Prohibition of insider trading
We respect the integrity of the capital markets and do not misuse sensitive information acquired while working for Bosch. Sensitive information not known to the public that could affect the price of stock or other financial instruments (securities) is called “inside information.”
Insider trading
We do not purchase or sell any securities or cancel or change existing orders based on this inside information, regardless of whether these transactions are carried out for our own benefit, for the benefit of third parties, or on behalf of others.
We do not use our inside information to recommend that anyone purchase or sell securities, or cancel or change respective orders, nor do we induce anyone to do so in any other way.
We treat inside information as strictly confidential. As a general principle, we do not disclose such information to third parties; this also applies to passwords that allow access to electronically stored inside information.
We disclose inside information only to associates or consultants from outside the company if the recipient needs the information to perform their jobs and is also obligated to treat it as strictly confidential.
Through your position at Bosch, you hear that one of Bosch’s stock-listed logistics suppliers is suffering from financial issues. This information will only be published in their next quarterly report. Your friend invests in this company, so you’re worried that he’ll lose money. Before sending him a message, you hesitate and ask yourself: Is this information confidential?
As you suspected, the logistics supplier’s financial issues are confidential or even strictly confidential information. You cannot tell your friend about the supplier’s problems, because nonpublic information from or regarding suppliers needs to be protected in accordance with legal and contractual requirements.
How do I identify inside information?
Examples of potential inside information include:
- Sales figures that are not intended for publication
- Information about M&A projects
- Major reorganizations
- New appointments to the board of management and supervisory board prior to their official publication
- Conclusion, or cancellation, of a major contract with a customer or supplier
- Important legal disputes
- Dealings with government agencies
How is this relevant to me?
At Bosch, we handle inside information not only about Bosch but also that of our business partners. Buying or selling securities while having such confidential information about these companies, or sharing the confidential information with others, can violate insider trading laws if it is considered “inside information.” We can also violate insider trading laws by sharing inside information about a company with others.
