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Date March 16, 2015, To: All Trustees, Officers and Employees of the Company From: Gerard H. Sweeney, Chief Executive Officer and President Subject: Trading in Company Securities Accompanying the
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How to fill out an insider trading memo:

01
Begin by clearly stating the purpose of the memo, which is to document any potential cases of insider trading within the organization.
02
Provide a brief explanation of what insider trading is and the legal implications associated with it.
03
Include a section for the date and time of the suspicious activity, along with the names of the individuals involved.
04
Outline the details of the suspected insider trading, including the specific securities or financial transactions involved.
05
Include any evidence or supporting documentation that you have, such as emails, phone records, or witness statements.
06
Analyze the potential impact of the insider trading on the company, its reputation, and its shareholders.
07
If applicable, include any prior warnings or disciplinary actions related to insider trading involving the individuals mentioned.
08
Conclude the memo by summarizing the findings and providing recommendations for further investigation or action.
09
Obtain any required approvals or signatures before distributing the memo to the appropriate parties.

Who needs an insider trading memo:

01
Legal and compliance departments within the organization need an insider trading memo as part of their efforts to ensure adherence to laws and regulations.
02
Executives and board members may also need an insider trading memo to keep informed about any potential legal risks and take appropriate action.
03
External stakeholders such as auditors, regulators, and investors may require an insider trading memo as part of their due diligence processes or investigations.
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The insider trading memo is a document that discloses any trades of securities made by individuals who may have access to non-public information.
The individuals who are required to file insider trading memo are typically corporate executives, directors, and employees who have access to non-public information.
To fill out an insider trading memo, the individual must report the details of any securities trades they have made, including the date, amount, price, and reason for the trade.
The purpose of the insider trading memo is to provide transparency and accountability in the trading activities of individuals who have access to sensitive information.
The information that must be reported on an insider trading memo includes the details of securities trades, such as the date, amount, price, and reason for the trade.
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