Insider Trading, Blackouts and Quiet PeriodsAccording to the TMX Equicom Website:
"Trading Restrictions and Blackout Periods Insiders and employees with knowledge of confidential material information about the Company or counter-parties in negotiations of potentially material transactions are prohibited from trading securities of the Company or any counter-party until the information has been fully disclosed and a reasonable period has passed for the information to be widely disseminated. Quarterly trading blackout periods will apply to all insiders and employees during periods when financial statements are being prepared but results have not yet been publicly disclosed. Quarterly trading blackouts will commence the earlier of the first day following the end of a quarter or when preliminary financial statements for the quarter are available, and will end on the second day following the disclosing of quarterly financial results. Blackout periods may be prescribed from time to time by the Committee as a result of special circumstances relating to the Company when insiders would be precluded from trading in its securities. All parties with knowledge of such special circumstances should be covered by the blackout. These parties may include external advisors such as legal counsel, investment bankers, investor relations consultants and other professional advisors, and counter-parties in negotiations of material potential transactions. To protect the reputation of the Company and avoid the appearance of impropriety, all directors, officers and other insiders are required to preclear all proposed trades in the Company’s securities (including the exercise of stock options) with the Corporate Secretary or other designated officer of the Company. Quiet Periods To avoid the potential for selective disclosure or even the perception or appearance of selective disclosure, the Company will observe quiet periods prior to quarterly earnings announcements or when material changes are pending. Regular quiet periods will commence on the first day following the end of a quarter and end with disclosing results for the quarter just ended. During a quiet period, the Company will not initiate any meetings or telephone contacts with analysts and investors, but will respond to unsolicited inquiries concerning factual matters. If the Company is invited to participate, during a quiet period, in investment meetings or conferences organized by others, the Committee will determine, on a case-by-case basis, if it is advisable to accept these invitations. If accepted, extreme caution will be exercised to avoid selective disclosure of any material, non-public information. A key phrase in this definition is “case-by-case.” At Equicom, we find that if issuers are too rigid in how they enforce their quiet periods, they risk really limiting the opportunities for increasing visibility with the investment community, in particular at investment dealer conferences. If you determine it is advisable to attend an event, management should take ample precautions. The best way to ensure compliance is to prepare, prepare, and prepare. Prepare speaking points and a thorough Q&A document so management is well-versed in what can and can’t be disclosed. And of course, management should feel free to decline certain questions with the simple explanation that the company is currently in a quiet period."