Insider Trading Policy

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Screenshot of the first page of Insider Trading Policy

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.

This sample policy outlines a set of policies and procedures for insider trading. Transactions must comply with these procedures in order to comply with securities laws as defined by the Security Exchange Commission. This document defines "insider" as an officer, director, employee or beneficial owner of a company’s stock who knows material information regarding the company that has not been fully disclosed to the public.

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