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INSIDER TRADING POLICY Approved by: Ray Board of Director Version: 1.0 Approved for release on: May 2010 1 Background This policy governs the trading on Ray shares by Ray employees and members of
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How to fill out insider trading policy

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How to fill out insider trading policy:

01
Start by familiarizing yourself with the relevant laws and regulations regarding insider trading. This includes understanding what constitutes insider trading, the penalties for non-compliance, and any reporting requirements.
02
Review existing insider trading policies or templates that may be available. This can provide a starting point and help ensure you cover all the necessary elements. Customize the policy to fit your organization's specific needs and requirements.
03
Define who the policy applies to. Identify employees, officers, directors, and any other individuals who may have access to material non-public information.
04
Clearly outline what constitutes material non-public information. Provide examples and scenarios to help employees understand what information they should not trade on.
05
Establish procedures for reporting and handling potential insider trading violations. This should include a designated person or team responsible for receiving and investigating reports, as well as the process for reporting to regulatory authorities if necessary.
06
Educate employees about the policy. Conduct training sessions or provide resources that explain the policy, its importance, and the consequences of non-compliance.
07
Implement monitoring and enforcement mechanisms to ensure compliance with the policy. This may include regular audits, monitoring of trading activities, and disciplinary measures for violations.
08
Continuously review and update the policy as needed. Insider trading laws and regulations can change, so it's important to stay informed and adapt the policy accordingly.

Who needs insider trading policy:

01
Publicly traded companies: It is essential for companies listed on stock exchanges to have insider trading policies in place to comply with regulatory requirements and protect the integrity of the financial markets.
02
Financial institutions: Banks, investment firms, and other financial institutions that handle sensitive financial information should have insider trading policies to prevent conflicts of interest and breaches of client confidentiality.
03
Privately held companies: While not required by law, privately held companies may still benefit from having an insider trading policy to promote ethical conduct and protect themselves from potential legal and reputational risks.
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Insider trading policy is a set of rules and guidelines that govern the buying and selling of a company's stock by individuals who have access to non-public information.
Any company or organization that is publicly traded on a stock exchange is required to have and file an insider trading policy.
To fill out an insider trading policy, individuals must review the policy, acknowledge their understanding of the rules, and comply with the guidelines set forth.
The purpose of insider trading policy is to prevent individuals with access to non-public information from using it for personal gain when buying or selling stocks.
Insider trading policy must include guidelines on when insiders can buy or sell stocks, blackout periods, reporting requirements, and penalties for violations.
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