Business Conduct Policy – Apple Inc.

The way we do business worldwide

Business Conduct

The way we do business worldwide

Apple conducts business ethically, honestly, and in full compliance with all
laws and regulations. This applies to every business decision in every area of
the company worldwide.

Business Conduct

The way we do business worldwide

July 2010

Apple’s Principles of Business Conduct

Apple’s success is based on creating innovative, high-quality products and
services and on demonstrating integrity in every business interaction. Apple’s
principles of business conduct define the way we do business worldwide. These
principles are:

Honesty. Demonstrate honesty and high ethical standards in
all business dealings.

Respect. Treat customers, suppliers, employees, and others
with respect and courtesy.

Confidentiality. Protect the confidentiality of Apple’s
information and the information of our customers, suppliers, and employees.

Compliance. Ensure that business decisions comply with all
applicable laws and regulations.

Your Responsibilities

Apple’s Business Conduct Policy and principles apply to employees,
independent contractors, consultants, and others who do business with Apple. All
such individuals are expected to comply with Apple’s Business Conduct Policy and
principles and with all applicable legal requirements. Apple retains the right
to discipline (up to and including termination of employment) or end working
relationships with those who do not comply.

If you have knowledge of a possible violation of Apple’s Business Conduct
Policy or principles, other Apple policies, or legal or regulatory requirements,
you are required to notify either your manager (provided your manager is not
involved in the violation), Human Resources, Legal, Internal Audit, Finance, or
the Business Conduct Helpline. If you have knowledge of a potential violation
and fail to report it, you may be subject to disciplinary action.

When facing a tough decision:

Use good judgment. Apply Apple’s principles of business
conduct, review our policies, review legal requirements, and then decide what to
do.

Need some help? When in doubt about how to proceed,
discuss pending decisions with your manager, your Human Resources
representative, or the Legal Department. If you need more support, contact the
Business Conduct Helpline.

Retaliation is Not Tolerated

Apple will not retaliate:and will not tolerate retaliation:against any
individual for filing a good-faith complaint with management, HR, Legal,
Internal Audit, Finance, or the Business Conduct Helpline, or for participating
in the investigation of any such complaint.

Contents

4

Customer Focus

4

Customer and Third-Party Information

4

Nondisclosure Agreements

4

Obtaining and Using Business Intelligence

4

Third-Party Intellectual Property

4

Copyright-Protected Content

5

Giving and Receiving Business Gifts

5

Kickbacks

5

Side Deals or Side Letters

6

Competition and Trade Practices

6

Endorsements

6

Open Source Software

7

Governments as Customers

7

Gifts to U.S. Officials

7

Gifts to Non-U.S. Officials

7

No Bribery or Corruption

7

Political Contributions

8

Charitable Donations

8

Hiring Government Employees

8

Trade Restrictions and Export Controls

8

Environment, Health, and Safety

8

Community Activities

9

Protecting Apple’s Assets and Information

9

Confidential Apple Information

9

The Apple Identity and Trademarks

9

Apple Inventions, Patents, and Copyrights

10

Activities Related to Technical Standards

10

Accuracy of Records and Reports

10

Business Expenses

10

Establishing Bank Accounts

10

Loans, Advances, and Guarantees

10

Money Laundering

11

Document Retention and Legal Hold

12

Conflicts of Interest

12

Outside Employment and Inventions

13

Personal Investments

13

Workplace Relationships

13

Buying and Selling Stock

13

Harassment and Discrimination

14

Confidential Employee Information

14

Privacy

14

Public Speaking and Press Inquiries

14

Publishing Articles

14

Substance Abuse

15

Your Obligation to Take Action

15

Business Conduct Helpline

16

Policies and References

Customer and Business

Relationships

Business Conduct

The way we do business worldwide

July 2010

Customer Focus

Every product we make and every service we provide is for our customers.
Focus on providing innovative, high-quality products and services and on
demonstrating integrity in every business interaction. Always apply Apple’s
principles of business conduct.

To what extent may I use an existing customer list to market other
Apple products or services?

Before using a customer list for marketing, sales, or other activities, talk
to your manager or the Legal Department. Using an existing customer list may or
may not be appropriate.

Customer and Third-Party Information

Customers, suppliers, and others disclose confidential information to Apple
for business purposes. It is the responsibility of every Apple employee to
protect and maintain the confidentiality of this information. Failure to protect
customer and third-party information may damage relations with customers,
suppliers, or others and may result in legal liability. See the Apple Customer
Privacy Policy.

Where can I learn more about information protection and nondisclosure
agreements?

View the Apple policy on Confidential, Proprietary, and Trade Secret
Information.

