Launching new business workflow: ETP

We played an instrumental role in launching a new service from scratch at one of the largest tech companies in the world with employees in 60 countries.

We managed the full lifecycle, in collaboartion, with Morgan Stanley and Schwab, to build a robust automated 10b5-1 Employe Trading Plan (ETP).

Our work started from employee surveys to understand business requirements, defining the minimum features sets for the launch, working with the engineers to build and test the workflows, and managing the post launch support such as hypercare, education, ticket management, and addition of new features.

So, what is ETP? Should your company offer one? Why do employees enroll in ETP? We can help you answer all those questions. And if you do choose to move forward with its implementation, let our steady experienced hands guide you into a smooth and cost-effective implementation.

In the meantime, here is a free primer on ETP:

10b5-1 Employee Trading Plan (ETP) Primer:

Managing executive and employee equity diversification shouldn’t depend on legacy paper forms, manual legal reviews, and fragmented blackout calendars.

The Automated 10b5-1 Employee Trading Plan (ETP) transforms SEC Rule 10b5-1 compliance into a frictionless, digitally integrated workflow—allowing participants to adopt plans online in minutes rather than weeks.

What is an ETP 10b5-1?

An Employee Trading Plan (ETP) is a streamlined, digital execution of an SEC Rule 10b5-1 trading plan. It enables employees and insiders to set up automated, pre-scheduled sales of employer-issued stock.

When adopted in good faith before becoming aware of Material Non-Public Information (MNPI), the plan provides affirmative defense against insider trading allegations—protecting both your workforce and your brand’s market reputation.

(Specific policies and nuances are customized on top of this basic framework to align with your corporate equity structure and regulatory requirements.)

Simplified Execution

To maintain operational efficiency at scale, ETPs streamline execution into two core order types:

1. Sell as Vested: Automatically sell shares at Volume-Weighted Average Price (VWAP) as grants vest during the active ETP trading period.
2. Sell Existing Holdings: Automatically sell previously held shares at market price according to a predetermined schedule. Limit and Stop Loss orders are also available but offering them can add operational and administrative burden in addition to friction in the participant experience.

Modernizing Compliance: Paper Plans vs. Digital ETP

Transitioning senior executives and corporate insiders from manual, paper-based 10b5-1 plans to an automated digital workflow eliminates significant administrative bottlenecks.

Capability & Metrics	Legacy Paper-Based 10b5-1 Plans	Automated Digital ETP Platform
Setup Time	Several weeks of manual drafting and legal reviews.	Under 10 minutes via guided online workflows.
Administrative Burden	High; extremely tedious to manage and track.	Minimal; automated rule-checking and pre-approved logic.
Reporting & Visibility	Static, fragmented tracking.	Real-time reporting dashboards for participants and admins.
Participation Rates	Less than 1% of employees; restricted to C-Suite due to operational friction.	10-11% of employees; simple user experience encourages broader insider adoption.

Why Scale 10b5-1 Protection to majority of employees?

While migrating Officers and Directors to a digital ETP is an immediate quick win, the true strategic power of an ETP lies in democratizing access across your entire organization.

In modern technology enterprises, exposure to sensitive IP, product roadmaps, or preliminary financials isn’t restricted to executive suites. Product managers, senior engineers, and sales leaders regularly handle MNPI. Because digital ETPs are pre-cleared by corporate legal, they can be deployed at scale without increasing administrative overhead.

Why Employees Participate in ETP?

• Affirmative Defense: Trade safely without worrying about insider trading exposure.
• Bypass Blackout Windows: Execute pre-scheduled transactions continuously, avoiding quarterly trading lockouts.
• Systematic Diversification: Reduce personal financial risk by converting employer equity into cash on a predictable timetable to cover living expenses or investment goals.

Is Your Enterprise Ready for a Scaled ETP Rollout?

Ask yourself these four key questions:

1.Broad Equity Distribution:

Does your company compensate a large percentage of its workforce with publicly traded stock?

2.Significant Wealth Allocation:

Does equity compensation represent a substantial portion of your employees’ overall income or net worth?

3.Frequent Blackout Periods:

Does your corporate policy enforce quarterly blackout windows across most or all employees?

4.Routine MNPI Exposure:

Are majority of employees regularly exposed to sensitive IP, financial data, or material non-public information?

If you answered “Yes” to these questions, implementing an automated Employee Trading Plan will significantly strengthen your corporate governance while enhancing the value of your equity compensation program.

Scale Your Insider Compliance Framework

Safeguard your corporate reputation, eliminate administrative friction, and streamline equity liquidity for your global workforce.

Reach out to us to learn about our capabilities in launching new services and workflows