Insider Trading Policy

Time Period for MNPI to be considered “public”

Start of quarterly blackout period

Start of Quarterly Blackout Period (No. of Days)

End of quarterly blackout period

Group of insiders subject to quarterly blackout periods

Group of insiders subject to preclearance procedures

Group of insiders prohibited from hedging/pledging

Are exceptions allowed for hedging/pledging?

How are gifts treated?

Who Administers the Policy?

Are Waivers of the Policy Permitted?

Approver of waivers

Does the Policy Explicitly Apply Post-Termination?

Is other company trading prohibited?

How other companies are addressed

Categories of prohibition on trading

Is the policy applicable to third parties?

Whether sell-to-cover transactions are exceptions to the policy?

Whether the exception only applies if the company sells on the employee’s behalf?

Whether certain insiders may only trade using a 10b5-1 plan (including subject to limited exceptions)?

Whether the Company has 10b5-1 plan guidelines/policy?

What groups the guidelines/policy of 10b5-1 plan applies to?

Do employees other than section 16/executive officers of 10b5-1 plan have a minimum cooling-off period?

Whether the company has an absolute prohibition on overlapping 10b5-1 plans?

How do guidelines address the termination of a 10b5-1 plan?

Prohibition on Prediction Market (Insider Trading Policies)

Prohibition on Prediction Market (Code of Ethics Only)