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湾流宇航公司公司政策手册 Gulfstream Aerospace Corporation Corporate Policy Manual(11)

时间:2011-10-01 16:41来源:蓝天飞行翻译 作者:admin
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Employees may not purchase or sell securities of General Dynamics, suppliers, customers or other companies with which Gulfstream has business or contractual relationships using insider information that is not available to the public.  Employees are also prohibited from communicating insider information to others who might use it for trading securities in violation of law.  Employees must preserve the confidentiality of such information by taking appropriate steps to protect against its inadvertent disclosure.
Proprietary/inside private information is information that, if made available to unauthorized persons, competitors, or to limited groups with resulting illegal use, could have an adverse legal, commercial, financial or securities-related impact on Gulfstream, its investors or its employees. In addition, Gulfstream and its employees must comply with all financial disclosure procedures and controls as set forth in General Dynamics Corporate Policy 08-101.  A complete copy of the policy is available on Gulfstream’s Intranet.
 
 E.        Conflict of Interest
 
A conflict of interest is defined as a conflict between the private interests and the official responsibilities of a person in a position of trust.  We should all consider ourselves as persons in a position of trust and conduct ourselves accordingly.  A conflict of interest exists when an employee is in a position to influence a Gulfstream decision that may result in a personal gain for that employee.  A conflict exists even if the benefit goes directly to a relative or friend instead of the employee and even if Gulfstream is not adversely affected by the action.  Employees must be free from the influence of personal or financial interests when they represent Gulfstream in any business dealings or make any recommendations that may influence an action of Gulfstream.  Employees are expected to avoid direct or indirect involvement in any situation in which they may have a conflict, real or apparent, with 
 
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