Please note that the window for buying and selling Groupon stock closes at the end of the day on Tuesday, September 15, 2015. The window will open again after we announce our third quarter results. We have not yet announced our earnings release date for the third quarter.
Under our Insider Trading Policy, all employees and others covered by the policy (including immediate family members) may trade Groupon stock beginning two full trading days after our earnings announcement through the 15th calendar day of the last month of that current quarter. So, for example, if we announce our earnings on Thursday, October 29, 2015, the next trading window will open on Tuesday, November 3, 2015, and you will be eligible to trade through the close of trading on December 15, 2015, subject to compliance with our policy.
As a reminder, no matter whether the trading window is open or closed, our policy and U.S. law (as well as the laws of many other countries) prohibit trading of Groupon stock any time you are in possession of material, non-public information about Groupon. Examples of potential material, non-public information include financial results, merger and acquisition activity, important metrics such as mobile activations and significant product launches. Our policy has a few limited exceptions, including gifts of stock, sales made by Groupon on our employees’ behalf to cover taxes on vesting RSUs, and sales made through pre-approved 10b5-1 plans. In addition, our policy also prohibits short sales, pledging Groupon stock (subject to limited exceptions) and any options trading in Groupon stock at any time, even during an open trading window. You can review our Insider Trading Policy here.
If you have any questions relating to our policy, please feel free to contact me or Erin Stone (estone@groupon.com). If you have questions about your stock plan account, please contact Total Rewards (totalrewards@groupon.com).
Thank you,
Dane Drobny
General Counsel