THESTREET.COM, INC.

CODE OF BUSINESS CONDUCT AND ETHICS

Introduction

This Code of Business Conduct and Ethics embodies the commitment of TheStreet.com, Inc. and its subsidiaries to conduct its business in an honest and ethical manner, in accordance with all applicable laws, rules, and regulations. All of our employees, as well as directors and outside contributors to our publications, are expected to adhere to the provisions of this code that apply to them.

TheStreet.com’s reputation for honesty, integrity, and editorial independence in the marketplace is central to our success as a business. Accordingly, all of us have a personal responsibility to conduct ourselves in a way that reflects positively on our company and that is in keeping with the letter and spirit of the law and the principles set forth in this code.

No written policy could possibly cover every business situation or ethical issue that may arise amidst the challenges of conducting business in a complex and rapidly changing environment. However, the code is intended to articulate standards of ethical conduct that should apply to all business dealings and activities of the company.

General Principles

Everyone associated with TheStreet.com should be guided by the following general principles in deciding what course of action to take in any particular circumstance.

Ethical Behavior

Your decisions and behavior can have far-reaching implications for you as an individual and on TheStreet.com as a corporation. Working at TheStreet.com means acceptance of individual responsibility for behaving in an honest and ethical manner in the pursuit of TheStreet.com’s business objectives.

Compliance with Laws, Rules, and Regulations

We as a firm must respect and obey all of the laws, rules, and regulations that apply to our business. TheStreet.com, a registered investment advisor, and Independent Research Group LLC, our registered broker dealer subsidiary, have policies and procedures designed specifically to meet applicable laws, rules, and regulations. Managers of each business unit are responsible for establishing (with the assistance of the Legal Department) procedures sufficient to ensure that their business units operate in compliance with the laws, rules, and regulations that apply to them. Although you as an employee are not expected to know the details of every law or rule affecting the business, it is your responsibility to become familiar with and comply with firm-wide policies and procedures, and those of your business unit. If you are
 

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