Where can I get a nondisclosure agreement?

In the U.S., see the forms Apple provides for nondisclosure agreements.
Outside the U.S., consult your local Apple Legal representative.

Nondisclosure Agreements

When dealing with a supplier, vendor, or other third party, never share
confidential information without your manager’s approval. Also, never share
confidential information outside Apple (for example, with vendors, suppliers, or
others) unless a nondisclosure agreement is in place. These agreements document
the need to maintain the confidentiality of the information. Original copies of
nondisclosure agreements must be forwarded to the Legal Department. Always limit
the amount of confidential information shared to the minimum necessary to
address the business need.

As long as the information helps Apple, why is the source of business
intelligence an issue?

Obtaining information illegally or unethically could damage Apple’s
reputation and in some cases could subject Apple to legal liability. For
example, using illegally or unethically obtained information in a bid to the
government could result in disqualification from future bidding and in criminal
charges.

Obtaining and Using Business Intelligence

Apple legitimately collects information on customers and markets in which we
operate. Apple does not seek business intelligence by illegal or unethical
means, and competitors may not be contacted for the purpose of obtaining
business intelligence. Sometimes information is obtained accidentally or is
provided to Apple by unknown sources. In such cases, it may be unethical to use
the information, and you should immediately contact your manager, the Legal
Department, or the Business Conduct Helpline to determine how to proceed.

Third-Party Intellectual Property

It is Apple’s policy not to knowingly use the intellectual property of any
third party without permission or legal right. If you are told or suspect that
Apple may be infringing an intellectual property right, including patents,
copyrights, trademarks, or trade secrets owned by a third party, you should
contact the Legal Department.

May I keep my personal music on my computer at work?

If you are authorized to make copies of the music for personal use (for
example, you own the original CD or you purchased the music on iTunes), you may
keep the music on your computer.

Copyright-Protected Content

Never use or copy software, music, videos, publications, or other
copyright-protected content at work or for business purposes unless you or Apple
are legally permitted to use or make copies of the protected content. Never use
Apple facilities or equipment to make or store unauthorized copies.

Customer and Business

Relationships

Business Conduct

The way we do business worldwide

July 2010

Are business meals, travel, and entertainment considered
gifts?

Yes. Anything of value given or received is considered a gift.

Can I avoid these rules if I pay for gifts to customers or business
associates myself?

No. If the gift is given for business reasons and you are representing Apple,
the gift rules apply.

Giving and Receiving Business Gifts

Employees may not give or receive gifts or entertainment to or from current
or potential vendors, suppliers, customers, or other business associates unless
all of the following conditions are met:

Nominal value. The value of the gift is less than US$150.
Exceptions must be approved by your Vice President (for Vice President:level
employees, exceptions must be approved by your manager).

Customary. The item is a customary business gift and would
not embarrass Apple if publicly disclosed. Cash is never an acceptable gift.
Giving or receiving cash is viewed as a bribe or kickback and is always against
Apple policy.

No favored treatment. The purpose of the gift is not to
obtain special or favored treatment.

Legal. Giving or accepting the gift is legal in the
location and under the circumstances where given.

Recipient is not a government official. Never provide a
gift, including meals, entertainment, or other items of value, to a U.S. or
foreign government official without checking with Government Affairs in advance.
See page 7 for more information on gifts to government officials.

This policy does not preclude Apple as an organization from receiving and
evaluating complimentary products or services. It is not intended to preclude
Apple from giving equipment to a company or organization, provided the gift is
openly given, consistent with legal requirements, and in Apple’s business
interests. The policy also does not preclude the attendance of Apple employees
at business-related social functions, if attendance is approved by management
and does not create a conflict of interest.

Important Note: Certain departments (e.g., Operations and
Retail) have more restrictive gift policies, which may prohibit giving or
receiving gifts altogether. Employees in those departments must adhere to those
stricter policies.

What is an example of a kickback?

Apple provides discounts to certain customers. However, if a customer gets an
inappropriate discount, and a sales representative gets a payment in return,
this is a kickback.

What is an example of a side deal?

In a sales environment, a side deal may involve a guarantee to accept back
unsold products or other special agreements to encourage certain customers to
place larger orders. Such a side deal, whether written or oral, can impact
Apple’s potential liability with respect to that transaction and may make it
inappropriate for Apple to recognize revenue on the products sold, affecting the
accuracy of Apple’s books and records. Side deals or side letters made outside
of Apple’s formal contracting and approvals process are strictly prohibited.

Kickbacks

Kickbacks are payments or items of value given to individuals in connection
with the purchase or sale of products or services, typically for providing a
discount in a sales agreement. Employees are prohibited from giving or receiving
kickbacks.

