Freddie Mac's Compliance & Ethics team is in the process of identifying potential enhancements to our trade monitoring program and its associated controls and would like to request input on what member companies (primarily in the financial and IT sectors) are doing in this space. Specifically, we'd like to inquire about processes you've implemented around the identification of employees and other personnel (contingent workers, contractors, board members, etc.) who are subject to trade monitoring, pre-clearance and related training, as well as the role their access to MNPI plays. A response is appreciated by Wednesday, August 31st.
Benchmarking Survey questions:
We'd also like to follow-up directly (and briefly-- five minutes, tops!) with any respondents to make sure that we are comparing apples and apples. Thank you in advance for your time and collaboration!
April JohnsonCompliance & Ethics Sr ManagerFreddie Macapril_johnson@freddiemac.com