Insider Trading Policy

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Purpose
Statement of Policies Prohibiting Insider Trading
Explanation of Insider Trading
Excluded Transactions
Pre-Clearance Procedures and Trading Restrictions for Officers, Directors and Designated Employees
Rule 10b5-1 Plans
Special and Prohibited Transactions
Post-Termination Transactions
Consequences of Violations
Company Assistance
Individual Responsibility
Certification

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NYSE:JOE
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12-15-17
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