Insider trading approaches: Bank of Russia review
The Bank of Russia has analysed requirements employed by Russian and foreign companies to insiders’ transactions with financial instruments. Market participants may use the summary of these approaches presented in the regulator’s review as a guideline for their own rules for insider transactions.
The law prescribes companies to set up such rules, and compliance with them may protect insiders against allegations of misuse of insider information. However, there do not exist any requirements for the form and content of the conditions of insider transactions, organisations operate at their own discretion.
The regulator has studied the documents where companies determine these conditions, persons covered by them, the list of instruments, transactions with which are permitted to insiders without limitations and vice versa, and so on. Practices listed in the review may be used by insiders on a stand-alone basis or in aggregate, considering the specifics of their activity and the nature of insider information, which will help to more efficiently counter illegal insider operations and manipulation.
Irrespective of the approach selected, companies are also recommended to protect information received from insiders and related parties in connection with fulfilling the conditions of transactions.