First and foremost, Gates Capital Corporation's ("GCC") policy is to provide our customers with the best possible execution available. GCC transmits customer orders for execution to various exchanges or market centers based on a number of factors. These include: size of order, trading characteristics of the security, favorable execution prices (including the opportunity for price improvement), access to reliable market data, availability of efficient automated transaction processing and reduced execution costs through price concessions from the market centers. Certain of the market centers may execute orders at prices superior to the publicly quoted market in accordance with their rules or practices. While a customer may specify that an order be directed to a particular market center for execution, the order-routing policies, taking into consideration all the factors listed above, are designed to result in favorable transaction procession for customers.

GCC does not receive any payment or credit for directing orders as described above.