The Board of Directors will also be responsible for adopting and periodically reviewing and updating the written disclosure policy for Northstar and its subsidiaries. This policy will, among other things:

• articulate Northstar’s legal obligations, its affiliates and their respective directors, managers, officers and employees with respect to confidential information;
• identify spokespersons who are the only persons authorized to communicate with third parties such as analysts, media and investors;
• provide guidelines on the disclosure of forward-looking information;
• require advance review by senior executives of any selective disclosure of financial information to ensure the information is not material, to prevent the selective disclosure of material information and to ensure that if selective disclosure does occur, a news release is issued immediately;
• establish “black-out” periods immediately prior to and following the disclosure of quarterly and annual financial results and immediately prior to the disclosure of certain material changes, during which periods Northstar and its subsidiaries and their respective managers, officers, employees and consultants are restricted with respect to the buying or selling of Northstar securities.