22 AAR Doing it right for our company Complying with Investigations and Audits At times, we may be asked to provide information in connection with an audit, inquiry or investigation. We have a responsibility to comply with these requests. How we own it • Be honest. • Cooperate fully with any request for information from an internal or external auditor, director of the Company, our General Counsel or any other authorized representative. • Provide all the information you have. • Do not conceal, alter or destroy any records, and do not try to interfere with any audit or investigation process. If you have questions about participating in an audit or investigation, contact an attorney in the Law Department. Avoiding insider trading During the course of our work, we may have access to material non-public information, or inside information, about AAR or another company with whom we do business. Information is material if a reasonable investor would consider it important when making a decision to hold, sell or buy a company’s stock. Information is considered non-public until it has been communicated to the marketplace and the market has had time to absorb it—usually a day or two. How we own it • Be able to identify common examples of inside information: financial results or forecasts, major personnel or management changes, new service or solution offerings or the gain or loss of a major customer. • Do not trade in the stock of any company while you have inside information about that company. • Never “tip” inside information to family or friends, or even to co-workers who do not have a business need to know it. If you have questions about the right way to handle inside information, speak to an attorney in our Law Department. See the Insider Trading policy for more information.
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