Avoiding insider trading
We never act on material nonpublic information for the benefit of us or others
We maintain trust with our investors and the public by complying with applicable financial laws, which means we do not trade, or tip others to trade, based on material nonpublic information.
Material nonpublic information includes any information that has not been widely disclosed to the general public and is likely to influence an investor to buy, hold, or sell securities.
Some examples of material nonpublic information include:
- Unannounced financial earnings
- Operational metrics & Key Performance Indicators
- Forecasts
- Business plans or budgets
- Changes in leadership
- Any other company confidential information that could have an impact on stock price
As part of your duties, you may obtain access to inside, or material, nonpublic information about AppFolio, our customers, and our business partners. You have a responsibility to keep this information private and avoid acting on it for personal gain.
This includes disclosing material nonpublic information (also referred to as "tipping") to others including immediate and household family members or anyone not authorized to receive it. Doing so can result in serious penalties, including fines and reputational risk for you and the company.
Blackout periods: AppFolio has a policy that establishes periods during which individuals with access to inside information cannot trade AppFolio stock. These periods are designed to help prevent insider trading violations that may result from acting on material nonpublic information. Insiders can only transact during open trading windows, which align with the release of the company’s financial information. View AppFolio’s Insider Trading Policy for more information on these periods and when you can and can’t trade.
Do
- Know the rules surrounding AppFolio's Open Window and Blackout Periods and how to obtain pre-clearance before buying or selling securities – review our Insider Trading Policy for additional guidance
- Tell the Compliance & Ethics team immediately if you inadvertently disclose inside information about AppFolio to an outsider
Don't
- Buy or sell AppFolio securities based on material, nonpublic information
- Recommend or suggest that anyone else trade in the securities of AppFolio or any company based on material nonpublic information, even if we are not sharing the information itself
- Give someone else (for example, a friend, spouse, or broker) a “tip” regarding material, nonpublic information
- Buy or sell the securities of other companies if you possess material nonpublic information about those companies through your work at AppFolio
- Buy or sell AppFolio securities based on material, nonpublic information
Resources:
Contact Information:
- Compliance & Ethics: [email protected]
- AppFolio Pre-Clearance: [email protected]
Frequently asked questions
A: No. It’s likely that information has not been made public yet, which means it is material nonpublic information. Tipping off your brother with this information to help his financial decision-making is illegal and could result in serious penalties.
A: Penalties for violating insider trading laws can be severe, both for individuals and the company and can include jail time and serious fines, as well as reputational damage.
A: No. Acting on this information is considered insider trading and is prohibited.
A: No. Do not engage with companies looking to obtain confidential information about AppFolio, its customers, or its partners. If you have been contacted by a company seeking information, contact the Legal & Compliance Team for guidance.
A: Contact the Compliance & Ethics Team or the Pre-Clearance Team for further guidance.
Key Takeaways
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Protect inside information about AppFolio and our business partners. Inside information includes any material nonpublic information that can influence investment decisions. Never act on or share information that can be used for personal gain.
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Don't trade on inside information. We maintain trust with our investors and the public by respecting financial laws, which means we do not trade based on material nonpublic information.
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Speak up. If you’re unsure whether you possess inside information that may improperly influence a future investment decision or transaction, or if you inadvertently disclose inside information, please contact the Compliance & Ethics Team or the Pre-Clearance Team.