This Policy Statement implements procedures to deter the misuse of material, nonpublic information in securities transactions. The Policy Statement applies to securities trading and information handling by directors, officers and employees of the company (including spouses, minor children and adult members of their households).
Virginia Policies and Procedures Designed to Detect and Prevent Insider Trading are put in place to ensure fair and transparent financial markets within the state. These policies aim to discourage illicit activities such as the unauthorized use of inside information for personal gains, protecting investors and maintaining market integrity. Virginia, like other jurisdictions, recognizes the detrimental effects insider trading can have on market efficiency and investor trust. Here are some key elements included in Virginia Policies and Procedures Designed to Detect and Prevent Insider Trading: 1. Insider Trading Awareness and Training Programs: Responsible organizations in Virginia conduct regular educational programs to increase awareness among employees regarding the legal and ethical implications of insider trading. These programs emphasize the legal framework in place, potential consequences, and the importance of maintaining confidentiality. 2. Code of Ethics and Conduct: Virginia entities often establish a clear code of ethics and conduct that explicitly addresses insider trading. It provides guidelines for employees and relevant parties to prevent any misuse or unauthorized disclosure of non-public information. Compliance with the code is usually mandatory for employees and may extend to contractors and business partners. 3. Restricted Trading Windows and Pre-Clearance Procedures: Virginia Policies and Procedures often require employees to comply with pre-clearance procedures before trading in certain securities to prevent any potential conflicts of interest or unauthorized transactions. Restricted trading windows may also be implemented, limiting when employees can engage in personal trading to minimize the risk of insider trading. 4. Access Controls and Segregation of Information: Entities may implement robust access controls to ensure that sensitive or non-public information is only available to authorized personnel. Segregation of duties and information is commonly adopted to prevent situations where individuals might have both access to non-public information and authority for trading decisions. 5. Monitoring and Surveillance: Virginia Policies and Procedures include robust monitoring and surveillance mechanisms to detect suspicious activities that may indicate insider trading. This involves the periodic review of trading patterns, comparison of trading against disclosure timelines, and implementation of technology-driven surveillance tools to identify potential misuse of inside information. 6. Whistleblower Programs: Virginia entities often establish confidential and anonymous reporting mechanisms to encourage employees to report any suspected insider trading activities. Whistleblower protection is provided to individuals offering information in good faith and ensures they are shielded from potential retaliation. It is important to note that while these policies and procedures serve as guidelines for organizations and individuals in Virginia, federal laws like the Securities Exchange Act of 1934 and regulations set forth by the Securities and Exchange Commission (SEC) apply nationwide and must also be adhered to. In conclusion, Virginia Policies and Procedures Designed to Detect and Prevent Insider Trading encompass multiple measures aimed at promoting fair and transparent financial markets. By implementing these policies, Virginia aims to uphold the integrity of its securities market, safeguard investor interests, and maintain public trust in the state's financial systems.
Para su conveniencia, debajo del texto en español le brindamos la versión completa de este formulario en inglés. For your convenience, the complete English version of this form is attached below the Spanish version.
