Avoiding Insider Trading

Our Commitment

We must never use material non-public information about Hexcel or its business partners to buy or sell securities. The misuse of non-public information goes against our Values. It is also against the law. If regulators find unlawful trading has occurred, enforcement is rigorous and penalties are severe. Such unlawful trading could subject you to criminal liability.

What Is Material Non-Public Information?

Deciding whether a piece of news or information could be material requires a lot of judgment. Two broad guidelines can be helpful to consider. First, is there a substantial likelihood that a reasonable investor would consider the news important to their decision to buy, sell or hold an investment? Second, if the news became public, could it have an effect, either positive or negative, on the market price of Hexcel securities?

Applying these guidelines is difficult since they involve future events. Meanwhile, the risks and costs of the improper handling of material information can be severe. Consult with the Law Department before concluding that a piece of information is not material. Also, always presume the following to be material:

Earnings forecasts or estimates
Unpublished financial data
Pending acquisitions or sales of business units
Major changes in management or strategies
Significant new contracts, partnerships, joint ventures or products, or the loss of a major contract
Decisions to expand or reduce operations

How We Act with Integrity

Learn to recognize when you may be in possession of material non-public information about Hexcel or another company.
Get help from the Law Department if you are unsure if you possess material non-public information or how to comply with insider trading rules.
Follow all Hexcel Insider Trading Policy requirements when transacting in the securities of Hexcel or its business partners.

Trade in the securities of Hexcel or another company when in possession of material non-public information relating to such company.
Advise, encourage, “tip off” or otherwise cause others to trade in the securities of Hexcel or another company when in possession of material non-public information.
Share or disclose material non-public information of Hexcel or another company unless authorized to do so.

Integrity in Action

I just overheard a conversation in the break room about a possible acquisition that could positively affect Hexcel stock prices. Can I share this information with my father-in-law?

No, this is considered “tipping” and is one of the most common forms of insider trading, which is strictly forbidden. Tipping is when you provide material non-public information about Hexcel to someone outside the Company, who uses it to trade Hexcel shares. Even if you told your father-in-law not to act on the information, if he did use it to trade shares, both of you could be found guilty of insider trading.