6.11 Insider Trading Policies and Blackout Periods
Adopt an insider trading policy that provides for a senior officer to approve and monitor the trading activity of your insiders, officers and senior employees. Your inside trading policy should prohibit purchases and sales at any time by insiders and employees who are in procession of material nonpublic information. Your policy should also provide for trading "blackout periods" when trading by insiders, officers and employees may typically not take place.(for example a blackout period which surrounds regularly scheduled earnings announcements.) However, insiders, officers and employees should have the opportunity to apply to the company's trading officer for approval to trade the company's securities during the blackout period. A company blackout period may mirror a quite period described above.
At first blush, I do not see how Interoil could be in a conservative consideration of compliance, as there is no senior officer than the CEO, for definitions of trading officer approval.
Some where there is a legal eagle who knows all the relatives.
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