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Inside Internal Controls

News and discussion on implementing risk management

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insider trading

Apple lawyer charged with insider trading

The recent insider trading case of a former senior lawyer at Apple Inc. serves as a reminder that those tasked with upholding a company’s insider trading rules are expected to ‘walk the walk’ when it comes to complying with ethical and legal obligations in handling confidential information. This case and similar prior cases remind us that counsel and firms ought to be vigilant and take proactive steps to monitor and enforce insider trading programs.

 

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Working together works: Ontario Securities Commission approves reduced sanction for insider tipper who cooperated with investigation

The OSC recently approved a settlement agreement in which the respondent admitted to providing material non-public information to a third party. The order in Re Hutchinson, which did not include an administrative penalty or disgorgement of profits, was held to be in the public interest given the respondent’s cooperation and other mitigating factors.

 

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Ethics and business conduct

The ethical standards of a company are driven from the top. The ethics policy should be recommended by the president, ratified by the board and rolled out to the company with appropriate explanations and training. Implementing and consistently following a top-down ethics policy—with input from all levels—will help employees, customers, stakeholders and others who interact with the company to understand and relate to the company’s intentions.

 

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