What is considered inside information?
All non-public precise information relating to your company, which, if made public, would be likely to have a significant effect on the price of financial instruments relating to your company is considered to be inside information. The existence of inside information must always be reported as soon as possible to the Inside Information Committee (IIC) by any person that suspects that certain information may constitute inside information.
No inside information may be publicly disclosed by other means than official press releases in accordance with the rules. Disclosing inside information by means of sharing such information with other people, such as but not limited to: journalists, analysts, shareholders, employees or other similar persons is strictly prohibited and can constitute a crime. Inside information can only be shared with persons who need access to such information in order to fulfil their professional duties, and as long as they are bound by a duty of confidentiality and are included in the relevant insider list.
Insider trading and inside information policy
All inside information must be handled with care and strict confidentiality in order to avoid a breach. Any employee who suspects a violation of your organisation’s policy must speak up and raise the issue to their immediate manager, or follow the company’s whistleblowing procedures. VinciWorks’ insider trading and inside information policy template can easily be edited to include your business’ reporting procedures and relevant contact information.
What should be included in an insider trading and inside information policy?
- Identification and Handling of Inside Information
- Definition of Inside Information
- Inside Information Committee
- Insider Trading
- Senior Directors
- Defining persons discharging managerial responsibilities and closely associated persons
- Insider Lists
- An explanation of what is meant by insider trading
- The procedure for raising concerns under this policy
VinciWorks’ online market abuse training
VinciWorks’ course, Market Abuse: Know Your Trade, guides users through how to deal with inside information. The gamified course takes users through three core modules relating to market abuse, providing interactive scenarios to test their understanding of the topic. The course can also be customised to include your company’s reporting procedures and policies.