Apple bans prediction market trades using confidential data
The policy applies even where the conduct would not count as insider trading under law, and extends to former and dismissed employees.
Key takeaways:
- Apple has added an explicit ban on employees using confidential company information to trade on prediction markets to its revised insider trading policy.
- Employees cannot wager, buy, sell or trade contracts using Apple Confidential Information, or share it with others who could do so.
- The restriction applies even when the conduct would not qualify as insider trading or securities trading under applicable laws.
US.- Apple has introduced an explicit ban on employees using confidential company information to trade on prediction markets, adding the activity to its revised insider trading policy. The company disclosed the rules in its fiscal 2026 Form 10-K, published on November 3, and they cover event contracts linked to future outcomes involving Apple and organisations with which it does business.
The policy prohibits employees from wagering, buying, selling or trading contracts on prediction markets and similar platforms when those transactions involve Apple-related confidential information. It also prevents staff from sharing such information with others who could use it to place bets or trade event contracts. It also applies to confidential information concerning suppliers, manufacturers, vendors, customers, including mobile network carriers and other business partners.
Apple defines confidential information broadly, including material non-public information. The policy states that the restriction applies even when the conduct would not qualify as insider trading or securities trading under applicable laws. The rules extend to individuals who have left Apple or been dismissed. Restrictions no longer apply once the relevant product, service or update has been publicly announced, as the information is then available to the market.
The policy comes as concerns grow over the potential use of non-public information in prediction markets. In April, special forces soldier Gannon Ken Van Dyke was indicted on three counts of violating the Commodity Exchange Act (CEA), as well as wire fraud and conducting an unlawful monetary transaction for allegedly using confidential information about the operation to capture Venezuelan leader Nicolás Maduro to place successful trades on Polymarket. He’s alleged to have earned approximately US$409,000 from an investment of around US$33,000.
Frequently asked questions (FAQs)
- What does Apple’s prediction market policy prohibit? Employees cannot wager, buy, sell or trade contracts on prediction markets and similar platforms when the transactions involve Apple Confidential Information. They also cannot share that information with others who could use it to place bets or trade event contracts.
- Does Apple’s ban apply to former employees? Yes. The rules also cover individuals who have left Apple or been dismissed. The restrictions no longer apply once the relevant product, service or update has been publicly announced, because the information is then available to the market.
- Does the policy cover information about Apple’s partners? Yes. It also applies to confidential information about suppliers, manufacturers, vendors and customers, including mobile network carriers and other business partners. Apple defines Confidential Information broadly, including material non-public information.
