SSW » Topics » Insider Information and Trading

This excerpt taken from the SSW 20-F filed Mar 17, 2006.

Insider Information and Trading

Employees and directors (whether or not citizens of the United States) are prohibited from trading in Corporation stock (the buying or selling of Corporation securities), based on material, non-public information. Information is “material” if it has the potential to affect the price of the Corporation’s stock. It is “non-public” if the information has not been released to



the public at large by means of a filing with the SEC or a press release issued through a major wire service. Furthermore, such information cannot be given to a third party for the purpose of trading in Corporation securities (a practice generally referred to as “tipping”). Additionally, employees and directors (whether or not citizens of the United States) who may have obtained material, non-public information regarding other companies (such as our customers, vendors or competitors) in the course of their employment are prohibited from trading in the securities of such companies.

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