This Insider Trading Policy establishes the rules and guidelines for Primax clients engaged in cryptocurrency trading. The purpose of this Policy is to prevent the unlawful use of insider information in trading activities, to maintain market integrity, and to protect the interests of all clients.
Prohibition on the Use of Insider Information and Market Manipulation
Federal Law No. 224-FZ “On Countering the Unlawful Use of Insider Information and Market Manipulation and on Amendments to Certain Legislative Acts of the Russian Federation” (hereinafter – Federal Law 224-FZ) prohibits actions involving financial instruments, foreign currency, and/or commodities admitted to trading on organized markets in the Russian Federation, or in respect of which an application for admission to trading has been submitted, as well as financial instruments whose prices depend on such assets. This prohibition extends to actions constituting market manipulation.
Insider Trading: The purchase or sale of securities in violation of fiduciary duties or other relationships of trust and confidentiality while in possession of material, non-public information regarding a security.
Insider Information: Material, non-public information about a company or security that could potentially affect the price of the security once it becomes public.
Our company strictly prohibits insider trading by any client. Clients must conduct all cryptocurrency transactions based solely on publicly available information and must refrain from using undisclosed, material, non-public information in their trading decisions. Clients engaging in insider trading will be subject to disciplinary measures, which may include account suspension or termination.
• Clients must not engage in the following activities:
• Trading cryptocurrencies based on material, non-public information;
• Disclosing material, non-public information to others for trading purposes;
• Misusing client funds or information for personal purposes.
Clients are required to adhere to this Insider Trading Policy at all times. Our platform may monitor trading activities and conduct periodic reviews to ensure compliance. Clients who violate this Policy will be subject to disciplinary actions determined by the company.
Clients must maintain the confidentiality of any material, non-public information obtained through our brokerage firm. Clients are strictly prohibited from sharing such information with others or using it for personal gain. Failure to comply with confidentiality obligations may result in account suspension or closure.
Clients who suspect or become aware of insider trading must immediately report such instances to our Security Team. Clients who fail to report violations may also face disciplinary action for participating in or facilitating insider trading.
Primax is committed to upholding the highest standards of integrity and fairness in the cryptocurrency market. This Insider Trading Policy is designed to prevent the unlawful use of insider information and to maintain a level playing field for all clients. Clients must comply with this Policy and report any violations to help ensure a transparent and ethical trading environment.
We appreciate your cooperation.