​Insider Trading

          Employees can invest in securities issued by customers, the Bank, or other listed companies, and stock futures wherein no insider information or conflicts of interest are involved. Employees are required to comply with our “Guidelines for Trading in Securities and Stock Futures”. To ensure fairness and integrity within financial markets, the buying or selling of securities is not permitted at any time by any employee who possesses material or price-sensitive information not available to the public vis-à-vis those securities. Material information is any information that an investor would reasonably consider important to making investment decisions. Examples would include knowledge of acquisitions or divestitures, new product launches, or other financial information. Insider information about the Bank must not be communicated without a legitimate business reason and proper management authorization. Employees having knowledge of, or having an opportunity to access the Bank inside information can buy, sell, or transfer securities, or accept transferred securities issued by the Bank, or invest in stock futures linked to the Bank common shares only within specific timeframes. Such employees must report such transactions to the Bank in compliance with the Bank “Guidelines for Trading in Securities and Stock Futures”. Employees are not permitted to borrow funds from the Bank for use in personal trading or speculative dealing.​