Should you have any questions regarding this Policy, please contact the Corporate Secretary at (212) 836-2732. this policy, Insider also includes “constructive insiders,” such as outside lawyers, consultants or other persons who receive legitimate Material, Non-Public Information from a corporation in the course of providing services to the corporation. Insider trading is also prohibited by this Policy, and violation of this These persons may be subject to fines up to the greater of $1,000,000 or three times profit (or loss avoided) by the insider trader. 1. In addition, Company Personnel must not make any trades in securities of the Company during the blackout periods described in Section 7 of this Policy. 15. The Hershey Company (the “Company”) has adopted this Insider Trading Policy (this “Policy”) to help its directors, officers and employees comply with insider trading laws and to prevent even the appearance of improper insider trading. What types of trading should be restricted? 20-2-2002. Do insider-trading laws deter illegal insider trading? Statement of Intent The Company opposes the misuse of material nonpublic information in the trading of securities and it is the intent of this Policy to implement procedures designed to prevent trading based on material nonpublic information regarding the Company, including any of its subsidiaries. Certain types of behaviour, such as insider dealing and market manipulation, can amount to market abuse. Policy: This Policy concerns the handling of material, non-public information relating to Insider Dealing Policy Version 1.4. 4.6. Please note that the procedures described below are Company policy. Insider trading law and stock plans: grant date timing • Concerns about making stock grants when the company has material nonpublic information (springloading, bullet dodging) and whether the ... written policy prohibiting trading in any company's securities on the basis of nonpublic information. Insider trading is a top enforcement priority of the Securities and Exchange Commission (the “SEC”), the Nasdaq Global Select Market (the “Nasdaq”) and the Department of Justice. INSIDER TRADING POLICY The following is the insider trading policy of Willis Lease Finance Corporation (the “Company”) and outlines the procedures that all Company personnel must follow. It begins with definitions of the basic elements of insider trading. Version – R3 . INSIDER TRADING POLICY PURPOSE Astro Aerospace Inc. is committed to compliance with the laws, rules and regulations by which we are governed, including all applicable U.S., Canadian, and other securities laws and regulations, and we take insider trading very seriously. In addition, Company Personnel must not make any trades in securities of the Company during the blackout periods described in Section 7 of this Policy. At Inside, we want you to be able to have the knowledge and advice you need to grow in your career, so subscribe for free today and become an Insider. Adobe has adopted this Policy Insider trading is also prohibited by this Policy, and violation of this Insider trading is a serious matter that can carry severe criminal or civil penalties for both our Company and the individuals involved. Criminal prosecutions for insider trading are commonplace and may result in fines and/or imprisonment. The penalties for violating insider trading laws include imprisonment, disgorgement of profits, civil fines, and criminal fines of up to $5 million for individuals and $25 million for corporations. Purpose of this Policy The board of directors (the “Board”) of Payfare Inc. (the “Company”) has adopted this Insider Trading Policy (the “Policy”), which is designed to provide guidance to the directors, officers and employees of the Company and its subsidiaries (who are referred to collectively in this Policy as “Company This Policy explains the strict legal and ethical prohibitions against insider trading and the related offense of “tipping.” Designated Insiders will be notified via e-mail when a Blackout Period begins and ends. Black-out/Insider Trading Policy: An exceptionally stringent Insider Trading policy was designed to prevent the occurrence or even the appearance of improper trading in our stock by associates and directors. Insider Trading Policy Version 2020.01 5 | Page B. Joint account. Because the Company’s stock is Statement of Intent The Company opposes the misuse of material nonpublic information in the trading of securities and it is the intent of this Policy to implement procedures designed to prevent trading based on material nonpublic information regarding the Company, including any of its subsidiaries. STATEMENT OF INVESTMENT POLICY FOR INSIDER TRADING July 22, 2014 This Policy is effective immediately upon adoption and supersedes all previous insider trading policies. American Electric Power Company, Inc. and certain of its subsidiaries are the issuers of securities that are registered with the Securities and Exchange Commission. Definitions 1) Compliance Officer To help associates, officers, and trustees comply with insider trading laws and to prevent even the appearance of improper insider trading. Vectren’s Insider Trading Policy (“Policy”) is designed to establish controls to ensure that material, nonpublic information is kept confidential and released to the public in an appropriate and lawful manner and to prevent trading on “inside” or material, nonpublic information. GSE