Survey Results: More on Blackout Periods
In the summer of 2004, we conducted a
survey about blackout and window periods. The questions
below supplement the results
of that survey. Please select one answer that applies to
each question.
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Does your company ever impose a "blanket blackout period"
for all or a large group of employees? (Total
responses: n=70)
(select only one) |
n=49 (70.00%) |
Regularly before, at, and right after the end of each
quarter |
n=9 (12.86%) |
Only in rare circumstances |
n=12 (17.14%) |
Never |
Our company's insider trading policy defines those
employees subject to a blackout period by roughly: (Total
responses: n=69)
(select only one) |
n=2 (2.90%) |
Stating that all Section 16 officers are subject to
blackout |
n=8 (11.59%) |
Stating that all Section 16 officers 'and those
employees privy to financial information' are subject to
blackout |
n=19 (27.54%) |
Stating that all Section 16 officers 'and others as
designated by the company' are subject to blackout |
n=24 (34.78%) |
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=8 (11.59%) |
All employees |
n=8 (11.59%) |
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=69)
(select only one) |
n=19 (27.54%) |
Yes, but they must preclear the gift first |
n=6 (8.70%) |
Yes, and they don't need to preclear the gift |
n=18 (26.09%) |
No |
n=26 (37.68%) |
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=68)
(select only one) |
n=22 (32.35%) |
Yes, but they must preclear the gift first |
n=6 (8.82%) |
Yes, and they don't need to preclear the gift |
n=13 (19.12%) |
No |
n=27 (39.71%) |
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=69)
(select only one) |
n=68 (98.55%) |
Yes |
n=1 (1.45%) |
No |
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