A trading policy is the principal control against insider trading by employees and is expected of any company with a class of securities held by others.
Covered persons. Directors, officers, employees, and in many policies household members and entities they control.
Blackout periods. Closed windows from a defined point before quarter end until a stated period after earnings release, plus event-specific blackouts imposed when material non-public information exists.
Pre-clearance required for designated insiders, with a compliance function maintaining a log and a defined approval authority.
Prohibited transactions. Short sales, options, hedging, margin accounts and pledging.
Trading plans. Adopted only during an open window while not in possession of material non-public information, with a cooling-off period before the first trade, a certification, restrictions on overlapping plans and on single-trade plans, and disclosure of adoption and termination.
Information barriers and a restricted list where the company handles non-public information about counterparties.
Training and certification annually.
Enforcement. Documented consequences for violations, applied consistently — because a policy that has never been enforced is evidence of the absence of a programme rather than of the presence of one.