“Nonpublic information” is information that is known
within the Company and has not been publicly
released. “Material information” is information that
a reasonable investor would consider important when
deciding to buy or sell securities. Employees who are
in possession of material nonpublic information maynot complete a security transaction until the first
business day that is at least 24 hours after the time that
the information is publicly released. Some examples
of nonpublic information that could be considered
material include:
• Financial forecasts
• Changes in sales, market share or production
• Changes in debt ratings or analyst upgrades or
downgrades of Chevron securities
• Earnings, dividends or stock splits
• Proposed mergers, acquisitions or divestitures
• Marketing plans
• Strategic plans
• New product information
• Changes in top management
Whether any particular information could be
considered “material” by a reasonable investor
depends on specific circumstances. A major factor
in determining whether information is material
is the impact that information could have on the
Company’s financial condition or stock price. If you
are in doubt as to whether nonpublic information you
have is material, you should seek guidance from your
supervisor or your local Chevron legal counsel.