Alabama Policies and Procedures Designed to Detect and Prevent Insider Trading

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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).

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FAQ

If you have 'inside information' relating to the Company, it is illegal for you to: ? apply for, acquire, or dispose of, securities in the Company; or ? procure another person to apply for, acquire, or dispose of, securities in the Company; or ? directly or indirectly, communicate the information, or cause the ...

The Securities Exchange Act of 1934 prohibits the misuse of material, non-public information. In order to avoid even the appearance of impropriety, the Company has instituted procedures to prevent the misuse of non-public information.

SEC Tracking Market surveillance activities: This is one of the most important ways of identifying insider trading. The SEC uses sophisticated tools to detect illegal insider trading, especially around the time of important events such as earnings reports and key corporate developments. 5.

To avoid such an appearance, the Company has adopted guidelines (the ?Window Period?) covering the purchase or sale of its stock or other securities by Insiders. The Window Period is a Company rule designed to protect the Company and its Insiders.

The government tries to prevent and detect insider trading by monitoring the trading activity in the market. The SEC monitors trading activity, especially around important events such as earnings announcements, acquisitions, and other events material to a company's value that may move their stock prices significantly.

Federal and state securities laws prohibit the purchase or sale of a company's securities by anyone who is aware of material information about that company that is not generally known or available to the public.

Definition: Insider trading is defined as a malpractice wherein trade of a company's securities is undertaken by people who by virtue of their work have access to the otherwise non public information which can be crucial for making investment decisions.

Courts impose liability for insider trading with Rule 10b-5 under the classical theory of insider trading and, since U.S. v. O'Hagan, 521 U.S. 642 (1997), under the misappropriation theory of insider trading.

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Alabama Policies and Procedures Designed to Detect and Prevent Insider Trading