A Comprehensive Look at Insider Trading Policies: The Litigator’s Perspective

Our guests – DLA Piper’s Deborah Meshulam and King & Spalding’s Dixie Johnson – dig really deep into everything you need to know about insider trading policies, including:

1. Is a policy required and if so, by what statute/rule/reg and what is the extent of what’s required (as opposed to advised)?
2. Definition of “Material Non-Public Information”
3. Scope / Covered persons & transactions / Differences for Section 16 persons
4. How the blackout period works
5. Exceptions to the policy
6. 10b5-1 plans
7. Pre-Clearance & inquiries / Who should pre-clear / Reporting of violations/ Attorney-client privilege issues for communications and records
8. Sanctions & penalties
9. Acknowledgement
10. Effective communication of the policy
11. How do you deal with “hot topics” – like cybersecurity breaches? Do you add them into the policy or address them in another manner?