Protecting Confidential Information
Information to be Protected
Confidential Information is all Company information (or information others have entrusted to Tronox) that is:
Not generally known by the public;
Might be of use to competitors if disclosed; or
Is harmful to Tronox (or its customers or business partners) if disclosed.
Material, non-public information may come in the form of business plans or other documents, conversations, or even through knowledge of an imminent press release, and must be treated carefully to maintain its confidentiality.
Generally, information is “material” if an investor would:
• Consider it important in deciding whether to buy or sell the Company’s securities; or
• View the information as having significantly altered the total mix of available information about the Company’s securities.
If you have any doubt whatsoever as to whether certain information is “material” you need to resolve all doubt before making any determination.
Additional language about trade secrets and proprietary information may be found in the section on Protecting Corporate Assets.
Everyone should feel comfortable reporting violations.
Tronox will neither retaliate nor tolerate any harassment or retaliation against anyone for reporting, in good faith, suspected violations of laws, regulations, or Tronox policies or procedures, including this Code.
Making a report in good faith does not mean you have to be certain that something unethical is happening – it just means that you have a genuine reason to believe something is wrong.
Retaliation means any negative employment action taken against someone because he or she has made a report in good faith or is going to make a report in the future. Specifically, this means Tronox will not terminate, demote, transfer to a less desirable assignment, or otherwise discriminate against you for calling attention to acts that are suspected to be illegal, unethical, or in violation of this Code, or for providing information relating to an investigation thereof.
However, Tronox reserves the right to discipline anyone who: (1) knowingly makes a false accusation; (2) provides false information to Tronox; (3) violates this Code, any applicable law, or other Tronox policies or procedures; or (4) has otherwise acted improperly.