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GIBSON ENERGY (and affiliated companies) POLICY Department Responsible: Legal Policy # CORP 6.0Policy Title: INSIDER TRADING POLICYInitial Approval Date: August 10, 2011Revision #: 2Approval Source:

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How to fill out insider trading policy

01

To fill out an insider trading policy, follow these steps: 1. Start by familiarizing yourself with the company's insider trading policies and any applicable laws or regulations. 2. Understand the definition of insider trading and the prohibited activities. 3. Determine who within the company should be subject to the policy. Identify key employees, directors, or other relevant parties. 4. Clearly define what constitutes material non-public information. 5. Establish rules for pre-clearance of trades and reporting of transactions. 6. Set forth guidelines for maintaining confidentiality of information. 7. Implement a training program to educate employees about the policy and insider trading risks. 8. Regularly review and update the policy to ensure compliance with new laws or regulations and changes within the company. 9. Foster a culture of ethical behavior and encourage employees to report any potential violations.

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Who needs insider trading policy?

01

Insider trading policies are essential for publicly traded companies, financial institutions, investment firms, and other entities involved in trading securities. They help maintain fair and transparent markets by preventing illegal trading activities based on non-public information. Any organization that deals with sensitive or confidential information and has access to material non-public information should have an insider trading policy in place to protect the integrity of the financial markets, shareholders, and stakeholders.

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What is insider trading policy?

Insider trading policy is a set of rules and regulations that govern the trading of securities by individuals who have access to non-public information about a company.

Who is required to file insider trading policy?

Employees, executives, directors, and other insiders of a company are required to file insider trading policy.

How to fill out insider trading policy?

Insiders must disclose their trades in a timely manner and comply with all regulations set forth in the company's insider trading policy.

What is the purpose of insider trading policy?

The purpose of insider trading policy is to prevent the misuse of material non-public information for personal gain.

What information must be reported on insider trading policy?

Insiders must report the date of the trade, the security traded, the quantity traded, and the price at which the trade was executed on the insider trading policy.

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