Remember, all your transactions in Polaris securities are subject to Polaris’ Insider Trading Policy.

The Chief Compliance Officer will be responsible for establishing, implementing, monitoring and enforcing all of Nuance’s policies and procedures regarding insider trading. If any supervised person is unsure whether information could violate Nuance’s policies and procedures on insider trading or has questions on any aspect of Nuance’s policies and procedures on insider trading, questions should be directed to the Chief Compliance Officer prior to implementing any trades. The prohibition on the use of inside information extends to family members, associates and acquaintances of the person coming into possession of such information.

You understand that your country may have insider trading and/or market abuse laws which may affect your ability to acquire or sell Shares during such times you are considered to have “inside information” (as defined in the laws in your country). The restrictions applicable under these laws may be the same or different from Walmart’s insider trading policy. You acknowledge that it is your responsibility to be informed of and compliant with such regulations and any applicable Walmart insider trading policy, and are advised to speak to your personal legal advisor on this matter.

Trading Policy Restrictions. Option exercises and other Awards under the Plan shall be subject to the Company’s insider trading policies and procedures, as in effect from time to time.

Other Documents. You acknowledge receipt of the Company’s insider trading policy and agree to comply with its terms.

To ensure alignment of interest with the Company’s stockholders, each of the Company’s directors is required to comply with the terms of the Company’s Stock Ownership and Retention Policy for Executive Officers and Directors. Non-Employee Directors are subject to the Company’s Insider Trading Policy, as in effect from time to time, including, but not limited to, restrictions on trading in the Company’s securities and entering into hedging transactions (each as further described in the Insider Trading Policy).

The Chief Compliance Officer will perform the following procedures no less than quarterly for the purpose of detecting insider trading:

all Participants remain subject to all applicable legal and regulatory restrictions such as insider trading restrictions and black-out periods.

Section # of the Exchange Act and Insider Trading Compliance - Any purchases or sales of the Company’s common stock that occur under the Program are, for the avoidance of doubt, subject to Section 16 of the Exchange Act, including the reporting and short-swing profits rules thereunder, and to the Company’s insider trading policy and other applicable policies as in effect from time to time.

I certify that if I transfer the stock purchased by this exercise I will not do so in a manner that violates Cortland Bancorp’s policy on insider trading.