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Published byIsabella Blake Modified over 9 years ago
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Insider Trading, Code of Ethics, and Procedures for Complaints re: Ethics & Accounting Controls By John Smith, General Counsel Investors, Inc.
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Insider Trading Policy Applies to anyone who has material non-public information – All employees –Board of directors –Certain others (consultants, contractors) Helps to prevent insider trading May not “tip” information
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Material Non-Public Information Material Information –“any type of positive or negative information which could reasonably be expected to affect the price of Company securities.” Page 7 of Insider Trading Policy of 6/25/04 Non-Public Information –“has not been widely disseminated to the public through major newswire services, national news services and financial news services.” Page 8 of Insider Trading Policy
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Insider Trading Policy You may exercise options at any time You may buy stock when you do not have material inside information May only sell stock during “trading window” Trading window is beginning of the close of trading on 2 nd full day following public release of earnings and ending 10 days prior to the last day of next quarterly period
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End of Demo.. By John Smith, General Counsel Investors, Inc.
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