Iowa 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 ...

How to reduce the risk of insider trading Conduct due diligence. ... Take extra care outside of the office. ... Clearly define sensitive non-public information. ... Never disclose non-public information to outsiders. ... Don't recommend or induce based on inside information. ... Be cautious in informal or social settings.

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.

If any Designated Person contravenes any of the provisions of the Insider Trading Code / SEBI Regulations, such Designated Person will be liable for appropriate penal actions in ance with the provisions of the SEBI Act, 1992. The minimum penalty under the SEBI Act, 1992 is Rs. 10 Lakhs, which can go up to Rs.

A person who violates insider trading laws by engaging in transactions in a company's securities when he or she has material nonpublic information can be sentenced to a substantial jail term and required to pay a penalty of several times the amount of profits Page 3 3 gained or losses avoided.

SEC Rule 10b-5 prohibits corporate officers and directors or other insider employees from using confidential corporate information to reap a profit (or avoid a loss) by trading in the Company's stock. This rule also prohibits ?tipping? of confidential corporate information to third parties.

Insider trading by a designated person or their close associates is forbidden at all times. ing to SEBI laws, a Designated Person who buys or sells any number of the company's stocks may not engage in a contrary transaction within 6 months of the date.

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Iowa Policies and Procedures Designed to Detect and Prevent Insider Trading