Inside information is any material non-public information that a reasonable investor
is likely to consider important when making an investment decision. Common examples
of inside information include:
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In general, fair competition laws do not allow:
- Projections of future earnings or loss.
- News of a significant or pending merger, acquisition, or tender
offer.
- News of a significant sale of assets, or the disposition of
a subsidiary.
- Changes in dividend policy, the declaration of a stock split,
or the offering of additional securities.
- Changes in executive management.
- Significant new products or discoveries.
- Impending bankruptcy or financial liquidity problems.
- Significant lawsuits or legal settlements.
- The gain or loss of a significant supplier or customer.
- The possible awarding or cancellation of a significant contract
to either Walmart or to a supplier.
It is illegal to buy or sell stock or other securities on the basis of material,
nonpublic (i.e., inside) information. It is also illegal to communicate (or “tip”)
inside information to others so that they can buy or sell stock or other securities.
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 the stock or other securities of that
company. These same restrictions apply to any person who lives in your household
or who is financially dependent upon you.
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Never buy or sell the stock or other securities of any company while you have inside
information about that company.
Never recommend that anyone buy or sell the stock or other securities of any company
while you have inside information about that company.
Don’t disclose inside information about Walmart to anyone outside of Walmart (including
your family members), 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.