Preventing Insider Trading
HOW WE WIN
We never use or share inside information about Johnson Controls or any other company for the purpose of trading on the stock market.
WHY WE PUT VALUES FIRST
In the course of our work, we may have access to information about Johnson Controls or other companies that could be potentially useful to investors. Putting integrity first means showing that we can always be relied on to protect information entrusted to us. “Inside” information consists of details that an investor would consider important in making an investment decision; it is also known as material, non-public information. Using this information for our own benefit or sharing it for the benefit of others is called insider trading. It’s illegal because it provides an unfair advantage and distorts financial markets. The insider trading laws are enforced aggressively, often resulting in heavy fines and imprisonment for those convicted.
WHAT WINNING LOOKS LIKE
We prevent insider trading by:
- Never using inside information to trade shares in Johnson Controls or any other publicly traded company—unless and until such information has been made public and the market has had a chance to digest it
- Not sharing inside information with anyone outside the Company, including family members, relatives or friends
- Sharing inside information with colleagues only on a need-to-know basis
- Taking care to protect inside information from accidental disclosure by being careful with Company documents and talking discreetly in open spaces
- Avoiding “tipping”—passing along material, non-public information about any company to anyone who may trade while being aware of such information
THINK FIRST
Q:
My uncle’s investments have never recovered from the global financial crisis and I know he is struggling to put his children though university. He asked if he should buy Johnson Controls stock. I feel that doing so would really help him, especially because we expect upcoming product launches to drive up the share price. Can I tell him about the new product launches or recommend the stock to him?
A:
Absolutely not. Details of the upcoming product launches is material, nonpublic information that could provide your uncle with an unfair trading advantage. Sharing that information would be illegal. Tell him that since you are a Johnson Controls employee, you cannot provide information that would encourage or discourage anyone from trading in the stock. Refer him to the Investor Relations section of our website or suggest he contact Investor Relations if he has specific questions.