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Arkansas 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).

Arkansas Policies and Procedures Designed to Detect and Prevent Insider Trading: Insider trading refers to the illegal practice of trading stocks or securities by individuals with access to non-public information, giving them an unfair advantage over other investors. It is crucial for organizations and states to implement robust policies and procedures to detect and prevent insider trading. The state of Arkansas recognizes the importance of maintaining fair and transparent financial markets and has established specific guidelines and regulations to tackle insider trading effectively. 1. Arkansas Securities Act: The Arkansas Securities Act outlines the legal framework for regulating securities and preventing fraudulent activities within the state. It includes provisions and guidelines related to insider trading, ensuring compliance by individuals and organizations operating within Arkansas. 2. Arkansas Securities Department: The Arkansas Securities Department (ASD) is responsible for the administration and enforcement of the state's securities laws. The ASD works in conjunction with other regulatory bodies such as the Securities and Exchange Commission (SEC) to detect and prevent insider trading. The department conducts investigations, audits, and examinations to identify potential cases of insider trading and takes necessary actions to enforce relevant laws. 3. Training and Education: Arkansas promotes education and training programs to create awareness about insider trading and its consequences. These programs aim to educate employees, executives, and professionals about their legal obligations, responsibilities, and the importance of maintaining a fair and level playing field in the securities market. 4. Reporting Obligations: Arkansas policies and procedures require individuals with access to non-public information to report any potential insider trading activities. This includes reporting suspicious transactions, red flags, or any indications of insider trading to the appropriate authorities promptly. The reporting obligations help in uncovering potential cases and initiating necessary investigations and actions. 5. Whistleblower Protection: Arkansas guarantees protection for individuals who report insider trading activities in good faith. Whistleblowers are safeguarded against retaliation and provided legal protection under state laws. This encourages individuals to come forward and disclose any information they might have regarding potential insider trading, thus facilitating the detection and prevention process. 6. Cooperation with Federal Authorities: Arkansas authorities closely cooperate with federal regulatory bodies such as the SEC and other law enforcement agencies in combating insider trading. This collaboration ensures the exchange of information, expertise, and resources required for effective detection, investigation, and enforcement of insider trading cases. 7. Enhanced Monitoring and Surveillance: The state employs advanced surveillance systems to monitor trading activities and detect suspicious patterns or abnormal trading behavior. These monitoring systems employ cutting-edge technology and algorithms to identify potential insider trading activities promptly. 8. Proactive Enforcement: Arkansas has a proactive enforcement strategy that emphasizes deterrence and punishment for insider trading violations. The state imposes substantial fines, penalties, and even imprisonment for individuals found guilty of insider trading. This strict enforcement regime acts as a deterrent for potential offenders and reinforces the commitment to maintaining fair and transparent securities markets. In conclusion, Arkansas has established comprehensive policies and procedures to detect and prevent insider trading effectively. By combining legal regulations, education programs, reporting obligations, whistleblower protection, cooperation with federal authorities, enhanced surveillance, and proactive enforcement, the state aims to safeguard its financial markets against unfair practices and maintain investor confidence.

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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.

Before it escalates to the government level, most companies take several measures to prevent insider trading within their securities. Some companies have blackout periods when officers, directors, and other designated people are barred from purchasing the company's securities (usually around earnings announcements).

What might constitute insider dealing? ing to the legislation which makes insider dealing a criminal offence (the Criminal Justice Act 1993), an individual is committing a crime if they use price-sensitive information relating to shares and then deal them on a regulated market or via a broker.

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.

Of particular relevance to directors and officers, companies will be required to (a) disclose quarterly whether any director or officer has adopted, modified or terminated a Rule 10b5-1 plan or other trading arrangement and (b) describe the material terms of each plan adopted, modified or terminated, including the name ...

Federal securities laws prohibit the purchase or sale of securities by persons who are aware of material nonpublic information about a company, as well as the disclosure of material, nonpublic information about a company to others who then trade in the company's securities.

No Insider may give trading advice of any kind about the Company to anyone, whether or not such Insider is aware of material nonpublic information about the Company. No Insider may trade in any interest or position relating to the future price of Company Securities, such as a put, call or short sale.

It states that anyone who misappropriates material non-public information and trades on that information in any stock may be guilty of insider trading. This can include elucidating material non-public information from an insider with the intention of trading on it or passing it on to someone who will.

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This Policy Statement implements procedures to deter the misuse of material, nonpublic information in securities transactions. The Policy Statement applies ... trading), and trading procedures and reviews designed to prevent and detect. Policies and procedures employed by broker-dealers to segment the flow of.Oct 12, 2021 — Review and revise as necessary, their insider trading policies and procedures to address the risk of trading in economically linked issuers. Each such person should contact the Company's Chief Accounting Officer prior to commencing any trade. The Chief Accounting Officer will consult as necessary ... This Insider Trading Policy (this “Policy”) summarizes the insider trading rules and explains how Insiders can buy or sell stock so that they are in compliance ... Advisors should implement written policies to prevent the misuse of material, nonpublic information. Essentially, this means employees cannot trade on insider ... The first way (manual process) requires the subject of the record check to sign the State Police form ASP-122. This form must be notarized. The cost is $25.00. To detect, counter, mitigate, or manage these risks throughout all stages of the M&A process, organizations should consider implementing the following best. ... rules that require certain issuers to file periodic and current reports with the Commission. ... Capital, agreed to the largest insider trading settlement in SEC ... Monitoring Trading Activity​​ The government tries to prevent and detect insider trading by monitoring the trading activity in the market.

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Arkansas Policies and Procedures Designed to Detect and Prevent Insider Trading