Prohibitions Against Trading on or Tipping Non-Public Information
The federal securities laws and rules promulgated thereunder prohibit any person that is aware of material, non-public information from purchasing or selling securities and from communicating such information to any other person for such use. Material information is any information that a reasonable investor would consider
important in determining whether to buy, sell or hold securities. Non-public information is information that has not been effectively disseminated to the investing public.
The sole exception to this prohibition is if the purchase or sale is made pursuant to a pre-existing written plan or arrangement complying with Rule 10b5-1 promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), and approved in advance by the Aramark Legal Department. During the period that a person is aware of material, non-public information and absent a pre-existing written plan or arrangement pursuant to Rule 10b5-1, he or she will have to forgo a proposed transaction in the securities, even though he or she may have planned to make the purchase or sale before learning of the material, non-public information and even though failure to execute the purchase or sale may result in an economic loss to, or nonrealization of anticipated profit by, the person possessing such information.
This Policy is intended to protect Aramark personnel, Board members and their families and the Corporation from insider trading violations. However, the matters set forth in this Policy are guidelines only and are not intended to replace your responsibility to understand and comply with the legal prohibition on insider trading. Appropriate judgment should be exercised in connection with all securities trading. If you have specific questions regarding this Policy or applicable law, please contact the persons listed at the end of this Policy.
It is Aramark’s policy that Aramark personnel and Board members may not purchase or sell securities issued by Aramark or any other company while aware of material, non-public information concerning Aramark or such other company (or its industry), respectively. It is also Aramark’s policy that 所有板塊 與aramark、其客戶、供應商及競爭對手有關的非公開信息,由aramark的員工或董事在其在aramark的工作或董事會成員任期內獲得,不得與任何其他人(包括親屬、朋友或業務聯繫人,或以任何顧問身份,不論該通訊所作的目的如何)進行傳達,除非在執行aramark授權工作所必需的範圍內或依法另行明確允許,也不應在aramark內與任何人討論該信息於任何可能被旁聽的情況。書面信息應適當保護,不應留置在可能被不具信息獲取權限的人看到的地方。未經授權的信息披露可能對aramark及其他公司造成嚴重後果,無論此披露是否是為了促進不當的證券交易。