AECOM legal chief reports RSU vesting and 10b5-1 stock sales

AECOM chief legal officer David Gan reported multiple equity award and stock transactions in December 2025.

Accepted by SEC EDGAR 12/17/2025 - 04:06 PM EST Learn about SEC filing dates

Rhea-AI Filing Summary

AECOM chief legal officer David Gan reported multiple equity award and stock transactions in December 2025. On December 15, 2025, 5,976 restricted stock units granted on December 15, 2022 vested into common shares, he received an annual grant of 6,534 restricted stock units that vest in full on December 15, 2028, and acquired 14,056 shares under AECOM’s Performance Earnings Program. Shares were also withheld to satisfy tax withholding obligations related to these awards.

Gan sold 6,000 shares of AECOM common stock on December 15, 2025 at $98.85 per share and 9,502 shares on December 17, 2025 at $97.01 per share, with these sales effected under a Rule 10b5-1 trading plan adopted on August 15, 2025. After the reported transactions, he directly owned 41,549 shares of AECOM common stock and held 576.55 shares indirectly through the AECOM Retirement & Savings Plan.

Insider Trade Summary

Exercise and sale activity reported; no spread calculated

Exercise and Sale 7 txns

Insider Gan David Y.

Role CHIEF LEGAL OFFICER

Sold 15,502 shs ($1.51M)

Approx. gross sale proceeds $1.51M

Approx. exercise cost $0.00

Share of Position Sold 27.2%

Type	Security	Shares	Price	Value
Sale	Common Stock	9,502	$97.01	$922K
Exercise	Restricted Stock Units	5,976	$0.00	$0.00
Exercise	Common Stock	5,976	$0.00	$0.00
Grant/Award	Common Stock	6,534	$0.00	$0.00
Grant/Award	Common Stock	14,056	$0.00	$0.00
Exercise Price or Tax Liability	Common Stock	10,530	$97.96	$1.03M
Sale	Common Stock	6,000	$98.85	$593K
Holding	Common Stock	--	--	--

Holdings After Transaction: Restricted Stock Units — 0 contracts (Direct); Common Stock — 41,549 shares (Direct); Common Stock — 576.55 shares (Indirect, by Merrill Lynch under AECOM Retirement & Savings Plan (RSP))

Holdings Before and After: Restricted Stock Units, 5,976 to 0 contracts (Direct); Common Stock, 41,015 to 41,549 shares (Direct)

Other Insiders: 1 other insider reported open-market sales of this stock in the 30 days up to this filing.

Footnotes (5)

1. F1. Each restricted stock unit represents a contingent right to receive, upon vesting, one share of the Issuer's common stock. These restricted stock units were granted on December 15, 2022, and vested in full on December 15, 2025.
2. F2. Represents annual grant of restricted stock units. Each restricted stock unit represents a contingent right to receive, upon vesting, one share of the Issuer's common stock in accordance with the Issuer's 2020 Stock Incentive Plan. The restricted stock units vest in full on December 15, 2028, subject to continued service through the vesting date.
3. F3. Represents shares acquired pursuant to AECOM's Performance Earnings Program under the 2020 Stock Incentive Plan.
4. F4. Represents shares of common stock withheld by the Issuer to satisfy certain tax withholding obligations in connection with the vesting of the restricted stock units and shares acquired under the Performance Earnings Program.
5. F5. The sales reported on this Form 4 were effected pursuant to a Rule 10b5-1 trading plan adopted by the Reporting Person on August 15, 2025.

FAQ

AI-generated questions and answers. How Rhea-AI works. Not financial advice.

What insider stock transactions did AECOM (ACM) chief legal officer David Gan report?

David Gan reported vesting of previously granted restricted stock units, a new restricted stock unit award, shares acquired under AECOM’s Performance Earnings Program, shares withheld for taxes, and open-market sales of AECOM common stock.

How many AECOM (ACM) shares did David Gan sell in December 2025 and at what prices?

He sold 6,000 shares of AECOM common stock on December 15, 2025 at $98.85 per share and 9,502 shares on December 17, 2025 at $97.01 per share.

What AECOM restricted stock units vested for David Gan in December 2025?

