Maryland 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.

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.

Securities and Exchange Commission.

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.

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.

Regulation 3(1): to a company or securities listed or proposed to be listed, to any person including other insiders except where such communication is in furtherance of legitimate purposes, performance of duties or discharge of legal obligations.

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.

No person shall procure from or cause the communication by any insider of unpublished price sensitive information, relating to the Bank or securities listed or proposed to be listed, except in furtherance of legitimate purposes, performance of duties or discharge of legal obligations.

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Maryland Policies and Procedures Designed to Detect and Prevent Insider Trading