How do you handle Insider Trading training in your organizations? Do you push out standalone training on the topic? If so, how do you determine your audience? Or, is Insider Trading covered in an existing training, such as Code of Conduct? Do you find that to be enough?
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Director of Legal2 years ago
In at least two organisations I've worked in it's sat within the company's Code of Ethics.
Director of Other in Finance (non-banking)2 years ago
In the majority of organizations I've worked at, it is primarily covered within the Code of Conduct annual training with an attestation at the end. Several also required officers/executives to make Conflicts of Interest disclosures annually. In addition, some companies provided reminders on their main company sites for when they are in a quiet period.
Similar to the others: (1) code of conduct, (2) dedicated training session, and (3) signed agreement not to trade individual public stocks (ETFs and mutual funds often excluded) either as part of the onboarding contractual docs (sometimes in the employment agt itself.