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).
Mecklenburg North Carolina Policies and Procedures Designed to Detect and Prevent Insider Trading: Insider trading refers to the unlawful practice of trading or sharing nonpublic information about a company's stocks or securities, typically used for personal gain. To combat this unethical behavior, Mecklenburg North Carolina has implemented a series of robust policies and procedures aimed at detecting and preventing insider trading within the region. 1. Insider Trading Identification Protocol: This policy outlines the systematic process employed in Mecklenburg North Carolina to identify potential instances of insider trading. This includes the establishment of a dedicated team responsible for monitoring and analyzing trading activities, keeping a close eye on suspicious transactions, and examining patterns that could indicate insider trading. 2. Regular Monitoring and Surveillance: To detect insider trading, Mecklenburg North Carolina Policies and Procedures involve continuous monitoring and surveillance of trading activities across various platforms. Cutting-edge technologies and data analysis tools are employed to scrutinize trading patterns and trends that might indicate insider trading. This constant vigilance helps promptly identify any illegal activities and take appropriate actions. 3. Compliance Training and Education: Mecklenburg North Carolina emphasizes the importance of educating individuals about insider trading laws and regulations. Policies and Procedures include comprehensive training programs to raise awareness among employees and stakeholders. These programs provide insights into the consequences of insider trading, reporting obligations, and maintaining confidentiality of nonpublic information. 4. Reporting Obligations: To promote transparency and prevent insider trading, Mecklenburg North Carolina Policies and Procedures mandate the prompt reporting of any suspicious or potentially illegal activities. Employees, investors, or any concerned individuals are encouraged to report any instances of potential insider trading to designated authorities. Robust whistleblower protection mechanisms are also in place to ensure the anonymity and protection of those reporting such acts. 5. Restricted Trading Window: One of the key policies implemented in Mecklenburg North Carolina is the establishment of a restricted trading window. This means that specific periods are designated when insiders, such as company employees, are not allowed to trade company securities. This policy aims to minimize the risk of insider trading by closing opportunities for individuals with inside information to illegally benefit from the market. 6. Periodic Audits and Examinations: To ensure ongoing compliance with insider trading regulations, Mecklenburg North Carolina conducts periodic audits and examinations of trading activities within the region. These assessments examine financial records, trading activities, and compliance with the established policies and procedures. The findings from these audits help identify potential weaknesses in existing systems and provide insights for necessary improvements. By implementing these comprehensive Policies and Procedures Designed to Detect and Prevent Insider Trading, Mecklenburg North Carolina demonstrates its commitment to maintaining the integrity of its financial markets. These measures not only deter insider trading but also promote fair and transparent trading practices, fostering investor confidence and protecting the rights of market participants.Mecklenburg North Carolina Policies and Procedures Designed to Detect and Prevent Insider Trading: Insider trading refers to the unlawful practice of trading or sharing nonpublic information about a company's stocks or securities, typically used for personal gain. To combat this unethical behavior, Mecklenburg North Carolina has implemented a series of robust policies and procedures aimed at detecting and preventing insider trading within the region. 1. Insider Trading Identification Protocol: This policy outlines the systematic process employed in Mecklenburg North Carolina to identify potential instances of insider trading. This includes the establishment of a dedicated team responsible for monitoring and analyzing trading activities, keeping a close eye on suspicious transactions, and examining patterns that could indicate insider trading. 2. Regular Monitoring and Surveillance: To detect insider trading, Mecklenburg North Carolina Policies and Procedures involve continuous monitoring and surveillance of trading activities across various platforms. Cutting-edge technologies and data analysis tools are employed to scrutinize trading patterns and trends that might indicate insider trading. This constant vigilance helps promptly identify any illegal activities and take appropriate actions. 3. Compliance Training and Education: Mecklenburg North Carolina emphasizes the importance of educating individuals about insider trading laws and regulations. Policies and Procedures include comprehensive training programs to raise awareness among employees and stakeholders. These programs provide insights into the consequences of insider trading, reporting obligations, and maintaining confidentiality of nonpublic information. 4. Reporting Obligations: To promote transparency and prevent insider trading, Mecklenburg North Carolina Policies and Procedures mandate the prompt reporting of any suspicious or potentially illegal activities. Employees, investors, or any concerned individuals are encouraged to report any instances of potential insider trading to designated authorities. Robust whistleblower protection mechanisms are also in place to ensure the anonymity and protection of those reporting such acts. 5. Restricted Trading Window: One of the key policies implemented in Mecklenburg North Carolina is the establishment of a restricted trading window. This means that specific periods are designated when insiders, such as company employees, are not allowed to trade company securities. This policy aims to minimize the risk of insider trading by closing opportunities for individuals with inside information to illegally benefit from the market. 6. Periodic Audits and Examinations: To ensure ongoing compliance with insider trading regulations, Mecklenburg North Carolina conducts periodic audits and examinations of trading activities within the region. These assessments examine financial records, trading activities, and compliance with the established policies and procedures. The findings from these audits help identify potential weaknesses in existing systems and provide insights for necessary improvements. By implementing these comprehensive Policies and Procedures Designed to Detect and Prevent Insider Trading, Mecklenburg North Carolina demonstrates its commitment to maintaining the integrity of its financial markets. These measures not only deter insider trading but also promote fair and transparent trading practices, fostering investor confidence and protecting the rights of 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.
