{"id":40839,"date":"2015-09-17T11:25:58","date_gmt":"2015-09-17T16:25:58","guid":{"rendered":"https:\/\/content.findlaw-admin.com\/ability-legal\/contracts\/uncategorized\/insider-trading-policy-harsco-corp.html"},"modified":"2015-09-17T11:25:58","modified_gmt":"2015-09-17T16:25:58","slug":"insider-trading-policy-harsco-corp","status":"publish","type":"corporate_contracts","link":"https:\/\/corporate.findlaw.com\/contracts\/corporate\/insider-trading-policy-harsco-corp.html","title":{"rendered":"Insider Trading Policy – Harsco Corp."},"content":{"rendered":"

GLOBAL FINANCIAL ACCOUNTING,
\nREPORTING<\/em><\/strong><\/p>\n

\n

AND GENERAL MANUAL<\/em><\/strong><\/p>\n

\n

TITLE:<\/strong> INSIDER TRADING POLICY<\/p>\n<\/p>\n

ISSUE DATE:<\/strong> 03-12-12<\/p>\n<\/p>\n

EFFECTIVE DATE:<\/strong> 03-12-12<\/p>\n<\/p>\n

REPLACES:<\/strong> 06-01-06<\/p>\n<\/p>\n

ISSUED BY: MEK<\/strong><\/p>\n<\/p>\n

AUTHORIZED BY: HWK<\/strong><\/p>\n<\/p>\n

\n

Introduction<\/u><\/strong><\/p>\n<\/p>\n

The purchase or sale of securities while aware of material nonpublic
\ninformation, or the disclosure of material nonpublic information to others who
\nthen trade in the Company’s securities, is prohibited by the federal securities
\nlaws. Insider trading violations are pursued vigorously by the U.S. Securities
\nand Exchange Commission (“SEC”) and the U.S. Attorney General153s office and are
\npunished severely. While the regulatory authorities concentrate their efforts on
\nthe individuals who trade, or who tip inside information to others who trade,
\nthe federal securities laws also impose potential liability on companies and
\nother “controlling persons” if they fail to take reasonable steps to prevent
\ninsider trading by company personnel.<\/p>\n<\/p>\n

The Company has adopted this Insider Trading Policy both to satisfy the
\nCompany’s obligation to prevent insider trading and to help Company personnel
\navoid the severe consequences associated with violations of the insider trading
\nlaws. The Insider Trading Policy also is intended to prevent even the appearance
\nof improper conduct on the part of anyone employed by or associated with the
\nCompany (not just so-called insiders).<\/p>\n<\/p>\n

The Consequences<\/u><\/strong><\/p>\n<\/p>\n

The consequences of an insider trading violation can be severe:<\/p>\n<\/p>\n

Traders and Tippers.<\/u><\/em> Company personnel (or their tippees) who
\ntrade while in possession of inside information are subject to the following
\npenalties:<\/p>\n<\/p>\n\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

A criminal fine of up to $5,000,000 (no matter how small the profit);<\/p>\n<\/td>\n<\/tr>\n

\n

–<\/p>\n<\/td>\n

\n

A jail term of up to twenty years;<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/p>\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

Civil injunctions;<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n

INSIDER TRADING POLICY<\/strong><\/p>\n

\n

\n\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

Disgorgement of profits;<\/p>\n<\/td>\n<\/tr>\n

\n

–<\/p>\n<\/td>\n

\n

Civil fines for the person who committed the violation of up to three times
\nthe profit gained or loss avoided, whether or not the person actually benefited;
\nand<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/p>\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

Criminal penalties of up to twenty-five years in prison for knowingly
\nexecuting a “scheme or artifice to defraud any person” in connection with any
\nregistered securities.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

An employee who tips information to a person who then trades is subject to
\nthe same penalties as the tippee, even if the employee did not trade and did not
\nprofit from the tippee’s trading.<\/p>\n<\/p>\n

Control Persons<\/u><\/em>.<\/u> The Company and its supervisory
\npersonnel, if they fail to take appropriate steps to prevent illegal insider
\ntrading or knew or recklessly disregarded the fact that an employee or other
\nperson associated with the Company was likely to engage in insider trading
\nviolations, are subject to the following penalties:<\/p>\n<\/p>\n\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

