Transaction Code Definitions General Transaction Codes P – Open market or private purchase of securities S – Open market or private sale of securities V – Transaction voluntarily reported earlier than required Rule 16b-3 Transaction Codes A – Grant, award, or other acquisition D – Sale (or disposition) back to the issuer of the securities F – Payment of exercise price or tax liability by delivering or withholding securities I – Discretionary transaction, which is an order to the broker to execute the transaction at the best possible price M – Exercise of conversion of derivative security Derivative Securities Codes C – Conversion of derivative security (usually options) E – Expiration of short derivative position (usually options) H – Expiration (or cancellation) of long derivative position with value received (usually options) O – Exercise of out-of-the-money derivative securities (usually options) X – Exercise of in-the-money or at-the-money derivatives securities (usually options) Other Sections 16b Exempt Transactions and Small Acquisition Codes G – Bona fide gift L – Small Acquisition W – Acquisition or disposition by will or laws of descent and distribution Z – Deposit into or withdrawal from voting trust Other Transaction Codes J – Other acquisition or disposition (transaction described in footnotes) K – Transaction in equity swap or similar instrument U – Disposition due to a tender of shares in a change of control transaction