RE:RE:RE:RE:RE:RE:RE:Huge ADC dealMannequin wrote: The blackout and extensions has to be that simple. There are deals on the table that 'if' this works, then said partner will 'insert here'. That is insider knowledge knowing a deal will happen if something happens. You can't trade.
Outside of THTX's code of ethics, I cannot find their specific insider trading policy. The Code of Ethics, however, does prohibit trading before one full business day after a press release.
From an example policy on SEC.gov.
| What is material inside information? |
Courts define “material inside information” as information which, if known, could reasonably be expected to affect the value of the Company’s stock, or which would affect the investment judgment of a person making a decision to buy or sell the stock. Information is considered “material” if there is a substantial likelihood that it would be considered important by a reasonable investor in deciding whether to purchase or sell stock, or other securities, or if the information would be viewed by the reasonable investor as having significantly altered the total mix of information available to the investor before making the purchase or sale. The information need not be the determining factor, but must assume actual significance in the investor’s deliberations. Examples of inside information include:
| | - | a material change in anticipated earnings (up or down); |
| | - | proposed public or private offerings of securities; |
| | - | loan defaults; |
| | - | pending or proposed mergers, acquisitions, joint ventures, or sales of significant assets or other strategic plans; |
| | - | regulatory approvals, patent registrations or issuances, investigations, etc.; |
| | - | a proposed offering or issuance of new securities; |
| | - | the occurrence of, or important developments in, major disputes, claims or significant litigation (whether or not meritorious); |
| | - | a change in management; |
| | - | new product announcements; and |
| | - | the gain or loss of significant customers, suppliers or business partners. |
Material inside information can be either positive or negative.
Information is “nonpublic” if it has not been disclosed to the public generally. For information to be considered public, there should be some evidence that it has been widely disseminated and that the investing public has had time to absorb the information. You should generally consider information nonpublic until after the second business day after the information is publicly released, such as by press release or widely circulated public disclosure documents filed with the SEC, such as prospectuses or 10-K, 10-Q or 8-K reports. For example, if information is disclosed via press release on a Monday, it can be considered public beginning that Thursday.
Please keep in mind that your transactions in the Company’s stock may be viewed “after the fact” with the full benefit of hindsight. If you have any questions whether certain information is material or has not been publicly disclosed, please call the Company’s Chief Financial Officer.