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 about Lockheed Martin or such company.

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?

The term "security" is defined very broadly by the securities laws and includes stock (common and preferred), restricted stock units, employee stock options, bonds, notes, debentures, put or call options, or similar instruments.

What is trading?

Trading includes all transactions in securities, including fund transfers or fund reallocations into or out of the Lockheed Martin stock fund in your savings, benefit or deferred compensation plans; any purchase or sale of common stock (including the sale of shares received from vested restricted stock units); gifts of Lockheed Martin securities if the value of the gift is established for tax purposes at the time the gift is made; and the exercise of employee stock options. It also includes trades executed pursuant to limit orders, even if these were placed prior to your coming into possession of material, nonpublic information.

Contact the Legal Department if you have a question about whether something is material nonpublic information.