Employee Trading Policy

Employee Trading Policy

Personal Information

Position Information

Policy Overview and Purpose

This Employee Trading Policy sets forth the rules, procedures and conditions that govern personal securities trading by employees, officers and directors to prevent misuse of material nonpublic information, to avoid conflicts of interest, and to protect the corporation and its stakeholders. All employees are required to read, understand and comply with this policy as a condition of employment.

Definitions

Material Nonpublic Information: specific corporate information that has not been disclosed to the public and that a reasonable investor would consider important in making an investment decision.

Insider: any employee, officer, director or agent who has access to material nonpublic information as a result of employment or position with the company.

Prohibited Conduct

Employees shall not buy, sell, transfer or recommend securities of any issuer while in possession of material nonpublic information relating to that issuer. This prohibition applies to transactions in the employee's own account and in the accounts of family members, household members, entities controlled by the employee, or others for whom the employee has investment discretion.

Employees must refrain from tipping others by passing along material nonpublic information or recommending transactions while aware of such information. Any such conduct will subject the employee to disciplinary action, up to and including termination, and potential civil or criminal liability.

Pre-Clearance, Blackout Periods and Trading Windows

Employees are required to obtain written pre-clearance from the Compliance Officer before executing trades in securities of any company when such trades could be impacted by material nonpublic information. The company will establish blackout periods during which trading is prohibited for specified employees. Trading outside of designated trading windows remains subject to the pre-clearance procedure and the prohibitions in this policy.

Request pre-clearance for a proposed transaction by completing the Pre-Clearance Request form and submitting it to the Compliance Officer. Acknowledge compliance with the pre-clearance requirement:

I will obtain pre-clearance from the Compliance Officer before executing reportable trades.

Permitted Transactions and Exceptions

The following transactions may be permitted without pre-clearance, provided the employee is not in possession of material nonpublic information and the transaction complies with other sections of this policy: transactions in mutual funds, exchange-traded funds, broad-based index funds, or transactions executed pursuant to pre-existing binding arrangements established prior to the employee's access to material nonpublic information. Any claim of exemption must be documented and approved by the Compliance Officer.

Reporting and Recordkeeping

Employees must promptly report all reportable trades and any suspected violations of this policy to the Compliance Officer. The company will maintain records of pre-clearance requests, trade reports, and related correspondence for the period required by applicable law and company record retention standards.

Conflicts of Interest

Employees must disclose any personal or familial financial interests that could create an actual or perceived conflict of interest with the company's business activities. Such disclosures should be made in writing to the Compliance Officer or Human Resources.

Disciplinary Measures and Legal Consequences

Violations of this policy may result in disciplinary action up to and including termination of employment. Employees may also be subject to civil and criminal penalties under applicable securities laws. The company reserves the right to pursue disciplinary action irrespective of whether regulatory enforcement occurs.

Exceptions and Waivers

Any request for an exception or waiver to this policy must be submitted in writing to the Compliance Officer and will be considered on a case-by-case basis. Written approval is required for any exception, and any approved waiver must be documented and retained with policy records.

Employment History (required)

Employer 1

Employer 2

Education

Professional References

Reference 1

Reference 2

Reference 3

Legal Disclosures

At-Will Employment: Employment with the company is at-will, which means that either the employee or the company may terminate the employment relationship at any time, with or without cause or prior notice, subject to applicable law.

Equal Opportunity: The company is an equal opportunity employer. Employment decisions are made without regard to race, color, religion, sex, national origin, age, disability, or any other protected characteristic under applicable law.

Acknowledgment, Certification and Authorizations

I certify that I have read, understand and will comply with the Employee Trading Policy. I declare that the information provided on this form is true and complete to the best of my knowledge. I understand that failure to comply with this policy may result in disciplinary action, including termination, and potential civil or criminal liability.

I certify that all information provided is true and complete and that I will comply with the Employee Trading Policy.

I authorize the company to contact prior employers and references and to conduct such background checks as permitted by law in connection with enforcement or implementation of this policy.

Compliance: Questions and Disclosures

If you have questions about whether information is material or whether a transaction is permitted, contact the Compliance Officer before trading. Disclose any suspected violation to the Compliance Officer immediately. The company will investigate alleged violations and protect the confidentiality of reports to the extent practicable.

Sign Now