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If you have access to confidential information, you are not permitted to use or share that information for stock trading purposes or for any other purpose except the conduct of our business.
Insider Trading
 Inside information is material information about a publicly traded company that is not known by the public. Information is deemed “material” if it could affect the market price of a security or if a reasonable investor would consider the information important in deciding whether to buy, sell or hold a security. Inside information typically relates to financial conditions, such as progress toward achieving revenue and earnings targets or projections of future earnings or losses of the Company. To the extent material and nonpublic, inside information also includes changes in strategy, information regarding a proposed merger, acquisition or tender offer, new products or services, contract awards and other similar information. Inside information is not limited to information about National. It also includes material non-public information about others, including National's customers, suppliers, and competitors.
Insider trading is prohibited by law. It occurs when an individual with material, non-public information trades securities or communicates such information to others who trade. The person who trades or “tips” information violates the law if he or she has a duty or relationship of trust and confidence not to use the information.
Trading or helping others trade while aware of inside information has potential serious legal consequences, even if the insider does not receive any personal financial benefit. Insiders may also have an obligation to take appropriate steps to prevent insider trading by others.
Communications with the Media and the Financial Community
National communicates with the press and with the financial community through official channels only and you should not communicate with the press or financial community unless you have been specifically authorized to do so. The Company provides accurate and timely information about its business to investors, the media, and the general public. All inquiries received from financial analysts or the media concerning National should be directed to National Investor Relations. All legal inquiries concerning National should be referred to the Legal Department. All inquiries regarding current or former employees of National should be referred to the Human Resources Department.
Confidential Information
You must maintain the confidentiality of information entrusted to you by the Company or its customers, suppliers, employees or other persons except when disclosure is authorized or legally mandated. Confidential information includes all non-public information, including information that might be of use to competitors, or harmful to the Company or its customers if disclosed. You must use the same care to protect any confidential information entrusted to the Company which belongs to customers, suppliers, the Company’s employees, or other persons, as must be used to protect the Company’s assets and confidential information.
The Company expects all of its employees to educate themselves about and be alert to threats to security of confidential information entrusted to the Company and its employees.
Confidential information within the Company’s possession can include (i) confidential proprietary information about the Company’s business including but not limited to trade secrets, other proprietary information, and information which may be patentable; (ii) confidential information entrusted to the Company by third parties such as customers, suppliers, or other third parties; and (iii) personally identifiable information received from employees, customers, suppliers, or other third parties which if misused could result in identity theft, credit card fraud or other serious harm.
As noted above, personal information may be subject to protection under federal, state or local laws in the U.S., or under laws of other countries and may not be transmitted from one country to another country without prior managerial approval.
Confidential information may not be disposed of except pursuant to the Company’s approved methods of disposal. If you have questions about how to appropriately handle or dispose of confidential information, you should immediately bring your questions to the attention of management before taking any action with respect to it.
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