Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / insider-trading-policy-draft.docx
insider-trading-policy-draft.docx
Parties
Harkness LLP
Lumos Analytics Inc
Purpose Lumos Analytics Inc
Equity Inc
Brindoval Data Centers LLC
Nordwell Financial Technologies Inc
Howe LLP
Pinnacle Securities LLC
Dates
December 31, 2021
Amounts
$0.0001
$5,000,000
$25,000,000
$1,000,000
$4.82
$187.4
$206.8
Obligations
Materiality must be assessed at the time of the trading decision, not with the benefit of hindsight
4 — "Compliance Officer" The Company's General Counsel and Corporate Secretary, Naomi Feinberg, shall serve as the "Compliance Officer" for purposes of this Policy
The Compliance Officer shall have primary responsibility for the interpretation, implementation, and enforcement of this Policy, and shall serve as the principal point of contact for all Covered Persons regarding questions about the Policy and its application
In the absence or unavailability of the Compliance Officer (due to recusal, vacation, illness, or any other reason), the Chief Financial Officer, David Lau, shall serve as the alternate Compliance Officer and shall have full authority to act in the Compliance Officer's stead for all purposes under this Policy
The Compliance Officer shall maintain a current list of all Designated Insiders and shall notify each person in writing upon their designation
Brindoval Data Centers LLC, or any other customer, vendor, partner, or potential acquisition target must not trade in the securities of those companies, and must not tip such information to any other person