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).
Keywords: Collin Texas, Policies and Procedures, Detect, Prevent, Insider Trading Detailed description: Collin Texas takes insider trading very seriously and has implemented robust policies and procedures to detect and prevent any such activities within the organization. These policies and procedures aim to maintain a fair and transparent trading environment, while also safeguarding the interests of stakeholders. 1. Insider Trading Policy: Collin Texas has established a comprehensive policy that strictly prohibits insider trading by employees, executives, and anyone associated with the company. This policy encompasses guidelines regarding the use of non-public information for personal gain, including trading restrictions and mandatory reporting procedures. 2. Employee Training and Education: To ensure awareness and understanding of insider trading regulations, Collin Texas conducts regular training sessions for all employees. These sessions cover the legal implications, consequences, and best practices surrounding insider trading, fostering a strong culture of compliance. 3. Restricted Trading Windows: Collin Texas maintains specific trading windows for individuals within the organization. These designated periods restrict trading activities, preventing the possibility of insider trading. Employees are informed about these windows and are required to adhere to them strictly. 4. Clearance and Reporting Procedures: Before executing any trades, employees are required to obtain pre-clearance from designated compliance officers. This process involves providing necessary information about the intended trade, enabling compliance officers to assess any potential conflicts or insider information. Additionally, all employees must promptly report any potential instances of insider trading or suspicious activities to the compliance team. 5. Monitoring and Surveillance: Collin Texas employs advanced monitoring and surveillance systems to detect any irregular trading patterns or suspicious activities. These systems utilize sophisticated algorithms and software solutions to identify possible instances of insider trading. Regular reviews and analysis are conducted to ensure the effectiveness of these systems. 6. Whistleblower Program: To encourage reporting of any misconduct related to insider trading, Collin Texas has established a confidential whistleblower program. This program allows employees to report suspected insider trading anonymously and provides protection against retaliation. The company ensures that all reports are adequately investigated and appropriate actions are taken. By implementing these rigorous policies and procedures, Collin Texas aims to create a culture of integrity, compliance, and transparency within the organization. These measures not only protect the company and its stakeholders but also contribute to the overall fairness and trust in the financial markets.Keywords: Collin Texas, Policies and Procedures, Detect, Prevent, Insider Trading Detailed description: Collin Texas takes insider trading very seriously and has implemented robust policies and procedures to detect and prevent any such activities within the organization. These policies and procedures aim to maintain a fair and transparent trading environment, while also safeguarding the interests of stakeholders. 1. Insider Trading Policy: Collin Texas has established a comprehensive policy that strictly prohibits insider trading by employees, executives, and anyone associated with the company. This policy encompasses guidelines regarding the use of non-public information for personal gain, including trading restrictions and mandatory reporting procedures. 2. Employee Training and Education: To ensure awareness and understanding of insider trading regulations, Collin Texas conducts regular training sessions for all employees. These sessions cover the legal implications, consequences, and best practices surrounding insider trading, fostering a strong culture of compliance. 3. Restricted Trading Windows: Collin Texas maintains specific trading windows for individuals within the organization. These designated periods restrict trading activities, preventing the possibility of insider trading. Employees are informed about these windows and are required to adhere to them strictly. 4. Clearance and Reporting Procedures: Before executing any trades, employees are required to obtain pre-clearance from designated compliance officers. This process involves providing necessary information about the intended trade, enabling compliance officers to assess any potential conflicts or insider information. Additionally, all employees must promptly report any potential instances of insider trading or suspicious activities to the compliance team. 5. Monitoring and Surveillance: Collin Texas employs advanced monitoring and surveillance systems to detect any irregular trading patterns or suspicious activities. These systems utilize sophisticated algorithms and software solutions to identify possible instances of insider trading. Regular reviews and analysis are conducted to ensure the effectiveness of these systems. 6. Whistleblower Program: To encourage reporting of any misconduct related to insider trading, Collin Texas has established a confidential whistleblower program. This program allows employees to report suspected insider trading anonymously and provides protection against retaliation. The company ensures that all reports are adequately investigated and appropriate actions are taken. By implementing these rigorous policies and procedures, Collin Texas aims to create a culture of integrity, compliance, and transparency within the organization. These measures not only protect the company and its stakeholders but also contribute to the overall fairness and trust 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.