Inside Information and Share Dealing​ Policy​

• do not deal in Rolls-Royce shares without obtaining clearance to deal first, if we have been notified that this restriction applies to us;
• do not deal in Rolls-Royce shares in a Closed Period, if we have been notified that this restriction applies to us;
• if we have been notified that we are included on a Confidential Project List we:
  • do not disclose the confidential information to anyone else;
  • acknowledge the notification and our obligations; and
  • contact the project manager first if we think we need to share the Confidential Information with a colleague;
• complete annual training to ensure we understand our obligations under MAR, if we have been notified that this is required;
• do not deal in Rolls-Royce shares on a short-Term nature;
• do not trade in options or other financial instruments in respect of Rolls-Royce shares;
• contact the Corporate Governance Director immediately if we think we have access to Inside Information but have not been advised that we are on an Insider List;
• if advised that we are on an Insider List, we:
  • do not deal in Rolls-Royce shares or make recommendations to others until we have been advised otherwise;
  • do not disclose the Inside Information to anyone else;
  • acknowledge our obligations and provide the required personal information immediately; and
  • contact the Corporate Governance Director first if we think we need to share the Inside Information with a colleague, recognising that failure to do so would be putting our colleagues at risk of committing a market abuse offence; and
• read the introduction to our Code and Group Policies to understand to whom they apply and the consequences for breaching them.

*Short-term trading means the acquisition and disposal (or vice versa) of shares within a 12-month period.
The short-term trading restriction excludes shares acquired through Rolls-Royce share plans.