Side Deals or Side Letters

All of the terms and conditions of agreements entered into by Apple must be
formally documented. Contract terms and conditions define the key attributes of
Apple’s rights, obligations, and liabilities and can also dictate the accounting
treatment given to a transaction. Making business commitments outside of the
formal contracting process, through side deals, side letters, or otherwise, is
unacceptable. You should not make any oral or written commitments that create a
new agreement or modify an existing agreement without approval through the
formal contracting process. In particular, all commitments must have visibility
to Finance so Apple can ensure it is properly accounting for each transaction.
If you have knowledge of any side deal, side letter, or agreement made outside
of the formal contracting process, you should report it immediately to your
manager, your Human Resources representative, or the Legal Department. You may
also contact the Business Conduct Helpline.

Customer and Business

Relationships

Business Conduct

The way we do business worldwide

July 2010

What can I do if a reseller complains to me about low prices at
another reseller?

Advise the reseller that you can’t discuss or attempt to influence pricing of
other parties, since this could violate antitrust laws.

How should I handle customer inquiries about resellers and service
providers?

Apple resellers and service providers are key members of the Apple family.
They promote and sell Apple products, and they provide service and support to
Apple customers. Accordingly, you should never make disparaging remarks to
customers about resellers or service providers.

Competition and Trade Practices

Laws regulating competition and trade practices vary around the world, but
certain activities, such as price fixing and agreeing with a competitor to
allocate customers, are almost always illegal and are absolutely prohibited
under Apple policy.

You should not:

Agree with competitors or exchange information with competitors on prices,
policies, contract terms, costs, inventories, marketing plans, or capacity
plans.

Agree with a competitor that the competitor will sell goods and services to
Customer A (and you will not), and that you will sell goods and services to
Customer B (and your competitor will not).

Agree with resellers on the resale pricing of Apple products without Legal
Department approval.

Require vendors to purchase Apple products in order to sell products or
services to Apple.

Describe the products or services of competitors inaccurately to promote
Apple products or services.

Engage in any pricing or other practices that could defraud a supplier or
others.

Violate fair bidding practices, including bidding quiet periods, or provide
information to benefit one vendor over other vendors.

What is an example of an endorsement?

A friend writes a great book on software design and asks you to endorse the
book by making a statement on the back cover. If you make such an endorsement,
don’t include your job title or affiliation with Apple.

Endorsements

When representing Apple, never endorse a product or service of another
business or an individual, unless the endorsement has been approved by your
manager and Corporate Communications. This does not apply to statements you may
make in the normal course of business about third-party products that are sold
by Apple.

Open Source Software

Open source software is software for which the source code is available
without charge under a free software or open source license. Before using or
modifying any open source software for Apple infrastructure or as part of an
Apple product or service development effort, you must review Apple’s Open Source
Policy and contact the Legal Department for approval using the forms referenced
in that policy.

Governments and

Communities

Business Conduct

The way we do business worldwide

July 2010

Governments as Customers

Governments shouldn’t be charged more for our products or services than Apple
charges other customers for the same products or services. There are laws that
make it a crime to overcharge the U.S. government. Some other countries have
similar laws.

Governments are unique customers for Apple. Governments often place special
bidding, pricing, disclosure, and certification requirements on firms with which
they do business. Discuss these requirements with Government Affairs or your
local Apple Legal representative before bidding for government business. For
example, Apple may have to certify that it is supplying the government with the
lowest price charged to Apple’s commercial customers. Apple may also have to
certify that its prices have been arrived at independently:that is, without
collaboration with a third party.

Gifts to U.S. Officials

No. If you are representing Apple, any gift to a government employee would be
viewed as coming from Apple.

What is considered a gift to a U.S. or

foreign official?

In most cases, anything of value that is given is considered a gift. This
includes items such as meals, golf, entertainment, and product samples. Cash is
never an acceptable gift. Typically, giving cash is viewed as a bribe or
kickback and is against Apple policy.

Who is considered a government official?

Any official or employee of a government, a public international organization
(such as the European Commission), any department or agency thereof, or any
person acting in an official capacity. It can also include employees of a
state-run or state-owned business, such as a public utility or university.

It may be illegal to give a gift, even an inexpensive meal or a T-shirt, to a
government employee. The rules vary depending on the location and job position
of the government employee (for example, rules may vary by state, school
district, and city, and there may be different rules for various elected and
nonelected officials).

To prevent violations, review planned gifts to government officials with
Government Affairs in advance of giving a gift.

