We are a publicly traded company and therefore we expect you to comply with securities trading laws (also referred to as “insider trading” laws), one of which is keeping non-public information confidential. Non-public information is defined as 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 also referred to as ‘inside information,’ ‘material non-public information’ or ‘proprietary information’ and should be considered confidential information.
While performing your job responsibilities you may learn of non-public information about our company, customers, suppliers or other business partners. You may not use this information when making a decision to buy or sell securities (for example, stocks, bonds or options) of these companies for which you have the inside information. You also may not share this information with someone else, including other team members who may buy or sell securities.
We have additional safeguards in place for our Board of Directors, senior management and those who they’ve designated as having routine access to inside information. There are trading restrictions in place around quarterly earnings releases when material non-public information hasn’t yet been released to the public. If you have questions about specific stock transactions or are aware of or suspect any securities trading violation, contact the Law Department.