The guidelines and procedures included in this policy sample can be used for developing a robust insider trading policy.

According to this sample, an "insider" may be an officer, director, employee or beneficial owner (holder of 10% or more) of a company’s stock who knows material information regarding the company that has not been fully disclosed to the public. All insider trading transactions should comply with the included procedures in order to comply with securities laws as defined by the Security Exchange Commission (SEC). These procedures should apply to all employees and their immediate families privy to undisclosed company information.