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Insider Trading Policy

Effective Date: 14/02/2025

1. Purpose

ZenithWave Capital Limited is committed to upholding the highest standards of integrity and transparency in financial trading. This Insider Trading Policy aims to prevent illegal trading activities and protect the company’s reputation by ensuring that employees, contractors, and trainees do not misuse material, non-public information (MNPI).

2. Scope

This policy applies to:

  • All employees, contractors, and partners of ZenithWave Capital Limited.
  • Traders and students who receive proprietary funding from the company.
  • Any person with access to non-public trading or financial information.

3. Definitions

  • Material Non-Public Information (MNPI): Any confidential financial or trading-related data that, if made public, could influence market prices.
  • Insider Trading: Buying or selling securities based on MNPI.
  • Tipping: Sharing MNPI with someone who might trade on it.

4. Prohibited Activities

  • Employees, contractors, or traders must not trade based on MNPI.
  • Sharing MNPI with third parties (e.g., family, friends) is strictly prohibited.
  • Engaging in market manipulation or false trading practices is a violation of this policy.

5. Compliance & Monitoring

  • The company reserves the right to monitor trades and accounts.
  • Any suspicious activity must be reported to the Compliance Officer immediately.
  • Violation of this policy may lead to termination and legal action.

6. Reporting Violations

Any suspected violations must be reported to support@zenithwavecapital.com or through the company’s whistleblower process.