The guide contains recommended principles and guidelines to help companies and their advisers in retaining control over the flow of confidential information, appropriately restricting staff dealing in the company’s securities and creating a culture of compliance. Specifically, this guide has suggestions on arrangements that companies and their advisors can put in place to more effectively deter insider trading.
Areas covered by the guide include:
1. arrangements for ensuring that confidential information generated and/or received remains confidential until it is reasonably expected to be disclosed under the relevant laws, regulations and the Listing Rules;
2. how to minimise the risks of accidental leakage of confidential information;
3. characteristics of effective trading restrictions on dealings in securities; and
4. how to promote strong awareness of the importance of appropriate handling and control of confidential information.
Examples are included to illustrate how the principles and guidelines can be put into practice. The guide is not meant to be prescriptive or exhaustive, and needs to be customised to each company’s unique profile and circumstances.
“Insider trading is hard to detect and prosecute as the leakage of inside information occurs covertly in private, off the exchange; the preemptive approach is we believe, the best way to deal with this risk. Our partnership with industry participants on this guide is similar to how we worked with member firms on the Trade Surveillance Handbook and Members’ Surveillance Dashboard. We look forward to more collaborative efforts with the whole eco-system to take the fight against market misconduct further upstream,” said Tan Boon Gin, CEO of Singapore Exchange Regulation (SGX RegCo).