Apple Adds Explicit Ban on Confidential Information Use in Prediction Markets to Insider Trading Policy
Apple updated its insider trading policy to ban use of confidential information for prediction market trades, even where not illegal under law. The rules, in the fiscal 2026 Form 10-K, extend to former employees, business partners and lift only after public announcements. It follows cases like Gannon Ken Van Dyke's alleged $409,000 Polymarket gains from a $33,000 stake.
SCCG Take — The policy exceeds statutory insider trading limits, signaling corporate tightening of information controls that prediction market operators must factor into counterparty compliance.
Apple has introduced an explicit ban on employees using confidential company information to trade on prediction markets, incorporating the prohibition into its revised insider trading policy. The update was disclosed in the company's fiscal 2026 Form 10-K published on November 3. It covers event contracts linked to future outcomes involving Apple and the organizations with which it does business.
The policy prohibits 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. Apple defines confidential information broadly, including material non-public information.
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.
Scope Covering Business Partners
The policy also applies to confidential information concerning suppliers, manufacturers, vendors, customers, including mobile network carriers and other business partners. This development arrives as concerns grow over the potential use of non-public information in prediction markets.
As reported by Focus Gaming News, in April special forces soldier Gannon Ken Van Dyke was indicted on three counts of violating the Commodity Exchange Act, as well as wire fraud and conducting an unlawful monetary transaction. Van Dyke allegedly used confidential information about the operation to capture Venezuelan leader Nicolás Maduro to place successful trades on Polymarket. He is alleged to have earned approximately US$409,000 from an investment of around US$33,000.
Where the Policy Draws the Line
By extending beyond what securities laws require and reaching former employees, the policy sets a clear corporate boundary on information use in this space. The approach addresses specific risks from expanding prediction market activity while tying relief from restrictions to public announcements. Such measures highlight the need for platforms to monitor how counterparties define and enforce information controls.
Gaming, betting and prediction markets — the desk’s read, every weekday.
Subscribe →