We follow the law
Insider trading laws
Your job at Cox may bring you into contact with material, nonpublic information (or “inside information”) about our company or one of our clients, vendors, subcontractors, business partners, portfolio companies or competitors.
If so, you cannot buy, sell or otherwise trade in stock or other securities of a company while you possess any such inside information about that company. This is known as
insider trading and is illegal.
Sharing inside information with others outside the scope of your work — including friends, family or coworkers who do not have a work-related need for the inside information — is also prohibited.
You are required to take reasonable precautions to protect inside information you have access to by virtue of your role at Cox, including keeping computer screens, work papers and conversations confidential while in the presence of outsiders.
Whether inside information is shared intentionally or not, it may still be considered “tipping,” which is another form of prohibited insider trading.
WHAT’S “INSIDE INFORMATION”?
It’s information that hasn’t been shared with investors or the public that might be important in deciding to buy, sell or hold stock or other securities of a company. It could include things like budgets, sales or marketing forecasts, financial estimates and results, M&A activity, information about gaining or losing a major client or supplier, or anything else that a reasonable investor may consider important when investing.
It can also include information about Cox that may be important to another company’s investors, such as Cox’s decision to invest in or enter into a strategic relationship
with another company, or the financial performance of a Cox business that may be acquired by another company.
Having such information while trading in the securities of the other company may also be considered insider trading and is prohibited.
SPEAK UP if you see or suspect an act of bribery or corrupt business practice.
DON’T TRADE if you have inside information and
DON’T SHARE inside information.
TRADE COMPLIANCE LAWS
For our businesses that serve clients and maintain business relationships around the world, we are committed to following trade compliance laws in the countries where we operate. Because our products and services move internationally, they are subject to several import and export laws. These laws regulate where and with whom we can do business. Violations of an import or export law, regulation or restriction could have serious consequences for our company.
If your duties involve the movement of products or services across international borders, it is your responsibility to:
Understand — and comply with — the import and export laws, regulations and restrictions in the countries where you work.
Refrain from transacting business with countries that are subject to U.S. trade embargoes or economic sanctions, or with individuals or entities owned or controlled by, or acting for or on behalf of, targeted countries.
Contact the Compliance Team for guidance anytime you see a counterparty request or a requirement, as part of any business transaction, that Cox boycott or agree to boycott any person, entity or country.
Seek help if you have questions.
What are trade compliance laws?
Trade compliance laws are laws that regulate the movement of goods and
services across international borders. They include:
Export laws that govern goods and services shipped out of one country to another country.
Import laws or regulations that control goods and services entering one country from another country.
Sanctions regulations that prohibit doing business with identified individuals and entities.