Insider trading controls mandate pre-clearance, restricted lists and monitoring of designated persons' trades under internal codes. Intermediaries and fiduciaries must adopt a Code of Conduct requiring a compliance officer to monitor and report trading by designated persons, maintain confidential restricted lists, require pre-clearance and declarations of absence of unpublished price sensitive information, impose execution timeframes and contra-trade restrictions (with limited written relaxations and disgorgement for violations), specify reporting and disclosure formats and obligations for designated persons, set out processes for admitting persons to sensitive transactions, and prescribe sanctions and prompt reporting of violations to stock exchanges.