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).
Harris Texas Policies and Procedures Designed to Detect and Prevent Insider Trading: Insider trading is a serious offense that can undermine the integrity and fairness of financial markets. To combat this illicit activity and ensure transparency, Harris Texas has established comprehensive policies and procedures designed to detect and prevent insider trading. These guidelines are in strict adherence with relevant laws and regulations, including the Securities Exchange Act of 1934 and the provisions set forth by the U.S. Securities and Exchange Commission (SEC). 1. Confidentiality and Trading Restrictions: Harris Texas maintains strict confidentiality protocols for all employees who have access to non-public information that could potentially impact the market value of a publicly traded security. Such individuals are prohibited from engaging in personal trading of these securities and are required to adhere to specific trading restrictions to prevent the misuse of privileged information. 2. Insider Trading Training and Education: Harris Texas places great emphasis on educating its employees regarding the laws and regulations governing insider trading to ensure their knowledge and understanding. Regular training programs and workshops are conducted to familiarize employees with the intricacies of insider trading and the severe penalties associated with violations. 3. Restricted Trading Windows: Harris Texas enforces restricted trading windows, wherein employees are restricted from trading in common stocks, options, and other securities during certain blackout periods. These periods are typically imposed before the release of significant financial information or during other relevant events to prevent the misuse of insider information. 4. Pre-Clearance and Reporting Mechanisms: To further safeguard against insider trading, Harris Texas mandates that employees seeking to trade in particular securities must obtain pre-approval. This pre-clearance process ensures rigorous scrutiny, with employees required to disclose their trading intentions and any potential conflicts of interest. Additionally, regular reporting of personal securities transactions is mandatory, allowing for closer monitoring and compliance checks. 5. Monitoring and Surveillance: Harris Texas employs advanced technological tools and automated systems to monitor trading activities of employees. These surveillance mechanisms are designed to identify unusual trading patterns, potential breaches of trading restrictions, and any suspicious activities that may indicate insider trading. 6. Reporting and Whistleblower Protection: Harris Texas maintains a robust reporting system that encourages employees to report any suspected instances of insider trading. The company guarantees anonymity and protects whistleblowers against any retaliatory actions, emphasizing its commitment to maintaining ethical and lawful practices within its operations. By implementing these Harris Texas Policies and Procedures Designed to Detect and Prevent Insider Trading, the company strives to maintain the highest standards of ethical conduct and market integrity. These measures provide employees with clear guidelines, preventive measures, and strict consequences for non-compliance, ensuring a level playing field that instills trust in investors and upholds the integrity of the financial markets.
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.
