Integrity
We do the right things the right way; it’s the cornerstone of our relationships with every stakeholder.
Preventing Insider Trading
We believe everyone should make investment decisions based on the same set of rules. We don’t trade on material, nonpublic (“inside”) information.
What Can You Do?
Understand the definition of inside information. It is information you may know about ATI or companies we work with that is:
Material, meaning that if known, it could affect the market value of the stock or securities or be important to an investor in deciding whether to buy, sell or hold onto stock
AND
Nonpublic, meaning it has not been released outside of our Company in a way that makes the information widely accessible to the investing public (through a press release, for example)
Examples of Inside Information:
- Projections of future earnings or losses
- Stock splits or dividend increases or losses
- Proposed mergers or acquisitions
- The gain or loss of a major customer, supplier or contract
- Significant pending lawsuits
- Major changes to executive leadership
- Don’t trade or tip. If you have inside information about ATI, our customers, suppliers or any other public company connected to our business, you may not trade in any securities issued by that company, or provide the inside information to others so that they may trade while possessing inside information, which is called “tipping.” The same prohibition applies to members of your immediate family and household. Both trading while in possession of material nonpublic information and tipping are considered insider trading and prohibited by law.
- Honor blackout periods. Certain ATI employees may be subject to trading blackout periods, which are periods of time during which you are not permitted to trade ATI securities, whether you have inside information or not. Check our Insider Trading Policy to determine if you are subject to these restrictions or if you are required to seek approval before trading ATI securities.
- Ask before you act. If you have questions about what is OK (and what is not), check with ATI’s Vice President, Corporate Secretary before trading.
On the Job
Go Deeper!
Check the Safeguarding Assets and Information topic here in our Code and the Insider Trading Policy (which can be found on ATI@work) for more information.
