Survey Results

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Survey Results: Rule 10b5-1 Plan Practices

1. Does your company require insiders to sell shares only pursuant to a Rule 10b5-1 trading plan?

Answer	Responses	Percent
Yes, insiders are required to use Rule 10b5-1 plans in order to sell shares	2	4.2%
No, but they are strongly encouraged	21	43.8%
No, and they are not explicitly encouraged	25	52.1%
Not sure, it hasn’t come up	0	0.0%

2. Does your company review and approve each insider’s Rule 10b5-1 trading plan?

Answer	Responses	Percent
Yes, it is subject to prior review and approval by the company pursuant to the insider trading policy	35	77.8%
Yes, but only the template plan is reviewed and not the actual trading schedule	6	13.3%
No, but we have a broker that we require to be used and have reviewed that brokers template	3	6.7%
No, and there is no requirement to go through a specific broker	1	2.2%

3. Does your company allow sales of shares through Rule 10b5-1 trading plans during blackout periods?

4. Does your company require a waiting period between execution of Rule 10b5-1 trading plans and time of first sale?

Answer	Responses	Percent
Yes, it is a two week waiting period or less	5	10.9%
Yes, it is a one month waiting period (or close to it)	15	32.6%
Yes, it is a two month waiting period (or close to it)	2	4.3%
Yes, it is a waiting period until the next open window	13	28.3%
No	7	15.2%
Not sure, it hasn’t come up	4	8.7%

5. Does your company allow insiders to voluntarily terminate a Rule 10b5-1 plan?

	Answer	Responses	Percent
	Yes	38	86.4%
	No, only terminations dictated by the trading plan are allowed	6	13.6%

6. Does your company make public disclosure of the insiders’ Rule 10b5-1 trading plans?

Answer	Responses	Percent
Yes, but only for directors and/or one or more officers	9	20.0%
Yes, for all directors and employees	1	2.2%
No	35	77.8%

7. If your company makes public disclosure, how does it do it?