Insider Trading Policy
Rules and procedures governing the trading of company securities by directors, officers, and employees.
Maintaining Market Integrity
This Insider Trading Policy is designed to prevent insider trading and to avoid even the appearance of improper conduct by directors, officers, employees, and other persons associated with Tacit Logistics.
What is Material Nonpublic Information?
Material nonpublic information is information that has not been disclosed to the public and that a reasonable investor would consider important in making an investment decision. Examples include:
- Financial results or forecasts
- Major contracts or business developments
- Merger and acquisition activities
- Changes in senior management
- Significant legal proceedings
- Major strategic initiatives
Trading Restrictions
Prohibited Activities
- Trading company securities while in possession of material nonpublic information
- Sharing material nonpublic information with others ("tipping")
- Trading securities of other companies based on material nonpublic information obtained through your position
- Short selling of company securities
Blackout Periods
Certain individuals may be subject to blackout periods during which they cannot trade company securities. These typically occur:
- Prior to earnings announcements
- During major corporate events
- When material information is pending disclosure
Pre-Clearance Requirements
Directors, officers, and certain designated employees must obtain pre-clearance before trading company securities. Contact the Legal Department at legal@tacitlogistics.com for pre-clearance procedures.
Consequences of Violations
Violations of this policy may result in severe consequences, including:
- Disciplinary action, up to and including termination
- Civil penalties imposed by the SEC
- Criminal prosecution
- Disgorgement of profits and additional fines