A civil penalty of up to $1,000,000 or, if greater, three times the profit
\ngained or loss avoided as a result of the employee’s violation; and<\/p>\n<\/td>\n<\/tr>\n

\n

–<\/p>\n<\/td>\n

\n

A criminal penalty of up to $25,000,000 dollars.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Company-Imposed Sanctions<\/u><\/em>.<\/u> An employee’s failure to
\ncomply with the Company’s insider trading policy may subject the employee to
\nCompany-imposed sanctions, including dismissal for cause, whether or not the
\nemployee’s failure to comply results in a violation of law. Needless to say, a
\nviolation of law, or even an SEC investigation that does not result in
\nprosecution, can tarnish one’s reputation and irreparably damage a career.<\/p>\n<\/p>\n

General Restrictions<\/u><\/strong><\/p>\n<\/p>\n

It is the policy of the Company that no director, officer or other employee
\nof the Company who is aware of material nonpublic information relating to the
\nCompany may, directly or through family members or other persons or entities,
\n(a) buy or sell securities of the Company (other than pursuant to a pre-approved
\ntrading plan that complies with SEC Rule 10b5-1), or engage in any other action
\nto take personal advantage of that information, or (b) pass that information on
\nto others outside the Company, including family and friends. In addition, it is
\nthe policy of the Company that no director, officer or other employee of the
\nCompany who, in the course of working for the Company, learns of material
\nnonpublic information about a company with which the Company does business,
\nincluding a customer or supplier of the Company, may trade in that company’s
\nsecurities until the information becomes public or is no longer material.<\/p>\n<\/p>\n

The securities laws do not recognize any mitigating circumstances, and, in
\nany event, even the appearance of an improper transaction must be avoided to
\npreserve the Company’s reputation for adhering to the highest standards of
\nconduct.<\/p>\n<\/p>\n

\n

INSIDER TRADING POLICY<\/strong><\/p>\n

\n

\n

Disclosure of Information to Others.<\/u><\/em> The Company is required
\nunder Regulation FD (Fair Disclosure) of the federal securities laws to avoid
\nthe selective disclosure of material nonpublic information. The Company has
\nissued a policy for releasing material information in a manner that is designed
\nto achieve broad public dissemination of the information immediately upon its
\nrelease. You may not, therefore, disclose information to anyone outside the
\nCompany, including family members and friends, other than in accordance with
\nthose procedures. The guidelines are outlined in the Investment Community
\nInformation Disclosure Guidelines Policy and Procedure<\/u>.<\/p>\n<\/p>\n

Material Information.<\/u><\/em> Material information is any information
\nthat a reasonable investor would consider important in making a decision to buy,
\nhold, or sell securities. Any information that could be expected to affect the
\nCompany’s stock price, whether it is positive or negative, should be considered
\nmaterial. Some examples of information that ordinarily would be regarded as
\nmaterial are:<\/p>\n<\/p>\n\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

Projections of future earnings or losses, or other earnings guidance;<\/p>\n<\/td>\n<\/tr>\n

\n

–<\/p>\n<\/td>\n

\n

Earnings that are inconsistent with the consensus expectations of the
\ninvestment community;<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/p>\n\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

A significant pending or proposed merger, acquisition or tender offer;<\/p>\n<\/td>\n<\/tr>\n

\n

–<\/p>\n<\/td>\n

\n

A pending or proposed acquisition or disposition of a significant asset;<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/p>\n\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

A change in dividend policy, the declaration of a stock split, or an offering
\nof additional securities;<\/p>\n<\/td>\n<\/tr>\n

\n

–<\/p>\n<\/td>\n

\n

A change in senior management;<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/p>\n\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

Development of a significant new product or process;<\/p>\n<\/td>\n<\/tr>\n

\n

–<\/p>\n<\/td>\n

\n

Impending bankruptcy or the existence of severe liquidity problems;<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/p>\n\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

Financial results that have not yet been published;<\/p>\n<\/td>\n<\/tr>\n

\n

–<\/p>\n<\/td>\n

\n

Significant regulatory proceedings and governmental investigations involving
\nthe Company; and<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/p>\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

The gain or loss of a significant customer or supplier.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

