Insider trading safeguards: expanded definitions and mandatory codes, controls and recordkeeping to protect unpublished price sensitive information. Amendments broaden the insider trading framework by defining 'financially literate', expanding 'proposed to be listed', and treating recipients of unpublished price sensitive information shared for a legitimate purpose as insiders. Boards must adopt policies defining legitimate purposes, maintain a structured digital database with identifiers and audit trails, and ensure internal controls. Intermediaries and fiduciaries must adopt codes of conduct per Schedule C identifying designated persons, imposing pre-clearance (with trading-plan exceptions), restricted lists, contra trade rules, disclosure obligations for designated persons, and disciplinary measures including recovery and clawback.
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Insider trading safeguards: expanded definitions and mandatory codes, controls and recordkeeping to protect unpublished price sensitive information.
Amendments broaden the insider trading framework by defining "financially literate", expanding "proposed to be listed", and treating recipients of unpublished price sensitive information shared for a legitimate purpose as insiders. Boards must adopt policies defining legitimate purposes, maintain a structured digital database with identifiers and audit trails, and ensure internal controls. Intermediaries and fiduciaries must adopt codes of conduct per Schedule C identifying designated persons, imposing pre-clearance (with trading-plan exceptions), restricted lists, contra trade rules, disclosure obligations for designated persons, and disciplinary measures including recovery and clawback.
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