Chapter 4: Our business integrity
We respect insider trading rules
The Nestlé way
While working at Nestlé, you may have access to confidential or non-public information about our company, or about our suppliers and business partners, which has the potential to influence our company’s, or another company’s, share price. This could include potential mergers and acquisitions, changes to the leadership team, product launches, significant litigation or sales and financial results. All of this constitutes ‘inside information’ and it is illegal to use it for personal gain by trading in shares.
Nestlé prohibits the purchase and sale of shares or securities based on potentially share price relevant information which is not yet public. Non-compliance may entail disciplinary action including dismissal and may also result in criminal charges.
How we live it, every day
- Understand the rules on insider trading and do not buy or sell shares or securities based on inside information.
- Keep inside information confidential. Disclosing, passing or tipping off inside information to another person is prohibited as they could use it to make investment decisions.
- Respect Nestlé’s rules on close periods. Colleagues involved in the preparation and communication of financial statements and sales figures must understand and comply with the additional rules that apply during these periods.
Putting our Code to the test
Q. A colleague is preparing to launch a new brand which I know will do very well in the market. I know I can’t buy stock myself, but can I let my spouse know and encourage them to buy shares?
A. If information about the new brand is not yet public, this is inside information, so sharing it and recommending another person to buy these shares could constitute ‘tipping off’. It is prohibited by law, even if you don’t personally receive any gain from it.
Ask yourself
If you are unsure whether you have inside information, ask yourself:
- Is this information unknown to the public?
- Do I, or would an investor, consider this information relevant when deciding whether or not to buy or sell shares or securities?
- If yes, it may be inside information.