Gifts to Non-U.S. Officials

In many countries it is considered common courtesy to provide
token/ceremonial gifts to government officials on certain occasions to help
build relationships. Check local requirements and review any such gifts
exceeding US$25 in advance with the Legal Department. For meals, the US$25 limit
does not necessarily apply. Check here for value limits by country on meals to
non-U.S. public officials and employees. Meals at any value should be avoided
with officials from government agencies where Apple has a pending application,
proposal, or other business.

No Bribery or Corruption

Offering or giving anything of value to a government official for the purpose
of obtaining or retaining business or to secure any improper advantage is
illegal. Apple personnel shall not offer or accept bribes or use other
inappropriate means to obtain an undue or improper advantage, or otherwise
violate U.S. or international anticorruption laws and regulations (e.g., the
U.S. Foreign Corrupt Practices Act).

For additional information, see Apple’s Foreign Corrupt Practices Act Policy.

Political Contributions

Apple contributes selectively to political candidates and committees. All
corporate political contributions, whether monetary or in-kind (such as the
donation/lending of equipment or technical services to a campaign), must be
approved in advance by Apple Government Affairs. Employees may not use Apple
assets (including employee work time, or use of Apple premises, equipment, or
funds) to personally support candidates and campaigns. It is illegal for Apple
to reimburse an employee for a contribution. For more information, see the Apple
Corporate Political Compliance Policy and the Political Contributions and
Expenditures Policy.

Governments and

Communities

Business Conduct

The way we do business worldwide

July 2010

Charitable Donations

Employees are encouraged to support charitable causes of their choice, as
long as that support is provided without the use or furnishing of Apple assets
(including employee work time, or use of Apple premises, equipment, or funds).
Any charitable donations involving Apple assets require the approval of the
Chief Executive Officer or Chief Financial Officer. For additional information,
see Finance Policy 1.10.

What should I do if I’m interested in hiring a current or recent
government employee?

Contact Government Affairs before beginning any negotiations to hire a
current or recent government, military or other public sector employee as an
Apple employee or consultant.

Hiring Government Employees

Laws often limit the duties and types of services that former government,
military or other public sector employees may perform as employees or
consultants of Apple. Employment negotiations with government employees are
prohibited while the employees are participating in a matter involving Apple’s
interests.

Trade Restrictions and Export Controls

Many countries periodically impose restrictions on exports and other dealings
with certain other countries, persons, or groups. Export laws may control
trading of commodities or technologies that are considered to be strategically
important because they have the potential to be used for military purposes. Laws
may cover travel to or from a sanctioned country, imports or exports, new
investments, and other related topics. Certain laws also prohibit support of
boycott activities. See Apple’s Export Control policy for more information.

If your work involves the sale or shipment of products, technologies, or
services across international borders, check with the Export Department to
ensure compliance with any laws or restrictions that apply.

How do I get more information regarding Apple’s environmental,
health, and safety programs?

Visit the Environment+Safety site.

Environment, Health, and Safety (EHS)

Apple operates in a manner that conserves the environment and protects the
safety and health of our employees. Conduct your job safely and consistent with
applicable EHS requirements. Use good judgment and always put the environment,
health, and safety first. Be proactive in anticipating and dealing with EHS
risks.

In keeping with our commitment to the safety of our people, Apple will not
tolerate workplace violence. For additional information, review Apple’s
Workplace Violence policy.

What if I want to get more involved in community activities?

Contact Community Affairs. This group promotes, supports, and facilitates
employees’ involvement in community volunteer activities. Outside the U.S.,
check with your local Public Relations team.

Community Activities

At Apple, we comply with all laws and regulations and operate in ways that
benefit the communities in which we conduct business. Apple encourages you to
uphold this commitment to the community in all your activities.

If you hold an elected or appointed public office while employed at Apple,
advise Government Affairs. Excuse yourself from involvement in any decisions
that might create or appear to create a conflict of interest.

Responsibilities to Apple

Business Conduct

The way we do business worldwide

July 2010

What are assets?

Assets include Apple’s extremely valuable proprietary information (such as
intellectual property, confidential business plans, unannounced product plans,
sales and marketing strategies, and other trade secrets); as well as physical
assets like cash, equipment, supplies, and product inventory.

Where can I learn more about information protection and nondisclosure
agreements?

View the Apple policy on Confidential, Proprietary, and Trade Secret
Information.

Protecting Apple’s Assets and Information

As an Apple employee you must protect Apple’s property and abide by the
following guidelines:

Follow all security procedures and be on the lookout for any instances you
believe could lead to loss, misuse, or theft of company property.

Protect physical assets such as equipment, supplies, cash, and charge
cards.

Use extreme care to protect Apple’s proprietary information from improper
disclosure to third parties. This information includes technical product
information, information related to current and future products and services,
confidential market research, sales and marketing plans, nonpublic earnings or
financial data, and organizational charts and information.

