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).
Hillsborough Florida Policy and Procedure: Hillsborough County, Florida, has implemented comprehensive policies and procedures designed to detect and prevent insider trading within its jurisdiction. These guidelines aim to uphold the integrity of financial markets and protect the interests of investors by ensuring fair and transparent practices. Insider trading refers to the illegal practice of trading stocks, securities, or other financial instruments based on non-public, material information not yet available to the public. This unfair advantage can harm market trust, distort market prices, and compromise investor confidence. Hillsborough County recognizes the significance of combating insider trading and has implemented several policies and procedures to address this issue. 1. Insider Trading Policy: Hillsborough County has a dedicated Insider Trading Policy, which outlines the requirements and expectations for employees, contractors, and other individuals associated with the county. This policy emphasizes the prohibition of trading based on non-public information, the necessity to report any suspicious activity, and the severe consequences of non-compliance. 2. Code of Conduct: The county has a Code of Conduct that sets ethical standards for all employees. This code explicitly prohibits insider trading and emphasizes the importance of maintaining confidentiality and integrity in any matters related to financial information or stakeholders' interests. 3. Whistleblower Protection: Hillsborough County ensures that individuals who report suspected insider trading are protected from retaliation through a comprehensive Whistleblower Protection Program. This program encourages employees and stakeholders to come forward with any information regarding potential insider trading activities, providing them with legal safeguards and anonymous reporting options. 4. Compliance Training: To promote awareness and understanding of insider trading laws and regulations, Hillsborough County offers comprehensive training programs. These programs educate employees and relevant individuals about the legal framework, obligations, and consequences related to insider trading. Regular training sessions and updates allow personnel to remain vigilant and well-informed about potential risks and preventive measures. 5. Monitoring and Detection Systems: Hillsborough County employs advanced monitoring systems and technologies to detect potential insider trading activities. These systems carefully analyze trading patterns, financial transactions, and other relevant data to identify suspicious behavior or trading activities conducted on the basis of non-public information. Regular inspections and audits are conducted to ensure compliance with the policies and detect any potential violations. 6. Collaborative Efforts: Hillsborough County actively engages in collaborative efforts with relevant regulatory bodies, such as the Securities and Exchange Commission (SEC) and other law enforcement agencies. This collaboration aims to enhance the effectiveness of insider trading detection and prevention by exchanging information, sharing best practices, and coordinating investigations when necessary. It is important to note that the specific policies and procedures might vary depending on the nature of Hillsborough County's jurisdiction and the regulatory frameworks applicable at the local, state, and federal levels. However, the above-mentioned guidelines reflect the comprehensive approach taken by the county to detect and prevent insider trading effectively. By implementing these policies and procedures, Hillsborough County demonstrates its commitment to maintaining the integrity of financial markets, safeguarding investor interests, and fostering an environment where fair and transparent trading practices thrive.Hillsborough Florida Policy and Procedure: Hillsborough County, Florida, has implemented comprehensive policies and procedures designed to detect and prevent insider trading within its jurisdiction. These guidelines aim to uphold the integrity of financial markets and protect the interests of investors by ensuring fair and transparent practices. Insider trading refers to the illegal practice of trading stocks, securities, or other financial instruments based on non-public, material information not yet available to the public. This unfair advantage can harm market trust, distort market prices, and compromise investor confidence. Hillsborough County recognizes the significance of combating insider trading and has implemented several policies and procedures to address this issue. 1. Insider Trading Policy: Hillsborough County has a dedicated Insider Trading Policy, which outlines the requirements and expectations for employees, contractors, and other individuals associated with the county. This policy emphasizes the prohibition of trading based on non-public information, the necessity to report any suspicious activity, and the severe consequences of non-compliance. 2. Code of Conduct: The county has a Code of Conduct that sets ethical standards for all employees. This code explicitly prohibits insider trading and emphasizes the importance of maintaining confidentiality and integrity in any matters related to financial information or stakeholders' interests. 3. Whistleblower Protection: Hillsborough County ensures that individuals who report suspected insider trading are protected from retaliation through a comprehensive Whistleblower Protection Program. This program encourages employees and stakeholders to come forward with any information regarding potential insider trading activities, providing them with legal safeguards and anonymous reporting options. 4. Compliance Training: To promote awareness and understanding of insider trading laws and regulations, Hillsborough County offers comprehensive training programs. These programs educate employees and relevant individuals about the legal framework, obligations, and consequences related to insider trading. Regular training sessions and updates allow personnel to remain vigilant and well-informed about potential risks and preventive measures. 5. Monitoring and Detection Systems: Hillsborough County employs advanced monitoring systems and technologies to detect potential insider trading activities. These systems carefully analyze trading patterns, financial transactions, and other relevant data to identify suspicious behavior or trading activities conducted on the basis of non-public information. Regular inspections and audits are conducted to ensure compliance with the policies and detect any potential violations. 6. Collaborative Efforts: Hillsborough County actively engages in collaborative efforts with relevant regulatory bodies, such as the Securities and Exchange Commission (SEC) and other law enforcement agencies. This collaboration aims to enhance the effectiveness of insider trading detection and prevention by exchanging information, sharing best practices, and coordinating investigations when necessary. It is important to note that the specific policies and procedures might vary depending on the nature of Hillsborough County's jurisdiction and the regulatory frameworks applicable at the local, state, and federal levels. However, the above-mentioned guidelines reflect the comprehensive approach taken by the county to detect and prevent insider trading effectively. By implementing these policies and procedures, Hillsborough County demonstrates its commitment to maintaining the integrity of financial markets, safeguarding investor interests, and fostering an environment where fair and transparent trading practices thrive.
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.
