TheCorporateCounsel.net

Here are results from our recent survey on COVID-related adjustments to insider trading policies:

1. Who owns/administers your company’s insider trading policy (e.g., sets window open/close dates, determines employees subject to window periods, provides pre-clearance for transactions, etc.)?

– Corporate secretary department – 77%
– Ethics & compliance office or similar function – 11%
– Corporate stock plan department – 1%
– Combination of 1 or more of the above – 11%

2. Has your company made changes to the policy as a result of Covid-19?

– Yes, it covers more employees – 2%
– Yes, we’ve instituted an event-specific closed window period – 10%
– No – 88%

3. Has your company issued more frequent communication about the policy during the Covid-19 pandemic?

– Yes – 22%
– No – 78%

4. If you’ve issued more frequent communication about the policy, how frequent?

– Once – 67%
– Twice so far – 28%
– More often – 5%

5. If you haven’t issued more frequent communication, are you planning to do so and if so when?

– No – 69%
– Yes, within the next month – 2%
– Haven’t decided yet, will depend upon ongoing developments – 29%

As a reminder, we’ve previously posted the transcript from our webcast for members, “Insider Trading Policies & Rule 10b5-1 Plans.” We’re keeping an eye out on further SEC developments with insider trading policies – stay tuned!

Please also take a moment to participate anonymously in these surveys:

– “Quick Survey on Board Meeting Health Protocols”

– “Quick Survey on Board Committees – Risk and Cybersecurity”

– Liz Dunshee