Follow procurement policies and procedures when acquiring goods or services
on behalf of Apple, avoiding any real or apparent conflict of interest. For more
information on procurement policies and procedures, talk to your manager or
visit Apple Procurement.

Use Apple’s assets in a manner that prevents damage, waste, misuse, or
theft. Use assets only for legal and ethical purposes.

Dispose of assets only with appropriate approval and in compliance with
applicable policies. Before disposing of assets, discuss your plans with your
manager.

Confidential Apple Information

One of Apple’s greatest assets is information about our products and
services, including future product offerings. Never disclose confidential
operational, financial, trade secret, or other business information without
verifying with your manager that such disclosure is appropriate. Typically,
disclosure of this information is very limited, and the information may be
shared with vendors, suppliers, or other third parties only after a
nondisclosure agreement is in place. Even within Apple, confidential information
should be shared only on a need-to-know basis. The Intellectual Property
Agreement you signed when you joined Apple defines your duty to protect
information.

First, verify that there is a business need for the disclosure. Second,
obtain your manager’s approval for the disclosure. Third, be sure that a
nondisclosure agreement is in place with the vendor or third party, and that you
forward the original copy of the agreement to the Legal Department. If you are
still unsure, check with the Legal Department before making the disclosure.

How do I identify confidential Apple information in
documents?

Mark these documents “Apple Confidential.”

What if I have a specific question on the use of the Apple name,
names of products or services, or the Apple logo?

Please direct questions about the Apple corporate identity to
corpID@apple.com.

How can I find out more about patents?

Visit Apple’s Patent Information site.

The Apple Identity and Trademarks

The Apple name, names of products (such as iPhone), names of services (such
as AppleCare), tag lines (such as “Don’t steal music”), and logos (such as the
familiar Apple logo) collectively create the Apple identity. Before publicly
using the Apple name, product names, service names, tag lines, or the Apple
logo, review Apple’s corporate identity guidelines on how names and logos can be
used and presented (for example, the size of the Apple logo and the amount of
white space surrounding the logo). Before using the product names, service
names, tag lines, or logos of third parties, check with the Legal Department.

Apple Inventions, Patents, and Copyrights

Apple’s practice is to consider for patenting the inventions of its
employees, regardless of whether the inventions are implemented in actual
products. If you are involved in product development, you should contact the
Legal Department regarding the patentability of your work. Be alert to possible
infringement of Apple’s patents and bring any possible infringements directly to
the Legal Department.

If you create original material for Apple that requires copyright protection,
such as software, place Apple’s copyright notice on the work and submit a
copyright disclosure form to the Legal Department. For more information, visit
the Apple Copyright Information site.

Responsibilities to Apple

Business Conduct

The way we do business worldwide

July 2010

Activities Related to Technical Standards

There are numerous organizations that develop or promote technical standards
(e.g., W3C, OASIS, INCITS, IEEE, ETSI). Before engaging in activities related to
technical standards, including, for example, joining a standards organization or
working group, contributing technology to a standard, or using a standard in the
development of an Apple product, employees must receive management and Legal
approval. For additional information, see Apple’s Standards Legal Policy.

Accuracy of Records and Reports

Accurate records are critical to meeting Apple’s legal, financial, and
management obligations. Ensure that all records and reports, including customer
information, technical and product information, correspondence, and public
communications, are full, fair, accurate, timely, and understandable.

Never misstate facts, omit critical information, or modify records or reports
in any way to mislead others, and never assist others in doing so.

Business Expenses

See Apple’s Travel policy or talk to your manager.

All employees must observe policies and procedures regarding business
expenses, such as meal and travel expenses, and submit accurate expense
reimbursement requests. Guidelines on daily meal expenses vary worldwide.

Establishing Bank Accounts

All Apple bank accounts must be approved and established by Apple’s Treasury
Department. All payments must be made by recordable and traceable methods. For
more information, contact the Treasury Department.

Loans, Advances, and Guarantees

Other than through established corporate programs, such as programs for
employee relocation and the cashless exercise of stock options, Apple does not
provide loans or advances of corporate funds to its employees, officers, Board
members, or their families and does not guarantee their obligations.

Money Laundering

Advise your manager or contact the Apple Legal Department.

Money laundering is the process by which individuals or organizations try to
conceal illicit funds or make these funds look legitimate. If you are in a
position to deal directly with customers or vendors, the following examples may
be indications of potential money laundering:

Attempts to make large payments in cash

Payments by someone who is not a party to the contract

Requests to pay more than provided for in the contract

Payments made in currencies other than those specified in the contract

Payments from an unusual, nonbusiness account

Responsibilities to Apple

Business Conduct

The way we do business worldwide

July 2010

Tell me more about “legal holds.”

