- Letter from the President/CEO
- PBG Mission Statement
- Business Ethics Line Numbers
- Things to consider as you read and apply our Worldwide Code of Conduct
- Enforcing Business Ethics and Legal Compliance
- Reporting a Violation
- Waivers and Amendments
- Conducting Business with Integrity
- The PBG Work Environment
- Trade Practices
- Product Quality and Environmental Protection
- Use and Protection of PBG’s Assets
- Insider Trading
- Community Relations and Political Participation
Insider Trading
PBG is committed to the principle of fair and open markets for publicly traded securities in accordance with the requirements of the United States securities laws. Insider trading – trading in a company’s stock based on knowledge of material facts not known to the public at large – is illegal. Tipping others to such material, non-public information is also illegal in many circumstances. There are significant civil and criminal penalties for both actions, including large penalties and jail terms.
You should never trade in PBG’s stock based on your knowledge of material information not known to the public at large. Information is considered material if there is a substantial likelihood that a reasonable investor would consider it important to his or her decision to buy, sell, or hold securities. This policy applies to direct purchases and sales of PBG stock and, where applicable, the exercise of PBG stock options and 401(k) plan and income deferred plan transactions (other than those resulting from your payroll deduction election).
You should also never give material non-public information about PBG to anyone outside PBG, including members of your immediate family. PBG strictly forbids all employees, directors, and officers from using material non-public information about PBG for personal advantage or enabling others to do so. PBG also prohibits all employees, directors, and officers from engaging in short selling (which means selling securities that you do not yet own) or trading in puts, calls, or market traded options with respect to PBG securities.
In addition, you should never trade in the stock of other companies based on material non-public information that you obtain about that company through your employment at, or association with, PBG. Examples of material information include a significant upward or downward revision of earnings forecasts, a significant development regarding a customer (such as acquisition or loss of a substantial contract), development of a significant new product, a major management change, a significant acquisition or divestiture, or events involving the Company’s securities, such as stock splits or dividends. Information is considered non-public until it appears in press releases or in filings with the SEC and the market has had time to absorb it (generally 48 hours).
For more information on insider trading and tipping, please contact the Law Department.
I’ve learned that PBG is getting close to awarding the bid for a large purchase of equipment to a new supplier. I know that our business will be a significant event for the supplier and I expect that its stock will go up once the news is announced. Can I purchase some of the supplier’s stock?
No. The information that you have regarding the pending award of the bid to this supplier would be considered “material non-public information” and you should not purchase the supplier’s stock prior to the news being announced publicly and not until the stock market has had a chance to absorb the news (generally 48 hours). Also, if your position gives you any decision-making authority with respect to this supplier, ownership of its stock may create a conflict of interest and you should discuss any potential purchase of the stock with your Human Resources Manager.