Company Personnel all employees and directors of the Company.
|
|
- Veronica Sarah Rose
- 5 years ago
- Views:
Transcription
1 PURPOSE The purpose of this insider trading policy statement ( ) is two-fold: (i) to establish guidelines so that all Insiders (as defined below) of the Company comply with all applicable laws prohibiting trading in the Company s securities by persons having knowledge of Inside Information (as defined below) and (ii) to ensure that the Company itself fulfills its responsibility to comply with those laws. DEFINITIONS Company Walter Energy, Inc. and its subsidiaries. Company Personnel all employees and directors of the Company. Controlled Entities any trust, corporation or other entity controlled by Company Personnel or a Family Member of Company Personnel. Family Members any person (i) whose securities transactions are directed by such Company Personnel or (ii) who permanently resides in Company Personnel s household (whether or not related to such Company Personnel). Insiders Company Personnel and their Family Members and Controlled Entities. Inside Information While the definition of what constitutes Inside Information is necessarily dependent on the facts of each case, in general, Inside Information means information that has not been disclosed to the public and is material. Material Information is generally considered material if a reasonable investor would consider it important in deciding whether to buy, sell, or hold a security or if the information would significantly affect the market price of a security. The information may concern the Company, another company or the Company s industry and may be positive or negative. Material information does not need to relate to the Company s business, and information about the contents of a forthcoming publication in the press that is expected to affect the market price of the Company s securities could also be material. Examples of material information may include, but are not limited to: 1 monthly, quarterly or annual financial results of the Company; estimates and guidance on earnings and changes in previously released earnings results, estimates or guidance; 1 Additional examples of what may constitute material information may be found at U.S. Securities and Exchange Commission Release Nos ; ; available at and Canadian Securities Administrators National Disclosure Standards Section 4.3: Examples of Potentially Material Information; available at Page 1
2 significant changes in the level of revenues, income or expenses; Company strategy or developments affecting the Company s technology, products or markets; negotiation, execution, or termination of significant contracts; significant changes in exposure to loss, production or reserves; significant changes in investment results; stock splits, dividend, redemption or repurchase information; major financings; significant personnel changes; significant acquisitions or dispositions of assets; significant litigation; merger negotiations, restructurings or a change in control of the Company; material changes in accounting policies; or significant developments involving proceedings with state or federal regulatory authorities. Information that something is likely to happen or even just that it may happen can be material. Company Personnel should err on the side of caution. Company Personnel should also keep in mind that certain applicable securities rules and regulations provide that the mere fact that a person is aware of the Inside Information is a bar to trading, even if such person s reasons for trading were not based on the information. Non-Public Information Non-public information is information that has not been publicly disclosed. Information is publicly disclosed if it has been widely disseminated, such as filed with the U.S. Securities and Exchange Commission or the Canadian securities regulatory authorities, published in a press release or in the newspapers and/or carried by a national television news service, and the public has had sufficient time to process and absorb it. As a general rule, it would be appropriate to refrain from trading for at least two full trading days after the initial release of material information to the public. Permanent Restricted Persons all members of Walter s Board of Directors, all of its executive officers and each such person s Family Members and Controlled Entities. Page 2
3 Securities Exchange Act U.S. Securities Exchange Act of 1934, as amended. Security or Securities The term security or securities includes stock (common and preferred), stock options, warrants, bonds, notes, debentures, convertible instruments, put or call options (i.e., exchange-traded options) or other similar instruments. Significant Subsidiaries as defined under the Securities Exchange Act generally means a subsidiary in which (i) the Company s investments in and advances to the subsidiary exceed 10% percent of the Company s total consolidated assets, (ii) the Company s share of the subsidiary s assets exceeds 10% percent of the Company s total consolidated assets; or (iii) the Company s equity in the income from continuing operations before income taxes, extraordinary items and cumulative effect of a change in accounting principle of the subsidiary exceeds 10% percent of the Company s consolidated income. Trade or trading means any purchase, sale or other acquisition, transfer or disposition of securities, including market option exercises, gifts or other contributions, exercises of stock options granted under the Company s stock plans, sales of stock acquired upon the exercise of options and trades made under an employee benefit plan, such as a 401(k) plan. Walter Walter Energy, Inc. SCOPE This applies to all Insiders of the Company. The Company may also determine on a case by case basis to subject to this other persons who have access to Inside Information. Company Personnel who, or whose Family Members and Controlled Entities, trade in the Company s securities while in the possession of Inside Information or Company Personnel who, or whose Family Members and Controlled Entities, provide Inside Information to others will be subject to appropriate disciplinary action, which may include dismissal. No exceptions will be made to this, even where the transaction may have been very small or the trading party may have planned to make the transaction before learning of the Inside Information. All Company Personnel are responsible for making sure that he or she and his or her Family Members and Controlled Entities comply with this. In all cases, the responsibility for determining whether an individual or entity is in possession of Inside Information rests with that individual and the individuals who control such entity. Neither this nor any action by the Company, the or any other employee or director of the Company taken pursuant to this or otherwise shall in any way constitute legal advice, result in the Company or any employee or director of the Company being responsible for any such individual s acts and omissions, or otherwise insulate any such individual from liability under applicable securities Page 3
