Seagate 2007 Annual Report Download - page 192

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If a law conflicts with a policy in this Code, Employees and Directors must comply with the law. If a local custom or policy conflicts with
a policy in the Code, Employees and Directors must comply with the Code.
Any questions as to the applicability of any law should be directed to the Company’s General Counsel.
The U.S. federal securities laws prohibit insider trading–that is, buying or selling a company’s securities at a time when a person has
“material nonpublic information” about a company or the market for a company’s securities. “Material nonpublic information” includes
information that is not available to the public at large that could affect the market price of a company’s securities and that a reasonable investor
would consider important in deciding whether to buy, sell, or hold the securities. Insider trading is a crime punishable by civil penalties of up to
three times the profit gained or losses avoided on a transaction, criminal fines of up to $5 million, and up to 20 years in prison. Companies may
also face civil penalties, up to the greater of $1.275 million, or three times the profit gained or losses avoided, for insider trading violations by
their employees and other agents.
The Company has a securities trading policy and all Employees and Directors must abide by its terms. This policy, among other things,
provides that Employees and Directors may not buy or sell shares of the Company’s stock when they are in possession of material, non-public
information. They also are prohibited from passing on such information to others who might make an investment decision based on it.
Employees and Directors also may not trade in stocks of other companies about which they learn material, non-public information through the
course of their employment or service with the Company. They also are prohibited from passing on such information to others who might make
an investment decision based on it.
Any questions relating to constraints on the purchase or sale of any of the Company’
s securities or the securities of any other company that
an Employee or Director is familiar with by virtue of his or her relationship with the Company should be directed to the Company’s General
Counsel.
2
prompt internal reporting of any suspected of known violations of this Code in accordance with the rules set forth in this Code; and
the understanding that failure to comply with this Code is cause for disciplinary action, up to and including termination of
employment.
2.
Insider Trading.