Survey Results: Trading Policies for Outside Directors

Our June 2005 survey on blackout practices ended with a question as to whether outside directors were subject to restrictions. The survey below follows up on that theme:

1. Are outside directors at your company subject to restrictions on trading in company securities? (Total responses: n=80)

(select only one)
n=80 (100.00%) Yes
n=0 (0.00%) No

2. If yes, are they subject to the same restrictions as senior management? (Total responses: n=79)
(select only one)
n=74 (93.67%) Yes
n=5 (6.33%) No

3. Are outside directors free to trade at any time when there are no restrictions or must they also preclear their trades (eg. with the compliance or legal department)? (Total responses: n=80)
(select only one)
n=71 (88.75%) Must always preclear
n=5 (6.25%) Only needs to preclear in limited circumstances
n=4 (5.00%) Never needs to preclear

4. If preclearance is required, how long is the preclearance valid? (Total responses: n=76)
(select only one)
n=27 (35.53%) Less than 3 trading days
n=22 (28.95%) 3-5 trading days
n=14 (18.42%) 5-10 trading days
n=13 (17.11%) More than 10 trading days