4 laws. You could be subject to severe legal penalties and disciplinary action by the Company for any conduct prohibited by this or applicable securities laws. Punishment for insider trading violations can be severe, and those who buy or sell the Company s securities while in the possession of Inside Information or fail to prevent insider trading by those under their control can be held personally liable for damages totaling up to three times the profits made. Insider trading may also expose the liable party to criminal penalties, including imprisonment. POLICY STATEMENT 1. U.S. federal and state securities laws, and similar laws in other jurisdictions where the Company conducts business ( applicable securities laws ), prohibit certain persons, deemed to be insiders, from trading in a company s securities when those persons are in possession of Inside Information. For purposes of those laws, insiders generally are persons who possess, or are deemed to possess, or have access, or are deemed to have access, to Inside Information. 2. No Insider may buy or sell the Company s securities at any time when the Insider has Inside Information concerning the Company. No Insider may buy or sell securities of another company at any time when the Insider has Inside Information about that company when that information was obtained as a result of the Insider s employment or relationship to the Company. 3. All Insiders are prohibited from trading in financial instruments or engaging in hedging transactions that are designed to hedge or offset the risks of price fluctuations in the value of Walter Energy common stock (including but not limited to collars or forward sale contracts, puts, calls or other exchange traded options, or short sales). 4. No Insider may disclose ( tip ) Inside Information to any other person (including relatives, friends and business associates) for any reason, or assist a third party s trading activities or make buy or sell recommendations to a third party based upon Inside Information. Insiders who reveal Inside Information to a third party may be liable as tippers and may face civil or criminal penalties. In addition, Insiders should take care before trading on the recommendation of others to ensure that the recommendation is not the result of an illegal tip. 5. Because of access to Inside Information on a regular basis, all (i) (ii) (iii) (iv) directors and officers of Walter; Walter senior accounting, finance, legal and investor relations personnel; Presidents and controllers at any of Walter s Significant Subsidiaries; persons referred to in Section 6; and Page 4
5 (v) Family Members and Controlled Entities of any of the persons identified in clauses (i) through (iv) (such persons and entities identified in clauses (i) though (v), ( Designated Personnel ) are hereby prohibited from effecting transactions in the Company s securities (excluding exercising an option, but including selling the option or the underlying stock) during Blackout Periods. Unless otherwise specified by the Company in a written notice to Company Personnel, Blackout Periods shall be the period commencing on and including the tenth calendar day of the last month of each fiscal quarter and expiring on and including the second trading day after the day on which the Company announces its quarterly or annual earnings. Even if a Blackout Period is not in effect (a Window Period ), the Company may impose additional or different Blackout Periods as it deems necessary. If any Designated Personnel comes into possession of Inside Information, such Designated Personnel may not effect a transaction in the Company s securities until at least two trading days after the public disclosure of such Inside Information, even if during a Window Period. 6. In order to facilitate compliance with certain securities regulations, Permanent Restricted Persons must always obtain the advance approval of the (in accordance with Section 7) before effecting transactions in the Company s securities (including any exercise of an option or warrant (whether cashless or otherwise) to acquire Company securities, or contributions to trusts, gifts, loans or pledges of Company securities), whether the transaction is for the individual s own account, one over which he or she exercises control or one in which he or she has a beneficial interest. 7. From time to time, the Company may notify persons other than Permanent Restricted Persons that they will be subject (indefinitely or for any limited period of time specified by the Company) to the pre-clearance requirements set forth in Section 7 ( Other Restricted Persons ). 8. Permanent Restricted Persons and Other Restricted Persons should request pre-clearance from the in advance of the proposed transaction (at least two business days in advance in the case of using shares as collateral for a permitted loan). The information set forth on Exhibit B must be conveyed to the as set forth therein. Approval for transactions and pledges of the Company s securities will generally be granted only during a Window Period (described in Section 4 above), and the transaction may only be performed during such period in which the approval was granted and in any event within three business days from the date of approval. Permanent Restricted Persons must comply with these pre-clearance requirements for six months after the termination of their status as a Permanent Restricted Person. 9. Other Company employees, other than Designated Personnel, may, from time to time, come into possession of Inside Information. Such temporary insiders may not effect a transaction in the Company s securities from the time they obtain the Inside Information until two trading days after the public disclosure of such Inside Information. Page 5
