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INSIDER TRADING POLICY Insider Trading Policy Manual Subject Approved by Approval date Subsequent updates 04th December 2014 Insider Trading Policy Manual Board of Directors 13th March 2014 04th December
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How to fill out insider trading policy:

01
Begin by clearly defining the purpose and scope of the insider trading policy. This should include a statement on the prohibition of insider trading and the consequences for violations.
02
Identify who the policy applies to within the organization. This may include officers, directors, employees, contractors, and other relevant parties.
03
Outline the key definitions and terms used in the policy. This may include defining what constitutes material nonpublic information, insiders, trading windows, and restricted trading periods.
04
Specify the procedures for obtaining and handling material nonpublic information. This should include guidelines on proper disclosure, reporting, and maintaining confidentiality.
05
Detail the restrictions on trading in the company's securities. This should include insider trading blackout periods, pre-clearance requirements, and restrictions on options trading or short-selling.
06
Provide guidance on reporting and disclosing transactions. This should include the requirements for reporting trades and the submission of initial and periodic holdings reports.
07
Outline the consequences for violating the insider trading policy. This may include disciplinary actions, legal ramifications, and potential remedies.
08
Ensure that the policy is reviewed and updated regularly to reflect regulatory changes, industry best practices, and internal developments.

Who needs insider trading policy:

01
Publicly traded companies: Insider trading policies are essential for publicly traded companies, as they are subject to strict regulations and face potential legal liabilities.
02
Employees and officers: Anyone within the organization who may have access to material nonpublic information, including employees and officers, should adhere to an insider trading policy.
03
Directors and board members: Directors and board members have a particular responsibility to avoid insider trading and should be covered under the policy.
04
External consultants and contractors: Any external party who is given access to confidential information should also be subject to the insider trading policy to prevent misuse of such information.
05
Shareholders and investors: Insider trading policies can help instill confidence in shareholders and investors that the company takes insider trading seriously and has measures in place to prevent it.
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Insider trading policy outlines the rules and regulations that govern the trading of securities by individuals who have access to non-public information.
Publicly traded companies and their employees, directors, and executives are required to have and adhere to insider trading policies.
Insider trading policy can be filled out by including guidelines on how to handle material non-public information, procedures for pre-clearance of trades, and reporting requirements for trades.
The purpose of insider trading policy is to prevent insider trading by individuals who have access to confidential information that could affect the valuation of a company's securities.
Insider trading policy must include details on the rules and restrictions related to trading in the company's securities, as well as procedures for reporting and monitoring trades by insiders.
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