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).
Miami-Dade Florida Policies and Procedures Designed to Detect and Prevent Insider Trading Miami-Dade County in Florida has implemented several policies and procedures to effectively detect and prevent insider trading within its jurisdiction. These measures aim to ensure fair and transparent financial practices, maintain public trust, and protect the integrity of the county's financial systems. 1. Insider Trading Definition and Prohibition: Miami-Dade County has a clearly defined insider trading policy that outlines the concept of insider trading and explicitly prohibits it. The policy defines insider trading as the act of buying or selling securities while in possession of material non-public information that could impact the securities' value. 2. Reporting Obligations: Employees and officials of Miami-Dade County are required to promptly report any suspicions or evidence of insider trading to the appropriate authorities. This reporting obligation is crucial in ensuring that instances of insider trading are promptly investigated and necessary actions are taken. 3. Regular Training and Education: Miami-Dade County conducts regular training and education programs to educate employees and officials about the risks and consequences of insider trading. These programs aim to increase awareness and understanding of insider trading laws, ethical obligations, and the potentially severe legal and reputational consequences associated with such activities. 4. Confidentiality and Non-Disclosure Agreements: To further deter insider trading, Miami-Dade County may require employees and officials to sign confidentiality and non-disclosure agreements. These agreements emphasize the non-disclosure of material non-public information and the importance of maintaining confidentiality in accordance with applicable laws and regulations. 5. Restricted Trading Windows: Miami-Dade County may implement restricted trading windows or blackout periods during which employees and officials are prohibited from buying or selling securities of certain entities or industries to prevent potential conflicts of interest and insider trading. These restricted trading windows coincide with the release of significant financial information or pending material transactions. 6. Monitoring and Detection Systems: The county utilizes advanced monitoring and detection systems to identify suspicious trading activities that may indicate potential insider trading. These systems leverage sophisticated algorithms and data analytics to analyze trading patterns, identify irregularities, and flag potential instances of insider trading for further investigation by regulatory authorities. 7. Whistleblower Protection: Miami-Dade County maintains a robust whistleblower protection policy that encourages employees, officials, and members of the public to report suspected insider trading activities without fear of retaliation. Whistleblowers are provided with channels to report their concerns anonymously and are protected from any adverse actions resulting from their reporting. 8. Collaboration with Regulatory Bodies: Miami-Dade County actively collaborates with regulatory bodies such as the Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), and the Miami-Dade State Attorney's Office to share information, coordinate investigations, and ensure compliance with insider trading regulations and enforcement efforts. By implementing these comprehensive policies and procedures, Miami-Dade County strives to create a culture of integrity and transparency, effectively deterring and preventing insider trading within its jurisdiction while safeguarding the interests of its citizens and the broader financial community.Miami-Dade Florida Policies and Procedures Designed to Detect and Prevent Insider Trading Miami-Dade County in Florida has implemented several policies and procedures to effectively detect and prevent insider trading within its jurisdiction. These measures aim to ensure fair and transparent financial practices, maintain public trust, and protect the integrity of the county's financial systems. 1. Insider Trading Definition and Prohibition: Miami-Dade County has a clearly defined insider trading policy that outlines the concept of insider trading and explicitly prohibits it. The policy defines insider trading as the act of buying or selling securities while in possession of material non-public information that could impact the securities' value. 2. Reporting Obligations: Employees and officials of Miami-Dade County are required to promptly report any suspicions or evidence of insider trading to the appropriate authorities. This reporting obligation is crucial in ensuring that instances of insider trading are promptly investigated and necessary actions are taken. 3. Regular Training and Education: Miami-Dade County conducts regular training and education programs to educate employees and officials about the risks and consequences of insider trading. These programs aim to increase awareness and understanding of insider trading laws, ethical obligations, and the potentially severe legal and reputational consequences associated with such activities. 4. Confidentiality and Non-Disclosure Agreements: To further deter insider trading, Miami-Dade County may require employees and officials to sign confidentiality and non-disclosure agreements. These agreements emphasize the non-disclosure of material non-public information and the importance of maintaining confidentiality in accordance with applicable laws and regulations. 5. Restricted Trading Windows: Miami-Dade County may implement restricted trading windows or blackout periods during which employees and officials are prohibited from buying or selling securities of certain entities or industries to prevent potential conflicts of interest and insider trading. These restricted trading windows coincide with the release of significant financial information or pending material transactions. 6. Monitoring and Detection Systems: The county utilizes advanced monitoring and detection systems to identify suspicious trading activities that may indicate potential insider trading. These systems leverage sophisticated algorithms and data analytics to analyze trading patterns, identify irregularities, and flag potential instances of insider trading for further investigation by regulatory authorities. 7. Whistleblower Protection: Miami-Dade County maintains a robust whistleblower protection policy that encourages employees, officials, and members of the public to report suspected insider trading activities without fear of retaliation. Whistleblowers are provided with channels to report their concerns anonymously and are protected from any adverse actions resulting from their reporting. 8. Collaboration with Regulatory Bodies: Miami-Dade County actively collaborates with regulatory bodies such as the Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), and the Miami-Dade State Attorney's Office to share information, coordinate investigations, and ensure compliance with insider trading regulations and enforcement efforts. By implementing these comprehensive policies and procedures, Miami-Dade County strives to create a culture of integrity and transparency, effectively deterring and preventing insider trading within its jurisdiction while safeguarding the interests of its citizens and the broader financial community.
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.
