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Policy on Insider TradingIssue Date: Approval: Board of DirectorsRevision Date: April 12, 2018In the course of conducting the business of Lakeland Industries, Inc. and its worldwide subsidiaries (collectively,
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How to fill out policy on insider trading

01
Begin by clearly defining what constitutes insider trading in your organization. This should include examples and specific situations that could be considered insider trading.
02
Identify the key roles and responsibilities in the policy. This could include designated insiders who have access to non-public information, compliance officers, and senior management.
03
Outline the procedures for handling non-public information. This should cover how information is identified as non-public, how it should be handled and communicated within the organization, and any restrictions on sharing or trading based on this information.
04
Include guidelines for reporting and seeking approval for trades. This should cover the process for reporting trades, seeking pre-clearance for trades, and any blackout periods or restrictions on trading for designated insiders.
05
Address the consequences and disciplinary actions for violating the policy. This should include the potential legal, regulatory, and reputational risks associated with insider trading, as well as the disciplinary actions that may be taken within the organization.
06
Review and update the policy regularly to ensure it remains up-to-date with changes in laws, regulations, and best practices.
07
Provide training and awareness programs to employees to ensure they understand the policy and the importance of compliance with insider trading laws.
08
Establish a process for monitoring and enforcing compliance with the policy, including regular audits and investigations if necessary.
09
Communicate the policy to all employees and make it easily accessible to ensure everyone is aware of the guidelines and requirements.
10
Seek legal advice or consult with experts to ensure the policy aligns with applicable laws and regulations.

Who needs policy on insider trading?

01
Any organization that deals with non-public information, such as publicly traded companies, financial institutions, investment firms, or any entity that has access to material non-public information about a company or its securities, needs a policy on insider trading. This policy ensures that employees and individuals within the organization understand and comply with the legal and ethical obligations related to insider trading laws.
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Insider trading policy refers to regulations and guidelines that govern the buying and selling of stocks or other securities based on material, non-public information about a company. It aims to prevent illegal trading based on confidential information to maintain fair trading practices in the market.
Typically, employees, executives, directors, and other affiliates of a public company are required to file disclosures regarding insider trading policies and any trades they engage in based on material non-public information.
To fill out a policy on insider trading, one must provide detailed information about the individual's relationship to the company, any trades made, the dates of the transactions, and the nature of the material non-public information involved in the trades.
The purpose of an insider trading policy is to ensure compliance with securities laws, protect the integrity of the market, prevent unfair advantages in trading, and uphold the company's reputation by ensuring that all trading is conducted transparently and fairly.
Information that must be reported includes the names of individuals involved, the number of shares traded, transaction dates, the nature of the non-public information, and any relevant agreements or contracts related to the trades.
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