Inside Information and Share Dealing Policy

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Principles

As a company listed on the London Stock Exchange, we comply with our obligations, including under the UK Market Abuse Regulation (MAR). This is so we avoid committing a share dealing or market abuse offence.
Under MAR, it is an offence to:
- deal in Rolls-Royce shares while in possession of Inside Information or recommend to someone that they deal in shares based on Inside Information;
- share / disclose Inside Information, other than in accordance with MAR’s procedures; and
- do anything which gives false or misleading signals regarding Rolls-Royce shares, including the price.
The Disclosure Committee of Rolls-Royce Holdings plc determines whether Inside Information exists and when it should be made public.

We

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 (that is the sale of shares within a year of them being purchased), except where shares are being sold to satisfy tax liabilities;
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.

Leaders

Our general expectations of leaders in relation to Our Code and Group Policies are set out in the introduction.

Our Code

Take a look back at our Code principles related to this policy:

Additional Guidance

Some of these are internal links and only available if accessing from a Rolls-Royce GAD network asset.

The Corporate Governance zone on the Governance Team Engine Room pages including:
- Share Dealing Guidelines and Clearance to Deal infographic
- Share Dealing Guidelines for PDMRs and infographic
- Guidance for our MAR Champions
Insidertrack web portal - the portal that we use to manage inside information, confidential information and share dealing
Group Decision Rights
Speak Up Policy

Contacts

Some of these are internal links and only available if accessing from a Rolls-Royce GAD network asset.

Governance Team – [email protected]
- For any general queries or advice
Corporate Governance Director
- For queries about Inside Information

Take a look back at our Code principles related to this policy:

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Inside Information and Share Dealing​ Policy​

Principles

We

Leaders

Inside Information and Share Dealing Policy