Insider Information & Trading

We protect insider information and prevent insider trading

Insider information is defined as non-public information about Roche or its business partners which a reasonable investor would consider important in deciding whether to buy or sell the company’s securities. Such information includes for example financial results and information about possible mergers, acquisitions or divestures, capital increases, capital market transactions, important licensing agreements and other collaborations as well as results from major clinical trials.

Roche employees who learn about insider information in the performance of their duties, whether
intentionally or by coincidence, are considered insiders. Likewise, non-employees who obtain
such insider information can also be considered as insiders.

Insiders must comply with the following rules:

  • Insider information must be kept strictly confidential and may not be disclosed to any non-insider within or outside Roche, including family members;
  • Insiders must not buy, sell or otherwise trade in securities of Roche or any other listed companies involved;
  • Insiders must not provide trading recommendations to non-insiders.

In most countries insider trading is strictly illegal and the acting insider as well as Roche may be penalised.

We are all expected to:
  • Protect insider information.
  • Prevent insider trading for our own gain or anyone else’s.
  • Contact the Group Legal Department if we have a question or are uncertain about the scope or application of the Roche Group Insider Directive.
Questions & Answers

I hear a rumour that Roche intends to acquire another pharmaceutical company. Am I allowed to trade in securities of Roche or of the possible target company?

Rumours do not count as insider information, so in principle the trading you are talking about would be OK. However, if your information is from a Roche source who might be involved in the transaction, you should be very careful and contact the Group Legal Department before buying or selling any securities.

I find a copy of mid-year results which are confidential and non-public. I believe that these results will have a material impact on the share price of the competitor. Based on this information, am I allowed to buy shares of the competitor’s stock?

No, you are not allowed to do anything with the confidential information, even if the information could be of use to you and the company. If the competitive information includes high-end results which are likely to have a material impact on the share price of the competitor, you are considered as an insider by coincidence and must comply with applicable insider rules.

Further Informations

Further information and guidance can be found on the Roche Internet and Intranet. For specific information consult the Roche Group Insider Directive.