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).
Introduction: Wayne, Michigan, being a well-regarded center of commerce and business, recognizes the importance of implementing robust policies and procedures to detect and prevent insider trading. This comprehensive approach aims to safeguard the integrity of financial markets, ensuring fairness and equal opportunities for all participants. By employing various measures, Wayne, Michigan, strives to detect, deter, and swiftly tackle any instances of insider trading. Let us delve into the different types of policies and procedures enacted in Wayne, Michigan. 1. Employee Education and Training Programs: To foster awareness and promote compliance with insider trading regulations, Wayne, Michigan provides comprehensive education and training programs for all employees. These programs aim to familiarize employees with legal obligations, ethical considerations, and the potential consequences of insider trading. By ensuring employees are well-informed, Wayne, Michigan reduces the likelihood of inadvertent insider trading and cultivates a culture of integrity. 2. Clear Communication Channels: Wayne, Michigan emphasizes the importance of establishing clear communication channels regarding insider trading policies and procedures. By disseminating information through regular updates, newsletters, and bulletins, the city ensures that all employees stay informed about any revisions or additions to the policies. This transparent approach helps maintain a consistent understanding of the rules and expectations surrounding insider trading. 3. Restricted Trading Windows: Wayne, Michigan employs restricted trading windows, wherein employees are prohibited from trading company securities during designated periods surrounding material non-public information (MNP). These windows aim to prevent any potential misuse of privileged information and decrease the opportunities for insider trading. Employees must adhere strictly to the outlined trading windows and obtain proper authorization before executing any trades. 4. Enhanced Monitoring and Surveillance Systems: To bolster their efforts in detecting insider trading, Wayne, Michigan implements advanced monitoring and surveillance systems. These systems employ cutting-edge technology to track and analyze trading activities, identifying any suspicious patterns or anomalies. By closely monitoring trading activities and comparing them with known MNP events, Wayne, Michigan can promptly investigate and address potential insider trading instances. 5. Whistleblower Programs: Wayne, Michigan recognizes the significance of empowering employees to report suspected insider trading activities. The city implements anonymous whistleblower programs to encourage individuals to come forward with confidential information. These programs protect whistleblowers from retaliation and provide a secure avenue to report potential violations of insider trading policies. By incentivizing reporting, Wayne, Michigan maximizes the chances of uncovering and addressing insider trading in its early stages. Conclusion: Wayne, Michigan demonstrates a steadfast commitment to preserving the integrity of financial markets by implementing a comprehensive framework of policies and procedures aimed at detecting and preventing insider trading. Through employee education, communication channels, restricted trading windows, monitoring systems, and whistleblower programs, the city strives to maintain a level playing field and foster a culture of compliance and ethical conduct. These efforts solidify Wayne, Michigan's position as a trusted hub of business and emphasize its dedication to upholding fairness and transparency in financial transactions.Introduction: Wayne, Michigan, being a well-regarded center of commerce and business, recognizes the importance of implementing robust policies and procedures to detect and prevent insider trading. This comprehensive approach aims to safeguard the integrity of financial markets, ensuring fairness and equal opportunities for all participants. By employing various measures, Wayne, Michigan, strives to detect, deter, and swiftly tackle any instances of insider trading. Let us delve into the different types of policies and procedures enacted in Wayne, Michigan. 1. Employee Education and Training Programs: To foster awareness and promote compliance with insider trading regulations, Wayne, Michigan provides comprehensive education and training programs for all employees. These programs aim to familiarize employees with legal obligations, ethical considerations, and the potential consequences of insider trading. By ensuring employees are well-informed, Wayne, Michigan reduces the likelihood of inadvertent insider trading and cultivates a culture of integrity. 2. Clear Communication Channels: Wayne, Michigan emphasizes the importance of establishing clear communication channels regarding insider trading policies and procedures. By disseminating information through regular updates, newsletters, and bulletins, the city ensures that all employees stay informed about any revisions or additions to the policies. This transparent approach helps maintain a consistent understanding of the rules and expectations surrounding insider trading. 3. Restricted Trading Windows: Wayne, Michigan employs restricted trading windows, wherein employees are prohibited from trading company securities during designated periods surrounding material non-public information (MNP). These windows aim to prevent any potential misuse of privileged information and decrease the opportunities for insider trading. Employees must adhere strictly to the outlined trading windows and obtain proper authorization before executing any trades. 4. Enhanced Monitoring and Surveillance Systems: To bolster their efforts in detecting insider trading, Wayne, Michigan implements advanced monitoring and surveillance systems. These systems employ cutting-edge technology to track and analyze trading activities, identifying any suspicious patterns or anomalies. By closely monitoring trading activities and comparing them with known MNP events, Wayne, Michigan can promptly investigate and address potential insider trading instances. 5. Whistleblower Programs: Wayne, Michigan recognizes the significance of empowering employees to report suspected insider trading activities. The city implements anonymous whistleblower programs to encourage individuals to come forward with confidential information. These programs protect whistleblowers from retaliation and provide a secure avenue to report potential violations of insider trading policies. By incentivizing reporting, Wayne, Michigan maximizes the chances of uncovering and addressing insider trading in its early stages. Conclusion: Wayne, Michigan demonstrates a steadfast commitment to preserving the integrity of financial markets by implementing a comprehensive framework of policies and procedures aimed at detecting and preventing insider trading. Through employee education, communication channels, restricted trading windows, monitoring systems, and whistleblower programs, the city strives to maintain a level playing field and foster a culture of compliance and ethical conduct. These efforts solidify Wayne, Michigan's position as a trusted hub of business and emphasize its dedication to upholding fairness and transparency in financial transactions.
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.
