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?

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