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WESBANCO INC.INSIDER TRADING AND DIRECTOR CONFIDENTIALITY POLICY POLICY AND PROCEDURESORGANIZATIONAL FUNCTIONAL AREA:EXECUTIVEPOLICY FOR:INSIDER TRADING REQUIREMENTSAPPROVED:February 23, 2023EFFECTIVE:
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How to fill out insider trading policy

01
Begin with a clear introduction explaining the purpose of the insider trading policy.
02
Define key terms such as 'insider trading,' 'material information,' and 'insider.'
03
Outline the legal framework surrounding insider trading, referencing applicable laws and regulations.
04
Specify who is considered an 'insider' within the organization.
05
Detail the types of information that are classified as material.
06
Include guidelines on when employees can buy or sell company stock, including blackout periods.
07
Explain the procedures for reporting trades and potential violations.
08
Highlight the consequences of violating the insider trading policy.
09
Provide a section for employees to acknowledge their understanding and acceptance of the policy.
10
Review and update the policy regularly to reflect changes in laws or company practices.

Who needs insider trading policy?

01
All employees of the organization, especially those with access to sensitive information.
02
Board members and executives who may trade based on privileged information.
03
Contractors and consultants engaged by the organization who might have access to insider information.
04
Any third parties who work closely with the organization and may come into contact with material nonpublic information.
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Insider trading policy is a set of guidelines that govern the buying or selling of a company's stock or other securities by individuals who have access to non-public, material information about the company.
Individuals considered insiders, such as executives, directors, and employees who have access to significant non-public information, are typically required to file insider trading policy.
To fill out insider trading policy, individuals should provide their name, position, and details about the transaction, including the type of security, number of shares, and the date of the transaction, following the designated format set by their company or regulatory body.
The purpose of insider trading policy is to prevent illegal trading based on confidential information, promote transparency, and maintain trust in the financial markets.
Reported information typically includes the insider's name, relationship to the company, details of the transaction, amount of securities involved, trade dates, and whether the transaction was a purchase or sale.
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