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).
New Hampshire Policies and Procedures Designed to Detect and Prevent Insider Trading In New Hampshire, stringent measures and policies have been put in place to combat the illegal practice of insider trading. These policies aim to maintain the integrity of the financial markets and safeguard the interests of investors. Various types of policies and procedures have been implemented to detect and prevent insider trading within the state. 1. Disclosure Requirements: New Hampshire has specific rules and regulations in place that require companies, their directors, officers, and other insiders to disclose any material non-public information. This information includes financial statements, strategic plans, mergers, acquisitions, or any other sensitive information that may impact the company's stock price. Such disclosures ensure transparency and prevent insider trading by reducing the information advantage of insiders. 2. Insider Trading Policies: Many companies operating within New Hampshire adopt strict insider trading policies that outline ethical standards and guidelines to prevent the misuse of insider information. These policies educate employees and insiders about their legal obligations and responsibilities, emphasizing the prohibition of trading with material non-public information. 3. Employee Training and Education: To create awareness and foster a culture of compliance, many organizations in New Hampshire provide regular training sessions and educational programs on insider trading. Employees are educated about the legal consequences, reporting obligations, and the importance of maintaining market integrity. These programs help employees understand the boundaries between legal and illegal behavior and promote the reporting of suspicious activities. 4. Restricted Trading Windows: Another commonly adopted practice is implementing restricted trading windows during which insiders are prohibited from trading company stock. These windows typically coincide with the release of significant financial information or corporate events. By restricting trading activities during these periods, the risk of insiders illegally capitalizing on non-public information is significantly mitigated. 5. Monitoring and Surveillance: Various regulatory bodies and market participants diligently monitor trading activities within New Hampshire's financial markets. Sophisticated surveillance systems are deployed to detect any irregularities or suspicious trading patterns. These systems analyze trading data, compare it with publicly available information, and flag potentially fraudulent activities. Insider trading cases detected by these systems are subjected to thorough investigations and appropriate legal action. 6. Whistleblower Protection: New Hampshire provides legal protections and mechanisms to encourage whistleblowing in cases of suspected insider trading. Employees who report such activities are shielded from retaliation and enjoy legal safeguards, motivating them to come forward with valuable information. This helps uncover illegal activities and aids in the enforcement of insider trading laws. By employing a combination of disclosure requirements, comprehensive insider trading policies, employee education, restricted trading windows, monitoring systems, and whistleblower protections, New Hampshire is committed to detecting and preventing insider trading activities. These policies work together to maintain the integrity of the financial markets and ensure fair and transparent trading practices for all market participants.New Hampshire Policies and Procedures Designed to Detect and Prevent Insider Trading In New Hampshire, stringent measures and policies have been put in place to combat the illegal practice of insider trading. These policies aim to maintain the integrity of the financial markets and safeguard the interests of investors. Various types of policies and procedures have been implemented to detect and prevent insider trading within the state. 1. Disclosure Requirements: New Hampshire has specific rules and regulations in place that require companies, their directors, officers, and other insiders to disclose any material non-public information. This information includes financial statements, strategic plans, mergers, acquisitions, or any other sensitive information that may impact the company's stock price. Such disclosures ensure transparency and prevent insider trading by reducing the information advantage of insiders. 2. Insider Trading Policies: Many companies operating within New Hampshire adopt strict insider trading policies that outline ethical standards and guidelines to prevent the misuse of insider information. These policies educate employees and insiders about their legal obligations and responsibilities, emphasizing the prohibition of trading with material non-public information. 3. Employee Training and Education: To create awareness and foster a culture of compliance, many organizations in New Hampshire provide regular training sessions and educational programs on insider trading. Employees are educated about the legal consequences, reporting obligations, and the importance of maintaining market integrity. These programs help employees understand the boundaries between legal and illegal behavior and promote the reporting of suspicious activities. 4. Restricted Trading Windows: Another commonly adopted practice is implementing restricted trading windows during which insiders are prohibited from trading company stock. These windows typically coincide with the release of significant financial information or corporate events. By restricting trading activities during these periods, the risk of insiders illegally capitalizing on non-public information is significantly mitigated. 5. Monitoring and Surveillance: Various regulatory bodies and market participants diligently monitor trading activities within New Hampshire's financial markets. Sophisticated surveillance systems are deployed to detect any irregularities or suspicious trading patterns. These systems analyze trading data, compare it with publicly available information, and flag potentially fraudulent activities. Insider trading cases detected by these systems are subjected to thorough investigations and appropriate legal action. 6. Whistleblower Protection: New Hampshire provides legal protections and mechanisms to encourage whistleblowing in cases of suspected insider trading. Employees who report such activities are shielded from retaliation and enjoy legal safeguards, motivating them to come forward with valuable information. This helps uncover illegal activities and aids in the enforcement of insider trading laws. By employing a combination of disclosure requirements, comprehensive insider trading policies, employee education, restricted trading windows, monitoring systems, and whistleblower protections, New Hampshire is committed to detecting and preventing insider trading activities. These policies work together to maintain the integrity of the financial markets and ensure fair and transparent trading practices for all market participants.
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.