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 |
|
