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| Buying and Selling Securities - Insider
Trading Summary - Procedure PRO-12 Boeing employees are prohibited from engaging in "insider trading." Prohibitions are based on federal securities laws and deal with the possession and use of "material" information, defined as information that an investor would consider important in deciding to purchase or sell a security and that could affect the price of the security. Employees who have "material nonpublic" information about Boeing or other companies as a result of their Boeing connections are prohibited from trading in those securities as well as from communicating such information to family or friends. "Material" information is information that a reasonable investor would very likely consider importnat in deciding to purchase or sell a security and that could affect the price of the security. "Nonpublic" information is information that is not available to the general public. Read full-text of procedure PRO-12 Questions to Ask Yourself Are my decisions about whether and when to buy Boeing stock or stock from other companies influenced by the facts I've learned as part of my role as a Boeing employee? Do I ensure that my discussions with relatives and friends avoid topics that are not yet public and that they could use to get an unfair advantage in the stock market or other areas of public financial trading?
Frequently Asked Questions about Insider Trading I'm aware that a large order for Boeing products has been placed by a customer but has not yet been announced. May I purchase company stock knowing that information? No. This is a violation of Boeing policy and a potential violation of federal securities laws. You may purchase company stock only after such information is known to the public. My organization reviewed a pitch by one of our vendors about a new product they plan to introduce soon on the market. We decided that the product would not be useful for Boeing, but I think the new device could be a real breakthrough and useful for other industries. I am willing to take a risk on this and invest in the vendor. May I buy stock in the vendor's company? You may not buy this stock until information about the new product is known to the public. The fact that the new product is not significant to Boeing is not the relevant test. If the new product may have an impact on the earnings of the vendor, then the pending introduction of the product is material to that company and you cannot trade on the information until after it is known to the public. I've become aware of financial information on one of the company's customers that indicates the customer is in better financial condition than most people realize. I want to purchase some of the customer's stock. May I do so? You may not purchase this stock until the financial information is known to the public. Information of this sort may have been provided to the company in trust by the customer to help the company determine how to best meet the customer's needs. Using this information for personal purposes or disclosing it to others is a violation of Boeing policy and is illegal. Are transfers of accumulated values within the Company Investment Plan subject to insider trading restrictions? A transfer (in or out of) or any election to the Boeing common stock fund in the VIP or any of the heritage compny fund programs should not be made while you are in possession of material nonpublic company information. The company offered me a stock option allowing me to buy Boeing stock at a good price. Am I limited by the insider trading policy as to when I can exercise the option? The exercise of a
company-granted stock option is not subject to the insider trading laws.
However, selling stock received from an option (such as selling through
a broker assisted same-day buy-and-sell exercise) is subject to the
laws and the procedure prohibiting insider trading.
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