6 10. Knowledge of Inside Information should be limited to Company Personnel who need to know such information in order to perform their jobs, and any Company Personnel who has received Inside Information must not disclose such information to anyone outside of the Company. When Inside Information is provided to a Company Personnel, he or she should be informed by the person providing such information that it is Inside Information and that he or she is restricted from trading in the Company s securities until two trading days after the public disclosure of such information. Company Personnel should refrain from discussing Inside Information in the presence of other Company Personnel who do not need to know such Inside Information and in any public area, such as elevators, hallways, airplanes and airports. If the Company becomes aware that Inside Information has been leaked widely within the Company, the Company may prohibit all trading by employees in the Company s securities for so long as it deems necessary. 11. In order to avoid selective disclosure of Inside Information to unauthorized third parties, Company Personnel should refer any requests for financial information or financial projections or forecasts to the Company s Chief Financial Officer. This includes requests by analysts or others to corroborate their financial projections for the Company. Other inquiries from the investing community or the press should be referred to Authorized Spokespersons of the Company as designated in the Company s Public Disclosure and Media Inquiries policy. 12. Any Insider who has concerns about whether he or she is in possession of information which falls within the definition of Inside Information should contact the Company s before trading in the Company s securities. This is aimed to ensure that Insiders unaware of a particular piece of information do not give the appearance of improperly trading in the Company s securities and to minimize the risk of civil and criminal liability under applicable securities laws. OTHER SECURITIES MATTERS Officers and directors will be liable for short-swing profits from purchases and sales of such securities under Section 16(b) of the Securities Exchange Act, excluding exercising an option, but including selling the option or the underlying stock. Section 16(b) of the Exchange Act provides that any such person who makes both a purchase and sale or a sale and purchase of a company s securities within a period of six months must pay to the company the excess of the sale price over the purchase price. If Company Personnel hold restricted securities, i.e., securities that cannot be resold by that Company Personnel unless registered under the Securities Act of 1933, sold pursuant to Rule 144, or disposed of pursuant to another exemption from the registration requirements of the Securities Act, he or she should consult with the prior to effecting purchases or sales of the Company s securities. CERTIFICATION All Company Personnel subject to this must certify their understanding of, and intent to comply with, this by completing the Certification form appended hereto as Exhibit A. Page 6
7 QUESTIONS AND CONTACT Questions about the scope or application of this should be directed to the Company s at generalcounsel@walterenergy.com. VIOLATIONS OF THE POLICY If you are aware of any violations or possible violations of this or applicable securities trading laws, rules or regulations, please report it through the special ethics hotline as follows: Toll free: (877) (UK residents will be subject to usual charge rates) Fax: (770) hotline@walterenergy.com Web: Page 7
8 Exhibit A CERTIFICATION I certify that: 1. I have read and understand the Company s (the ). I understand that the is available to answer any questions I have about the. 2. I have complied with this since the latest of (a) the date of my last certification and (b) the first date on which I became an employee or director of the Company. 3. I will continue to comply with the for as long as I am subject to the. Date Employee Signature Printed Name Employing Company
9 Exhibit B INFORMATION REGARDING WALTER ENERGY, INC. SECURITIES TO BE TRADED (Information previously provided and unchanged need not be completed; new information can be provided to the orally or via ; will complete the form.) Type of Security to be Traded [check all applicable boxes] Common stock Preferred stock Restricted stock Stock Option Other type of security (please describe) Number of securities to be sold Proposed Date of Transaction Type of Transaction Stock option exercise Exercise Price $ /share Exercise Price paid as follows: Broker s cashless exchange cash pledge other Withholding tax paid as follows: Broker s cashless exchange cash other Purchase Sale Gift Broker Contact Information Company Name Contact Name Telephone Fax Account Number Social Security or other Tax Identification Number Status (check all applicable boxes) Executive Officer Board Member Other (position, title and/or association with the Company)
10 Filing Information (check all applicable boxes and complete blanks) Date of filing of last Form 3 or 4 Is a Form 144 Necessary? Date of filing of last Form 144 By completing this form or providing the information to the orally or via , I hereby confirm that I am not currently in possession of any Inside Information (as defined in the Walter Energy, Inc. ) and that the information I have provided is true and correct. Page 10
Insider Trading Policy
FINAL ANIKA THERAPEUTICS, INC. Insider Trading Policy The Board of Directors (the Board ) of Anika Therapeutics, Inc. (including its subsidiaries, Anika ) has approved this Insider Trading Policy (this
More informationInsider Trading Policy
Insider Trading Policy Dated August 18, 2014 BACKGROUND The board of directors of Mateon Therapeutics, Inc. (the Company or Mateon ) has adopted this Insider Trading Policy (the Policy ) for our directors,
More informationLPL FINANCIAL HOLDINGS INC. INSIDER TRADING POLICY
LPL FINANCIAL HOLDINGS INC. INSIDER TRADING POLICY This policy applies to all employees, officers, directors and consultants of LPL Financial Holdings Inc. and its affiliates (the Company ). This policy
More informationNORTHERN OIL AND GAS, INC. INSIDER TRADING POLICY. and Guidelines with Respect to Certain Transactions in Company Securities. (Adopted March 12, 2012)
NORTHERN OIL AND GAS, INC. INSIDER TRADING POLICY and Guidelines with Respect to Certain Transactions in Company Securities (Adopted March 12, 2012) Background Northern Oil and Gas, Inc. (the Company )
More informationHURON CONSULTING GROUP INC. INSIDER TRADING POLICY. (As amended October 20, 2016)
HURON CONSULTING GROUP INC. INSIDER TRADING POLICY (As amended October 20, 2016) The federal securities laws generally prohibit persons who receive or become aware of material nonpublic information about
More informationOpus Bank. Insider Trading And Disclosure Policy. Board Approval Date: December 15, 2016
Opus Bank Insider Trading And Disclosure Policy Board Approval Date: December 15, 2016 BOD Approved: December 15, 2016 Table of Contents Purpose... 1 Application of Policy... 1 General Statement... 1 Insider
More informationINSIDER TRADING POLICY
INSIDER TRADING POLICY BACKGROUND: This Policy applies to directors, officers and employees at all levels of Alcoa Corporation ( Alcoa ) and of each domestic and foreign subsidiary, partnership, venture
More informationInsider Trading Policy
Statement of Policy It is the policy of JDSU that all members of the Company s Board of Directors, employees and consultants comply with federal and state securities laws governing insider trading and
