4. RESTRICTIONS AND PROHIBITED TRANSACTIONS
Participating in any of the following transactions is strictly prohibited, irrespective whether the perpetrator makes a subsequent gain or loss after conduction such transactions:
Insider Trading Restrictions
a) Trading on Nonpublic Material Information. Associates in possession of, or aware of, Nonpublic Material Information relating to the Group and/or the Tokens may not purchase or sell (or offer to purchase or sell) Tokens, engage in or encourage a Related Person to purchase, sell or in any way encourage any other action which would take advantage of such Nonpublic Material Information, until after the lapse of one full day following the date of public disclosure of such Material Information.
b) Tipping. Associates may not disclose Nonpublic Material Information to other persons or entities (including Related Persons) that could purchase or sell Tokens. An Associate who tips others may also be liable for transactions done by such ‘tipped’ persons to whom the Associate had disclosed Nonpublic Material Information. Tippers can be subject to the same penalties and sanctions as the ‘tipped’ persons that have executed the transaction, even when the tipper did not profit from the transaction.
c) Information about other Companies. Associates may become aware of Nonpublic Material Information of other companies, separate and distinct from the Group, in the course of their association with the Group. Associates are prohibited from purchasing or selling tokens or securities of other companies while they are in possession of, or aware of, such Nonpublic Material Information and from passing such information on to other persons or entities who could purchase or sell the Tokens or any other instruments of such other companies. This Policy requires Associates to treat Nonpublic Material Information of such companies with the same care required with respect to Nonpublic Material Information related directly to the Group.
i) Additional Prohibited Transactions.
An Associate may not engage in short term or speculative transactions involving Tokens unless such transactions has been notified to the Group as indicated in this Policy.
This Policy also applies to the ‘Pre-order’ and ‘Piggy Bank’ functions on the Socios App.
The restrictions set out in this Policy do not apply in cases where the Group issues dedicated guidelines and instructions in relation to the trading of Tokens pursuant to any token distribution scheme, or similar document, launched by the Group following the distribution of (any) Tokens to employees and/or Associates.
iii) Trading Blackouts
Specific Events. Under certain circumstances, the Group may impose on certain Associates a complete ban on trading Tokens as a result of specific events or during a specific timeframe. Associates affected by such even specific blackouts will be notified with respect to the event specific blackout periods and all such periods will be managed in all respects by the Group’s Senior Personnel.
iv) Pre-Notice Requirement for Trading.
Group Associates must notify the Group prior to any purchase, sale, trade, gift, or other transfer of Tokens other than (a) purchases, sales or trades of Tokens pursuant to a prior notification to the Group; or (b) any transaction described in the exceptions contained above. Such pre-trade notice can be done by sending an email to ‘[email protected]’ indicating clearly the following information concerning the planned transaction:
(i) Nature of transaction (sale, buy, etc.) and forum where such transaction will take place (Socios Platform, third party exchange, or any other platform)
The value of the transaction
Planned date for the transaction (which has to be at least 24 hours after the notice date)
(ii) The Group reserves the right to ask for further clarifications concerning the planned transaction if it deems necessary or completely block the transaction, as the Group may determine in its absolute discretion.
(iii) If the Group does not request further information or restrict the planned transaction within 24 hours from receipt of the email notification mentioned above, Associates must complete the proposed transaction within one week or otherwise submit a new e-mail and follow the notification process all over again.