Kansas Policies and Procedures Designed to Detect and Prevent Insider Trading

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US-TC1012
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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 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.

Congress has criminalized these insiders' use of non-public information under the theory that the use fraudulently violates a fiduciary duty with which the company has charged the insider. Courts impose liability for insider trading with Rule 10b-5 under the classical theory of insider trading and, since U.S. v.

Common defenses to insider trading charges typically focus on: whether the transaction involved a security; whether the information the trader had at the time of the trade was both non-public and material (MNPI); whether a deceptive act occurred or whether a breach of duty was involved;

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.

MAR requires that issuers create an insider list in a specific digital format and make every reasonable effort to ensure that any person on the insider list acknowledges in writing their legal and regulatory duties relating to the use of inside information and preventing insider trading.

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.

One of the most effective measures to prevent insider trading is blackout periods. Under the insider trading policy, a blackout period is when the corporation's employees and directors are barred from buying and selling their holdings in the company's shares or making changes to their investment structure.

How to Create More Robust Securities Compliance and Reduce Insider Trading Risk Have a Securities Trading Policy in Place. Monitor Personal Trade Activities. Communicate Blackout Periods. Record and Maintain Insider Lists. Set Up a Pre-Clearance Process. Make it Your Business to Be a Business with Ethics.

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Kansas Policies and Procedures Designed to Detect and Prevent Insider Trading