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SMARTLY HOLDINGS LIMITED (Smartly) SECURITIES TRADING POLICY AND GUIDELINES This policy applies to all directors, officers, employees and contractors of Smartly and its subsidiaries in New Zealand
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How to fill out securities trading policy

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How to fill out securities trading policy?

01
Be familiar with the purpose and regulations: Before filling out a securities trading policy, it is essential to understand its purpose and the relevant regulations governing securities trading. This will ensure that you comply with all legal requirements and establish appropriate guidelines for trading activities.
02
Identify key stakeholders: Determine who will be responsible for drafting, implementing, and enforcing the securities trading policy. This may include compliance officers, legal advisors, and senior executives who have a vested interest in maintaining transparency and preventing conflicts of interest.
03
Define prohibited activities: Clearly outline the actions or behaviors that are strictly prohibited under the securities trading policy. This may include insider trading, front-running, market manipulation, and unauthorized disclosure of material non-public information. By explicitly defining prohibited activities, you can set clear expectations and discourage any unethical or illegal behavior.
04
Establish trading restrictions: Specify any trading restrictions that employees or individuals covered by the policy must adhere to. This may include blackout periods, during which trading is prohibited, as well as restrictions on specific securities, derivatives, or investment products. It is crucial to tailor these restrictions to your organization's specific needs and risk tolerance.
05
Outline disclosure requirements: Detail the procedures for reporting and disclosing any potential conflicts of interest or insider information. This may involve establishing a systematic process for employees to report their personal trading activities, as well as disclosure requirements for transactions involving company securities. By ensuring transparency, you can minimize the risk of non-compliance and reputational damage.
06
Implement monitoring and enforcement mechanisms: Develop systems and controls to ensure ongoing compliance with the securities trading policy. This may include regular monitoring of trading activities, periodic training and education programs for employees, and disciplinary measures for policy violations. By actively monitoring and enforcing the policy, you can create a culture of accountability and mitigate potential risks.

Who needs securities trading policy?

01
Publicly traded companies: Securities trading policies are essential for publicly traded companies to ensure compliance with securities laws and regulations. These policies help to prevent insider trading, maintain market integrity, and protect the interests of investors.
02
Financial institutions: Banks, brokerage firms, and other financial institutions often deal with various investment products and securities. Having a securities trading policy is crucial for these entities to safeguard against conflicts of interest, maintain client trust, and comply with industry regulations.
03
Investment firms and hedge funds: Investment firms and hedge funds engage in complex trading strategies and handle large amounts of assets. A securities trading policy helps these entities manage the risks associated with their trading activities, ensure fair practices, and protect investors' interests.
04
Corporate executives and directors: Executives and directors of public companies often possess material non-public information that can influence the market. A securities trading policy helps these individuals navigate legal and ethical obligations, preventing insider trading and maintaining trust among shareholders.
05
Compliance officers and legal advisors: Compliance officers and legal advisors play a critical role in developing, implementing, and overseeing securities trading policies. Their expertise ensures that organizations meet regulatory requirements, monitor trading activities effectively, and address any potential violations promptly.
Overall, a thorough and well-implemented securities trading policy is crucial for organizations and individuals involved in securities trading. It ensures compliance with regulations, fosters ethical behavior, and protects the integrity of the financial markets.
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A securities trading policy is a set of guidelines and rules that govern the buying and selling of securities within a company or organization.
Individuals who are considered insiders, such as officers, directors, and certain employees of a company, are required to file securities trading policy.
To fill out securities trading policy, individuals need to provide information on their trades and holdings of securities, as well as any other relevant information required by regulatory bodies.
The purpose of securities trading policy is to ensure transparency and prevent insider trading by providing clear guidelines on buying and selling securities.
Securities trading policy requires the reporting of trades and holdings of securities, including details such as the type of securities, date of transaction, and any associated parties.
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