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INSIDER TRADING POLICY AND GUIDELINES As a public company, Northern Power Systems Corp. (Northern Power or the Company) and its officers, directors and employees are subject to the requirements and
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How to fill out insider trading policy and

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How to fill out insider trading policy:

01
Review the company's existing insider trading policy, if one exists. Familiarize yourself with its contents and ensure that it aligns with current regulations and best practices.
02
Identify the individuals who should be involved in the policy development and review process. This may include members of the legal team, compliance officers, senior executives, and members of the board of directors.
03
Conduct thorough research on insider trading laws, regulations, and guidelines applicable to your jurisdiction and industry. Understand the specific requirements and restrictions that need to be covered in the policy.
04
Begin drafting the policy by including a comprehensive definition of insider trading. Clearly outline what constitutes insider trading and provide examples to ensure a shared understanding among employees.
05
Specify who falls under the definition of insiders within the organization. This may include employees, board members, contractors, consultants, and other individuals who have access to confidential or non-public information about the company.
06
Outline the procedures and restrictions that must be followed by insiders to prevent insider trading. This may include pre-clearance requirements for trading in company securities, trading blackout periods, and limitations on trading based on material non-public information.
07
Provide guidelines for reporting and disclosing potential violations of the policy. Establish a process for reporting suspicions of insider trading and ensure there are no repercussions for employees who come forward with information.
08
Review and revise the policy with the involvement of key stakeholders, legal advisors, and compliance experts. Ensure that the language used is clear, concise, and easily understandable for all employees.
09
After finalizing the policy, disseminate it to all employees and provide training sessions to ensure awareness and understanding of the policy's provisions. Employees should be made aware of the consequences of non-compliance with the insider trading policy.
10
Regularly review and update the insider trading policy to reflect changes in regulations, industry practices, and internal procedures. Stay abreast of developments in insider trading laws and adjust the policy accordingly.

Who needs insider trading policy:

01
Publicly traded companies: Any company that is publicly listed on a stock exchange should have an insider trading policy to comply with legal and regulatory obligations.
02
Company employees: All employees, including executives, managers, and even temporary or part-time staff, should be aware of and abide by the insider trading policy to prevent unauthorized or illegal trading activities.
03
Board members and directors: Board members and directors have access to sensitive information, making them potential insiders. They should adhere to the insider trading policy in order to maintain the integrity of the company's trading activities.
04
Contractors and consultants: Individuals who work closely with the company and have access to confidential information should also be subject to the insider trading policy to prevent any misuse of that information.
05
Shareholders: While not directly involved in drafting or enforcing policies, shareholders should be aware of the company's insider trading policy to understand the measures taken to protect their investments and maintain a fair trading environment.
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An insider trading policy is a set of guidelines and regulations that govern the trading of securities by individuals who have access to non-public information about a company.
Publicly traded companies are required to have an insider trading policy in place.
Insider trading policies can vary by company, but they typically require individuals to disclose their securities transactions and comply with blackout periods.
The purpose of an insider trading policy is to prevent individuals from profiting from material non-public information.
Information that must be reported on an insider trading policy includes details of securities transactions, ownership interests, and compliance with the policy.
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