Insider Trading Policies and Procedures
Cooley is committed to providing public companies and their boards with relevant, on-demand resources. As a part of that effort, we are excited to be conducting a multipart survey series designed to provide insights and best practices on key corporate governance topics, practices and market trends.
Here are the results and key takeaways from Part 2 of the survey series, which focused on insider trading policies and procedures.
Nearly all respondents said that they subject all employees to the company insider trading policy, while less than half of respondents subject all consultants to the policy. A significant majority also subject non-employee members of the board of directors to the policy. Others subjected to the policy mentioned by respondents include family members of covered people and former employees, among others.
Of the 86% of companies whose insider trading policy covers non-employee directors, respondents were divided on whether the policy also covers director-related investment funds.
The most common groups identified by respondents as being subject to trading blackout periods under their company insider trading policies were non-employee directors, all employees, all Section 16 reporting individuals, and employees...
MANILA (UPDATED) — The Chinese Embassy on Monday claimed that some Filipino politicians have “fabricated and spread a false narrative” about China’s alleged funding for an unnamed local political ...