Nebraska 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

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 ?tip? or disclose material nonpublic information concerning the Company to any outside person, including family members, even if that person is expected to hold such ?tip? in confidence, unless required as part of that Insider's regular duties for the Company or authorized by the Compliance Officer.

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.

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.

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.

The legislation regarding insider dealing means that anyone who trades on the basis of information that isn't in the public domain is acting illegally.

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.

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Nebraska Policies and Procedures Designed to Detect and Prevent Insider Trading