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).
Title: Riverside California Policies and Procedures Designed to Detect and Prevent Insider Trading: Ensuring Fairness and Transparency Introduction: Riverside, California, has implemented a robust set of policies and procedures aimed at detecting and preventing insider trading. This comprehensive approach prioritizes fairness, transparency, and the protection of investors' interests. This article explores the various types of policies and procedures in place, which are crucial in safeguarding the integrity of the financial markets. 1. Insider Trading Definition: Insider trading refers to the illegal practice of trading securities based on material, non-public information, affording an unfair advantage to those with privileged access. Riverside actively combats this misconduct through stringent regulations and guidelines. 2. Compliance Program: Riverside's compliance program is designed to ensure adherence to securities laws and regulations. It encompasses regular training and education sessions for employees, providing them with up-to-date knowledge of insider trading laws while emphasizing ethical behavior. 3. Insider Trading Policies: a. Prohibition Policy: Riverside's prohibition policy explicitly prohibits company insiders from trading securities based on any undisclosed material information. This blanket restriction effectively deters the misuse of privileged information. b. Wall Crossing Policy: To manage situations where non-public information must be shared with selected individuals, Riverside employs a wall crossing policy. This policy ensures that appropriate steps are taken to prevent the unauthorized trading or dissemination of sensitive information. c. Pre-Clearance Policy: Riverside requires insiders to seek prior approval before conducting certain types of securities transactions. This pre-clearance policy provides an opportunity for compliance officers to review trades and identify any potential conflicts of interest or violations. 4. Reporting and Monitoring: a. Reporting Suspicious Activities: Riverside encourages employees to report any suspicious trading activity or potential insider trading instances promptly. An anonymous reporting mechanism is in place to protect whistleblowers. b. Regular Monitoring: To maintain vigilance, Riverside continuously monitors market activities, closely reviewing trading patterns to identify any irregularities or suspicious transactions. Advanced technology and data analytics play a significant role in this ongoing surveillance. 5. Enforcement: Riverside holds individuals accountable for any proven instances of insider trading through a strong enforcement program. Disciplinary actions, including fines, penalties, and potential legal consequences, act as a deterrent against fraudulent behavior. Conclusion: Riverside California's policies and procedures designed to detect and prevent insider trading have set high standards for transparency, fairness, and market integrity. By implementing these comprehensive guidelines, Riverside continues to foster an environment where investors can confidently participate in the financial markets, knowing that their interests are protected from the risk of insider trading.Title: Riverside California Policies and Procedures Designed to Detect and Prevent Insider Trading: Ensuring Fairness and Transparency Introduction: Riverside, California, has implemented a robust set of policies and procedures aimed at detecting and preventing insider trading. This comprehensive approach prioritizes fairness, transparency, and the protection of investors' interests. This article explores the various types of policies and procedures in place, which are crucial in safeguarding the integrity of the financial markets. 1. Insider Trading Definition: Insider trading refers to the illegal practice of trading securities based on material, non-public information, affording an unfair advantage to those with privileged access. Riverside actively combats this misconduct through stringent regulations and guidelines. 2. Compliance Program: Riverside's compliance program is designed to ensure adherence to securities laws and regulations. It encompasses regular training and education sessions for employees, providing them with up-to-date knowledge of insider trading laws while emphasizing ethical behavior. 3. Insider Trading Policies: a. Prohibition Policy: Riverside's prohibition policy explicitly prohibits company insiders from trading securities based on any undisclosed material information. This blanket restriction effectively deters the misuse of privileged information. b. Wall Crossing Policy: To manage situations where non-public information must be shared with selected individuals, Riverside employs a wall crossing policy. This policy ensures that appropriate steps are taken to prevent the unauthorized trading or dissemination of sensitive information. c. Pre-Clearance Policy: Riverside requires insiders to seek prior approval before conducting certain types of securities transactions. This pre-clearance policy provides an opportunity for compliance officers to review trades and identify any potential conflicts of interest or violations. 4. Reporting and Monitoring: a. Reporting Suspicious Activities: Riverside encourages employees to report any suspicious trading activity or potential insider trading instances promptly. An anonymous reporting mechanism is in place to protect whistleblowers. b. Regular Monitoring: To maintain vigilance, Riverside continuously monitors market activities, closely reviewing trading patterns to identify any irregularities or suspicious transactions. Advanced technology and data analytics play a significant role in this ongoing surveillance. 5. Enforcement: Riverside holds individuals accountable for any proven instances of insider trading through a strong enforcement program. Disciplinary actions, including fines, penalties, and potential legal consequences, act as a deterrent against fraudulent behavior. Conclusion: Riverside California's policies and procedures designed to detect and prevent insider trading have set high standards for transparency, fairness, and market integrity. By implementing these comprehensive guidelines, Riverside continues to foster an environment where investors can confidently participate in the financial markets, knowing that their interests are protected from the risk of insider trading.
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.
