Insider Trading and Non-Public Information
Employees of Travelport may, in the course of performing their duties, come into possession of “material non-public information” about Travelport or its subsidiaries or other companies with whom Travelport does business. “Material non-public information” is defined as any information that a reasonable investor would consider important in making a decision to buy or sell securities. In short, it includes any information that could be expected to affect the price of securities, either positively or negatively. Buying or selling securities based on such information is referred to as “insider trading” and can result in substantial fines and imprisonment.
It is illegal for Travelport employees to directly or indirectly buy or sell stocks (shares) or bonds based on insider information or to discuss such information with others who might buy or sell such securities, including shares or bonds.
For example, if in the course of your work and prior to a public announcement, you become aware of an acquisition, divestiture, material contract, or a major change in management that would materially affect Travelport or one of its subsidiaries or another company, you may be guilty of insider trading if you bought or sold securities of Travelport or some other company based on this knowledge or passed this information to anyone who then bought or sold such securities. Please refer to the applicable Code Guidance Supplement for more information.
Any directors, officers or employees who are unsure whether the information that they possess is material or nonpublic should consult the Securities Trading Compliance Officer for guidance before trading in any securities.