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LOGO ONCOLOGY, INC. INSIDER TRADING POLICY As adopted on July 18, 2014, I. PURPOSE Logo Oncology, Inc. (collectively with its subsidiaries, the Company) is committed to promoting high standards of
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How to fill out insider trading policy?

01
Start by familiarizing yourself with the relevant laws and regulations regarding insider trading. Research the guidelines and requirements set forth by government authorities such as the Securities and Exchange Commission (SEC) or other regulatory bodies in your jurisdiction.
02
Review any existing insider trading policies within your organization, if applicable. Familiarize yourself with the current policies, procedures, and protocols that are already in place. This will help you understand the organization's approach and ensure consistency while filling out the policy.
03
Determine the scope and objectives of your insider trading policy. Consider the specific needs and characteristics of your organization, such as its size, industry, and geographic presence. Clarify the purpose of the policy, whether it is to prevent insider trading, educate employees, or ensure compliance with legal requirements.
04
Identify key stakeholders involved in the creation and implementation of the policy. This may include management, legal or compliance departments, human resources, and any other relevant parties. Collaborate with these stakeholders to gather their input and ensure that the policy reflects the organization's values and objectives.
05
Outline the prohibited activities and define insider trading within the policy. Provide clear definitions of insider trading, including what constitutes inside information and potential penalties for violations. Specify the types of transactions or activities that are subject to restrictions, such as trading company stocks based on non-public information.
06
Establish policies and procedures for handling confidential information. Include guidelines on who has access to sensitive information, how it should be handled, and the steps employees should take to maintain confidentiality. Consider implementing additional security measures, such as restricted access to certain databases or requiring employees to sign confidentiality agreements.
07
Define the reporting mechanisms for potential violations or suspicions of insider trading. Establish procedures for employees to report potential breaches of the policy, whistleblower protections, and the process for conducting investigations. Clearly communicate the channels available to report concerns, ensuring anonymity and protection against retaliation.
08
Provide guidance and training for employees. Develop comprehensive training programs to educate employees about insider trading regulations, the organization's policy, and the potential consequences of non-compliance. Consider incorporating real-life examples and case studies to enhance understanding and promote ethical behavior.
09
Regularly review and update the insider trading policy. As laws and regulations change, it is important to keep the policy up to date. Conduct periodic reviews to ensure ongoing compliance, identify areas for improvement, and make any necessary revisions. Communicate updates and changes to employees to maintain transparency and awareness.

Who needs insider trading policy?

01
Publicly traded companies: Any company listed on stock exchanges or subject to securities regulations typically needs an insider trading policy. This policy helps protect the integrity of the financial markets and ensures fairness in trading activities.
02
Employees with access to material non-public information: Individuals within an organization who have access to confidential or sensitive information that could affect the market value of the company's securities, such as executives, board members, or employees in finance, legal, or marketing departments, need to abide by an insider trading policy.
03
Financial institutions and brokerage firms: Organizations involved in trading securities or providing investment advice are subject to strict insider trading regulations. Developing and implementing an effective insider trading policy is essential to ensure compliance and maintain the trust of clients and investors.
04
Regulatory bodies: Government authorities and regulatory bodies responsible for overseeing securities markets and enforcing insider trading regulations may need to have their own internal insider trading policies. These policies help maintain the integrity of the regulatory process and ensure compliance within the organization.
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The insider trading policy is a set of rules and regulations that govern the trading of company securities by individuals who have access to non-public information.
Companies listed on stock exchanges are required to have an insider trading policy in place.
The insider trading policy can typically be filled out by the company's legal team or compliance department in accordance with regulations set by the relevant stock exchange.
The purpose of the insider trading policy is to prevent insider trading and maintain the integrity of the financial markets by ensuring fair and equal access to information.
The insider trading policy typically includes details on who is considered an insider, trading restrictions, pre-clearance requirements, and consequences for violations.
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