Lawson employees, temporary workers, consultants, and other persons doing business with Lawson might learn or receive access to "material inside information" about Lawson's clients or prospects, or other companies with whom Lawson does business. Examples of "material inside information" include, for example, unannounced quarterly financial results, the win or loss of a large and substantial contract, a large pending acquisition or other non-public information that could reasonably be expected to affect the price of a stock. Using material inside information to buy or sell stock, or tipping others to do so, is a crime and can lead to civil and criminal penalties and liabilities under federal and state securities laws. Lawson employees and members of their family (or other persons) living in the employee's household are subject to Lawson's Insider Trading Policy and Blackout Restrictions, which limits the time periods each fiscal quarter when those persons can buy or sell Lawson stock on Nasdaq.

Lawson employees should review Lawson's Policy titled "Insider Trading and Blackout Restrictions" policy located on the employee portal under the Employee Self Service section. Access ERG Policy 3.71 through the Handbook section.

You should ask yourself:

• Does information I have learned about the company make me want to buy or sell stock?
• If the newspaper published what I know, would it make the company's stock rise or fall?
• How would the stock trade I am considering look to government prosecutors if it became the subject of an investigation?

Members of the greater Lawson community can obtain a copy of Lawson's Insider Trading and Blackout Restrictions from Lawson's Legal Department.

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