GE Vernova (GEV) 10-K 2024 FY Annual report

Exhibit 19.1__

WHAT TO KNOW

•Prohibition on insider trading and stock tipping.  Insider trading and stock tipping are criminal

and civil offenses that can result in fines, imprisonment of up to 20 years and other penalties and

may result in disciplinary action at GE Vernova, including termination of employment.

•This policy establishes standards of conduct for employees and others who obtain material or

price-sensitive nonpublic information through their work for GE Vernova to ensure full compliance

with laws prohibiting (and to avoid even the appearance of) insider trading and stock tipping. 

•Insider trading means buying or selling stock or other securities of any company while in

possession of material nonpublic information about the company.

•Stock tipping means sharing material nonpublic information about a company with a person who

buys or sells stock or other securities of the company while aware of such information.

HOW TO COMPLY

•When not to trade. Never buy or sell the stock or other securities of any company, including GE

Vernova, while you have material nonpublic information about the company.

•Giving stock tips.  Never recommend or suggest that anyone else buy or sell the stock or other

securities of any company, including GE Vernova, while you have material nonpublic information

about the company.

•When you may disclose information externally.  Never disclose material nonpublic information to

anyone outside GE Vernova (including family members), except when (i) such disclosure is needed

to enable GE Vernova to carry on its business and (ii) appropriate steps have been taken to

prevent trading while aware of the information. If unsure, consult with company legal counsel to

decide whether such disclosure is needed.

•When you may disclose information internally.  Only disclose material nonpublic information

within GE Vernova to others who (i) have a business need to know it and (ii) when you have no

reason to believe that the information will be misused.

•Serving as an independent consultant or adviser. Do not serve as an independent consultant or

adviser outside the company on business matters within the scope of your GE Vernova

employment.

oFor example, independent investment research firms (sometimes called “expert networks”)

or other third parties may seek consultations or informational interviews to learn about GE

Vernova and its businesses, and the requests may even offer to compensate GE Vernova

employees for their time.

oGE Vernova prohibits employees from engaging in such consultations in order to avoid the

risk of disclosing nonpublic information or insider trading violations that these types of

arrangements can create.

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•Additional transaction- and business-specific policies.  Abide by the terms of any non-disclosure

or similar written confidentiality agreement that you may be required to sign in connection with

work on particular deal teams, transactions or other matters.

oIf you work for certain GE Vernova affiliates or components (e.g., businesses that invest in

or trade securities), you may be subject to additional restrictions and requirements. Learn

and follow all such restrictions and requirements.

•Derivative Transactions in GE Vernova Stock. Members of the board of directors and executive

officers should not enter into any derivative transaction in GE Vernova stock. This includes any

short-sale, forward, equity swap, option, or collar that is based on GE Vernova’s stock price.

GET HELP

•If you don’t know whether information in your possession is materialor nonpublic and you have

questions about the implications under this policy, contact legal/compliance.

•Raise an integrity concern right away if you become aware of a potential violation of this policy.

You can raise a concern through our Open Reporting channels.

PENALTIES FOR VIOLATION

Employees who violate the spirit or the letter of GE Vernova’s policies are subject to disciplinary action up

to and including termination of employment if allowed under applicable law. In addition, if laws are

violated, employees or the Company may be subject to criminal penalties (fines or jail time) or civil

sanctions (damage awards or fines). GE Vernova could also lose government contracting privileges and

export privileges. 

DEFINITIONS

•Material information means information that has a reasonable likelihood of being viewed by a

reasonable investor as significantly altering the total mix of information available.  This means

information that is likely to move the price of stocks or other securities, and generally includes

information that is important to analysts and investors or which we have encouraged them to

focus on.   

oExample: Material information may relate to GE Vernova or to one of its customers,

business partners, or suppliers. It may include information concerning financial forecasts

and guidance; earnings, cash flows, or other financial results; liquidity; impairments or

other charges; tax rates; a pending merger, acquisition, disposition, or joint venture; a

substantial contract award or termination; a major lawsuit or claim; a significant

restructuring program; changes in dividend policy or buyback program; significant product

developments; the gain or loss of a significant customer or supplier; government or internal

investigations; changes in leadership; the board of directors; audit matters; current or

potential GE Vernova shareowners; or changes in credit ratings.

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•Nonpublic information means information that is not available to the general public. Information is

considered public if it is communicated by the company by:

opress release,

oSEC filing,

opublic conference calls and webcasts (for which adequate advance notice has been given),

or

oofficial news releases on the company’s website.   

Even after the information is publicly announced, enough time must pass for the market to become fully

aware of the information before it is considered to be public (generally at least 24 hours).

oExample:  If you learn that GE Vernova is considering buying a company or entering into a

major purchase contract, assume the information is nonpublic until after GE Vernova or the

counterparty has publicly announced the transaction and the market has had time to

absorb the information.

•Securities are defined broadly to include any stock, bond, note, debenture, put or call option or

other instrument commonly known as a security.