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).
Illinois Policies and Procedures Designed to Detect and Prevent Insider Trading: Insider trading refers to the illegal practice of trading stocks or other securities based on non-public information. To combat this unethical behavior and ensure fair and transparent financial markets, Illinois has implemented various policies and procedures specifically designed to detect and prevent insider trading. 1. Illinois Securities Act: The Illinois Securities Act serves as the foundation for all insider trading regulations within the state. It establishes guidelines and regulations to prevent fraud and protect investors' interests. The Act prohibits individuals from trading securities based on material non-public information. 2. Illinois Securities Department: The Illinois Securities Department is responsible for overseeing and enforcing the state's securities laws. This department works in collaboration with federal regulatory agencies, such as the Securities and Exchange Commission (SEC), to detect, investigate, and prosecute cases of insider trading. 3. Insider Trading Awareness Training: Illinois companies and financial institutions are encouraged to provide comprehensive insider trading awareness training to their employees. This training educates employees about the legal and ethical implications of insider trading and highlights the importance of maintaining the confidentiality of non-public information. 4. Effective Internal Control Systems: Illinois-based companies are strongly advised to implement robust internal control systems designed to detect and prevent insider trading. These systems include procedures for monitoring employee trading activities, maintaining restricted lists, and regularly reviewing and updating their policies to ensure compliance with insider trading regulations. 5. Whistleblower Protection: Illinois has established whistleblower protection programs to encourage individuals to report suspected insider trading. Whistleblowers who provide information leading to successful prosecutions or enforcement actions against insider trading are offered legal protection and may also receive financial rewards. 6. Cooperation with Law Enforcement Agencies: Illinois state agencies, including the Illinois Attorney General's Office and the Department of Financial and Professional Regulation, collaborate closely with federal law enforcement agencies, such as the FBI and the SEC, to identify, investigate, and prosecute insider trading cases. This cooperation contributes to the effectiveness of Illinois' efforts to detect and prevent insider trading. It is essential to note that these policies and procedures align with federal regulations and complement the initiatives and guidelines implemented at the national level. While Illinois may have specific measures in place, they largely adhere to the overall framework established by federal institutions, ultimately aiming to maintain integrity and fairness in the financial markets.Illinois Policies and Procedures Designed to Detect and Prevent Insider Trading: Insider trading refers to the illegal practice of trading stocks or other securities based on non-public information. To combat this unethical behavior and ensure fair and transparent financial markets, Illinois has implemented various policies and procedures specifically designed to detect and prevent insider trading. 1. Illinois Securities Act: The Illinois Securities Act serves as the foundation for all insider trading regulations within the state. It establishes guidelines and regulations to prevent fraud and protect investors' interests. The Act prohibits individuals from trading securities based on material non-public information. 2. Illinois Securities Department: The Illinois Securities Department is responsible for overseeing and enforcing the state's securities laws. This department works in collaboration with federal regulatory agencies, such as the Securities and Exchange Commission (SEC), to detect, investigate, and prosecute cases of insider trading. 3. Insider Trading Awareness Training: Illinois companies and financial institutions are encouraged to provide comprehensive insider trading awareness training to their employees. This training educates employees about the legal and ethical implications of insider trading and highlights the importance of maintaining the confidentiality of non-public information. 4. Effective Internal Control Systems: Illinois-based companies are strongly advised to implement robust internal control systems designed to detect and prevent insider trading. These systems include procedures for monitoring employee trading activities, maintaining restricted lists, and regularly reviewing and updating their policies to ensure compliance with insider trading regulations. 5. Whistleblower Protection: Illinois has established whistleblower protection programs to encourage individuals to report suspected insider trading. Whistleblowers who provide information leading to successful prosecutions or enforcement actions against insider trading are offered legal protection and may also receive financial rewards. 6. Cooperation with Law Enforcement Agencies: Illinois state agencies, including the Illinois Attorney General's Office and the Department of Financial and Professional Regulation, collaborate closely with federal law enforcement agencies, such as the FBI and the SEC, to identify, investigate, and prosecute insider trading cases. This cooperation contributes to the effectiveness of Illinois' efforts to detect and prevent insider trading. It is essential to note that these policies and procedures align with federal regulations and complement the initiatives and guidelines implemented at the national level. While Illinois may have specific measures in place, they largely adhere to the overall framework established by federal institutions, ultimately aiming to maintain integrity and fairness in the financial markets.
Para su conveniencia, debajo del texto en español le brindamos la versión completa de este formulario en inglés. For your convenience, the complete English version of this form is attached below the Spanish version.
