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).
Alaska Policies and Procedures Designed to Detect and Prevent Insider Trading: Insider trading refers to the illegal practice of trading stocks or securities using confidential information that is not available to the public. Alaska, like many other jurisdictions, has implemented various policies and procedures to prevent insider trading and maintain the integrity of its financial markets. These measures are designed to detect any suspicious activities and ensure compliance with the laws and regulations set forth by regulatory bodies such as the Securities and Exchange Commission (SEC). Alaska has several types of policies and procedures in place to detect and prevent insider trading, including: 1. Code of Conduct: Alaska requires its employees, contractors, and other relevant parties to adhere to a strict code of conduct that explicitly prohibits insider trading. This code outlines the ethical and legal obligations regarding the use of non-public information for personal financial gain. 2. Insider Trading Awareness Training: Alaska provides comprehensive training programs to educate its employees on the risks and consequences of insider trading. These training sessions emphasize the importance of maintaining confidentiality and avoiding any actions that could be perceived as insider trading. 3. Restricted Trading Windows: Alaska establishes restricted trading windows during which employees are prohibited from buying or selling company stock. These windows typically coincide with the release of significant non-public information, such as financial reports or merger announcements, to prevent any potential misuse of confidential information. 4. Pre-Clearance Requirements: Alaska employees are required to obtain pre-clearance from the compliance department before executing any trades involving company securities. This process ensures that potential trades are properly vetted and reviewed to identify any potential conflicts of interest or misuse of non-public information. 5. Monitoring and Surveillance Systems: Alaska employs sophisticated monitoring and surveillance systems to detect any suspicious trading activities that may indicate insider trading. These systems utilize advanced algorithms and artificial intelligence to flag unusual trading patterns, large volume trades, or any other suspicious behavior that may warrant further investigation. 6. Reporting and Whistleblowing Mechanisms: Alaska encourages employees and stakeholders to report any suspected insider trading activities through designated reporting channels. Whistleblowing mechanisms provide a confidential and secure platform for individuals to come forward with any information that could help prevent or uncover instances of insider trading. 7. Compliance Oversight: Alaska assigns a dedicated compliance team to oversee and enforce insider trading prevention policies. This team works closely with legal departments, senior management, and external regulatory bodies to ensure compliance with relevant laws and regulations related to insider trading. By implementing these robust policies and procedures, Alaska aims to create a culture of transparency, integrity, and accountability, minimizing the risk of insider trading and maintaining the confidence of its investors and stakeholders.
