Information is nonpublic if it has not been published, or if investors have not had an opportunity to react to the information. Note that disclosing the information to a selected group of analysts does not make it public. For example, a disclosure made to a room full of analysts does not make the disclosed information "public."

Note that this standard prohibits use of material nonpublic information, not:

• Nonmaterial public information.
• Nonmaterial nonpublic information.
• Material public information.

You are prohibited from seeking or using any inside information in making investment decisions if:

• Such trading would breach a duty.
• The information is misappropriated.
• The information relates to a tender offer.
• Members receive material information in confidence.