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).
Washington Policies and Procedures Designed to Detect and Prevent Insider Trading: Insider trading refers to the act of trading stocks or other securities based on material, non-public information about the company. It is considered illegal and unethical as it provides an unfair advantage to individuals who possess such information. To combat insider trading, Washington has implemented a comprehensive set of policies and procedures. These measures aim to detect and prevent any illicit activities and maintain the integrity of the financial markets. 1. Washington Securities Exchange Commission (SEC) Regulations: The SEC plays a crucial role in regulating and overseeing the securities' industry. It has established specific regulations to detect and prevent insider trading. These regulations include stringent reporting requirements for insiders, prohibiting trades based on non-public information, and imposing penalties for violations. 2. Washington State Ethics Code: Washington has a State Ethics Code that applies to public officials, government employees, and those involved in the procurement process. This code aims to ensure transparency and prevent conflicts of interest. It prohibits these individuals from using insider information for personal gain and mandates disclosure of any potential conflicts. 3. Washington Department of Financial Institutions (DFI) Guidelines: The DFI provides guidelines specifically designed to prevent insider trading within financial institutions. These guidelines emphasize the importance of internal controls, risk assessment, and training programs. They require financial institutions to implement robust monitoring systems and ensure their employees are aware of the legal and ethical implications of insider trading. 4. Washington State Whistleblower Protection Act: The Whistleblower Protection Act in Washington safeguards individuals who report illegal activities, including insider trading. This act establishes protection for whistleblowers from retaliation, ensuring that those who come forward to report insider trading are shielded from adverse consequences. 5. Corporate Governance Policies: Many Washington-based companies have their own internal policies and procedures to prevent insider trading. These policies include strict trading blackout periods around important company events, like earnings announcements or mergers and acquisitions. They also often require employees to receive regular training on insider trading laws and identify potential violations within the organization. 6. Collaboration between Regulatory Bodies: Washington State regularly collaborates with federal regulatory bodies like the SEC and Financial Industry Regulatory Authority (FINRA) to share information and coordinate efforts to detect and prevent insider trading. This collaboration strengthens compliance and enforcement mechanisms, ensuring a comprehensive approach to combating insider trading. In summary, Washington has implemented a range of policies and procedures to detect and prevent insider trading. These measures involve SEC regulations, the State Ethics Code, DFI guidelines, the Whistleblower Protection Act, corporate governance policies, and collaboration between regulatory bodies. By implementing such comprehensive measures, Washington aims to safeguard the financial markets and foster an environment of integrity and fairness.
