. “rocket” or “set to soar.”

 7. Anonymity and accountability
* Authors agree to provide their real names, phone number and an active email to Seeking Alpha, even if they intend their articles to be published anonymously under a pseudonym.

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