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).
Montgomery County, Maryland is a vibrant and diverse county located in the state of Maryland, just outside of Washington D.C. Known for its thriving economy, high quality of life, and strong community spirit, Montgomery County is committed to maintaining integrity and fair practices in its financial markets. To ensure that insider trading remains highly discouraged and promptly identified, the county has implemented a robust set of policies and procedures designed to detect and prevent such practices. One of the prominent types of Montgomery Maryland policies and procedures designed to detect and prevent insider trading is the establishment of clear guidelines regarding the dissemination and handling of material non-public information. Montgomery County requires its employees and stakeholders with access to confidential information to strictly adhere to established protocols and maintain the utmost confidentiality. In addition, periodic training sessions are conducted to educate employees about the risks and consequences associated with insider trading. To further fortify the framework, Montgomery County has implemented a systematic internal control system for the detection of insider trading activities. This system includes regular monitoring of transactions, data analysis, and the utilization of advanced technology to identify suspicious trading patterns or abnormal behavior. By analyzing trading records, evaluating market activities, and comparing them with available information, the county can swiftly detect any potential instances of insider trading. Additionally, Montgomery County has developed a stringent pre-clearance process for employees or individuals with access to material non-public information, especially when engaging in trades related to the county's assets or transactions. This pre-clearance system requires individuals to seek authorization from designated compliance officers before executing any trades. This mechanism ensures that transactions are conducted in a transparent and ethical manner, reducing the likelihood of insider trading. Furthermore, Montgomery County has established effective reporting mechanisms to encourage employees and stakeholders to report suspected instances of insider trading. A whistleblower hotline and email address are available to individuals who wish to convey their concerns anonymously. The county has implemented a policy that guarantees protection from retaliation for good faith reporting, providing reassurance to potential whistleblowers. Overall, Montgomery County's policies and procedures designed to detect and prevent insider trading reflect a proactive and diligent approach in safeguarding the integrity of its financial systems. By adhering to strict guidelines regarding the handling of confidential information, implementing robust internal control systems, enforcing pre-clearance requirements, and facilitating anonymous reporting, they are committed to maintaining transparency, fairness, and trust within the county's financial markets.Montgomery County, Maryland is a vibrant and diverse county located in the state of Maryland, just outside of Washington D.C. Known for its thriving economy, high quality of life, and strong community spirit, Montgomery County is committed to maintaining integrity and fair practices in its financial markets. To ensure that insider trading remains highly discouraged and promptly identified, the county has implemented a robust set of policies and procedures designed to detect and prevent such practices. One of the prominent types of Montgomery Maryland policies and procedures designed to detect and prevent insider trading is the establishment of clear guidelines regarding the dissemination and handling of material non-public information. Montgomery County requires its employees and stakeholders with access to confidential information to strictly adhere to established protocols and maintain the utmost confidentiality. In addition, periodic training sessions are conducted to educate employees about the risks and consequences associated with insider trading. To further fortify the framework, Montgomery County has implemented a systematic internal control system for the detection of insider trading activities. This system includes regular monitoring of transactions, data analysis, and the utilization of advanced technology to identify suspicious trading patterns or abnormal behavior. By analyzing trading records, evaluating market activities, and comparing them with available information, the county can swiftly detect any potential instances of insider trading. Additionally, Montgomery County has developed a stringent pre-clearance process for employees or individuals with access to material non-public information, especially when engaging in trades related to the county's assets or transactions. This pre-clearance system requires individuals to seek authorization from designated compliance officers before executing any trades. This mechanism ensures that transactions are conducted in a transparent and ethical manner, reducing the likelihood of insider trading. Furthermore, Montgomery County has established effective reporting mechanisms to encourage employees and stakeholders to report suspected instances of insider trading. A whistleblower hotline and email address are available to individuals who wish to convey their concerns anonymously. The county has implemented a policy that guarantees protection from retaliation for good faith reporting, providing reassurance to potential whistleblowers. Overall, Montgomery County's policies and procedures designed to detect and prevent insider trading reflect a proactive and diligent approach in safeguarding the integrity of its financial systems. By adhering to strict guidelines regarding the handling of confidential information, implementing robust internal control systems, enforcing pre-clearance requirements, and facilitating anonymous reporting, they are committed to maintaining transparency, fairness, and trust within the county's 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.
