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).
Travis Texas, a leading financial institution, has implemented robust policies and procedures designed to detect and prevent insider trading. These measures serve to maintain a fair and transparent marketplace, ensuring that both clients and the institution's reputation are protected. The following description discusses the various types of Travis Texas policies and procedures concerning insider trading detection and prevention. 1. Employee Training and Education: Travis Texas prioritizes educating its employees to recognize and understand the significance of insider trading. Regular training programs cover relevant laws, regulations, and ethical standards, enabling staff members to identify potential signs of illegal trading activities. 2. Prohibition Policies: Travis Texas strictly prohibits insider trading by implementing comprehensive policies that outline specific behaviors and activities considered as insider trading. Employees are required to adhere to these policies, ensuring they understand the consequences of engaging in such activities. 3. Pre-Trade Clearance Procedures: To prevent insider trading, Travis Texas maintains pre-trade clearance procedures. These protocols require employees to obtain permission before executing trades. This process involves submitting detailed information about the securities involved, trading intentions, and the individual's relationship or access to inside information. 4. Monitoring and Surveillance: Travis Texas employs advanced technological systems to monitor and surveil trading activities. These systems use algorithms and data analytics to detect suspicious patterns, including significant price movements, trading volume anomalies, and insider trading indicators. Any identified potential insider trading activity triggers an investigation for further scrutiny. 5. Restricted Lists: To deter insider trading, Travis Texas maintains restricted lists that identify securities and companies subject to insider trading restrictions. Employees are notified of these restrictions and are strictly prohibited from trading in such securities until public disclosure is made or a designated period has passed. 6. Reporting Obligations: Travis Texas mandates its employees to promptly report any suspected or potential instances of insider trading. Whistleblower policies ensure that individuals who report such activities are protected against retaliation and are encouraged to come forward to assist in the prevention and detection of insider trading. 7. Regular Audits and Reviews: To ensure the effectiveness of policies and procedures, Travis Texas conducts regular internal audits and reviews. These assessments evaluate the implementation, efficiency, and improvement of existing insider trading detection and prevention measures. By employing these comprehensive policies and procedures, Travis Texas actively promotes a culture of compliance and integrity, fostering an environment where insider trading is swiftly detected and prevented. The institution's commitment to maintaining ethical standards not only safeguards its clients and reputation but also contributes to the overall trust and stability of the financial markets.
Travis Texas, a leading financial institution, has implemented robust policies and procedures designed to detect and prevent insider trading. These measures serve to maintain a fair and transparent marketplace, ensuring that both clients and the institution's reputation are protected. The following description discusses the various types of Travis Texas policies and procedures concerning insider trading detection and prevention. 1. Employee Training and Education: Travis Texas prioritizes educating its employees to recognize and understand the significance of insider trading. Regular training programs cover relevant laws, regulations, and ethical standards, enabling staff members to identify potential signs of illegal trading activities. 2. Prohibition Policies: Travis Texas strictly prohibits insider trading by implementing comprehensive policies that outline specific behaviors and activities considered as insider trading. Employees are required to adhere to these policies, ensuring they understand the consequences of engaging in such activities. 3. Pre-Trade Clearance Procedures: To prevent insider trading, Travis Texas maintains pre-trade clearance procedures. These protocols require employees to obtain permission before executing trades. This process involves submitting detailed information about the securities involved, trading intentions, and the individual's relationship or access to inside information. 4. Monitoring and Surveillance: Travis Texas employs advanced technological systems to monitor and surveil trading activities. These systems use algorithms and data analytics to detect suspicious patterns, including significant price movements, trading volume anomalies, and insider trading indicators. Any identified potential insider trading activity triggers an investigation for further scrutiny. 5. Restricted Lists: To deter insider trading, Travis Texas maintains restricted lists that identify securities and companies subject to insider trading restrictions. Employees are notified of these restrictions and are strictly prohibited from trading in such securities until public disclosure is made or a designated period has passed. 6. Reporting Obligations: Travis Texas mandates its employees to promptly report any suspected or potential instances of insider trading. Whistleblower policies ensure that individuals who report such activities are protected against retaliation and are encouraged to come forward to assist in the prevention and detection of insider trading. 7. Regular Audits and Reviews: To ensure the effectiveness of policies and procedures, Travis Texas conducts regular internal audits and reviews. These assessments evaluate the implementation, efficiency, and improvement of existing insider trading detection and prevention measures. By employing these comprehensive policies and procedures, Travis Texas actively promotes a culture of compliance and integrity, fostering an environment where insider trading is swiftly detected and prevented. The institution's commitment to maintaining ethical standards not only safeguards its clients and reputation but also contributes to the overall trust and stability of the 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.
