Rs, Actually that is a fairly interesting question that might make a good final exam question for a law school Corporate Law exam. I think the answer is that it would be a violation, as the law is directed at those who acquire information from a privileged position, not whether or not they work for the issuer. If you were the security guard and saw exec's coming and going from Becthel offices and put two and two together, probably not a violation. If you were in on the contract award, I think you have material nonpublic information and cannot trade on it. Now I am assuming Bechtel awarded a contract to a specific company. If you bought shares in Bechtel suppliers on the theory that good times at Bechtel will lift all boats, then I don't see a violation.