Code of Ethics

It is the Company’s intention to promote:

  • Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships
  • Full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, the Securities and Exchange Commission and in other public communications made by the Company
  • Compliance with applicable governmental laws, rules, and regulations
  • The prompt internal reporting of violations of this Code of Ethics to the Chairman of the Audit Committee of the Board of Directors (or any member of that committee as the reporting person may choose)
  • The accountability of all Company officers for adherence to this Code of Ethics

The Company will make available to the public a copy of this Code of Ethics by filing it as an exhibit to its annual report and by providing it on the Company’s Internet Web site.

Fair Disclosure Policy

ReposiTrak (the “Company”) is committed to the fair disclosure of information about the Company consistent with the Securities and Exchange Commission’s Regulation FD. Our Fair Disclosure Policy (i) prohibits the selective disclosure of material, non-public information about the Company, (ii) sets forth certain procedures that will help prevent such selective disclosure, and (iii) provides for the broad, public distribution of material information regarding the Company.

Insider Trading and Unauthorized Disclosure Policy

This Insider Trading and Unauthorized Disclosure Policy provides guidelines to employees, officers and directors of, and consultants and contractors to ReposiTrak with respect to transactions in the Company’s securities.

ReposiTrak Whistleblower Policy

Procedures for the Submission of Complaints are described in this document. Any employee of the Company may submit, on a confidential, anonymous basis if the employee so desires, any good faith concerns regarding financial statement or other disclosure, accounting, internal accounting or disclosure controls, auditing matters or violations of the Company’s Code of Conduct.

Board Diversity

The table below provides certain highlights of the diversity characteristics of our directors:

Board Diversity Matrix

(As of October 4, 2022)
Total Number of Directors 4

Female Male Non-Binary Did Not Disclose Gender

Part I: Gender Identity

Directors 4

Part II: Demographic Background

African American or Black
Alaskan Native or Native American
Hispanic or Latinx
Native Hawaiian or Pacific Islander
White 3
Two or More Races or Ethnicities
Did Not Disclose Demographic Background 1*