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Skipper Limited CODE OF CONDUCT FOR PREVENTION OF INSIDER TRADING CONTENTS Sr. No. Topic Page No. CHAPTER I INTRODUCTION 1 The Policy and Obligations 2 2 Applicability 2 3 Definition 35 CHAPTER II
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How to fill out insider trading policy:

01
Start by reviewing relevant laws and regulations relating to insider trading. Familiarize yourself with the requirements and obligations outlined in these laws.
02
Assess your organization's specific needs and risks. Consider factors such as the size and nature of your business, the industry you operate in, and any previous incidents or allegations related to insider trading.
03
Develop a clear and comprehensive policy that outlines prohibited activities and provides guidelines for employees on how to comply with insider trading regulations.
04
Include sections on what constitutes material non-public information, trading restrictions for insiders, procedures for handling potential conflicts of interest, and rules regarding reporting and disclosure.
05
Ensure that the policy is communicated effectively to all employees who may be considered insiders. Consider conducting training sessions or workshops to educate staff members on their responsibilities and obligations under the policy.
06
Establish procedures for monitoring and enforcing compliance with the insider trading policy. This may include regular reporting requirements, internal audits, and disciplinary actions for violations.
07
Periodically review and update the policy to reflect any changes in laws or regulations, as well as any evolving risks or circumstances within your organization.

Who needs insider trading policy:

01
Companies listed on stock exchanges: Publicly traded companies are firmly regulated by securities laws, making an insider trading policy essential to ensure compliance and prevent illegal activities.
02
Financial institutions: Banks, investment firms, and other financial entities handle sensitive information and are subject to strict regulations, making an insider trading policy crucial for protecting clients and maintaining integrity.
03
Government agencies: Government departments that oversee financial markets or deal with sensitive information should have stringent policies in place to prevent any abuse of privileged information.
04
Non-profit organizations: While not subject to the same legal requirements as publicly traded companies, non-profits often deal with confidential information and should still have policies to maintain transparency and ethical behavior.
05
Private companies: Even though private companies may not be subject to the same legal obligations, having an insider trading policy can help establish ethical business practices and demonstrate a commitment to transparency and fairness.
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Insider trading policy is a set of rules and regulations that govern the buying and selling of securities by individuals who have access to non-public material information about a company.
Companies listed on stock exchanges are typically required to have and file insider trading policies.
Insider trading policies should be filled out by legal and compliance departments of a company, ensuring they comply with relevant laws and regulations.
The purpose of insider trading policy is to prevent insider trading and to ensure fairness and transparency in the financial markets.
Insider trading policies typically require reporting of any non-public material information about a company and restrictions on trading based on this information.
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