The above list is only illustrative; many other types of information may be
\nconsidered “material,” depending on the circumstances. The materiality of
\nparticular information is subject to reassessment on a regular basis. When in
\ndoubt, please contact the General Counsel.<\/p>\n<\/p>\n

Twenty-Twenty Hindsight.<\/u><\/em> Remember, anyone scrutinizing your
\ntransactions will be doing so after the fact, with the benefit of hindsight. As
\na practical matter, before engaging in any transaction, you should carefully
\nconsider how enforcement authorities and others might view the transaction in
\nhindsight.<\/p>\n<\/p>\n

\n

INSIDER TRADING POLICY<\/strong><\/p>\n

\n

\n

When Information is “Public”.<\/u><\/em> If you are aware of material
\nnonpublic information, you may not trade until the information has been
\ndisclosed broadly to the marketplace (such as by press release or an SEC filing)
\nand the investing public has had time to absorb the information fully. To avoid
\nthe appearance of impropriety, as a general rule, information should not be
\nconsidered fully absorbed by the marketplace until noon on the second business
\nday after the information is released. If, for example, the Company were to make
\nan announcement at the close of business on a Monday, you should not trade in
\nthe Company’s securities until noon on Wednesday. If an announcement were made
\nat the close of business on a Friday, noon on Tuesday generally would be the
\nfirst eligible trading day. Note that this restriction is in addition<\/u> to
\nany other restrictions that apply under this policy, including the requirement
\nthat trades be pre-cleared (see below).<\/p>\n<\/p>\n

Transactions by Family Members.<\/u><\/em> The Insider Trading Policy
\nalso applies to your family members who reside with you, anyone else who lives
\nin your household, and any family members who do not live in your household but
\nwhose transactions in company securities are directed by you or are subject to
\nyour influence or control (such as parents or children who consult with you
\nbefore they trade in company securities). It also applies to partnerships in
\nwhich you are a general partner, corporations in which you either singly or
\ntogether with other “related persons” own a controlling interest, trusts or
\nwhich you are a trustee, settler or beneficiary, estates of which you are an
\nexecutor or beneficiary, or any other group or entity where the insider has or
\nshares with others the power to decide whether to buy Company stock. You are
\nresponsible for the transactions of these other persons and therefore should
\nmake them aware of the need to confer with you before they trade in the
\nCompany’s securities.<\/p>\n<\/p>\n

Transactions Under Company Plans<\/u><\/strong><\/p>\n<\/p>\n

Stock Option Exercises.<\/u><\/em> The prohibitions of the policy apply
\nto any sale of stock as part of a broker-assisted cashless exercise of an
\noption, and any other market sale for the purpose of generating the cash needed
\nto pay the exercise price of an option. However, the Company’s insider trading
\npolicy does not apply solely to the exercise of an employee stock option, or to
\nsolely the exercise of a tax withholding right pursuant to which you elect to
\nhave the Company withhold shares subject to an option to satisfy tax withholding
\nrequirements, provided that a sale is not coupled with such exercise.<\/p>\n<\/p>\n

401(k) Plan.<\/u><\/em> The Company’s Insider Trading Policy does not
\napply to purchases of Company stock in the 401(k) plan resulting from your
\nperiodic contribution of money to the plan pursuant to your payroll deduction
\nelection. The policy does apply, however, to certain elections you may make
\nunder the 401(k) plan, including (a) an election to increase or decrease the
\npercentage of your periodic contributions that will be allocated to the Company
\nstock fund,<\/p>\n<\/p>\n

\n

INSIDER TRADING POLICY<\/strong><\/p>\n

\n

\n

(b) an election to make an intra-plan transfer of an existing account balance
\ninto or out of the Company stock fund, (c) an election to borrow money against
\nyour 401(k) plan account if the loan will result in a liquidation of some or all
\nof your Company stock fund balance, and (d) your election to pre-pay a plan loan
\nif the pre-payment will result in allocation of loan proceeds to the Company
\nstock fund.<\/p>\n<\/p>\n