More informationFIESTA RESTAURANT GROUP, INC. Dallas, Texas. Subject: MANAGEMENT INSIDER TRADING POLICY Effective Date: May 7, 2012 Revised: June 12, 2017
FIESTA RESTAURANT GROUP, INC. Dallas, Texas Subject: MANAGEMENT INSIDER TRADING POLICY Effective Date: May 7, 2012 Revised: June 12, 2017 Affects: Covered Individuals 1. Covered Individuals. In addition
More informationFurthermore, no director, officer or employee who is in possession of material nonpublic information about the Company may disclose or pass along such
ACCO BRANDS CORPORATION INSIDER TRADING COMPLIANCE POLICY I. Purpose U.S. federal and state securities laws regulate the sale and purchase of securities in the interest of protecting the investing public
More informationPOLICY STATEMENT ON TRADING IN SECURITIES OF DOMTAR CORPORATION. [Amended and Restated as of August 2, 2016]
POLICY STATEMENT ON TRADING IN SECURITIES OF DOMTAR CORPORATION [Amended and Restated as of August 2, 2016] This memorandum sets forth the policy of Domtar Corporation and its subsidiaries (the Company
More informationGI DYNAMICS, INC. RESTRICTIONS ON BUYING AND SELLING STOCK AND SECURITIES (INSIDER TRADING POLICY)
GI DYNAMICS, INC. RESTRICTIONS ON BUYING AND SELLING STOCK AND SECURITIES (INSIDER TRADING POLICY) 1. Policy Statement. Employees, consultants, officers, the Board of Directors and entities (such as trusts,
More informationHURON CONSULTING GROUP INC. INSIDER TRADING COMPLIANCE PROGRAM (As Amended August 10, 2006)
HURON CONSULTING GROUP INC. INSIDER TRADING COMPLIANCE PROGRAM (As Amended August 10, 2006) In order to take an active role in the prevention of insider trading violations by its officers, directors, employees
More information(Updated and Effective as of April 24, 2012)
NUVASIVE, INC. INSIDER TRADING POLICY Procedures and Policies Governing Securities Trading and Communications by Employees, Officers, Consultants and Directors I. Statement of Purpose (Updated and Effective
More informationCIT Group Inc. General Counsel FOR INTERNAL USE ONLY. CIT Group Inc. Securities Trading Policy
FOR INTERNAL USE ONLY CIT Group Inc. Securities Trading Policy Contents 1 Securities Trading Policy... 2 1.1 Purpose... 2 1.2 Scope... 2 2 Roles and Responsibilities... 3 2.1 Board of Directors... 3 2.2
More informationTRANSATLANTIC PETROLEUM LTD. INSIDER TRADING POLICY
TRANSATLANTIC PETROLEUM LTD. INSIDER TRADING POLICY Introduction TransAtlantic Petroleum Ltd. (the Company ) has formulated this Insider Trading Policy (this Policy ) to assist the Company and its employees,
More informationTHE HERSHEY COMPANY INSIDER TRADING POLICY
THE HERSHEY COMPANY INSIDER TRADING POLICY I. PURPOSE The Hershey Company (the Company ) has adopted this Insider Trading Policy (this Policy ) to help its directors, officers and employees comply with
More informationINSIDER TRADING AND TIPPING PROCEDURES AND GUIDELINES
INSIDER TRADING AND TIPPING PROCEDURES AND GUIDELINES ERA GROUP INC. EFFECTIVE: NOVEMBER 16, 2017 Table of Contents I. Scope... 2 II. Purpose... 2 III. Definitions... 2 IV. Duties of the Compliance Officer...
More informationAVANGRID, INC. INSIDER TRADING POLICY
AVANGRID, INC. INSIDER TRADING POLICY The Board of Directors of Avangrid, Inc. ( Avangrid ) oversees the management of Avangrid and its business with a view to enhance the long-term value of Avangrid for
More informationInsider Trading Policy
Insider Trading Policy (As amended April 30, 2018) This Policy concerns the handling of material, non-public information relating to Consolidated Communications Holdings, Inc. and its subsidiaries ( Consolidated
More informationPERSHING RESOURCES COMPANY INC. Adopted as of April 9, All Employees, Officers and Directors, and Contractors
PERSHING RESOURCES COMPANY INC. Adopted as of April 9, 2018 TO: RE: All Employees, Officers and Directors, and Contractors Pershing Resources Company Insider Trading Policy Statement This Policy Statement
More informationAdvanced Emissions Solutions, Inc.
Insider Trading Policy No director, officer or employee of Advanced Emissions Solutions, Inc. ( Company or ADES ) or its subsidiaries may purchase or sell any Company securities while in possession of
More informationBYLINE BANCORP, INC. INSIDER TRADING POLICY
BYLINE BANCORP, INC. INSIDER TRADING POLICY Purpose The Board of Directors (the Board ) of Byline Bancorp, Inc. (together with Byline Bank and its other subsidiaries, the Company ) has adopted this Insider
More informationStatement of Policy and Procedures Governing Trading in Shares of Prudential Bancorp, Inc.
Statement of Policy and Procedures Governing Trading in Shares of Prudential Bancorp, Inc. QUESTIONS AND ANSWERS ABOUT INSIDER TRADING THE COVERAGE OF THE PROHIBITION Q: Does the insider trading prohibition
More informationNEOGEN CORPORATION INSIDER TRADING
NEOGEN CORPORATION INSIDER TRADING Introduction Dated 12/31/09 Effective 12/31/09 Replaces all previously issued documents As a public company, NEOGEN CORPORATION (the Company ) is subject to federal and
More informationNETFLIX, INC. INSIDER TRADING POLICY
NETFLIX, INC. INSIDER TRADING POLICY In order to take an active role in the prevention of insider trading violations by officers, directors, employees and other related individuals of Netflix, Inc. (the
More informationNEOGEN CORPORATION INSIDER TRADING
NEOGEN CORPORATION INSIDER TRADING Introduction Dated 4/12/18 Effective [4/12/18] Replaces all previously issued documents As a public company, NEOGEN CORPORATION (the Company ) is subject to federal and
More informationInsider Trading Policy
Insider Trading Policy GLOBAL RESOURCE CORPORATION (and Guidelines with Respect to Certain Transactions in Global's Securities) I. GENERAL U.S. securities laws and the SEC's rules and regulations prohibit
More informationINSIDER TRADING POLICY OF IBERDROLA RENEWABLES, LLC
INSIDER TRADING POLICY OF IBERDROLA RENEWABLES, LLC IBERDROLA RENEWABLES, LLC (the Company ) is integrated into the group of companies controlled by Iberdrola, S.A. and, as a result, is a subsidiary of
More informationRIMINI STREET, INC. INSIDER TRADING POLICY and Guidelines with Respect to Certain Transactions in Securities
RIMINI STREET, INC. INSIDER TRADING POLICY and Guidelines with Respect to Certain Transactions in Securities Amended and Approved as of September 13, 2017 TABLE OF CONTENTS Page INTRODUCTION...1 Legal
More informationinsider Trading Policy
insider Trading Policy Dealings in QiaGen stock based on non-public material information about the Company are strictly prohibited under US and German Securities laws. These laws are complex and penalties
More information2.0 Scope: This policy applies to all Board members, officers and employees of the Company and its subsidiaries in all global locations.