In a litigation case or other legal matter, Apple may be required to produce
documents. In these cases the Legal Department may put a “legal hold” on certain
documents to prevent the documents from being destroyed, altered, or modified.
If it is found that Apple has failed to retain or produce required documents,
penalties or adverse rulings may result. Adverse rulings in major litigation
cases can cost Apple a significant amount of money. Failure of employees to
retain and preserve documents placed on a legal hold may result in discipline or
discharge.

Document Retention and Legal Hold

As an Apple employee, you have a responsibility to manage documents and make
decisions on document retention. The definition of “document” is extremely
broad. For example, every email or other electronic file, every customer record,
and every transaction involves the creation of a document. Different documents
have different retention periods. Check with your manager or contact Records
Management to determine the appropriate retention period for documents in your
area.

At times, Apple may need to retain documents beyond the period they would
normally be retained. The most common reasons are litigation or other legal
matters. In these situations, retention and preservation of documents is
critical. If you have documents that may be required for litigation or other
legal matters, the Legal Department will place those documents on a “legal
hold,” meaning the documents cannot be altered, destroyed, deleted, or modified
in any manner. Legal will notify the individuals most closely identified with
the documents about the legal hold and will provide instructions for retaining
the documents. Recipients of a legal hold must ensure that these instructions
are followed. A legal hold remains in effect until you are notified by the Legal
Department in writing.

Individual Conduct

Business Conduct

The way we do business worldwide

July 2010

Can you give an example of conflicts of interest or potential divided
loyalty?

Your brother-in-law owns a business, that business is being considered as a
vendor for Apple, and you are one of the decision makers.

Conflicts of Interest

A conflict of interest is any activity that is inconsistent with or opposed
to Apple’s best interests, or that gives the appearance of impropriety or
divided loyalty. Avoid any situation that creates a real or perceived conflict
of interest. Use good judgment, and if you are unsure about a potential
conflict, talk to your manager, contact Human Resources, check with the Legal
Department, or contact the Business Conduct Helpline.

Do not conduct Apple business with family members or others with whom you
have a significant personal relationship. In rare cases where exceptions may be
appropriate, written approval from the Senior Vice President for your
organization is required.

You shouldn’t use your position at Apple to obtain favored treatment for
yourself, family members, or others with whom you have a significant
relationship. This applies to product purchases or sales, investment
opportunities, hiring, promoting, selecting contractors or suppliers, and any
other business matter. This does not apply to special purchase plans offered by
Apple. If you believe you have a potential conflict involving a family member or
other individual, disclose it to your manager.

Outside Employment and Inventions

No. Employees are not permitted to have any involvement in the development of
outside iPhone or iPad apps, either alone or jointly with others.

Full-time Apple employees must notify their manager before taking any other
employment. In addition, any employee (full-time or part-time) who obtains
additional outside employment, has an outside business, or is working on an
invention must comply with the following rules.

May I occasionally use my Apple email address for my outside
business?

Limited personal use of your Apple email is permitted for activities such as
sending a brief message to a friend. You may never use your Apple email for an
outside business.

I’m working on an invention on my own time. Does Apple need to
know?

If your invention relates to your job at Apple or could compete with current
or reasonably anticipated future products or services of Apple, disclose the
invention to your manager.

May I serve on the board of directors of an outside enterprise or
organization?

If you plan to serve on a board, you must obtain approval from your manager
and the Senior Vice President for your organization. In addition, Vice
Presidents and Executive Team members must obtain the approval of their manager
and the CEO before they can accept a position on the board of directors of a
private or publicly traded company (other than nonprofit entities).

Do not:

Use any time at work or any Apple assets for your other job, outside
business, or invention. This includes using Apple workspace, telephones,
computers, Internet access, copy machines, and any other Apple assets or
services.

Use your position at Apple to solicit work for your outside business or
other employer, to obtain favored treatment, or to pressure others to assist you
in working on your invention.

Use confidential Apple information to benefit your other employer, outside
business, or invention.

Participate in an outside employment activity that could have an adverse
effect on your ability to perform your duties at Apple.

Participate in an outside business or outside employment, or develop an
invention, that is in an area of Apple’s present or reasonably anticipated
future business.

Before participating in inventions or businesses that are in the same area as
your work for Apple or that compete with or relate to present or reasonably
anticipated Apple products or services, you must have written permission from
your manager, an Apple product law attorney, and the Senior Vice President of
your organization. For additional information, see Apple’s policy on Conflicts
of Interest.

