Under U.S. insider trading laws, you and your immediate family members may not, either directly or through other persons or entities, buy or sell CA Technologies securities (such as stocks, bonds, or put or call options) while you are in possession of material non-public information relating to the Company, even if the decision to trade is based on other factors. These laws—including the definitions of "material" and "non-public" and other types of transactions covered—are very broad. If you are considering engaging in a transaction in CA Technologies securities you should first review our Policy Against Insider Trading and Tipping to ensure that any such activity is in compliance with our Policy. If you have any questions or concerns about the Policy or generally around the rules governing the trading of CA Technologies securities, please contact a member of the Worldwide Law Department for advice.
In addition, there may be situations where through your work at CA Technologies you receive material non-public information about another company. Trading in the securities of that company under these circumstances is also prohibited by our Policy and the law.
Finally, you should never recommend or suggest that anyone else buy or sell the securities of CA Technologies or another company while you are in possession of material non-public information. Such "tipping" can be every bit as illegal as engaging in trading that is prohibited by insider trading rules.