Policy Title: Prohibition on Insider Trading Policy 1.0 Purpose: This insider trading policy (the policy) has been adopted by Meritor, Inc. (the Company ) to establish procedures intended to prevent both
More informationSECURITIES TRADING POLICY
SECURITIES TRADING POLICY Adopted by the Board of Directors of First Mining Gold Corp. (the Company ) with immediate effect on November 17, 2017 POLICY STATEMENT Directors, officers, employees and consultants
More informationJohn G. Chou, Executive Vice President and General Counsel Hyung J. Bak, Vice President, Group General Counsel and Secretary
TO: FROM: RE: All Directors, Officers, Associates and Consultants John G. Chou, Executive Vice President and General Counsel Hyung J. Bak, Vice President, Group General Counsel and Secretary Policy Statement
More informationINSIDER TRADING COMPLIANCE MANUAL. Dipexium Pharmaceuticals, Inc.
INSIDER TRADING COMPLIANCE MANUAL Dipexium Pharmaceuticals, Inc. Adopted March 18, 2014 In order to take an active role in the prevention of insider trading violations by its officers, directors, employees,
More informationCODE OF ETHICS. for. Hennessy Funds Trust and Hennessy Advisors, Inc. Code of Ethics. June 2017
CODE OF ETHICS for Hennessy Funds Trust and Hennessy Advisors, Inc. TABLE OF CONTENTS I. GENERAL... 1 Page A. Introduction... 1 B. Definitions... 1 II. STANDARDS OF BUSINESS CONDUCT... 3 A. General Standards...
More informationINSIDER TRADING POLICY
Valeant POLICY NO. EFFECTIVE DATE PAGE NO 1 of 6 Pharmaceuticals H.R. Sec. 9-911 August 17, 2016 International, Inc. ISSUED BY: PREPARED BY: Legal Department General Counsel SUBJECT: APPROVED BY: Insider
More informationENERGY FUELS INC. (the Company ) INSIDER TRADING POLICY
As approved by the Board of Directors on November 5, 2015. PURPOSE ENERGY FUELS INC. (the Company ) INSIDER TRADING POLICY The Company is a publicly traded company listed on the Toronto Stock Exchange
More informationStatement of Policy Regarding Insider Trading
Statement of Policy Regarding Insider Trading This Statement of Policy Regarding Insider Trading ( Policy Statement ) sets forth FormFactor, Inc. (the Company or FormFactor ) s internal rules and procedures
More informationJABIL CIRCUIT, INC. INSIDER TRADING POLICY
EXHIBIT A JABIL CIRCUIT, INC. INSIDER TRADING POLICY and Guidelines with Respect to Certain Transactions in Company Securities and other matters (Amended and Restated October 15, 2012) In order to take
More informationALLETE, INC. PURCHASE AND SALE OF COMPANY SECURITIES POLICY
Approved by the ALLETE Board of Directors on October 24, 2017 ALLETE, INC. PURCHASE AND SALE OF COMPANY SECURITIES POLICY POLICY STATEMENT This policy has been established to assure that directors, officers,
More informationDirectors: Members of Brunswick s Board of Directors and anyone living in their households, including family members.
Policy Statement Subject: Insider Trading and Policy Number: L.01.01 Unauthorized Disclosures Department Name: Law Department Page: 1 of 7 Original Issue Date: July 30, 2002 Revision Date: October 2016
More informationSYNERGY PHARMACEUTICALS INC.
