We Prevent Insider Trading

Our Principle

We deliver on our commitment to act ethically when we never use or share material, non-public information for the purpose of buying or selling securities.

Why It Matters

We are careful to preserve our reputation as a company that can be relied on to protect information entrusted to us. Often in the course of our jobs we may have access to information about our company or our customers and business partners that is not yet known to the public. We do not engage in insider trading because it is unethical, illegal and would harm investors, employees, and our reputation.

What is Insider Trading?

Insider trading occurs when an individual makes use of or shares inside information for personal gain or to avoid a loss in the stock market. It a serious crime punishable by heavy fines and imprisonment. You may hear the terms “material” and non-public information. Material, non-public information is information known to us but not yet released to the public. It is also information that an investor would consider important in deciding whether to buy or sell shares.

Our Insider Trading Policy

Here is a simple decision-making process to help you understand whether or not our Insider Trading Policy applies to you and a transaction you are about to make.

Step 1

Am I subject to a trading black out period?

Proceed

If you are unsure, consult with your manager or other resources and ask for help.

Don't do it.

If you are unsure, consult with your manager or other resources and ask for help.

go here xxx for help/guidance

If you are unsure, consult with your manager or other resources and ask for help.

Step 2

Is the trading window open?

Proceed

If you are unsure, consult with your manager or other resources and ask for help.

Don't do it.

If you are unsure, consult with your manager or other resources and ask for help.

go here xxx for help/guidance

If you are unsure, consult with your manager or other resources and ask for help.

Step 3

Do I have information about our Company or others we conduct business with that isn’t available to the public?

Proceed

If you are unsure, consult with your manager or other resources and ask for help.

Don't do it.

If you are unsure, consult with your manager or other resources and ask for help.

go here xxx for help/guidance

If you are unsure, consult with your manager or other resources and ask for help.

Step 4

Is the information material?

Proceed

If you are unsure, consult with your manager or other resources and ask for help.

Don't do it.

If you are unsure, consult with your manager or other resources and ask for help.

go here xxx for help/guidance

If you are unsure, consult with your manager or other resources and ask for help.

How We Live Our Values

  • Never Buying or Selling

    Never buying or selling shares in our Company or any other publicly traded company when in possession of inside information.

  • Waiting for Investors

    Never buying or selling shares until the inside information about the relevant company becomes available publicly and investors have had a chance to evaluate it.

  • Not Disclosing

    Not disclosing inside information to anyone outside the Company, including family members, relatives, or friends.

  • Need-to-Know-Basis

    Only sharing inside information with fellow employees on a “need-to-know” basis.

  • Taking Care

    Taking care to protect inside information from accidental disclosure.

  • Not Encouraging

    Never encouraging others to trade on inside information.

Food for Thought

What is Insider Trading? Insider trading occurs when an individual makes use of or shares inside information for personal gain or to avoid a loss in the stock market.

Know the Code

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