Zororium Insider Trading Policy
Effective Date: October 30, 2023


1. Purpose


The purpose of this Insider Trading Policy (‘Policy’) is to establish guidelines for the treatment and restricted use of Nonpublic Material Information related to Zororium and its affiliated and subsidiary entities (the ‘Zororium Ecosystem’). This Policy aims to safeguard confidential and price-sensitive information, ensuring the transparency of the Zororium token (ZRT) market, and maintaining fairness for all participants.


2. Scope


This Policy applies to all individuals associated with the Zororium Ecosystem (referred to as ‘Associates’) and shall remain in effect throughout their employment or association with the Zororium Ecosystem. The Policy is also specifically applicable to Associates who may receive ZRT tokens from the Zororium Ecosystem through any distribution scheme.


The Zororium Ecosystem has implemented this Policy to ensure compliance with relevant laws and to prevent insider trading by its Associates. The Zororium Ecosystem’s legal team is responsible for the enforcement, interpretation, and implementation of this Policy, as well as reporting any breaches or matters that may result in criminal actions taken against the individuals involved. Any inquiries regarding this Policy should be directed to the Zororium Ecosystem’s legal team.


The Zororium Ecosystem expects strict adherence to this Policy by all Associates. Failure to comply with the requirements of this Policy may lead to severe legal consequences, including criminal fines and civil penalties. Violations of this Policy may also result in disciplinary actions, including the termination of employment or association with the Zororium Ecosystem, as deemed appropriate at the Zororium Ecosystem’s sole discretion.


3. Definitions


  • Associates: All directors, officers, employees, consultants, contractors, and their Related Persons.


  • Zororium Token (ZRT): The digital token issued by Zororium.


  • Material Information: Information that a reasonable individual would consider important for making a decision to buy or sell ZORO tokens. Material Information can relate to any aspect of Zororium’s business, including but not limited to changes in prospects, partnerships, projects, assets, earnings, management, or any agreements.


  • Nonpublic: Information that has not been disclosed to the public. Nonpublic information may include facts subject to rumors, information entrusted to the Zororium Ecosystem on a confidential basis, or information not disclosed for at least one day after becoming known.


  • Related Person: Individuals and entities closely associated with an Associate, as defined within the Policy.


  • Tokens: Refers to ZORO tokens and any other digital tokens issued by the Zororium Ecosystem in the future.


4. Restrictions and Prohibited Transactions


Participating in the following transactions is strictly prohibited, regardless of whether a gain or loss is incurred:


4.1. Insider Trading Restrictions


  • Trading on Nonpublic Material Information: Associates with access to Nonpublic Material Information about the Zororium Ecosystem or $ZRT tokens may not purchase, sell, or recommend the purchase or sale of tokens until one full day has passed since the public disclosure of that Material Information.


  • Tipping: Associates may not disclose Nonpublic Material Information to others who could buy or sell tokens. Tipping such information can also result in liabilities for the Associate, even if they did not personally benefit from the transaction.


  • Information about Other Companies: Associates must not purchase or sell tokens or securities of other companies while in possession of Nonpublic Material Information about those companies.


5. Trading Blackouts


In specific circumstances, the Zororium Ecosystem may impose a ban on the purchase or trading of tokens due to particular events or during specific timeframes, leading to the temporary locking of Associate accounts. Affected Associates will be notified of blackout periods, which will be managed by the Zororium Ecosystem’s Senior Personnel.


6. Permitted Token Transactions


Subject to the Insider Trading Restrictions in section 4.1 above, the following transactions are permitted on Zororium platforms:


  1. Purchase of ZORO tokens during predetermined periods for fixed prices (if applicable).
  2. Associates shall ensure that they do not hold excessive numbers of tokens in their Zororium wallets, which may be set by the Zororium Ecosystem.


7. Monitoring and Compliance with This Policy


All Associates are required to disclose their user IDs for any Zororium-owned platforms. The Zororium Ecosystem will periodically monitor Associate accounts. Breaches of this Policy may result in disciplinary proceedings, including account blocking and token confiscation.


8. Exceptions


The restrictions outlined in this Policy do not apply when the Zororium Ecosystem issues specific guidelines and instructions regarding token trading in accordance with any token distribution scheme or related document following the distribution of tokens to employees and Associates.


9. Trading Orders


Associates may establish written orders with authorized exchanges for the automatic trading of tokens, provided that these trading plans do not conflict with blackout periods and adhere to the Insider Trading Restrictions in Section 4.1 above.


10. Protecting Confidential Information


All Associates are expected to treat nonpublic Material Information regarding the Zororium Ecosystem as sensitive and confidential. They must avoid disclosing such information to third parties without a legitimate need for it. Conversations should be conducted discreetly, and confidential documents should be secured. Inquiries from the press or public should be referred to designated individuals within the Zororium Ecosystem.


Queries related to this Policy should be directed to the Zororium Ecosystem’s legal department at [email protected].