Insider trading governance practices

This discussion is more relevant for publicly listed entities (whether US or India) and it assumes even more importance for companies having larger ESOP programs. I wanted to know good practices around communicating insider trading governance related matters.

Most of the Insiders are fairly senior people and many of them are in country other than stock listing. So in such a situation, is the governance and communication around insider trading policies and restrictions done centrally or is delegated to country level teams, is central corp comm teams involved in creating those communications, is there a separation in function between teams who govern ESOPs vs teams who look into Insider trading governance? IS HR function involved in anyway to educate new joiners about such obligations during joining formalities?

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