Dividend Reinvestment Plan<\/u><\/em>.<\/u> The Company’s Insider
\nTrading Policy does not apply to purchases of Company stock under the Company’s
\ndividend reinvestment plan resulting from your reinvestment of dividends paid on
\nCompany securities. The policy does apply, however, to voluntary purchases of
\nCompany stock resulting from additional contributions you choose to make to the
\nplan, and to your election to participate in the plan or increase your level of
\nparticipation in the plan. The policy also applies to your sale of any Company
\nstock purchased pursuant to the plan.<\/p>\n<\/p>\n

Additional Prohibited Transactions<\/u><\/strong><\/p>\n<\/p>\n

The Company considers it improper and inappropriate for any director, officer
\nor other employee of the Company to engage in short-term or speculative
\ntransactions in the Company’s securities. It therefore is the Company’s policy
\nthat directors, officers and other employees may not engage in any of the
\nfollowing transactions:<\/p>\n<\/p>\n

Short-term Trading<\/u><\/em>.<\/u> An employee’s short-term trading
\nof the Company’s securities may be distracting to the employee and may unduly
\nfocus the employee on the Company’s short-term stock market performance instead
\nof the Company’s long-term business objectives. For these reasons, any director,
\nofficer or other employee of the Company who purchases Company securities in the
\nopen market may not sell any company securities of the same class during the six
\nmonths following the purchase. Likewise, any director, officer or other employee
\nof the Company who sells Company securities in the open market may not purchase
\nany Company securities of the same class during the six months following this
\nsale.<\/p>\n<\/p>\n

Short Sales.<\/u><\/em> Short sales of the Company’s securities are
\nprohibited by this Policy Statement. In addition, Section 16(c) of the Exchange
\nAct prohibits officers and directors from engaging in short sales.<\/p>\n<\/p>\n

Publicly Traded Options<\/u><\/em>.<\/u> Transactions in puts, calls
\nor other derivative securities, on an exchange or in any other organized market,
\nare prohibited by this Policy Statement. (Option positions arising from certain
\ntypes of hedging transactions are governed by the section below captioned
\n“Hedging Transactions.”)<\/p>\n<\/p>\n

Hedging Transactions.<\/u><\/em> Certain forms of hedging or
\nmonetization transactions, such as prepaid variable forward contracts, equity
\nswaps, collars or exchange<\/p>\n<\/p>\n

\n

INSIDER TRADING POLICY<\/strong><\/p>\n

\n

\n

funds, enable a securityholder to lock in much of the value of his or her
\nholdings. These transactions are designed so that the securityholder may
\ncontinue to own his or her securities without the full risks and rewards of
\nownership, such as the potential of upside appreciation. If a director, officer
\nor employee of the Company were to enter into such a transaction, his or her
\ninterests could become misaligned with the interests of the Company153s other
\nsecurityholders. For this reason, transactions involving hedging or monetization
\nwith respect to the Company153s securities are prohibited by this Policy
\nStatement.<\/p>\n<\/p>\n

Margin Accounts and Pledges<\/u><\/em>. Securities held in a margin
\naccount and securities pledged (or hypothecated) as collateral for a loan may be
\nsold without the knowledge of the insider and therefore are prohibited under
\nthis Policy. An exception to this prohibition may be granted where a person
\nwishes to pledge Company securities as collateral for a loan (not including
\nmargin debt) and clearly demonstrates the financial capacity to repay the loan
\nwithout resort to the pledged securities. Any person who wishes to pledge
\nCompany securities as collateral for a loan must submit a request for approval
\nto the General Counsel at least one week prior to the proposed execution of
\ndocuments evidencing the proposed pledge.<\/p>\n<\/p>\n

Pre-clearance Procedures<\/u><\/strong><\/p>\n<\/p>\n

To help prevent inadvertent violations of the federal securities laws and to
\navoid even the appearance of trading on inside information the following
\nindividuals together with their family members (“Restricted Individuals”), may
\nnot engage in certain transactions without the prior clearance of the
\ntransaction from the General Counsel:<\/p>\n<\/p>\n\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

directors,<\/p>\n<\/td>\n<\/tr>\n

\n

–<\/p>\n<\/td>\n

\n

corporate officers,<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/p>\n\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

divisional officers,<\/p>\n<\/td>\n<\/tr>\n

\n

–<\/p>\n<\/td>\n

\n

Key Leadership Team Members,<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/p>\n\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

director-level employees at the Corporate Headquarters,<\/p>\n<\/td>\n<\/tr>\n

\n

–<\/p>\n<\/td>\n

\n

Controller153s Department employees employed at the Corporate Headquarters and,\n<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/p>\n\n\n\n
\n

