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).
Title: Understanding the Wisconsin Policies and Procedures Designed to Detect and Prevent Insider Trading Introduction: The state of Wisconsin, like many other jurisdictions, has enacted specific policies and procedures to detect and prevent insider trading. Insider trading refers to the unlawful practice of trading stocks or securities based on non-public information, giving insiders an unfair advantage in the market. This comprehensive description provides an overview of Wisconsin's policies and procedures, highlighting their significance in maintaining fair and transparent financial markets. 1. "Wisconsin Insider Trading Law": Wisconsin operates under the purview of federal securities laws, such as the Securities Exchange Act of 1934 and the Securities Act of 1933. These laws provide a legal framework for regulating securities transactions, including provisions to combat insider trading. Wisconsin's implementation of these federal laws ensures consistency and compliance within the state. 2. "The Wisconsin Division of Securities": The Wisconsin Division of Securities, a branch of the Department of Financial Institutions, is responsible for enforcing securities laws within the state. They oversee various aspects, including the detection and prevention of insider trading. Compliance with their procedures helps maintain market integrity and protect investors. 3. "Wisconsin's Prohibition on Insider Trading": Wisconsin strictly prohibits insider trading and has put in place rigorous measures to prevent and detect such activities. The law prohibits individuals from buying or selling securities based on material non-public information, or disclosing such information to others for trading purposes. Violators are subject to penalties, including fines, imprisonment, and civil liability. 4. "Maintaining Fair and Transparent Financial Markets": To ensure market fairness and transparency, Wisconsin has established guidelines for corporations and entities, requiring them to establish and maintain internal controls, systems, and procedures to detect and prevent insider trading. These guidelines also emphasize the periodic review of existing procedures to adapt to emerging challenges and changing market dynamics. 5. "Training and Education Programs": Wisconsin encourages corporations to provide comprehensive training and education programs for their employees, with a specific focus on insider trading prevention. These programs raise awareness and educate employees about the consequences associated with insider trading, thereby promoting ethical behavior and compliance with the law. 6. "Reporting and Whistleblower Protection": Wisconsin's policies and procedures include provisions for reporting suspected instances of insider trading. Individuals are encouraged to report any suspicious activities to the Wisconsin Division of Securities, who ensure that whistleblower protection laws safeguard those who come forward with relevant information. 7. "Cooperation with Federal Securities Authorities": Wisconsin actively cooperates and shares information with federal securities authorities, such as the Securities and Exchange Commission (SEC), in cases involving insider trading. This cooperation facilitates the coordination of investigations and enhances the overall effectiveness of preventing and detecting insider trading activities at both state and federal levels. Conclusion: Wisconsin's policies and procedures designed to detect and prevent insider trading play a crucial role in maintaining a fair and transparent financial marketplace within the state. Through the implementation of laws, enforcement by regulatory bodies such as the Wisconsin Division of Securities, and collaboration with federal authorities, Wisconsin aims to safeguard investors and uphold the integrity of its securities markets. Compliance with these policies and procedures remains essential for corporations, employees, and individuals operating within the state.
