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Survey Results: More on Blackout Periods

Every few years, we survey the practices relating to blackout and window periods (last done in 2012). Here is the latest one:

1. Does your company ever impose a "blanket blackout period" for all or a large group of employees? (select only one)

  Answer Responses Percent  
Regularly before, at, and right after the end of each quarter 57 78.1%
Only in rare circumstances 11 15.1%
Never 5 6.8%
2. Does your company allow employees (that are subject to blackout) to gift stock to a charitable, educational or similar institution during a blackout period? (select only one)
  Answer Responses Percent  
Yes, but they must preclear the gift first 34 46.6%
Yes, and they don’t need to preclear the gift 12 16.4%
No 22 30.1%
Not sure, it hasn’t come up and it’s not addressed in our insider trading policy 5 6.8%
3. Does your company allow employees (that are subject to blackout) to gift stock to a family member during a blackout period? (select only one)
  Answer Responses Percent  
Yes, but they must preclear the gift first 27 37.0%
Yes, and they don’t need to preclear the gift 10 13.7%
No 28 38.4%
Not sure, it hasn’t come up and it’s not addressed in our insider trading policy 8 11.0%
4. Are your company's outside directors covered by blackout or window periods and preclearance requirements? (select only one)
  Answer Responses Percent  
Yes 74 100.0%
No 0 0.0%
5. Our company’s insider trading policy defines those employees subject to a blackout period by roughly: (select only one)
  Answer Responses Percent  
Stating that all Section 16 officers are subject to blackout 2 2.7%
Stating that all Section 16 officers “and those employees privy to financial information” are subject to blackout 3 4.1%
Stating that all Section 16 officers “and others as designated by the company” are subject to blackout 28 37.8%
Stating that all Section 16 officers “and those employees privy to financial information and others as designated by the company” are subject to blackout 26 35.1%
All employees 12 16.2%
Some other definition 3 4.1%
Our company doesn’t have an insider trading policy 0 0.0%

 

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