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).
Franklin Ohio has implemented comprehensive policies and procedures specifically designed to detect and prevent insider trading within its organization. These measures are crucial in maintaining a fair and transparent trading environment, while safeguarding the interests of both employees and stakeholders. Franklin Ohio's commitment to preventing insider trading is evident in the following policies and procedures: 1. Insider Trading Policy: The first line of defense against insider trading is a robust policy that clearly defines what constitutes insider trading and provides guidelines for employees to adhere to. Franklin Ohio's Insider Trading Policy outlines the restrictions, prohibitions, and consequences associated with trading on non-public information. This policy serves as the foundation for all other preventative measures. 2. Restricted Trading Windows: To further minimize the risk of insider trading, Franklin Ohio employs restricted trading windows. During these periods, employees are prohibited from trading company securities unless given explicit permission by the designated compliance officer. Restricted trading windows help ensure that employees do not capitalize on material non-public information. 3. Pre-Clearance Procedures: Employees who may have access to material non-public information are required to follow pre-clearance procedures before engaging in any company-related securities transactions. This procedure involves obtaining approval from the compliance officer or designated authority before executing any trades. Pre-clearance procedures are in place to prevent employees from unknowingly trading on potentially sensitive information. 4. Blackout Periods: In addition to restricted trading windows, Franklin Ohio utilizes blackout periods. These intervals typically occur before the release of significant company news or financial statements. During blackout periods, employees are entirely prohibited from buying or selling company securities. This temporary restriction ensures that employees do not inadvertently trade on material non-public information or influence the market improperly. 5. Insider Lists: Maintaining accurate insider lists is crucial in preventing any unauthorized trading. Franklin Ohio maintains up-to-date insider lists that include all employees, officers, directors, and other relevant personnel who have access to material non-public information. These lists help monitor and identify potential insider trading activities effectively. 6. Training and Education: Franklin Ohio emphasizes the importance of training and education regarding insider trading prevention. Regular training sessions are conducted to educate employees on the laws, regulations, and consequences associated with insider trading. These awareness programs ensure that employees are well-informed and can actively contribute to the prevention efforts. 7. Monitoring and Reporting: Franklin Ohio employs a robust monitoring and reporting system to detect any potential instances of insider trading. This includes regular surveillance of trading activities, monitoring communication platforms, and analyzing trading patterns. Additionally, an anonymous reporting hotline is available to employees for reporting any suspected insider trading activities, ensuring a confidential channel to flag potential violations. By implementing these comprehensive policies and procedures, Franklin Ohio aims to create a culture of compliance and ethical conduct, ensuring that all employees understand the importance of preventing insider trading. These measures not only protect the integrity of the financial markets but also safeguard the reputation and trust of Franklin Ohio as a responsible and law-abiding organization.Franklin Ohio has implemented comprehensive policies and procedures specifically designed to detect and prevent insider trading within its organization. These measures are crucial in maintaining a fair and transparent trading environment, while safeguarding the interests of both employees and stakeholders. Franklin Ohio's commitment to preventing insider trading is evident in the following policies and procedures: 1. Insider Trading Policy: The first line of defense against insider trading is a robust policy that clearly defines what constitutes insider trading and provides guidelines for employees to adhere to. Franklin Ohio's Insider Trading Policy outlines the restrictions, prohibitions, and consequences associated with trading on non-public information. This policy serves as the foundation for all other preventative measures. 2. Restricted Trading Windows: To further minimize the risk of insider trading, Franklin Ohio employs restricted trading windows. During these periods, employees are prohibited from trading company securities unless given explicit permission by the designated compliance officer. Restricted trading windows help ensure that employees do not capitalize on material non-public information. 3. Pre-Clearance Procedures: Employees who may have access to material non-public information are required to follow pre-clearance procedures before engaging in any company-related securities transactions. This procedure involves obtaining approval from the compliance officer or designated authority before executing any trades. Pre-clearance procedures are in place to prevent employees from unknowingly trading on potentially sensitive information. 4. Blackout Periods: In addition to restricted trading windows, Franklin Ohio utilizes blackout periods. These intervals typically occur before the release of significant company news or financial statements. During blackout periods, employees are entirely prohibited from buying or selling company securities. This temporary restriction ensures that employees do not inadvertently trade on material non-public information or influence the market improperly. 5. Insider Lists: Maintaining accurate insider lists is crucial in preventing any unauthorized trading. Franklin Ohio maintains up-to-date insider lists that include all employees, officers, directors, and other relevant personnel who have access to material non-public information. These lists help monitor and identify potential insider trading activities effectively. 6. Training and Education: Franklin Ohio emphasizes the importance of training and education regarding insider trading prevention. Regular training sessions are conducted to educate employees on the laws, regulations, and consequences associated with insider trading. These awareness programs ensure that employees are well-informed and can actively contribute to the prevention efforts. 7. Monitoring and Reporting: Franklin Ohio employs a robust monitoring and reporting system to detect any potential instances of insider trading. This includes regular surveillance of trading activities, monitoring communication platforms, and analyzing trading patterns. Additionally, an anonymous reporting hotline is available to employees for reporting any suspected insider trading activities, ensuring a confidential channel to flag potential violations. By implementing these comprehensive policies and procedures, Franklin Ohio aims to create a culture of compliance and ethical conduct, ensuring that all employees understand the importance of preventing insider trading. These measures not only protect the integrity of the financial markets but also safeguard the reputation and trust of Franklin Ohio as a responsible and law-abiding organization.