–<\/p>\n<\/td>\n

\n

any other persons designated by the General Counsel.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

The transactions which Restricted Individuals may not engage in include any
\ntransaction involving the Company’s securities (including a stock plan
\ntransaction such as an option exercise, gift, loan or pledge or hedge,
\ncontribution to a trust, or any other transfer). Request for approval must be
\nsubmitted to the General Counsel at least two days in advance of the proposed
\ntransaction. The General Counsel is under no obligation to approve a trade
\nsubmitted for pre-clearance, and may determine not to permit the trade.<\/p>\n<\/p>\n

\n

INSIDER TRADING POLICY<\/strong><\/p>\n

\n

\n

Rule 10b5-1 Plans.<\/u><\/em> Any person who wishes to implement a
\ntrading plan under SEC Rule 10b5-1 must first pre-clear the plan with the
\nGeneral Counsel. As required by Rule 10b5-1, you may enter into a binding
\ncontract, or instruction, or a trading plan only when you are not in possession
\nof material nonpublic information. In addition, you may not enter into a trading
\nplan during a blackout period. Transactions effected pursuant to a pre-cleared
\ntrading plan will not require further pre-clearance at the time of the
\ntransaction if the plan specifies the dates, prices and amounts of the
\ncontemplated trades, or establishes a formula for determining the dates, prices
\nand amounts. To comply with Rule 10b5-1, you must not exercise any subsequent
\ndiscretion affecting the transactions, and if your broker or any other person
\nexercises discretion in implementing the trades, you must not influence his or
\nher actions and he or she must not possess any material non-public information
\nat the time of the trades. Trading plans can be established for a single trade
\nor a series of trades.<\/p>\n<\/p>\n

It is important that you document the details of a trading plan properly.
\nPlease note that, in addition to the requirements of a trading plan described
\nabove, there are a number of additional procedural conditions to Rule 10b5-1(c)
\nthat must be satisfied before you can rely on a trading plan as an affirmative
\ndefense against an insider trading charge. These requirements include that you
\nact in good faith, that you not modify your trading instructions while you
\npossess material non-public information and that you not enter into or alter a
\ncorresponding or hedging transaction or position. Because this rule is complex,
\nthe Company recommends that you work with a broker and the General Counsel and
\nbe sure you fully understand the limitations and conditions of the rule before
\nyou establish a trading plan.<\/p>\n<\/p>\n

Blackout Periods<\/u><\/strong><\/p>\n<\/p>\n

Quarterly Blackout Periods.<\/u><\/em> The Company’s announcement of its
\nquarterly financial results almost always has the potential to have a material
\neffect on the market for the Company’s securities. Therefore, to avoid even the
\nappearance of trading while aware of material nonpublic information, Restricted
\nIndividuals will not be pre-cleared to trade in the Company’s securities during
\nthe period beginning two weeks prior to the end of the Company’s fiscal quarter
\nand ending on noon of the second business day following the Company’s issuance
\nof its quarterly earnings release.<\/p>\n<\/p>\n

The Company may on occasion issue interim earnings guidance or other
\npotentially material information by means of a press release, SEC filing on Form
\n8-K or other means designed to achieve widespread dissemination of the
\ninformation. Restricted Individuals are unlikely to be pre-cleared while the
\nCompany is in the process of assembling the information to be released and until
\nthe information has been released and fully absorbed by the market.<\/p>\n<\/p>\n

\n

INSIDER TRADING POLICY<\/strong><\/p>\n

\n

\n

Event-specific Blackout Periods<\/u><\/em>.<\/u> From time to time, an
\nevent may occur that is material to the Company and is known by only a few
\ndirectors or executives. So long as the event remains material and nonpublic,
\ndirectors, executive officers, and such other persons as are designated by the
\nGeneral Counsel may not trade in the Company’s securities. The existence of an
\nevent-specific blackout will not be announced, other than to those who are aware
\nof the event giving rise to the blackout. If, however, a person whose trades are
\nsubject to pre-clearance requests permission to trade in the Company’s
\nsecurities during an event-specific blackout, the General Counsel will inform
\nthe requester of the existence of a blackout period, without disclosing the
\nreason for the blackout. Any person made aware of the existence of an
\nevent-specific blackout should not disclose the existence of the blackout to any
\nother person. The failure of the General Counsel to designate a person as being
\nsubject to an event-specific blackout will not relieve that person of the
\nobligation not to trade while aware of material nonpublic information.<\/p>\n<\/p>\n

