Insider Trading
Under U.S. securities and other trading laws, we may not trade based on inside information about a company or share that information with anyone else.
“Inside information” is material non-public information. Non-public information is information that has not been made available to the public and that a reasonable person would consider important when making an investment decision. Non-public information is proprietary and confidential.
Trading the company, competitor, or third-party securities while in possession of inside information is considered “insider trading” and is illegal. You also may not share this inside information with someone else, including family members, members of your household or other team members who may use it to buy or sell securities. Follow all trading restrictions and “black-out periods” if they apply given your job responsibilities or position. Exercise caution and avoid even the appearance of anything improper. If you have any questions regarding what is considered inside information or specific stock transactions, contact the Law Department .
Remember, it’s your responsibility to follow the securities trading requirements. It’s always best to ask before you act.
