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FSA HOLDINGS INC.
INSIDER TRADING POLICY
(Amended as of May 6, 2015)
This Insider Trading Policy (this Policy) provides guidelines to directors, officers,
employees and consultants of FSA Holdings
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How to fill out this insider trading policy

How to fill out this insider trading policy?
01
Start by reviewing the policy document carefully to understand the requirements and guidelines outlined.
02
Identify the key individuals or stakeholders who will be responsible for complying with and enforcing the policy. This may include top management, shareholders, directors, employees, and consultants.
03
Customize the policy to the specific needs and characteristics of your organization. This may involve incorporating industry-specific regulations or tailoring the policy language to align with your company's values and culture.
04
Clearly define what constitutes insider trading within your organization. This should include examples of prohibited activities, such as trading based on non-public material information or sharing confidential information with others for personal gain.
05
Outline the procedures for reporting potential insider trading violations. This should include a designated reporting channel and the steps to be taken if a violation is suspected or identified.
06
Provide guidance on how to maintain confidentiality and handle material non-public information appropriately. This may involve implementing strict information security measures, such as restricted access to sensitive data or required training for employees.
07
Communicate the insider trading policy to all relevant parties within the organization. This can be done through employee training sessions, email notifications, or posting the policy in a conspicuous location.
08
Encourage employees to seek clarification or ask questions about the policy. This can be achieved by providing a contact person or a designated compliance officer who can address any concerns or uncertainties.
09
Regularly review and update the insider trading policy to ensure it remains up-to-date and compliant with any changes in regulations or industry practices.
Who needs this insider trading policy?
01
Publicly traded companies: Companies listed on stock exchanges or publicly traded have a legal obligation to prevent insider trading. Having an insider trading policy helps guide employees and stakeholders to understand their responsibilities and comply with relevant regulations.
02
Financial institutions: Banks, investment firms, and other financial institutions are particularly susceptible to insider trading due to their access to sensitive financial information. Implementing an insider trading policy is crucial to maintain the integrity and trustworthiness of these organizations.
03
Corporate organizations: Even companies that are not publicly traded can benefit from having an insider trading policy. Ensuring employees are aware of the restrictions and ethical considerations surrounding insider trading can help prevent potential legal and reputational risks.
04
Employees and stakeholders: Anyone who has access to non-public material information about a company, such as employees, directors, or consultants, should be aware of their responsibilities and obligations regarding insider trading. Implementing an insider trading policy helps create a culture of compliance and ethics within the organization.
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What is this insider trading policy?
This insider trading policy is a set of rules and regulations that govern the buying and selling of company securities by individuals who have access to non-public information.
Who is required to file this insider trading policy?
All employees and insiders of the company are required to file this insider trading policy.
How to fill out this insider trading policy?
The insider trading policy can typically be filled out electronically through a secure portal provided by the company.
What is the purpose of this insider trading policy?
The purpose of this insider trading policy is to prevent insider trading and ensure fair and transparent trading practices within the company.
What information must be reported on this insider trading policy?
The insider trading policy typically requires individuals to report any transactions involving company securities and to disclose any material non-public information they possess.
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