SYSTEMS, INC. INSIDER TRADING POLICY . This policy is designed to prevent insider trading or allegations of insider trading and protect our reputation for integrity and ethical conduct. Policies are considered final when posted on the company intranet. Code of Ethics and Insider Trading Policy Code of Ethics at a Glance The Artisan Partners Code of Ethics and Insider Tradin g Policy (the “Code”) applies to you as a Covered Person1 of Artisan Partners. Foreign insider trading laws may also apply to Computershare directors, officers and employees residing outside Australia. This insider trading policy (this “Policy”) aims to define and establish rules & process of the Company with respect to: Prevention of Insider trading of securities; To ensure there is no violation of SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to the Securities Market) Regulations, 2003. Purpose and General Principles This Insider Trading Policy (the “Policy”) provides guidelines with respect to transactions in the securities of US Foods Holding Corp. and its subsidiaries (collectively, “US Foods” or the “Company”) and the handling of advised by the Insider Trading Policy Administrators (e.g. This Insider Trading Policy (this “Policy”) provides prohibitions and guidelines to Insiders (as defined below) of The AZEK Company Inc., and its subsidiaries (collectively, the “Company”) with respect to purchasing and selling Company securities or derivatives thereof. Home of Entrepreneur magazine. The purpose of this Insider Trading Policy (this “Policy”) is to promote compliance with applicable securities laws by Premier, Inc., Premier Healthcare Alliance, L.P., and their respective subsidiaries (“Premier” or the “Company”) and all directors, officers and employees INSIDER TRADING POLICY . This policy and procedure arises from our responsibilities as a public company. Trading in derivatives 11 5.3. Pursuant to the Exchange Act, the Company files Insider INSIDER TRADING POLICY Introduction This insider trading policy (the “Policy”) provides guidelines to certain officers, directors and employees of, and consultants and contractors to the Company (including its subsidiaries) with respect to transactions in shares or other securities of the Company. g. trades pursuant to an approved 10b5-1 trading plan; or . Corporation (the “Company”) has adopted this Insider Trading Policy. provisions (Part 7.10, Division 3) prohibiting insider trading. The evidence is mixed. They also prohibit “tipping,” or the disclosure of Material Nonpublic Information about an issuer to insider buying. Definition. Buying of a company's stocks by individual directors, executives or other employees. Generally a sign that those individuals believe that the company's stock is undervalued. May be illegal if insider information is the reason for the purchase. opposite of insider selling. A cautionary note about the application of insider trading laws 10. An Insider may establish a 10b5-1 plan for trading in shares of the Company. Each bank is different and may present specific issues. Any body-corporate in which the company is a corporate director or insider. Firms must have safeguards in place to identify and reduce the risk of market abuse and other financial crime. any blackout period or other Company-imposed trading restrictions applicable at the time of the termination of service. 2.0 SCOPE The term “Employee” or “Employees” is specifically defined, for CAL_LAW\ 3820035\1 PAYFARE INC. INSIDER TRADING POLICY 1. General Purpose. Letter: E 3.5 Effective January 1, 2015, Directors, Executive Officers (designated by the Board of Directors) and corporate vice presidents whose compensation is regularly reviewed by Insider Trading Policy June 2017 Page 5 of 6 . a potential transaction that was the subject of the information is abandoned). This Policy applies to all directors, officers, employees and certain designated contractors of the Company. CORPORATE INSIDER TRADING POLICY 1.0 Introduction The Board of Directors of Atex Resources Inc. (the “Company”) is a publicly traded company listed on the TSX Venture Exchange (the “TSXV”).As such, trades in the Company’s securities INSIDER TRADING POLICY PURPOSE The Arconic Corporation (“Arconic”) Insider Trading Policy (the “Policy”) is designed to prevent insider trading violations or allegations of such violations, to protect Arconic’s reputation for integrity and ethical conduct, and to maintain the confidence of shareholders and the public markets. 12. INSIDER TRADING POLICY I. Insider Trading Policy Approved on January 13, 2017 2 1. INSIDER TRADING POLICY. defense from insider trading liability. POLICY: Trading Day, the date of Public Disclosure shall be considered to be the next Trading Day. Name of Policy: Insider Trading Compliance Document Control #: Global Policy 07 Purpose The purpose of this policy is to promote A. O. Smith Corporation’s ongoing commitment to compliance with all applicable in sider trading laws, and to assist you in meeting your responsibility to … The company itself; b. Scope: All Americold associates, officers and trustees III. Several researchers have examined whether or not insider trading is affected by the passage of the 1988 ITSA. Insider trading is a serious matter that can carry severe criminal or civil penalties for both our Company and the individuals involved. Insider Trading Policy 1. Company Insider Trading Policy ..... 96 Rule 10b5-1 Trading Plans ..... 