It is illegal to buy or sell stock or other securities on the basis of material, non-public information or inside information. Inside information is any material, non-public information a reasonable investor is likely to consider important when making an investment decision. Some common examples include periodic sales or earnings information for Walmart U.S., Walmart international or the total company prior to the public release of such information, projections of future earnings or loss or news of a significant event such as a pending merger, a change in operations structure or a change in executive management.
It also is illegal to communicate or tip inside information to others so they can buy or sell stock or other securities on the basis of such information. If you are aware of inside information about Walmart or any other company, including our suppliers or business partners, you are prohibited from trading directly or indirectly or tipping others to trade in stock or other securities of that company. These same restrictions apply to any person living in your household or who is financially dependent upon you, as well as to any entity or securities account you may control. As Walmart associates, we all must remember to:
- Never buy or sell stock or other securities of any company while you have inside information about that company.
- Never recommend anyone buy or sell stock or other securities of any company while you have inside information about that company.
- Never disclose inside information about Walmart to anyone outside of Walmart (including your family members), unless such information has been released to the general public or unless such disclosure has been approved by the Legal Department and only after the Legal Department has informed you that adequate steps have been taken to prevent misuse of the information.
- Disclose inside information to people within Walmart only on a need-to-know basis.
- Never attempt to manipulate market prices, or spread market rumors or false information.
- Never buy or sell Walmart securities while the trading window is closed if you are subject to trading windows as described in Walmart’s Insider Trading policy.
If you have questions or concerns about insider trading, refer to Walmart’s Insider Trading policy, contact the Legal Department or Global Ethics.