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).
Connecticut Policies and Procedures Designed to Detect and Prevent Insider Trading refers to the buying or selling of stocks or other securities based on material non-public information, which gives traders an unfair advantage over the public. To combat this unethical practice, Connecticut has implemented a robust set of policies and procedures aimed at detecting and preventing insider trading within its financial markets. These measures aim to promote fair and transparent transactions, protect investors, and maintain the integrity of the state's financial systems. 1. Connecticut Uniform Securities Act (Curacy): The Connecticut Uniform Securities Act serves as the primary legal framework governing securities transactions within the state. It regulates insider trading by defining illegal activities and providing penalties for violations. The Curacy empowers regulatory authorities to investigate potential cases of insider trading and take appropriate enforcement actions. 2. Connecticut Department of Banking: The Connecticut Department of Banking acts as the state's primary regulatory agency for the financial industry. It works to enforce the Curacy and collaborates with other authorities to identify and prevent insider trading. The department conducts regular audits and examinations of financial institutions to ensure compliance with established regulations and guidelines. 3. Market Surveillance and Investigation: Connecticut's financial markets are closely monitored for suspicious trading activities. Through advanced surveillance systems, securities regulators track unusual trading patterns or transactions that may indicate insider trading. These systems rely on sophisticated algorithms and data analysis techniques to identify potential violations promptly. 4. Whistleblower Programs: Connecticut encourages individuals with knowledge of insider trading to come forward and report any such activities. Whistleblower programs provide protection and incentives to those who disclose information about insider trading violations. Reporting mechanisms ensure confidentiality while allowing whistleblowers to provide essential evidence to regulatory agencies for investigation. 5. Ongoing Education and Training: Financial professionals and market participants in Connecticut are required to undergo regular training and education programs on insider trading prevention. These programs familiarize individuals with the laws and regulations related to insider trading, making them aware of the consequences of non-compliance. Training ensures that professionals remain updated on the evolving nature of insider trading practices. 6. Collaboration with Federal Authorities: Connecticut actively collaborates with federal agencies such as the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) to combat insider trading. This collaboration involves sharing information, conducting joint investigations, and aligning enforcement strategies to promote consistency across jurisdictions. 7. Fostering a Culture of Compliance: Connecticut's policies and procedures emphasize the importance of fostering a culture of compliance with insider trading regulations. Financial institutions and market participants are expected to establish internal controls and mechanisms that prevent unauthorized access to material non-public information. Robust compliance programs are implemented to ensure adherence to regulations and ethics. By implementing these comprehensive policies and procedures, Connecticut aims to create a fair and level playing field for all market participants. The state prioritizes investor protection, market integrity, and the overall stability of its financial systems. Through ongoing surveillance, education, and collaboration, Connecticut endeavors to maintain its reputation as a trusted and secure destination for investment.
