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? (Total responses: n=35)
(select only one)
n=0 (0.00%) Yes, insiders are required to use Rule 10b5-1 plans in order to sell shares
n=11 (31.43%) No, but they are strongly encouraged
n=24 (68.57%) No, and they are not explicitly encouraged
n=0 (0.00%) Not sure, it hasn't come up

2. Does your company review and approve each insider's Rule 10b5-1 trading plan? (Total responses: n=34)
(select only one)
n=31 (91.18%) Yes, it is subject to prior review and approval by the company pursuant to the insider trading policy
n=2 (5.88%) Yes, but only the template plan is reviewed and not the actual trading schedule
n=0 (0.00%) No, but we have a broker that we require to be used and have reviewed that brokers template
n=1 (2.94%) No, and there is no requirement to go through a specific broker

3. Does your company allow sales of shares through Rule 10b5-1 trading plans during blackout periods? (Total responses: n=35)
(select only one)
n=32 (91.43%) Yes
n=1 (2.86%) No
n=2 (5.71%) Not sure, it hasn't come up

4. Does your company require a waiting period between execution of Rule 10b5-1 trading plans and time of first sale? (Total responses: n=34)
(select only one)
n=5 (14.71%) Yes, it is a two week waiting period or less
n=15 (44.12%) Yes, it is a one month waiting period (or close to it)
n=4 (11.76%) Yes, it is a two month waiting period (or close to it)
n=4 (11.76%) Yes, it is a waiting period until the next open window
n=6 (17.65%) No
n=0 (0.00%) Not sure, it hasn't come up

5. Does your company allow insiders to voluntarily terminate a Rule 10b5-1 plan? (Total responses: n=33)
(select only one)
n=27 (81.82%) Yes
n=6 (18.18%) No, only terminations dictated by the trading plan are allowed

6. Does your company make public disclosure of the insiders' Rule 10b5-1 trading plans? (Total responses: n=34)
(select only one)
n=5 (14.71%) Yes, but only for directors and/or one or more officers
n=2 (5.88%) Yes, for all directors and employees
n=27 (79.41%) No

7. If your company makes public disclosure, how does it do it? (Total responses: n=12)
(select only one)
n=6 (50.00%) Form 8-K
n=1 (8.33%) Press release
n=1 (8.33%) Website posting
n=1 (8.33%) Combination of above
n=3 (25.00%) Other

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