its simply a formalisation of policy which the law requires any company to have.
Even if they didn't have this policy documented any buy/sell transaction which contravened the policy would still need action by regulator/bod. I guess if anything, the junior staff members would now be excluded from buying during blackout period, only because FAR hire so few that information or conversations could be heard by junior staff moreso than larger organisations. Good or bad info I may add.;
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Ann: Securities Trading Policy, page-7
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