The Quant Foundry Insider Trading Policy provides guidelines to all employees on trading of other publicly-traded companies while in possession of material non-public information.
The policy applies to all Quant Foundry employees who have access to financial and other highly sensitive information regarding the Company’s business.
Penalties for trading on or communicating material non-public information is severe, both for individuals involved in such unlawful conduct and Quant Foundry managing directors. Sanctions may include jail terms, criminal fines, civil penalties and civil enforcement injunctions. Given the severity of the potential penalties, compliance with this Policy is mandatory.
A person who tips others may also be liable for transactions by the tippees to whom he or she has disclosed material non-public information. Tippers can be subject to the same penalties and sanctions as the tippees.
Quant Foundry requires all employees to declare any holding of an existing or potential client that they have direct control of or are in a restricted stock vestment scheme such as those founding with banking clients.
Quant Foundry records all stock holdings on a central record and restricts the employee from subsequent buying and selling. The managing directors lift the restriction after the employee has completed their Quant Foundry engagement with the client.
Insider trading is part of the code of conduct that all Quant Foundry employees must adhere. For all potential exceptions to this policy, the employee must escalate the details to either managing director of Quant Foundry for specific signoff. The signoff is not available to post-event.
Quant Foundry covers Market abuse and insider trading in adherence to the following regulation: Regulation (EU) 596/2014 of the European Parliament and of the Council of 16 April 2014 on market abuse, which repealed Directive 2003/6/EC of the European Parliament and of the Council and Commission Directives 2003/124/EC, 2003/125/EC and 2004/72/EC (“Market Abuse Regulation” or “MAR”).
Insider trading is a criminal offence. No amount of financial return will compensate for having a criminal record.