SEC Rule 10b5-1 allows executives of public companies to adopt pre-arranged stock trading plans when they are not aware of any material nonpublic information about the company. These plans permit executives to diversify their investment portfolio gradually in order to minimize the market effects of stock sales by spreading sales out over an extended period of time rather than only carrying out sales during limited trading “windows” following public earnings and other disclosures. Once a plan is established, the executive does not retain or exercise any discretion over sales of stock under the plan and the pre-planned trades can be executed at later dates as set forth in the plan, without regard to any subsequent material nonpublic information that the executive might later become aware of.

St. Mary Land & Exploration Company’s insider trading policy facilitates the adoption of Rule 10b5-1 plans. St. Mary executives may adopt such plans from time to time in order to diversify their holdings of St. Mary stock.

Currently, there are no Rule 10b5-1 Plans in effect for any St. Mary executives.