We follow all state and federal securities laws, and we do not tolerate insider trading. We conduct business with the highest ethical standards.
How We Safeguard Our Company
Prevent Insider Trading
Insider trading is the illegal practice of buying or selling a public company’s stock while having nonpublic, material information about that stock. It is also illegal to share such information with someone else who may then buy or sell the stock: a practice known as “tipping.”
Material, nonpublic information refers to information that our employees have about HHH or a company we do business with that is not available to the public and that a reasonable investor would find useful in deciding whether to buy or sell stock. Examples include:
- Unpublished financial results (including earnings estimates)
- News of pending or proposed transactions
- Major litigation
- Changes in control or management
- Financial problems
How We Prevent Insider Trading
- Follow all securities laws and regulations
- Notify Legal if we are asked to share material, nonpublic information for any reason
- Never share material, nonpublic information outside HHH or with employees who do not require it for their job
Follow the Blueprint
A: No. Trading Company stock based on material, nonpublic information is considered insider trading and is illegal. As an employee of a publicly traded company, you have a duty to refrain from trading on information that has not been disclosed to the public. Doing so not only violates securities laws but also undermines the integrity of financial markets. Adhere to strict insider trading policies and refrain from any transactions involving Company stock until the information is publicly disclosed.
A: No. Your knowledge of our unreported earnings is material, nonpublic information. Sharing this information would violate insider trading laws. Don’t do it. Make it clear that, while you cannot share confidential information about HHH or advise him, he can research publicly available information and decide for himself.