Insider Trading Policy

C.1. All Directors, Officers, Employees, and Consultants handling ARTHALAND securities or its subsidiaries; including their family members, anyone else who lives with them, and any entities that is controlled or influenced by the Director, Officer, Employee, or Consultant; should not be allowed to trade in the securities of ARTHALAND, or in the securities of other companies, such as customers or suppliers or companies with which ARTHALAND may be negotiating for major transactions, such as an acquisition, investment or sale; if the Director, Officer, Employee and Consultant is aware of material non-public information relating to ARTHALAND.


Trading includes purchases and sales of stock, derivative securities such as put and call options, convertible debentures and stocks, and debt securities. The trading restrictions generally do not apply to the exercise of a stock option or to the vesting of restricted stock or restricted stock unit awards. However, it will apply to any sale of the underlying stock or to a cashless exercise of the option through a broker or any sale of restricted stock to a third party.


C.2. Information is material if there is a substantial likelihood that a reasonable investor would consider it important in deciding whether to buy, hold or sell a security. Any information that could reasonably be expected to affect the price of the security is material. Both positive and negative information can be material. Depending on circumstances, the following may constitute material information:


Conflicts of interest may arise in the relations of Directors, Officers, and Employees with any of the following third parties:

  • a. Projections of future earnings or losses, or other earnings guidance;
  • b. Earnings or operating results that are inconsistent with the consensus expectations of the investment community;
  • c. A pending or proposed merger, acquisition or tender offer or an acquisition or disposition of significant assets;
  • d. A change in senior management;
  • e. Major events regarding ARTHALAND’s securities, including the declaration of a stock split or the offering of additional securities;
  • f. Severe financial liquidity problems;
  • g. Actual or threatened major litigation, or the resolution of such litigation;
  • h. The acquisition or license of products;
  • i. New major contracts, orders, suppliers, customers, partners or finance sources, or the loss thereof;
  • j. The introduction or a change in status of significant new products;
  • k. A change in auditors or notification that the auditor’s reports may no longer be relied upon; and
  • l. The imposition of a ban on trading in ARTHALAND securities or the securities of subsidiaries.


C.3. Non-public information is information that is not generally known or available to the public. Information is considered to be available to the public only when it has been released broadly to the market place, such as by a press release or an SEC filing and the investing public has had time to absorb the information fully.


C.4. All Directors, Officers, Employees, and Consultants should treat all information they learn about ARTHALAND or its business plans in connection with their employment/agreement as confidential and proprietary to ARTHALAND.


The timing and nature of ARTHALAND’s disclosure of material information to outsiders is subject to legal rules. Accordingly, it is important that responses to inquiries about ARTHALAND by the press, investment analysts or others in the financial community should be made on ARTHALAND’s behalf only through authorized individuals. In addition, Directors, Officers, Employees, and Consultants are prohibited at all times from posting any information about ARTHALAND, its products, its customers, its potential customers or its competitors, as well as any other material, non-public information, in any internet discussion group.


C.5. All questions about this policy or its application to any proposed transaction, can be obtained from the President & CEO and/or the Compliance Officer. All determinations and interpretations by them should be final and not subject to further review.


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