Insider Trading

We must not use or disclose confidential Company information.

During the course of performing our job responsibilities, we may learn of confidential, non-public information regarding the Company’s business, including planned activities or transactions with business partners. We must respect and maintain the confidentiality of such “inside” information. It is illegal and unethical to use inside information or provide inside information to others for use in trading securities, also known as insider trading.

Employees may never take advantage of confidential information about the Company or its business partners for personal financial gain or pass that information to others, including friends or family members. Inside information, if disclosed or used, may have a significant impact on the Company and its employees, including criminal penalties.

Securities laws and Company policy restrict us from disclosing or using any inside information gained, either intentionally or by mistake, while employed at the Company. Only authorized Company employees are allowed to make previously confidential Company information public in accordance with the principles of ad hoc publicity and the requirements any relevant stock exchange.