Insider Trading

DO WHAT'S RIGHT
RESPECT OTHERS

PERFORM WITH EXCELLENCE
We Do Not Engage in Insider Trading

We Set the Standard

We do not:

  • Use or share material, nonpublic information for personal gain
  • Pass along such information to someone without a need to know
  • Trade Lockheed Martin's, or any other company's, securities while in possession of material nonpublic information

Why We Do It

  • We believe in a fair and open market.
  • We are obligated to comply with the securities laws and regulations of the United States and other countries.

What is material nonpublic information?

In the course of your employment, you may learn of material information related to Lockheed Martin or other companies, teammates, suppliers, vendors, subcontractors or others before the general public knows the information. Information, both positive and negative, is "material" if there is a substantial likelihood that a reasonable investor would consider it important in deciding whether to trade a security. Information is "nonpublic" until it is official, widely disseminated and has been assimilated by the general public.

What are securities?

Securities include stocks, stock options, bonds, notes, debentures and put or call options. Your trades in the retirement savings plan are regulated just like stock transactions.

What is trading?

Trading includes any decision to buy or sell a security including within Lockheed Martin's equity compensation and retirement benefit plan.


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Contact the Legal Department or Ethics Office if you have a question as to whether something is "material nonpublic information."