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).
Nevada Policies and Procedures Designed to Detect and Prevent Insider Trading
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Before it escalates to the government level, most companies take several measures to prevent insider trading within their securities. Some companies have blackout periods when officers, directors, and other designated people are barred from purchasing the company's securities (usually around earnings announcements).
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.
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.
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.
Unfair For Other Investors Insider trading is seen as unfair to other investors in the stock market, who do not have access to the information. The investor with the non-public information could potentially make far larger profits from the stock market than a typical investor could not make.
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.
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.
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.