INSIDER TRADING Don’t use or share nonpublic information to buy or sell stock We share necessary and appropriate information about Nike’s business with our teammates to help us get our work done. Some of this information isn’t available to the public and may be what United States securities laws deem to be material: sensitive and important enough that it could influence an investment decision. To use material nonpublic information to buy or sell stock – or to pass it along to someone else so they may do so – could constitute insider trading. Insider trading not only violates our Code, it violates the law. Don’t do it. You can help to prevent insider trading by keeping Nike information tight. Don’t share material nonpublic information with anyone, including family and friends. In addition, if you need to share confidential information with a third party as part of your job, make sure the party receiving the information has signed a non-disclosure agreement or is otherwise required to keep the information confidential. Two good rules of thumb: Share sensitive Nike information with colleagues only when absolutely needed to accomplish your business objectives. And never discuss sensitive or nonpublic information in open spaces. My brother asks me whether it’s a good time to buy Nike stock. Can I mention an upcoming acquisition to him? His buying stock wouldn’t benefit me personally. You should not share any nonpublic information with your brother. If he buys or sells stock based on nonpublic information that you give him, you and he could be in violation of the law. And you would definitely be in breach of Nike policy simply by sharing that information, regardless of whether your brother uses it or benefits from it. I just saw that the acquisition I was going to mention to my brother is now being reported in the press. Can I recommend my brother buy Nike stock using that information? In most cases, yes, you or anyone may purchase stock using that information since it appears in a public forum and it is not based on anything you know because of your relationship with Nike. WHAT IF...? LEARN MORE Policy on Insider Trading Visit the Office of the Corporate Secretary 24
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