Insider Trading & Tipping
Steencore maintains a zero-tolerance position on insider trading and unlawful disclosure of material nonpublic information (MNPI). In alignment with applicable federal and state securities laws, the Company prohibits trading in securities while in possession of MNPI and strictly forbids the direct or indirect communication (“tipping”) of such information to third parties.
This policy applies to directors, officers, employees, designated contractors, advisers, and immediate family members or affiliates who may have access to confidential information. It is designed to prevent both actual violations and the appearance of impropriety, thereby protecting market integrity and institutional trust.
Controls include confidentiality obligations, information-barrier protocols, trading blackout periods where applicable, and escalation procedures for suspected breaches. Non-compliance may result in disciplinary action and referral to regulatory authorities.
Steencore’s framework reflects its broader governance commitment to transparency, regulatory compliance, and the protection of shareholders, lenders, insurers, and counterparties.
Further detail is available in the full Insider Trading Policy (see linked document).
Steencore Group - Insider Trading Policies
