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).
Montana Policies and Procedures Designed to Detect and Prevent Insider Trading: In Montana, policies and procedures have been put in place to detect and prevent insider trading, ensuring a fair and transparent financial market. These specific guidelines and measures aim to safeguard against the misuse of material nonpublic information by individuals within organizations involved in trading securities. This comprehensive system seeks to maintain market integrity and protect investors. Key Keywords: Montana, Policies and Procedures, Detect, Prevent, Insider Trading 1. Prohibition Policies: Montana incorporates stringent prohibition policies that explicitly forbid insider trading within the state's financial market. These policies outline the legal framework and define insider trading, establishing the boundaries for ethical and legal conduct. 2. Education and Training: To raise awareness and promote compliance, Montana offers comprehensive education and training programs to individuals working within the financial sector. These training sessions address the nuances of insider trading, consequences, and proper handling of material nonpublic information, equipping employees with the necessary knowledge to identify and avoid potential infractions. 3. Restricted Lists: Montana policies incorporate the establishment and maintenance of restricted lists. These lists help regulate trading activities by identifying specific securities or companies for which insiders are prohibited from trading due to their access to confidential information. The restricted list acts as a practical tool for compliance officers to monitor and prevent potential insider trading instances. 4. Insider Trading Surveillance: To actively identify potential insider trading activities, Montana employs sophisticated surveillance systems. These systems utilize advanced technologies and algorithms to monitor trading patterns, track unusual activities, and flag suspicious behavior that might indicate insider trading. These surveillance mechanisms ensure detection in near real-time, enabling the regulatory bodies to intervene promptly and investigate any alleged misconduct. 5. Whistleblower Protection: Montana recognizes the importance of encouraging individuals to come forward and report any instances of suspected insider trading. Thus, they have implemented whistleblower protection policies that safeguard individuals who disclose information related to potential insider trading from retaliation or adverse actions. Such protection encourages transparency and assists in the detection and prevention of insider trading activities. 6. Regulatory Cooperation: Montana actively collaborates with other regulatory bodies, such as the Securities and Exchange Commission (SEC), to share information and best practices related to insider trading detection and prevention. This cooperation enhances the effectiveness of enforcement efforts, intelligence gathering, and provides opportunities to align policies in a robust and unified manner. These Montana policies and procedures collectively create a robust framework designed to detect and prevent insider trading effectively. By emphasizing education, surveillance, collaboration, and protection, Montana aims to ensure fair and equitable financial markets, inspiring trust and confidence among investors.Montana Policies and Procedures Designed to Detect and Prevent Insider Trading: In Montana, policies and procedures have been put in place to detect and prevent insider trading, ensuring a fair and transparent financial market. These specific guidelines and measures aim to safeguard against the misuse of material nonpublic information by individuals within organizations involved in trading securities. This comprehensive system seeks to maintain market integrity and protect investors. Key Keywords: Montana, Policies and Procedures, Detect, Prevent, Insider Trading 1. Prohibition Policies: Montana incorporates stringent prohibition policies that explicitly forbid insider trading within the state's financial market. These policies outline the legal framework and define insider trading, establishing the boundaries for ethical and legal conduct. 2. Education and Training: To raise awareness and promote compliance, Montana offers comprehensive education and training programs to individuals working within the financial sector. These training sessions address the nuances of insider trading, consequences, and proper handling of material nonpublic information, equipping employees with the necessary knowledge to identify and avoid potential infractions. 3. Restricted Lists: Montana policies incorporate the establishment and maintenance of restricted lists. These lists help regulate trading activities by identifying specific securities or companies for which insiders are prohibited from trading due to their access to confidential information. The restricted list acts as a practical tool for compliance officers to monitor and prevent potential insider trading instances. 4. Insider Trading Surveillance: To actively identify potential insider trading activities, Montana employs sophisticated surveillance systems. These systems utilize advanced technologies and algorithms to monitor trading patterns, track unusual activities, and flag suspicious behavior that might indicate insider trading. These surveillance mechanisms ensure detection in near real-time, enabling the regulatory bodies to intervene promptly and investigate any alleged misconduct. 5. Whistleblower Protection: Montana recognizes the importance of encouraging individuals to come forward and report any instances of suspected insider trading. Thus, they have implemented whistleblower protection policies that safeguard individuals who disclose information related to potential insider trading from retaliation or adverse actions. Such protection encourages transparency and assists in the detection and prevention of insider trading activities. 6. Regulatory Cooperation: Montana actively collaborates with other regulatory bodies, such as the Securities and Exchange Commission (SEC), to share information and best practices related to insider trading detection and prevention. This cooperation enhances the effectiveness of enforcement efforts, intelligence gathering, and provides opportunities to align policies in a robust and unified manner. These Montana policies and procedures collectively create a robust framework designed to detect and prevent insider trading effectively. By emphasizing education, surveillance, collaboration, and protection, Montana aims to ensure fair and equitable financial markets, inspiring trust and confidence among investors.
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.
