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).
Bronx New York Policies and Procedures Designed to Detect and Prevent Insider Trading refers to the illegal practice of trading stocks or other securities based on confidential and non-public information that is not yet available to the public. To combat insider trading, the Bronx in New York has put in place various policies and procedures aimed at detecting and preventing such illicit activities. These measures are crucial to maintain the integrity and fairness of the financial markets within the Bronx. 1. Reporting Obligations: Financial institutions, corporations, and individuals are required to report any suspicious trading activity to the appropriate regulatory authorities in the Bronx. This includes unusual trading patterns, significant changes in ownership, or any other behavior suggestive of insider trading. 2. Restricted Trading Lists: The Bronx implements restricted trading lists to regulate the buying and selling of securities by employees or individuals with access to material non-public information. These lists prevent insiders from trading in certain securities during specific periods to avoid potential conflicts of interest or improper trading. 3. Insider Trading Training: Companies within the Bronx conduct regular training sessions to educate their employees on what constitutes insider trading and its various forms. Training enhances awareness of legal obligations, ethical conduct, and the consequences of engaging in insider trading activities. 4. Information Barriers: Adequate information barriers or "Chinese walls" are established within financial institutions to prevent the flow of material non-public information between different departments or individuals. These barriers ensure that individuals with access to such information do not improperly use it for personal gain or share it with unauthorized parties. 5. Whistleblower Programs: The Bronx encourages the implementation of whistleblower programs to promote the reporting of suspected insider trading. These programs provide a means for individuals to anonymously report potential violations and protect them against retaliation. 6. Continuous Monitoring and Surveillance: Regulatory authorities in the Bronx employ advanced surveillance technologies and data analytics to monitor trading activities in real-time. This enables them to identify suspicious patterns, unusual trading activities, or any other behavior indicative of insider trading. 7. Enforcement and Penalties: The Bronx has strict enforcement mechanisms in place to deter individuals from engaging in insider trading. Penalties for insider trading can include hefty fines, imprisonment, civil penalties, disgorgement of profits, and suspension or revocation of trading licenses. In conclusion, the Bronx in New York recognizes the importance of combatting insider trading to safeguard the integrity of its financial markets. The policies and procedures mentioned above, among others, serve as crucial tools to detect potential insider trading activities, ensure fair trading practices, and maintain investor confidence.Bronx New York Policies and Procedures Designed to Detect and Prevent Insider Trading refers to the illegal practice of trading stocks or other securities based on confidential and non-public information that is not yet available to the public. To combat insider trading, the Bronx in New York has put in place various policies and procedures aimed at detecting and preventing such illicit activities. These measures are crucial to maintain the integrity and fairness of the financial markets within the Bronx. 1. Reporting Obligations: Financial institutions, corporations, and individuals are required to report any suspicious trading activity to the appropriate regulatory authorities in the Bronx. This includes unusual trading patterns, significant changes in ownership, or any other behavior suggestive of insider trading. 2. Restricted Trading Lists: The Bronx implements restricted trading lists to regulate the buying and selling of securities by employees or individuals with access to material non-public information. These lists prevent insiders from trading in certain securities during specific periods to avoid potential conflicts of interest or improper trading. 3. Insider Trading Training: Companies within the Bronx conduct regular training sessions to educate their employees on what constitutes insider trading and its various forms. Training enhances awareness of legal obligations, ethical conduct, and the consequences of engaging in insider trading activities. 4. Information Barriers: Adequate information barriers or "Chinese walls" are established within financial institutions to prevent the flow of material non-public information between different departments or individuals. These barriers ensure that individuals with access to such information do not improperly use it for personal gain or share it with unauthorized parties. 5. Whistleblower Programs: The Bronx encourages the implementation of whistleblower programs to promote the reporting of suspected insider trading. These programs provide a means for individuals to anonymously report potential violations and protect them against retaliation. 6. Continuous Monitoring and Surveillance: Regulatory authorities in the Bronx employ advanced surveillance technologies and data analytics to monitor trading activities in real-time. This enables them to identify suspicious patterns, unusual trading activities, or any other behavior indicative of insider trading. 7. Enforcement and Penalties: The Bronx has strict enforcement mechanisms in place to deter individuals from engaging in insider trading. Penalties for insider trading can include hefty fines, imprisonment, civil penalties, disgorgement of profits, and suspension or revocation of trading licenses. In conclusion, the Bronx in New York recognizes the importance of combatting insider trading to safeguard the integrity of its financial markets. The policies and procedures mentioned above, among others, serve as crucial tools to detect potential insider trading activities, ensure fair trading practices, and maintain investor confidence.
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.
