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 Corporations 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.