Below is a list of pre-emptive actions you can take to prevent the firm’s exposure to Insider Trading:
1. Annual Investment Adviser Representative attestations of the Code of Ethics, Compliance Manual, Outside Business Activities;
2. Thorough review of quarterly personal securities transaction reports;
3. Use of restricted securities lists, when appropriate;
4. Ongoing employee training; and
5. Clear and concise policies and procedures that are enforced equally across the firm.