5,976 restricted stock units granted on December 15, 2022 vested in full on December 15, 2025, with each unit representing a contingent right to receive one share of AECOM common stock.

What new AECOM equity awards did David Gan receive in this Form 4 filing?

He received an annual grant of 6,534 restricted stock units under AECOM’s 2020 Stock Incentive Plan, which vest in full on December 15, 2028, and 14,056 shares were acquired under AECOM’s Performance Earnings Program.

Were David Gan’s AECOM stock sales made under a Rule 10b5-1 trading plan?

Yes. The filing states that the sales reported were effected pursuant to a Rule 10b5-1 trading plan adopted by David Gan on August 15, 2025.

How many AECOM (ACM) shares does David Gan own after these reported transactions?

Following the transactions, David Gan directly owned 41,549 shares of AECOM common stock and 576.55 shares indirectly through Merrill Lynch under the AECOM Retirement & Savings Plan.

AI-generated analysis. How Rhea-AI works. Not financial advice.

Form 4 Insider Transactions: What Each Field Means →

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SEC Form 4

FORM 4

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL

OMB Number:			3235-0287
Estimated average burden
hours per response:			0.5

Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

X

Check this box to indicate that a transaction was made pursuant to a contract, instruction or written plan for the purchase or sale of equity securities of the issuer that is intended to satisfy the affirmative defense conditions of Rule 10b5-1(c). See Instruction 10.

1. Name and Address of Reporting Person^*

Gan David Y.

(Last) (First) (Middle)

C/O AECOM

13355 NOEL RD, SUITE 400

(Street)

DALLAS TX 75240

(City) (State) (Zip)

2. Issuer Name and Ticker or Trading Symbol
AECOM [ ACM ]

5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

	Director		10% Owner
X	Officer (give title below)		Other (specify below)
	CHIEF LEGAL OFFICER

3. Date of Earliest Transaction (Month/Day/Year)
12/15/2025

4. If Amendment, Date of Original Filed (Month/Day/Year)

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	3. Transaction Code (Instr. 8)		4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5)			5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4)	6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
			Code	V	Amount	(A) or (D)	Price
Common Stock	12/15/2025		M(1)		5,976	A	$0(1)	46,991	D
Common Stock(2)	12/15/2025		A		6,534	A	$0	53,525	D
Common Stock	12/15/2025		A(3)		14,056	A	$0	67,581	D
Common Stock	12/15/2025		F(4)		10,530	D	$97.96	57,051	D
Common Stock	12/15/2025		S		6,000	D	$98.85(5)	51,051	D
Common Stock	12/17/2025		S		9,502	D	$97.01(5)	41,549	D
Common Stock								576.55	I	by Merrill Lynch under AECOM Retirement & Savings Plan (RSP)

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	4. Transaction Code (Instr. 8)		5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5)		6. Date Exercisable and Expiration Date (Month/Day/Year)		7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4)		8. Price of Derivative Security (Instr. 5)	9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4)	10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
				Code	V	(A)	(D)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares
Restricted Stock Units	(1)	12/15/2025		M			5,976	(1)	(1)	Common Stock	5,976	(1)	0	D

Explanation of Responses:

1. Each restricted stock unit represents a contingent right to receive, upon vesting, one share of the Issuer's common stock. These restricted stock units were granted on December 15, 2022, and vested in full on December 15, 2025.

2. Represents annual grant of restricted stock units. Each restricted stock unit represents a contingent right to receive, upon vesting, one share of the Issuer's common stock in accordance with the Issuer's 2020 Stock Incentive Plan. The restricted stock units vest in full on December 15, 2028, subject to continued service through the vesting date.

3. Represents shares acquired pursuant to AECOM's Performance Earnings Program under the 2020 Stock Incentive Plan.

4. Represents shares of common stock withheld by the Issuer to satisfy certain tax withholding obligations in connection with the vesting of the restricted stock units and shares acquired under the Performance Earnings Program.

5. The sales reported on this Form 4 were effected pursuant to a Rule 10b5-1 trading plan adopted by the Reporting Person on August 15, 2025.

Remarks:

	Matt Benson, Attorney-in-Fact for David Gan	12/17/2025
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
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