What Researchers Need To Know About HHS’ New Insider and Personal Trading Policy
Insider Trading is the trading of a public company‘s stock or other securities by individuals with access to Inside Information about the company. Inside Information includes information about a company which, if known, could have a significant impact on the market value of the company, such as a new business product or innovation, a reorganization, or an acquisition. Trading stocks with Inside Information is against the law.
How do I know if I have Inside Information?
- If you are working on a research study that could lead to a new discovery or product that could influence the price of a stock, this would be considered inside information.
- If you’re not sure about whether the information you have is considered Inside Information, consult the HHS Compliance Monitor, Diana Rozich at email@example.com
What if I have Inside Information?
- Only share that information with only the people that need to know as part of the study (this is already covered in your non-disclosure agreements).
- Don’t own any stock of that company or recommend the stock to anyone.
- Make sure that all the members of your research team know about these rules because they apply to them as well.
What if I have mutual funds or use an investment advisor?
These rules don’t apply if:
- You own mutual funds even if they include shares of a company for which you have Inside Information; or
- Someone else is investing money on your behalf even if your portfolio includes shares of a company for which you have inside information, provided you haven’t directed him or her to invest in that company.
- Training Sessions for Research Administration staff are planned for early 2014, check the website for details. For more information please contact HHS Compliance Monitor, Diana Rozich at firstname.lastname@example.org