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The policy applies to Covered Persons including employees, contingent labor, consultants, contractors, agents, and Board members, and defines penalties for violations, including criminal and civil exposure for individuals and the company. It restricts Covered Persons from trading Boeing or related securities while possessing Material Nonpublic Information, prohibits improper communication and recommendations, and establishes timing rules such as a 48-hour post-announcement waiting period and trading-window guidance after SEC filings.",{"@graph":69,"@context":122},[70,84,105],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/prohibition-on-insider-trading-requirements-compliance-policy/639170/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/prohibition-on-insider-trading-requirements-compliance-policy/639170.png","ImageObject",300,407,{"name":92,"@type":93},"jayni","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-10-24","2026-10-22",true,{"@type":102,"interactionType":103,"userInteractionCount":8},"InteractionCounter",{"@type":104},"ViewAction",{"@type":106,"mainEntity":107},"FAQPage",[108,114,118],{"name":109,"@type":110,"acceptedAnswer":111},"Who must comply with the insider trading prohibition policy?","Question",{"text":112,"@type":113},"All employees, contingent labor, consultants, contractors, agents, and members of the Board of Directors are covered as “Covered Persons,” with additional obligations for those who receive Material Nonpublic Information from a Covered Person.","Answer",{"name":115,"@type":110,"acceptedAnswer":116},"What trading is prohibited for Covered Persons when they have Material Nonpublic Information?",{"text":117,"@type":113},"Covered Persons may not trade Boeing stock or other covered securities, including securities of certain customers, suppliers, parties Boeing is negotiating with, and potential corporate development counterparties, when they are aware of Material Nonpublic Information.",{"name":119,"@type":110,"acceptedAnswer":120},"When can Covered Persons trade after information becomes publicly disclosed?",{"text":121,"@type":113},"After Material Nonpublic Information is publicly disclosed via a press release or official announcement, Covered Persons should not trade until 48 hours following the announcement, including at least several hours when the New York Stock Exchange is open.","https://schema.org",{"og:url":83,"og:type":124,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":126,"canonical":83},"index,follow",{"doc_id":128,"site_id":62},639170,1792811165,{"code":4,"msg":5,"data":131},{"doc_id":128,"user_id":132,"nickname":92,"user_avatar":133,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":8,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":29,"language":139,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":140,"faqs":141,"seo_title":142,"seo_description":67,"update_tm":143,"read_time":144},3985747859343,"https://ap-avatar.wpscdn.com/davatar_276721f389ce27ea32af1340a28f341c","Prohibition on Insider Trading  \nPurpose  \nThis PRO explains the prohibition, based on federal securities law, against “insider trading” and establishes the enterprise-wide control structure to promote and monitor compliance.  \nThis PRO applies to all employees, contingent labor, consultants, contractors, agents, and members of the Board of Directors (each, a“Covered Person”) .  \nPenalties for non-compliance include:  \n1. Under federal securities laws, individuals who engage in insider trading or tipping can face substantial criminal and civil penalties, including imprisonment and significant criminal fines and civil penalties.  \n2. Boeing could also face severe criminal and civil penalties as a consequence of a Covered Person’s insider trading or tipping, and individual controlling persons (e.g. , directors, officers, supervisory personnel) could also be liable for civil penalties as a result of such transactions.  \n3. Covered Persons who fail to comply with this PRO may also be subject to company-imposed sanctions, including dismissal for cause, whether or not the failure to comply results in a violation of law.  \nApplies To  \n\n| Function | Business Unit / Operating Group | Program | Location |\n| --- | --- | --- | --- |\n| All Functions | All Boeing | All Boeing\u003Cbr>Programs | All Locations |\n\n1. Requirements  \nA. Covered Persons may not Trade in the stock or other securities of Boeing or the companies noted below, when that person, as a result of Boeing employment or service, is aware of Material Nonpublic Information about Boeing or that company.  \n1. This restriction includes Trading in the securities of Boeing and the securities of companies that are current or prospective customers or suppliers of Boeing, those with which Boeing may currently be  \nnegotiating to do business, and those that are involved in potential corporate development transactions with Boeing (such as mergersand acquisitions) .  \n2. Covered Persons may not communicate Material Nonpublic Information learned or developed through Boeing employment or service (“tipping”) to other persons within Boeing whose jobs do not require them to have that information, or outside Boeing unless such disclosure is made in accordance with Boeing’s policies, and may not recommend that anyone purchase, hold, or sell any securities on the basis of such information.  \nNote: Family Members or Insider Entities and others who have received Material Nonpublic Information from a Covered Person are not permitted to Trade in securities of Boeing and other securities covered by this PRO. It is the obligation of each Covered Person to make Family Members and Insider Entities aware of, and understand and comply with, the provisions and obligations of this PRO.  \n3. After Material Nonpublic Information learned or developed through Boeing employment or service has been publicly disclosed through a press release or other official announcement, Covered Persons should not Trade in the securities until 48 hours following the announcement, which period must include at least several hours during which the New York Stock Exchange is open for trading, to allow the market to absorb the information.  \n4. Certain elections affecting balances in or contributions into or out of the Boeing Stock Fund within The Boeing Company 401(k) Plan, The Boeing Company Supplemental Savings Plan and The Boeing Company Executive Supplemental Savings Plan (together, the“Plans”) are treated as Trading in Boeing securities, including:  \na. Transfers of any amount into or out of the Boeing Stock Fund of any of the Plans.  \nb. A reallocation of balances that affects your Boeing Stock Fund balance in any of the Plans.  \nc. An election to have future contributions to any of the Plans invested in the Boeing Stock Fund or any cancellation of or change in such an election.  \nd. An election into or out of the rebalancing program in The Boeing Company 401(k) Plan and modification of a prior rebalancing election.  \ne. Signing u","cbCaia4CZq2CBZcb","https://ap.wps.com/l/cbCaia4CZq2CBZcb","pdf",96379,"English","# Purpose\n# Applies To\n# Penalties for Non-Compliance\n# Requirements\n## Covered Person Trading Restrictions\n## Prohibited Tipping and Recommendations\n## Post-Disclosure Waiting Period\n## Special Treatment for Elections and Plan Transactions\n## Trading Window and Derivatives/Short Sales Guidance\n## Designated Insider Pre-Clearance Requirements","[{\"question\":\"Who must comply with the insider trading prohibition policy?\",\"answer\":\"All employees, contingent labor, consultants, contractors, agents, and members of the Board of Directors are covered as “Covered Persons,” with additional obligations for those who receive Material Nonpublic Information from a Covered Person.\"},{\"question\":\"What trading is prohibited for Covered Persons when they have Material Nonpublic Information?\",\"answer\":\"Covered Persons may not trade Boeing stock or other covered securities, including securities of certain customers, suppliers, parties Boeing is negotiating with, and potential corporate development counterparties, when they are aware of Material Nonpublic Information.\"},{\"question\":\"When can Covered Persons trade after information becomes publicly disclosed?\",\"answer\":\"After Material Nonpublic Information is publicly disclosed via a press release or official announcement, Covered Persons should not trade until 48 hours following the announcement, including at least several hours when the New York Stock Exchange is open.\"}]","Prohibition on Insider Trading - Requirements - Compliance Policy | PDF",1792702118,15]