TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED HELPLINE 36 We play fair when buying or selling stock Our promise To never use or share inside information to gain an unfair advantage What are some examples of Our process “inside information”? There may be times when we learn information about our Company, or companies It could be nonpublic information about: we work with, that isn’t known to the public. If that nonpublic information is + Mergers or acquisitions + Changes in leadership signi昀椀cant enough that it could a昀昀ect the price of a stock (or other type of security) + New products and + Projected earnings then it is considered inside information. We never use inside information to our services or losses advantage, and we never pass along inside information so that others may do so. + Strategic business plans + Pending lawsuits We know how to identify inside information. Inside information is both: + Material, meaning it could in昀氀uence an investor to buy or sell stock + Nonpublic, meaning it hasn’t been released to the public THINK ABOUT IT We respect inside information. When we have inside information, we don’t Q: I am part of the broader team that is in the process of helping Prologis buy or sell stock or other securities (“trade”), and we don’t pass it along to acquire one of our competitors by merger. The proposed merger has not others (“tip”). We only share it with coworkers and business partners on a yet been publicly announced. I know I can’t share the inside information need-to-know basis. I have learned, but would it be OK if I just bought stock in the company at We pay attention to blackout periods. Depending on our jobs, some of us current stock market prices? may at times be subject to additional trading restrictions—meaning we can’t A: No. It’s against Company policy to purchase or sell shares in the company buy or sell Company stock regardless of what we know. It’s important that we that Prologis seeks to acquire by merger while you have inside information. learn the rules before we trade. Even though you’re not actually sharing the information, you would still be We follow our fair disclosure obligations. If we as a company do disclose gaining an unfair advantage. material, nonpublic information, whether intentional or non-intentional, we always do it in accordance with legal requirements and we do so publicly. This way, we can be sure that the investing public as a whole has the LEARN MORE same information. Prologis Insider Trading Policy Prologis Global Policy on Financial Reporting, Disclosure of Material Information and Fair Disclosure Code of Ethics and Business Conduct Ethics Helpline
