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).
Puerto Rico Policies and Procedures Designed to Detect and Prevent Insider Trading is a serious offense that undermines the integrity of financial markets and erodes investor confidence. To combat this illegal practice, Puerto Rico has implemented a robust framework of policies and procedures designed to detect and prevent insider trading. 1. Legal Framework: — Securities and Exchange Act of Puerto Rico: This legislation serves as the foundation for insider trading regulations in Puerto Rico. It defines insider trading, outlines prohibited activities, and establishes penalties for violators. — Securities Regulation Code: Provides guidance on various aspects of securities trading, including insider trading regulations, reporting requirements, and enforcement mechanisms. — Code of Ethics: Many organizations, including financial institutions and corporations operating in Puerto Rico, have developed their own codes of ethics that explicitly address insider trading prevention. 2. Regulatory Oversight: — Office of the Commissioner of Financial Institutions (CIF): CIF is responsible for supervising and enforcing insider trading regulations in Puerto Rico. They conduct periodic examinations of market participants, audit trading activities, and investigate potential violations. — Puerto Rico Department of Justice: Collaborating with CIF, the Department of Justice plays a crucial role in enforcing insider trading laws, prosecuting offenders, and conducting thorough investigations. 3. Reporting and Disclosure Requirements: — Insider Trading Reporting: Puerto Rico requires insiders, such as company directors, officers, and significant shareholders, to report their transactions in the securities of their own companies. This ensures transparency and allows regulators to identify potential insider trading patterns. — Material Non-public InformationMNPPI) Disclosure: Organizations are obligated to establish policies that prohibit the release or misuse of MNP. Any employees with access to such information must acknowledge the importance of safeguarding it, and procedures must be in place to report any unauthorized disclosures or potential insider trading situations. 4. Education and Training Programs: — Puerto Rico Stock Exchange: The stock exchange provides educational resources and training programs to market participants on insider trading regulations and best practices for compliance. — Seminars and Workshops: Industry associations, regulatory bodies, and legal firms often organize seminars and workshops to educate professionals about insider trading laws, detection techniques, and prevention strategies. 5. Whistleblower Protection: — Incentives for Reporting: Puerto Rico offers incentives and protection to individuals who report insider trading violations. Whistleblowers may receive anonymity, financial rewards, and safeguards against retaliation. — Reporting Channels: Companies are required to establish accessible and confidential reporting channels for employees to report suspicions of insider trading anonymously. It is important to note that the aforementioned policies and procedures may vary in their specific implementation and application among different organizations and market participants in Puerto Rico. However, the overall objective remains consistent: to create a transparent and fair marketplace that guards against insider trading and ensures investor protection.
