09-04-2015, 10:27 AM
I think an important point is being missed ===> Rule 10b5-1 Trading Plans are allowed by law and as such are allowed by IOC. They can be initiated during any open window. Surely the window has been open more than once in the past 2+ years.
QUOTE
At page 7, it states: 'In addition, the Company has imposed a blackout applying to all Covered Persons while any appraisal or exploration drilling program is being conducted by the Company. During such a blackout period a Covered Person is prohibited from undertaking any sale, purchase or other transactions of any kind in Company securities (other than those in which the Company is the buyer or seller for its own account or transactions made pursuant to an approved, RULE 10b5-1 TRADING PLAN as described above). The Compensation Committee may grant an exception to this prohibition on a case-by-case basis in the circumstances described under “Hardship and Special Circumstances Cases” above.'
EMD QUOTE
"Getting Back to Basics with Rule 10b5-1 Trading Plans"
http://www.skadden.com/insights/getting-...ding-plans
RULE 10b5-1
Rule 10b5-1 was adopted by the SEC in 2000 to provide affirmative defenses to the assertion that a purchase or sale of a security was made on the basis of material nonpublic information about the security or its issuer. The rule generally allows individuals or entities to enter into a prearranged plan for future stock trades. The plan must be entered into in good faith when the person or entity does not possess material nonpublic information about the subject security.
Rule 10b5-1 plans are most commonly used by executives of publicly traded issuers, or the issuers themselves, who are likely to have only limited windows in which they do not possess material nonpublic information. Rule 10b5-1 plans must include instructions with respect to the amount, price and date for the planned transactions (or give discretion to a broker to determine when to purchase or sell, provided the broker does not possess material nonpublic information). To benefit from the affirmative defense provided by Rule 10b5-1, the trades must be made in accordance with the plan instructions, without hedging transactions.
QUOTE
At page 7, it states: 'In addition, the Company has imposed a blackout applying to all Covered Persons while any appraisal or exploration drilling program is being conducted by the Company. During such a blackout period a Covered Person is prohibited from undertaking any sale, purchase or other transactions of any kind in Company securities (other than those in which the Company is the buyer or seller for its own account or transactions made pursuant to an approved, RULE 10b5-1 TRADING PLAN as described above). The Compensation Committee may grant an exception to this prohibition on a case-by-case basis in the circumstances described under “Hardship and Special Circumstances Cases” above.'
EMD QUOTE
"Getting Back to Basics with Rule 10b5-1 Trading Plans"
http://www.skadden.com/insights/getting-...ding-plans
RULE 10b5-1
Rule 10b5-1 was adopted by the SEC in 2000 to provide affirmative defenses to the assertion that a purchase or sale of a security was made on the basis of material nonpublic information about the security or its issuer. The rule generally allows individuals or entities to enter into a prearranged plan for future stock trades. The plan must be entered into in good faith when the person or entity does not possess material nonpublic information about the subject security.
Rule 10b5-1 plans are most commonly used by executives of publicly traded issuers, or the issuers themselves, who are likely to have only limited windows in which they do not possess material nonpublic information. Rule 10b5-1 plans must include instructions with respect to the amount, price and date for the planned transactions (or give discretion to a broker to determine when to purchase or sell, provided the broker does not possess material nonpublic information). To benefit from the affirmative defense provided by Rule 10b5-1, the trades must be made in accordance with the plan instructions, without hedging transactions.
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