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).
Nebraska Policies and Procedures Designed to Detect and Prevent Insider Trading: Insider trading refers to the illegal practice of trading securities based on non-public, material information that can significantly impact the stock's value. In order to maintain transparency, fairness, and protect investors, financial markets adhere to strict policies and procedures to detect and prevent such illegal activities. Nebraska also has robust regulations and guidelines in place to address insider trading. Here are some key policies and procedures designed to detect and prevent insider trading in Nebraska: 1. Nebraska Uniform Securities Act (Neb. Rev. Stat. § 8-1101 et seq.): This act serves as the foundation for regulating the securities' industry in Nebraska. It includes provisions that explicitly prohibit insider trading and establishes penalties for violations. 2. Code of Ethics: Many organizations and companies in Nebraska, especially those involved in the securities' industry, have established comprehensive codes of ethics. These codes outline the ethical standards that employees must adhere to, including prohibitions on insider trading. 3. Insider Trading Policies: Various companies and organizations have specific insider trading policies tailored to their industry and operations. These policies clearly define what constitutes insider trading, address reporting requirements, and outline the consequences for violations. 4. Employee Training and Education: Companies operating in Nebraska often provide regular training sessions and educational resources to their employees to raise awareness about insider trading regulations and best practices. These programs ensure employees understand their obligations and the potential consequences of insider trading. 5. Restricted Trading Windows: Some organizations establish restricted trading windows during which employees, particularly those with access to material non-public information, are prohibited from buying or selling company securities. This measure helps prevent any potential conflicts of interest and illicit trading activities. 6. Internal Control Systems: Organizations implement robust internal control systems that monitor and track employee access to confidential information. These systems help identify any suspicious activities and enable the detection of potential instances of insider trading. 7. Whistleblower Programs: Many companies encourage employees to report any suspected insider trading activities through confidential whistleblower programs. These programs provide protection to individuals who come forward with valuable information, promoting a culture of integrity and transparency. 8. Regulatory Oversight: The Nebraska Department of Banking and Finance, along with the Securities and Exchange Commission (SEC), actively monitors and enforces compliance with insider trading regulations. These regulatory bodies conduct investigations, audits, and inspections to identify and prosecute offenders. Nebraska, like other states, recognizes the importance of effectively detecting and preventing insider trading to safeguard the integrity of financial markets. By implementing comprehensive policies, conducting regular employee education, and maintaining regulatory oversight, Nebraska aims to maintain a fair and transparent investment environment, benefiting both investors and market participants.
