CONFIDENTIAL, INSIDE, AND PERSONAL INFORMATION
We consider confidential or proprietary information an important asset. You should maintain the confidentiality of any business information that’s been entrusted to you by GATX or any of our business partners, suppliers, or customers. You must not disclose such information unless you’ve been authorized to do so by GATX or it has been legally mandated.
Confidential information includes all non-public information that might be of use tocompetitors or investors or harmful to GATX, or its customers, if disclosed.
As an employee of GATX, you have access to information about our company that may not be available publicly. That information impacts when and how you may buy or sell GATX securities. You may not buy or sell GATX securities if you have material information that’s not available publicly. Other employees, including officers and directors, may not buy or sell GATX securities during an earnings blackout period.This prohibition also extends to your family members, family trusts and other entities that you or your family control. Finally, you may not communicate or “tip” third parties to any material, nonpublic information
You may not buy and sell securities of other companies if your job at GATX gives you access to material, nonpublic information about those companies. When is information considered “material”? When it would have a significant impact on the market price of a company’s stock or if a reasonable investor would consider it important when deciding to buy, sell, or hold stock.
Examples of material information include facts about:
Wherever we do business, we’re committed to complying with laws that govern how personal informationabout current and former employees is collected, used and managed. Transfers of personal informationbetween countries must comply with applicable laws. You should report any concern that personal information isn’t properly protected or has been compromised.
Personal information in any form must be kept confidential, held securely and disclosed only to those who have a legal and legitimate business reason to access it.
We have records retention and disposal procedures to ensure that all GATX records are retained to serve our needs and comply with applicable legal and regulatory requirements. These records include paper and electronic copies of documents. You are expected to know the specific requirements that apply to your area of responsibility. Historical documents or artifacts must be identified and stored in a reasonable manner intended to protect such documents from damage. Contact the Director of Investor Relations with any questions about historical archiving.
If you destroy, shred, delete, or otherwise alter documents or records to impede a governmental investigation, lawsuit, audit or examination, you may be subject to criminal liability. If you aren’t sure whether a document can be destroyed, consult a member of the Law Department before doing so.
GATX public statements must be carefully managed to ensure accuracy, fairness and compliance with legal requirements, as well as to protect ;vour reputation and ensure consistency with our values and brand. If you receive an inquiry from the media, immediately notify the Director of Investor Relations.