Individual Conduct

Business Conduct

The way we do business worldwide

July 2010

I have stock in companies that do business with Apple. Is this a
problem?

It’s unlikely that this is a problem. However, it could be a concern if (1)
you’re influencing a transaction between Apple and the company, and (2) the
transaction is significant enough to potentially affect the value of your
investment.

Personal Investments

Many Apple employees have investments in publicly traded stock or privately
held businesses. These personal investments may give rise to a conflict of
interest if you are involved in or attempt to influence transactions between
Apple and a business in which you are invested. If a real or apparent conflict
arises, disclose the conflict to your manager. The manager will help determine
whether a conflict exists and, if appropriate, the best approach to eliminate
the conflict.

Workplace Relationships

Personal relationships in the workplace may present an actual or perceived
conflict of interest where one individual in the relationship may be in a
position to make or influence employment decisions regarding the other. If you
find yourself in such a relationship, you must notify Human Resources so they
may assist you in resolving any potential conflicts. Employees should not allow
their relationships to disrupt the workplace or interfere with their work or
judgment. For additional information, see Apple’s policy on Personal
Relationships.

How do I know whether information is material?

Determining what constitutes material information is a matter of judgment. In
general, information is material if it would likely be considered important by
an investor buying or selling the particular stock.

Does Apple’s policy apply to buying or selling stock in other
companies?

Yes. For example, say you learn about a customer’s nonpublic expansion plans
through discussions about hardware purchases. If you purchase stock in the
customer’s company or advise others to do so, it could be viewed as insider
trading.

Buying and Selling Stock

Never buy or sell stock while you are in possession of information obtained
through your employment at Apple that has not been publicly announced and could
have a material effect on the value of the stock. This applies to decisions to
buy or sell Apple securities and to investments in other companies. It is also
against Apple policy and may be illegal to give others, such as friends and
family, tips on when to buy or sell stock while you are in possession of
material, nonpublic information concerning that stock.

In addition, employees are prohibited from investing in derivatives of
Apple’s securities. This includes, but is not limited to, trading in put or call
options related to securities of the company.

Members of Apple’s Board of Directors, executive officers, and certain other
individuals are subject to blackout periods during which they are prohibited
from trading in Apple stock. If you are subject to these restrictions, you will
be notified by the Legal Department. Even if you are subject to blackout
periods, you may never buy or sell stock while you are in possession of
material, nonpublic information.

Review Apple’s Insider Trading policy. Specific questions on buying and
selling stock should be referred to the Legal Department.

What is harassment?

Harassment can be verbal, visual, or physical in nature. Specific examples of
prohibited harassing conduct include, but are not limited to: slurs, jokes,
statements, notes, letters, electronic communication, pictures, drawings,
posters, cartoons, gestures, and unwelcome physical contact that are based on an
individual’s protected class.

Need more information?

In the U.S., refer to Apple’s Harassment policy. Outside the U.S., contact
Human Resources.

Harassment and Discrimination

Apple encourages a creative, culturally diverse, and supportive work
environment. Apple does not tolerate harassment or discrimination based on
factors such as race, color, sex, sexual orientation, gender identity
characteristics or expression, religion, national origin, age, marital status,
disability, medical condition, veteran status, or pregnancy. Additional
restrictions may apply based on regional laws and regulations.

These requirements apply to interactions with employees, customers,
suppliers, and applicants for employment and any other interactions where you
represent Apple.

If you feel that you have been harassed or discriminated against or have
witnessed such behavior, report the situation to a manager or to Human
Resources. You may also contact the Business Conduct Helpline.

Individual Conduct

Business Conduct

The way we do business worldwide

July 2010

Confidential Employee Information

View the Apple Safe Harbor Privacy Policy.

As part of your job, you may have access to personal information regarding
other Apple employees or applicants, including information regarding their
employment history, personal contact information, compensation, health
information, or performance and disciplinary matters. This information is
confidential and should be shared only with those who have a business need to
know. It should not be shared outside Apple unless there is a legal or business
reason to share the information and you have approval from your manager.

Privacy

Limited personal use of Apple equipment and systems is allowed, but subject
to local regulations, Apple may monitor equipment and systems. If in doubt,
check with the Legal Department.

Subject to rules or regulations affecting an employee’s rights, Apple may
monitor or search its work environments, including equipment, networks, mail,
and electronic systems, without notice. Apple monitors facilities and equipment
to promote safety, prevent unlawful activity, investigate misconduct, manage
information systems, comply with legal guidelines, and for other business
purposes.

