Survey Results: More on Blackout Periods

Every few years, we survey the practices relating to blackout and window periods (last done in 2005). Here is the latest one:


Does your company ever impose a "blanket blackout period" for all or a large group of employees? (Total responses: n=58)
(select only one)
n=43 (74.14%) Regularly before, at, and right after the end of each quarter
n=10 (17.24%) Only in rare circumstances
n=5 (8.62%) Never

Our company's insider trading policy defines those employees subject to a blackout period by roughly: (Total responses: n=59)
(select only one)
n=4 (6.78%) Stating that all Section 16 officers are subject to blackout
n=3 (5.08%) Stating that all Section 16 officers 'and those employees privy to financial information' are subject to blackout
n=11 (18.64%) Stating that all Section 16 officers and others as designated by the company are subject to blackout
n=28 (47.46%) Stating that all Section 16 officers and those employees privy to financial information and others as designated by the company are subject to blackout
n=3 (5.08%) All employees
n=10 (16.95%) Some other definition
n=0 (0.00%) Our company doesn't have an insider trading policy

Does your company allow employees (that are subject to blackout) to gift stock to a charitable, educational or similar institution during a blackout period? (Total responses: n=59)
(select only one)
n=31 (52.54%) Yes, but they must preclear the gift first
n=5 (8.47%) Yes, and they don't need to preclear the gift
n=12 (20.34%) No
n=11 (18.64%) Not sure, it hasn't come up and it's not addressed in our insider trading policy

Does your company allow employees (that are subject to blackout) to gift stock to a family member during a blackout period? (Total responses: n=58)
(select only one)
n=23 (39.66%) Yes, but they must preclear the gift first
n=5 (8.62%) Yes, and they don't need to preclear the gift
n=14 (24.14%) No
n=16 (27.59%) Not sure, it hasn't come up and it's not addressed in our insider trading policy

Are your company's outside directors covered by blackout or window periods and preclearance requirements? (Total responses: n=58)
(select only one)
n=57 (98.28%) Yes
n=1 (1.72%) No