SYNERGY PHARMACEUTICALS INC. INSIDER TRADING COMPLIANCE PROGRAM In order to take an active role in the prevention of insider trading violations by its officers, directors, employees and other related individuals,
More informationRichard Buchband General Counsel & Chief Compliance Officer, ManpowerGroup
Richard Buchband General Counsel & Chief Compliance Officer, ManpowerGroup We at ManpowerGroup have a legal and ethical obligation to play by the rules it s part of who we are, and one of the reasons we
More informationINSIDER TRADING POLICY FEBRUARY 10, 2004 (LAST AMENDED FEBRUARY 9, 2016)
INSIDER TRADING POLICY FEBRUARY 10, 2004 (LAST AMENDED FEBRUARY 9, 2016) TELUS Insider Trading Policy INTRODUCTION TELUS Corporation as a public company has internal guidelines to control transactions
More informationINSIDER TRADING AND BLACKOUT POLICY
HUMAN RESOURCES POLICY Policy Number RH-GEN.10 Date issued 2005-09-08 Date updated Approved at October 27, 2016 meeting of the Board of Directors Issued by Human Resources Department Approved by Management
More informationPolicy on Trading in Securities by Directors, Officers, Employees and Consultants
Policy on Trading in Securities by Directors, Officers, Employees and Consultants Purpose The purpose of this Policy is to ensure (a) compliance with provincial securities laws governing trading in securities
More informationSecurities Trading Policy
Page 1 of 9 A. Overview Persons Subject to this Policy. This (this Policy applies to all (i) domestic and international employees of Best Buy Co., Inc. Best Buy or the Company and its subsidiaries, (ii)
More informationINSIDER TRADING POLICY
INSIDER TRADING POLICY 2 Insider Trading Summary Guidelines DO NOT TRADE IN SECURITIES OF CANADIAN ZINC CORPORATION OR OF ANOTHER PUBLIC COMPANY WHEN YOU: know Material Information about Canadian Zinc
More informationInsider Trading Policy Preclearance
Insider Trading Policy Preclearance CONTANGO OIL & GAS COMPANY SUPPLEMENTAL POLICY CONCERNING TRADING IN COMPANY SECURITIES BY CERTAIN DESIGNATED PERSONS This policy supplements our Policy Prohibiting
More informationRE: Amended and Restated Insider Trading Policy Statement and Blackout Restrictions
TO: FROM: Directors, Officers and All Employees Matthew Shurte, General Counsel and Secretary DATE: August 19, 2015 RE: Amended and Restated Insider Trading Policy Statement and Blackout Restrictions Basis
More informationPolicy on Inside Information and Insider Trading
Policy on Inside Information and Insider Trading Issued By: The Legal Department Policy Number: Region: Global Supersedes: Previous version issued 2/18/2015 Segment: All Issue Date: January 1, 2016 Policy
More informationCiner Resource Partners LLC
Ciner Resource Partners LLC INSIDER TRADING POLICY REVISED: February 10, 2017 TABLE OF CONTENTS Page I. SUMMARY OF CINER RESOURCE PARTNERS LLC POLICY CONCERNING INSIDER TRADING... 1 II. TRADING GUIDELINES...
More informationCORPORATE POLICY AND PROCEDURE ON INSIDER TRADING
CORPORATE POLICY AND PROCEDURE ON INSIDER TRADING Amended by the Board of Directors, July 14, 2010 1. Introduction United States federal securities laws seek to ensure that all investors in the publicly
More informationUNIQURE N.V. Insider Trading Policy. (Effective as of February 10, 2014; Amended as of January 26, 2016 and February 6, 2017)
UNIQURE N.V. Insider Trading Policy (Effective as of February 10, 2014; Amended as of January 26, 2016 and February 6, 2017) 1. BACKGROUND AND PURPOSE The U.S. federal securities laws prohibit any member
More informationINSIDER TRADING POLICY
INSIDER TRADING POLICY GLOBAL BLOCKCHAIN TECHNOLOGIES CORP. (THE "COMPANY") INSIDER TRADING POLICY 1. PURPOSE AND APPLICATION A. This Policy contains the Company's policy concerning the handling of material,
More informationGVK POWER & INFRASTRUCTURE LIMITED
GVK POWER & INFRASTRUCTURE LIMITED STATEMENT OF POLICIES AND PROCEDURES FOR GOVERNING MATERIAL, NON-PUBLIC INFORMATION AND THE PREVENTION OF INSIDER TRADING This Statement consists of four sections: Section
More informationSECURITIES TRADING MEMORANDUM
SECURITIES TRADING MEMORANDUM In order to take an active role in the prevention of insider trading violations by its officers, directors, employees and other related individuals, Booking Holdings Inc.
More informationVIRTU FINANCIAL, INC. SECURITIES TRADING POLICY (adopted by the Board of Directors April 3, 2015)
VIRTU FINANCIAL, INC. SECURITIES TRADING POLICY (adopted by the Board of Directors April 3, 2015) To Directors, Officers and Employees of Virtu Financial, Inc. and its subsidiaries (collectively, the Company
More informationCOMPANY POLICY CODE OF BUSINESS CONDUCT AND ETHICS
COMPANY POLICY Number: 1-96-206 Effective Date: 6/28/89 Revision: 05/13/13 Reviewed: 02/27/18 Approved: Board of Directors of Appvion, Inc. CODE OF BUSINESS CONDUCT AND ETHICS I. PURPOSE. The purpose of
More informationTrades of Woodward Stock
1 of 6 Purpose This policy and the attached Rule 10b5-1 Trading Plan Requirements Addendum are designed to prevent insider trading or the appearance of improper insider trading by our directors, officers,
More informationInsider Trading Policy
Page 1 of 9 CARIBBEAN UTILITIES COMPANY, LTD. INSIDER TRADING POLICY Effective Date: (amended September 14, 2010) 1. Introduction Caribbean Utilities Company, Ltd. (the Company ) encourages all employees,
More informationShare trading policy. Clean TeQ Holdings Limited ACN (Company)
Share trading policy Clean TeQ Holdings Limited ACN 127 457 916 (Company) Share trading policy 1. Introduction 1.1 The securities of the Company are listed on ASX. 1.2 This policy outlines: when directors,
More informationBOARD MEMBER AND EXECUTIVE OFFICER POLICIES AND PRACTICES RELATING TO AXCELIS SECURITIES
BOARD MEMBER AND EXECUTIVE OFFICER POLICIES AND PRACTICES RELATING TO AXCELIS SECURITIES OVERVIEW These Policies and Practices are designed to ensure compliance with applicable United States securities
