EMPLOYEES MAY NOT TRADE STOCK OF AN OPERATING UNIT WHILE IN POSSESSION OF MATERIAL, NONPUBLIC INFORMATION CONCERNING THAT OPERATING UNIT OR AMCOL. This policy applies to all employees of all operating units, regardless of title or function. There are significant civil and criminal penalties which can be imposed upon individuals who break the law in this area.

"Material" information generally has been defined to mean information which might reasonably be expected to affect the market for or price of such stock. It is not feasible to list all kinds of information which might by considered “material,” but some examples are current earnings, proposed changes in dividends, proposed stock splits, major acquisition or divestiture proposals, significant new product developments, and major plant closings.

"Nonpublic" information is information that has not been generally disclosed to the public. Employees coming into possession of non-public material information about an operating unit should refrain from trading in the stock of that operating unit until at least three business days after public announcement by the operating unit of such material information. Equally important, employees of an operating unit must refrain from informing anyone else (including other employees, relatives, or friends) about material information during the same time span.

All of the above applies to any nonpublic material information that an employee receives in the course of employment regarding any other company, such as supplier or customer.