Miscellaneous<\/u><\/strong><\/p>\n<\/p>\n

No Circumvention<\/u><\/em><\/p>\n<\/p>\n

No circumvention of this policy is permitted. Do not try to accomplish
\nindirectly what is prohibited directly by this policy. The short-term benefits
\nto an individual cannot outweigh the potential liability that may result when an
\nemployee is involved in the illegal trading of securities.<\/p>\n<\/p>\n<\/p>\n

Amendments, Waivers<\/u><\/em><\/p>\n<\/p>\n

The Board of Directors of the Company reserves the right to amend this policy
\nat any time. The Board of Directors of the Company, a committee of the Board,
\nand, in some circumstances, their designees, may grant a waiver of this policy
\non a case-by-case basis, but only under special circumstances.<\/p>\n<\/p>\n<\/p>\n

Trade Reversals<\/u><\/em><\/p>\n<\/p>\n

Should any individual violate any aspect of this Policy, the Company will
\ntake actions to reverse the execution of the stock option trade and the
\nindividual shall be responsible for any and all costs and losses that may be
\nincurred.<\/p>\n<\/p>\n

Power of Attorney<\/u><\/em><\/p>\n<\/p>\n

In order to enable the company to prepare and file the Forms 4 or other SEC
\nrequired documents on a timely basis, certain directors and officers will be
\nasked to sign and return a company prepared power of attorney.<\/p>\n<\/p>\n

Post-Termination Transactions.<\/u><\/em><\/p>\n<\/p>\n

This Insider Trading Policy continues to apply to your transactions in
\nCompany securities even after you have terminated employment. If you are in
\npossession of material nonpublic information when your employment terminates,
\nyou may not trade in Company securities until that information has become public
\nor is no longer material.<\/p>\n<\/p>\n

\n

INSIDER TRADING POLICY<\/strong><\/p>\n

\n

\n

Company Assistance.<\/u><\/em><\/p>\n<\/p>\n

Any person who has a question about this Insider Trading Policy or its
\napplication to any proposed transaction may obtain additional guidance from the
\nGeneral Counsel. Ultimately, however, the responsibility for adhering to this
\nInsider Trading Policy and avoiding unlawful transactions rests with the
\nindividual employee.<\/p>\n<\/p>\n

Employee Obligation.<\/u><\/em><\/p>\n<\/p>\n

All employees will be provided a copy of this Insider Trading Policy and are
\nexpected to read and understand their obligations under this Policy. If you have
\nany questions regarding your obligations under this Policy, you should
\nimmediately contact the General Counsel to obtain clarification. Ignorance is
\nnot an excuse for non-compliance.<\/p>\n<\/p><\/p>\n","protected":false},"template":"","meta":{"_acf_changed":false,"_stopmodifiedupdate":true,"_modified_date":"","_cloudinary_featured_overwrite":false},"corporate_contracts_companies":[7728],"corporate_contracts_industries":[9455],"corporate_contracts_types":[9553],"class_list":["post-40839","corporate_contracts","type-corporate_contracts","status-publish","hentry","corporate_contracts_companies-harsco-corp","corporate_contracts_industries-manufacturing__metal","corporate_contracts_types-corporate"],"acf":[],"_links":{"self":[{"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/corporate_contracts\/40839","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/corporate_contracts"}],"about":[{"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/types\/corporate_contracts"}],"wp:attachment":[{"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/media?parent=40839"}],"wp:term":[{"taxonomy":"corporate_contracts_companies","embeddable":true,"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/corporate_contracts_companies?post=40839"},{"taxonomy":"corporate_contracts_industries","embeddable":true,"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/corporate_contracts_industries?post=40839"},{"taxonomy":"corporate_contracts_types","embeddable":true,"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/corporate_contracts_types?post=40839"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}