To reinforce the Company's belief in linking the interests of management and shareholders, the Board has approved a stock ownership policy for JOE directors and senior management (defined as corporate senior vice presidents, regional presidents and above).  This policy specifies that senior management own a minimum number of shares or a minimum total intrinsic value of owned shares ranging from 5,000 shares (or $275,000 value) to 100,000 shares (or $5.5 million value).  The highest requirements of this range are applicable to those members of senior management having the highest level of authority and responsibility.  In the case of directors, the minimum number of shares required to be owned under the policy is 5,000 shares (or $275,000 value).  The Board approved this new policy on May 15, 2007, and senior management subject to this policy will have 5 years from this date, or date of appointment, to reach these minimum thresholds.

In order to provide diversification relief for senior management nearing retirement, the minimum required thresholds will be reduced 10% per year beginning at age 55.  The maximum reduction of these requirements will be 50%.

JOE shares held directly by senior management, or held in the 401(k) plan, employee stock purchase plan, deferred compensation accounts, in a trust for the benefit of immediate family members, and/or any unvested restricted stock will count toward satisfying the ownership requirement.  Anyone subject to this policy who does not meet the requirement may receive a portion or all of his/her annual cash bonus compensation in the form of restricted stock up to the point that the minimum requirement is met.  This restricted stock will have a vesting of one year.