November 27, 2024 – 10-K Annual Report: Ex-19 Filing for Section 13 and 15(d) Compliance

As of July 31, 2024, Becton, Dickinson and Company (BD) has put in place a strict policy to prevent insider trading and ensure that all employees and directors act in accordance with the law when trading securities. The purpose behind this policy is to maintain a level playing field for all individuals trading in BD securities, ensuring that everyone has access to the same important information about the company.

Violating insider trading laws can lead to serious consequences, including civil or criminal penalties from regulatory bodies like the Securities and Exchange Commission (SEC) and the Department of Justice. These penalties can mean hefty fines and even prison time. It’s essential for every employee and director at BD to follow this policy to the letter, as failure to comply could result in severe sanctions, including termination.

This policy extends to all majority-owned or controlled subsidiaries of BD and is a global standard that all directors and employees must adhere to. Additionally, directors and employees in supervisory roles must ensure that those under their supervision also follow these guidelines.

Individuals covered by this policy include not only directors and employees but also their family members and anyone living in their household. This means that any trades made by family members, even if financially independent, should be treated as if they were made by the director or employee themselves. The same goes for any entities controlled by the director or employee.

In addition, there is a group of individuals known as the “Restricted Group” who are subject to even stricter rules and procedures laid out in the policy. These individuals are listed separately and can be updated at the discretion of the General Counsel.

Overall, the policy prohibits any director or employee from engaging in transactions involving BD securities while in possession of non-public material information about the company. This includes buying or selling stock, bonds, or other securities, as well as giving advice or recommendations related to BD securities. It also prohibits disclosing inside information to individuals who do not require it for their jobs or to persons outside of BD. Any trades made with such insider knowledge violate the policy and could lead to serious consequences.

It’s crucial for everyone at BD to understand and adhere to these guidelines to ensure compliance with securities laws and maintain the integrity of the company.