More informationSECURITIES TRADING POLICY
We re with you for life RC 2176 SECURITIES TRADING POLICY 1 Table of Contents Page 1. Introduction 3 2. Policy Statement 3 3. Purpose 3 4. Covered Parties 4 5. Covered Transactions 4 6. Material Non-Public
More informationStatement of Our Policy Regarding Securities Trades By Personnel of Resource America, Inc. ( RAI ) The Need For A Policy Statement
TO: FROM: All Employees, Officers and Directors Edward E. Cohen, Chief Executive Officer DATE: January 14, 2004 RE: Statement of Our Policy Regarding Securities Trades By Personnel of Resource America,
More informationLEGAL ADDENDUM TO ITT/ESI INSIDER TRADING POLICY LE 4.1
INTENT OR PURPOSE The purpose of this policy is to summarize briefly certain federal securities law considerations that are relevant in determining when and under what circumstances members of the Board
More informationSYNERGY PHARMACEUTICALS INC. INSIDER TRADING COMPLIANCE PROGRAM
SYNERGY PHARMACEUTICALS INC. INSIDER TRADING COMPLIANCE PROGRAM In order to take an active role in the prevention of insider trading violations by its officers, directors, employees and other related individuals,
More informationPolicy for Dealing in Securities
Policy Policy for Dealing in Securities Alliance Aviation Services Limited ACN 153 361 525 Adopted by the board on 2 December 2011 Policy 1 Introduction The purpose of this Policy is to: explain the types
More informationZOOMERMEDIA LIMITED INSIDER TRADING, REPORTING AND BLACKOUT POLICY
ZOOMERMEDIA LIMITED INSIDER TRADING, REPORTING AND BLACKOUT POLICY Introduction The purpose of this Insider Trading, Reporting & Blackout Policy (the Insider Trading Policy ), is to explain certain legal
More informationPOLICY GUIDANCE & STANDARDS
Current versions of approved documents are maintained online. Printed copies are uncontrolled. Page 1 of 5 POLICY GUIDANCE & STANDARDS TRADING BLACKOUTS FOR RESTRICTED PERSONS Number : CO-059 Date Developed:
More informationInsider Trading Compliance Manual
Insider Trading Compliance Manual In order to take an active role in the prevention of insider trading violations by its officers, directors, employees, consultants, attorneys, advisors and other related
More informationPAYLOCITY HOLDING CORPORATION INSIDER TRADING POLICY Revised April 30, 2015
PAYLOCITY HOLDING CORPORATION INSIDER TRADING POLICY Revised April 30, 2015 I. TRADING IN COMPANY SECURITIES WHILE IN POSSESSION OF MATERIAL NONPUBLIC INFORMATION IS PROHIBITED The purchase or sale of
More informationSecurity Trading Policy
Security Trading Policy DirectMoney Limited (ACN 004 661 205) (DirectMoney or Company) 1. Introduction 1.1 Purpose This policy summarises the law relating to insider trading, considers the perception of
More informationTOREX GOLD RESOURCES INC. Insider Trading Policy
TOREX GOLD RESOURCES INC. Insider Trading Policy Purpose The trading of securities of a public company is governed by extensive and complex securities laws and regulations, the fundamental idea being that
More informationCORPORATE COMPLIANCE POLICY MANUAL
CORPORATE COMPLIANCE POLICY MANUAL TRADING IN TENNECO SECURITIES 08/01/2006 Policy Number: 20-100 SUBJECT: TRADING IN TENNECO SECURITIES Application: Worldwide Strategic Business Units and Subsidiaries.
More informationTravelCenters of America LLC Insider Trading Policies and Procedures
TravelCenters of America LLC Insider Trading Policies and Procedures Following are the policies and procedures approved and adopted by the Board of Directors of TravelCenters of America LLC (the Company
More informationPRECISION DRILLING CORPORATION CORPORATE POLICY CP 11 INSIDER TRADING POLICY
PRECISION DRILLING CORPORATION CORPORATE POLICY CP 11 INSIDER TRADING POLICY Effective Date: 24 October 2007 Approved by the Board of Directors Table of Contents 1 Scope...3 2 Purpose...3 3 Definitions...3
More informationWILLDAN GROUP, INC. INSIDER TRADING POLICY
WILLDAN GROUP, INC. INSIDER TRADING POLICY 2016 I. PURPOSE Federal and state securities laws prohibit any member of the Board of Directors (the Board ) of and its subsidiaries (collectively, the Company
More informationInformation Disclosure Policy
Information Disclosure Policy Employees, Officers and Directors Page i Table of Contents OBJECTIVES OF THIS POLICY... 1 POLICY/PROGRAM SCOPE... 1 POLICY ELEMENTS... 1 MATERIAL INFORMATION... 1 NON-PUBLIC
More informationCode of Ethics. JPG Wealth Management, LLC Shepherds Lane NE Atlanta, Georgia 30324
Code of Ethics Of JPG Wealth Management, LLC 1158 Shepherds Lane NE Atlanta, Georgia 30324 TABLE OF CONTENTS 1. GENERAL PROVISIONS... 1 1.1 Provisional Responsibilities... 1 1.2 Failure to Comply... 2
More informationYANDEX N.V. Insider Trading Policy. (Effective as of May 23, 2011)
1. BACKGROUND AND PURPOSE YANDEX N.V. Insider Trading Policy (Effective as of May 23, 2011) The US federal securities laws prohibit any member of the Board of Directors (a Director ) or employee of Yandex
More informationINSIDER TRADING POLICY
1 of 11 INSIDER TRADING POLICY Effective March, 2017 Version 1.0 Scope of the Policy Legal Background Obligations INTRODUCTION ABcann Global Corporation as a public company has internal guidelines to control
More informationSUPERIOR PLUS CORP. INSIDER TRADING POLICY
SUPERIOR PLUS CORP. INSIDER TRADING POLICY First Approved by Board: August 9, 2005 Current Version Approved by Board: August 8, 2018 Policy Review Cycle: Annually Responsible Executive: Senior Vice President
More informationSecurities Trading Policy
Securities Trading Policy Version Approved By Date Released Amendment 0 Marc Ducler des Rauches 22/07/2016 Document Created 1. Introduction Egan Street Resources Limited (Company) has Shares and Options
More informationSecurities Trading Policy. Martin Aircraft Company Limited
Securities Trading Policy Martin Aircraft Company Limited October 2014 CONTENTS 1 Background and Purpose of this Policy... 1 2 Company Personnel... 1 3 Securities Covered By This Policy... 1 3.1 Securities...