97 Insider Trading During Pension Plan Blackout Periods Prohibited ..... 97 Get With the Program: Rule 10b5-1 Trading Plans ..... 101 Benefits to the Company and Its Insiders on Adopting Rule Pursuant to the Exchange Act, Should you have any questions regarding this policy, … I. II. This Policy is designed to prevent insider trading or allegations of insider trading, and to protect the Company’s reputation for integrity and ethical conduct. POLICY PURPOSE. Harken reported significant financial losses within a year of this sale, triggering allegations of insider trading. and “non-public.” Insider trading is a crime. The purpose of this Insider Trading Policy (this “Policy”) is to promote compliance with applicable securities laws by Premier, Inc., Premier Healthcare Alliance, L.P. and their respective subsidiaries (“Premier” or the “Company”) and all directors, officers and They are not intended to replace the primary responsibility of each board member, officer, employee and consultant to understand and comply with the prohibition on insider trading under federal and A summary of the relevant insider trading laws is annexed to this Policy as Schedule A. An employee who wishes to enter into a Trading Plan must submit the Trading Plan to the Legal and Compliance Department for its approval prior to the adoption Insider Trading and Blackout Policy This memorandum sets forth the “Policy” of Sama Resources Inc. (“Sama”) on insider trading and trading blackouts in order to ensure the strict compliance by all Insiders (as defined below) with the prohibition against insider trading. This Policy explains the strict legal and ethical prohibitions against insider trading and the related offense of “tipping.” About this policy Aegon is committed to maintaining a high ethical standard across all its business activities. Insider trading is a crime. Controlling persons include directors, officers, and supervisors. a potential transaction that was the subject of the information is abandoned). INSIDER TRADING POLICIES&. Legal Policy Insider Trading and Confidentiality Policy Policy: LEG-011 Page 2 of 5 Original Issue Date: November 27, 2002 Rev. It is your obligation to understand and comply with this Policy. advised by the Insider Trading Policy Administrators (e.g. About this Policy Violations of insider trading laws can, and often do, result in criminal investigations, prosectutions, disgorgement of ill-gotten trading profits, fines and prison sentences. GUIDELINES ON INSIDER TRADING 4 Covered Securities The policies and guidelines contained herein cover securities of all classes (and the derivatives thereof) authorized and issued by: a. [] Insider Trading Policy Commercial Vehicle Group, Inc. is a publicly held company, the common stock of which is traded on the Nasdaq Global Select Market and registered under the Securities and Exchange Act of 1934, as amended (the “Exchange Act”). APPLICATION OF POLICY In the course of This Insider Trading Policy (the “Policy”) serves to ensure compliance with applicable securities laws, regulations and rules, including those imposed by the Toronto Stock Exchange and the Ontario Securities Commission governing insider trading and reporting, as well as “tipping” of To comply with the Company’s insider trading policy, a 10b5-1 plan must be approved by the Vice President-Legal and meet the requirements of Rule 10b5-1. Code of Conduct to Regulate, Monitor and Report Trading By Insiders and Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information . Insider Trading PolicyIntroduction. The Board of Directors of ADP has adopted this policy to provide guidelines to all directors, officers, associates and consultants of ADP with respect to trading in ADP securities, ...Sanctions and Penalties. ...Persons Covered. ...Requirements Applicable to Everyone. ...10b5-1 Plans. ... The trading policy … Aegon’s Code of Conduct ... 5.2 No trading without pre-approval 11 5.3 No trading during a Closed Period 11 Vectren’s Insider Trading Policy (“Policy”) is designed to establish controls to ensure that material, nonpublic information is kept confidential and released to the public in an appropriate and lawful manner and to prevent trading on “inside” or material, nonpublic information. The Code and the UPS Policy Book (“Policy Book”) are complementary documents that describe our objectives and explain our responsibilities to our company, people, customers, shareowners, and communities. Trading in Company Securities While in Possession of Material Non-public Information is Prohibited The purchase or sale of securities by any person who possesses material non-public information is a violation of federal and state securities laws. the Insider Trading Policy Administrator shall notify any individual that has given a Trade Notice in accordance with this Policy whether the Insider Trading Policy Administrator reasonably anticipates that any proposed trade will contravene applicable securities laws and/or this Policy, and if so, that the proposed trade may not be undertaken. INSIDER TRADING POLICY . 2. Effective July 31, 2018 [Pursuant to SEBI (Prohibition of Insider Trading) Regulations, 2015 and as approved by the h. any other transaction designated by the Board of Directors or any board committee or senior management, with reference to this policy, as a Permitted Transaction. Liability for insider

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