Survey Results: More on Blackout Periods
| Every few years, we survey the practices
relating to blackout and window periods (last done in 2008).
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=93)
(select only one)
|
| n=63 (67.74%) |
Regularly before, at, and right after the end of each
quarter |
| n=16 (17.20%) |
Only in rare circumstances |
| n=14 (15.05%) |
Never |
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=94)
(select only one)
|
| n=30 (31.91%) |
Yes, but they must preclear the gift first |
| n=9 (9.57%) |
Yes, and they don’t need to preclear the gift |
| n=31 (32.98%) |
No |
| n=24 (25.53%) |
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=94)
(select only one) |
| n=23 (24.47%) |
Yes, but they must preclear the gift first |
| n=8 (8.51%) |
Yes, and they don’t need to preclear the gift |
| n=31 (32.98%) |
No |
| n=32 (34.04%) |
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=94)
(select only
one) |
| n=91 (96.81%) |
Yes |
| n=3 (3.19%) |
No |
Our company’s insider trading policy defines those
employees subject to a blackout period by roughly:(Total
responses: n=94)
(select only one)
|
| n=1 (1.06%) |
Stating that all Section 16 officers are subject to
blackout |
| n=10 (10.64%) |
Stating that all Section 16 officers “and those
employees privy to financial information” are subject to
blackout |
| n=26 (27.66%) |
Stating that all Section 16 officers “and others as
designated by the company” are subject to blackout |
| n=39 (41.49%) |
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=13 (13.83%) |
All employees |
| n=5 (5.32%) |
Some other definition |
| n=0 (0.00%) |
Our company doesn’t have an insider trading policy
|
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