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SYNERGY PHARMACEUTICALS INC. INSIDER TRADING COMPLIANCE PROGRAM In order to take an active role in the prevention of insider trading violations by its officers, directors, employees and other related
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How to fill out synergy insider trading policy

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How to fill out synergy insider trading policy:

01
Begin by reviewing the purpose and objectives of the insider trading policy. Understand the importance of preventing insider trading and the implications it may have on the company and individuals involved.
02
Familiarize yourself with the legal and regulatory requirements surrounding insider trading. It is crucial to ensure compliance with applicable laws and regulations governing insider trading, such as the Securities and Exchange Commission (SEC) regulations.
03
Develop a comprehensive definition of insider trading. Clearly outline what constitutes insider trading within the organization, including the types of information that should not be disclosed or traded upon. This may involve consulting legal counsel or compliance professionals to ensure accuracy.
04
Identify the individuals within the company who may be considered insiders. This includes employees, officers, directors, and any other individuals with access to confidential or non-public information that could potentially impact trading decisions. These individuals should be clearly defined and listed in the policy.
05
Outline the processes and procedures for obtaining pre-clearance of trades. Establish a system where individuals who are considered insiders must seek approval from the appropriate authority before executing any trades. This helps to prevent potential conflicts of interest or misuse of confidential information.
06
Provide guidelines on reporting requirements for insiders. Outline the obligations of insiders to report their securities transactions promptly, including the submission of periodic reports to ensure transparency and accountability.
07
Clarify the consequences of insider trading violations. Clearly communicate the disciplinary actions that will be taken in case of a breach of the insider trading policy. This may include termination of employment, civil or criminal penalties, and legal action.

Who needs synergy insider trading policy?

01
Employees: All employees of the company, regardless of their level or position, need to be aware of and follow the insider trading policy. This helps maintain integrity and prevents any unethical behavior within the organization.
02
Executives and Officers: As individuals who hold influential roles within the company, executives and officers need to comply with the insider trading policy. This ensures transparency and prevents any misuse of insider information that could benefit them personally.
03
Board of Directors: Members of the company's board also should adhere to the insider trading policy, as they often possess access to sensitive information that could impact trading decisions. They have a special responsibility to protect the interests of shareholders and maintain the integrity of the company.
04
Other Insiders: Any individual who has access to confidential or non-public information that could potentially impact trading decisions should be covered by the insider trading policy. This may include consultants, contractors, or any other third parties who have access to sensitive information.
Overall, having a synergy insider trading policy is essential for maintaining a fair and transparent trading environment and preventing any misuse of non-public information. It helps safeguard the company's reputation and ensures compliance with legal and regulatory requirements.
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The synergy insider trading policy outlines the guidelines and regulations that employees must follow when buying or selling company stocks based on non-public information.
All employees and executives of Synergy are required to file the insider trading policy.
Employees must review the policy, sign the acknowledgement of understanding, and disclose any relevant financial information.
The purpose of the synergy insider trading policy is to prevent insider trading and ensure fairness in the market.
Employees must report any transactions involving company stocks, as well as any material non-public information they possess.
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