Avoiding Insider
Trading

While working on behalf of P&G, we may become aware of material nonpublic information about P&G or other companies with whom we do business. Material nonpublic information (also known as “inside information”) is information about a company that is not known to the general public and that a reasonable investor would consider important when deciding whether to buy, sell or hold that company’s stocks, bonds, options, or other financial instruments (“securities”).

You must not buy or sell the securities of a company on the basis of material nonpublic information (known as “insider trading”).

• Doing so is a criminal offense in many countries and is prohibited by P&G.
  
  

• If you have any doubt about a potential securities transaction, seek guidance from Legal or submit your question to insidertradingps.im@pg.com.
  
  

• Our Global Insider Trading Policy applies to all employees and the Board of the Directors.
  
  

• Individuals who are on P&G’s “Insider Trading List” are subject to additional requirements.
  
  

If you reveal material nonpublic information to anyone, including any member of your immediate family or household, and that person then buys or sells securities based on that information, you may be legally liable for “tipping.”

• This is true even if you do not personally trade on the information.
  
  

• Tipping is a violation of our WBCM and the securities laws, and carries severe penalties, including potential criminal liability for at-fault individuals.