More informationSecurities Trading Policy. (Adopted by the board on 25 April 2017)
Securities Trading Policy (Adopted by the board on 25 April 2017) Securities Trading Policy Afterpay Touch Group Limited and its subsidiaries (the Company) 1. Introduction and Purpose 1.1 Background This
More informationSecurities Trading Policy
Securities Trading Policy Securities Trading Policy 1. Introduction and Purpose The Board encourages Key Management Personnel (including Directors) and employees to own securities in Ruralco Holdings Limited
More informationACNB CORPORATION CODE OF ETHICS
ACNB CORPORATION CODE OF ETHICS The directors, officers and employees of ACNB Corporation and all its subsidiaries and affiliates (the Company ) hold an important and elevated role in corporate governance.
More informationTPN CODE OF ETHICS AND INSIDER TRADING POLICIES AND PROCEDURES
TPN CODE OF ETHICS AND INSIDER TRADING POLICIES AND PROCEDURES A. General The Code of Ethics is predicated on the principle that TPN, in its capacity as an SEC registered investment adviser, owes a fiduciary
More informationSagePoint Financial, Inc. FSC Securities Corporation
CODE OF ETHICS SagePoint Financial, Inc. 2800 N. Central Ave., Suite 2100 Phoenix, AZ 85004 (800)552-3319 FSC Securities Corporation 2300 Windy Ridge Parkway, Suite 1100 Atlanta, GA 30339 (800)547-2382
More informationSECURITIES TRADING POLICY
SECURITIES TRADING POLICY june 2017 Nusantara Resources Limited ACN 150 791 290 Level 2, 175 Flinders Lane Melbourne Vic 3000 Australia T: 9620 0718 www.nusantararesources.com 1. Introduction Nusantara
More informationDUPREE MUTUAL FUNDS CODE OF ETHICS
DUPREE MUTUAL FUNDS CODE OF ETHICS 1. Statement of General Fiduciary Principles This Code of Ethics is based on the principles that (i) Access Persons (as such term is hereinafter defined) owe a fiduciary
More informationCONTRAVIR PHARMACEUTICALS, INC. INSIDER TRADING COMPLIANCE PROGRAM
CONTRAVIR PHARMACEUTICALS, INC. INSIDER TRADING COMPLIANCE PROGRAM In order to take an active role in the prevention of insider trading violations by its officers, directors, employees and other related
More informationCorporate Policies and Procedures Manual. Corporate Governance: Code of Ethics
Corporate Corporate Governance: Code of Ethics Policy Created: December 11, 2006 Last Revision: October 3, 2009 Table of Contents STATEMENT OF PURPOSE AND APPLICABILITY...3 DEFINITIONS...3 STANDARDS OF
More informationCHECKFREE CORPORATION CODE OF BUSINESS CONDUCT FOR DIRECTORS, OFFICERS AND ASSOCIATES
CHECKFREE CORPORATION CODE OF BUSINESS CONDUCT FOR DIRECTORS, OFFICERS AND ASSOCIATES INTRODUCTION CheckFree Corporation operates its business in accordance with the highest ethical standards and relevant
More informationShare Trading Policy. Helloworld Limited ABN Approved 26 August Effective 27 August 2014
Share Trading Policy Helloworld Limited ABN 60 091 214 998 Approved Effective 27 August 2014 Share Trading Policy 1. Introduction The Corporations Act of Australia, and the laws of other countries in which
More informationContents. Contravention of this policy will be regarded as a serious matter by Woodside and may also give rise to criminal or civil actions.
WOODSIDE POLICY Securities Dealing Policy Contents 1 OVERVIEW...1 2 PROHIBITION ON INSIDER TRADING...3 3 PROHIBITION AGAINST SHORT TERM OR SPECULATIVE DEALING...5 4 PROHIBITION AGAINST DEALING DURING BLACK-OUT
More informationTRADING IN COMPANY SECURITIES POLICY & PROCEDURES
TRADING IN COMPANY SECURITIES POLICY & PROCEDURES 1 CONTENTS PROCEDURE FOR TRADING... 3 BLACKOUT PERIODS & TRADING WINDOWS (INDICATIVE ONLY)..3 NOTES... 4 SCHEDULE 1 Metminco Securities Trading Policy...
More informationThis Policy further mitigates risk by monitoring Investment Account activity.
Title Securities Disclosure and Trading Policy Effective Date October 4, 2017 Update Date April 11, 2018 1.0 Policy Objective S&P Global has a worldwide reputation for integrity and objectivity. With that
More information