Public Speaking and Press Inquiries

That depends. If you are representing Apple, you may not accept payment. If
you are on your own time and are not representing Apple, you may be allowed to
accept payment. Before accepting this type of opportunity, check with your
manager, Human Resources, or the Business Conduct Helpline.

All public speaking engagements that relate to Apple’s business or products
must be preapproved by your manager and Corporate Communications. If you receive
approval to make a public presentation at a business meeting or conference, you
may not request or accept any form of personal compensation from the
organization that requested the presentation. This does not prohibit accepting
reimbursement for expenses, if approved by your manager.

All inquiries from the press or the financial analyst community must be
referred to Corporate Communications or the Investor Relations Department.

Publishing Articles

If you author an article or other publication, do not identify yourself in
the publication as an employee of Apple without prior approval from Corporate
Communications. This could be viewed as an endorsement by Apple.

What if I have a substance abuse issue?

Help yourself and Apple by taking action. Talk to your Human Resources
representative or, in the U.S., view information on the Employee Assistance
Program.

Substance Abuse

Employees are prohibited from manufacturing, distributing, dispensing,
possessing, using, or being under the influence of illegal drugs in the
workplace. Use of alcohol or medications on the job or before work can cause
safety issues, damage customer relations, and hurt productivity and innovation.
Use good judgment and keep in mind that you are expected to perform to your full
ability when working for Apple. View Apple’s policy on Drugs in the Workplace.

Taking Action

Business Conduct

The way we do business worldwide

July 2010

Your Obligation to Take Action

Always apply Apple’s principles of business conduct, follow Apple policies,
and comply with laws and regulations. When you are unsure, take the initiative
to investigate the right course of action. Check with your manager, Human
Resources, Legal, Internal Audit, or Finance, and review our policies on
AppleWeb. If you would like to talk with someone outside your immediate area,
consider contacting the Business Conduct Helpline.

If you know about a possible violation of Apple’s Business Conduct Policy or
legal or regulatory requirements, you are required to notify your manager
(provided your manager is not involved in the violation), Human Resources,
Legal, Internal Audit, Finance, or the Business Conduct Helpline. Failure to do
so may result in disciplinary action.

Employees must cooperate fully in any Apple investigation and must keep their
knowledge and participation confidential to help safeguard the integrity of the
investigation.

Business Conduct Helpline

The Business Conduct Helpline is available 24/7 to all employees worldwide to
help answer your questions on business conduct issues, policies, regulations,
and compliance with legal requirements. It also allows you to advise Apple of
situations that may require investigation or management attention.

The Business Conduct Helpline is committed to keeping your issues and
identity confidential. If you would be more comfortable doing so, you may
contact the Helpline anonymously. Your information will be shared only with
those who have a need to know, such as those involved in answering your
questions or investigating and correcting issues you raise. Note that if your
information involves accounting, finance, or auditing, the law may require that
necessary information be shared with the Audit and Finance Committee of Apple’s
Board of Directors.

Due to legal restrictions, anonymous use of the Business Conduct Helpline is
not encouraged in certain countries (e.g., France).

Apple will not retaliate:and will not tolerate retaliation:against any
individual for their good-faith use of the Business Conduct Helpline.

Information on contacting the Business Conduct Helpline:including via email,
toll-free telephone, and web access:is available on AppleWeb.

Additional Resources

Business Conduct

The way we do business worldwide

July 2010

Policies and References

Alcohol in the Workplace

Books and Publications

Business Conduct Helpline

Buying and Selling Stock: Blackout Periods

Buying and Selling Stock: Insider Trading

Community Affairs

Confidential, Proprietary, and Trade Secret Information

Copyright Information

Copyright Policy

Corporate Identity Guidelines

Customer Privacy Policy

Diversity

Employee Assistance Program (U.S. only)

Environment+Safety

Equal Employment Opportunity

Export Control

Foreign Corrupt Practices Act Policy

Government Affairs

Additional Resources

Business Conduct

The way we do business worldwide

July 2010

Policies and References (continued)

Harassment

Information Security

Intellectual Property

Legal Department Contacts

Mail and Electronic Communications

Name and Logo Use Questions: corpID@apple.com

Nondisclosure and Confidentiality Agreements

Open Communication

Open Source Software

Outside Business Activities

Patent Information

Patent Policy

Personal Relationships

Political Compliance

Procurement

Reasonable Accommodation

Records Management

Safe Harbor Privacy Policy

Standards Legal Policy

Trademarks

Travel Policy

2010 Apple Inc. All rights reserved. Apple, the Apple logo,
iPhone, iPad, and iTunes are trademarks of Apple Inc., registered in the U.S.
and other countries. AppleCare is a service mark of Apple Inc., registered in
the U.S. and other countries.