Insider Trading Policy review

Insider trading policy under Rule 10b-5 + Rule 10b5-1 (Dec. 2022 amendments).

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5 document-specific checks
+ 104 general checks
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What it checks

Material non-public information (MNPI) prohibition

Policy must prohibit trading on material non-public information (Rule 10b-5).

Critical · POL-018

Blackout periods + pre-clearance for insiders

Policy must establish blackout periods around earnings + pre-clearance for Section 16 insiders.

Critical · POL-019

Rule 10b5-1 trading-plan provisions

Policy should address Rule 10b5-1 trading plans (December 2022 amendments — cooling-off + good faith).

Warning · POL-020

Tipper / tippee liability + family members + 'spreading the love' prohibition

Policy must address tipping liability (covers family members / friends / brokers).

Critical · POL-021

Short sales / derivatives / hedging restrictions

Policy should restrict short sales, hedging, and derivative transactions by insiders.

Warning · POL-022

Every run also applies 104 general checks that belong to any agreement: structure, parties and signatures, defined terms, cross-references, dates, amounts, and one-sided terms.

Often reviewed with

Code of Conduct / Ethics

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