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).
Oakland, Michigan Policies and Procedures Designed to Detect and Prevent Insider Trading Oakland, Michigan has implemented robust policies and procedures designed to detect and prevent insider trading, ensuring a fair and transparent securities market. These policies aim to safeguard against corporate information misuse by insiders for personal gains, ultimately fostering investor confidence. One of the primary policies employed to combat insider trading in Oakland, Michigan is the implementation of strict trading blackout periods. These periods restrict company insiders from trading their own securities during specific time frames when crucial material information is likely to be disclosed. This prohibition helps prevent the exploitation of non-public information by insiders, maintaining a level playing field for all investors. To ensure compliance with these blackout periods and prevent unauthorized trading, Oakland, Michigan also has established a comprehensive monitoring and surveillance system. This system utilizes cutting-edge technology to track and analyze trading activities of company insiders. It flags suspicious trades or patterns that may indicate potential insider trading, enabling swift and proactive investigations. Furthermore, Oakland, Michigan mandates that all company insiders, including executives, board members, and employees, undergo thorough training on insider trading regulations and their obligations under these policies. This training educates insiders about the legal and ethical implications of insider trading and emphasizes the severe penalties associated with such activities. By promoting a strong culture of compliance, Oakland, Michigan aims to prevent inadvertent violations and reduce the likelihood of intentional misconduct. To enhance the effectiveness of these policies, Oakland, Michigan also maintains strict internal controls over the dissemination of confidential corporate information. This includes implementing robust information security measures and restricted access protocols. Only individuals with a legitimate need-to-know basis are granted access to sensitive data, minimizing the risk of unauthorized disclosure and potential abuse. In addition to general policies and procedures, Oakland, Michigan has specific measures tailored to different types of insiders. For executives and senior management, additional restrictions and reporting requirements may be imposed due to their potential access to highly material non-public information. These individuals may be subject to pre-clearance procedures, where they are required to seek prior approval from designated compliance officers before engaging in any securities transactions. For employees with access to market-sensitive information, Oakland, Michigan may implement insider lists. These lists compile the names of individuals who possess non-public information and impose strict trading restrictions on them. By closely monitoring trading activities of individuals on insider lists, Oakland, Michigan can effectively detect and prevent any potential unauthorized transactions. Overall, Oakland, Michigan's policies and procedures designed to detect and prevent insider trading exemplify a commitment to maintaining market integrity and protecting the rights of investors. By implementing stringent controls, conducting regular training, and leveraging advanced surveillance technology, Oakland, Michigan strives to create a fair and transparent securities' environment for all market participants.
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.
