An Insider is any Person who, by virtue of his position, is in possession of information or data that has or may have a material effect on a Security or Listed Company which is not available to the public. This shall include the following categories: 1. Members of a Board of Directors and the administrative body in a Listed Company, its Parent Company and Subsidiaries, which have Inside Information which is, directly or indirectly, related to such Listed Company. 2. Employees of other entities who are in possession Inside Information related to a Listed Company or listed Securities. This shall include the Auditor, advisory entities, Credit Rating Agencies, and other entities. 3. Shareholders who are informed by their representatives in the Board of Directors in the Listed Company of the Inside Information they have of such company. 4. Employees of a Licensed Person who have information concerning selling or purchasing a listed Security by a Client. 5. Persons who illegally possess Inside Information of a Listed Company or the trading of listed Security. 6. Any other Person defined as an Insider.