{"id":42114,"date":"2015-09-17T11:25:58","date_gmt":"2015-09-17T16:25:58","guid":{"rendered":"https:\/\/content.findlaw-admin.com\/ability-legal\/contracts\/uncategorized\/business-conduct-policy-apple-inc.html"},"modified":"2015-09-17T11:25:58","modified_gmt":"2015-09-17T16:25:58","slug":"business-conduct-policy-apple-inc","status":"publish","type":"corporate_contracts","link":"https:\/\/corporate.findlaw.com\/contracts\/operations\/business-conduct-policy-apple-inc.html","title":{"rendered":"Business Conduct Policy – Apple Inc."},"content":{"rendered":"\n\n\n\n
Business Conduct<\/strong><\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

The way we do business worldwide<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

Apple conducts business ethically, honestly, and in full compliance with all
\nlaws and regulations. This applies to every business decision in every area of
\nthe company worldwide.<\/p>\n<\/td>\n<\/tr>\n

\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n\n

Apple’s Principles of Business Conduct<\/p>\n

Apple’s success is based on creating innovative, high-quality products and
\nservices and on demonstrating integrity in every business interaction. Apple’s
\nprinciples of business conduct define the way we do business worldwide. These
\nprinciples are:<\/p>\n

Honesty.<\/strong> Demonstrate honesty and high ethical standards in
\nall business dealings.<\/p>\n

Respect.<\/strong> Treat customers, suppliers, employees, and others
\nwith respect and courtesy.<\/p>\n

Confidentiality.<\/strong> Protect the confidentiality of Apple’s
\ninformation and the information of our customers, suppliers, and employees.<\/p>\n

Compliance.<\/strong> Ensure that business decisions comply with all
\napplicable laws and regulations.<\/p>\n

Your Responsibilities<\/p>\n

Apple’s Business Conduct Policy and principles apply to employees,
\nindependent contractors, consultants, and others who do business with Apple. All
\nsuch individuals are expected to comply with Apple’s Business Conduct Policy and
\nprinciples and with all applicable legal requirements. Apple retains the right
\nto discipline (up to and including termination of employment) or end working
\nrelationships with those who do not comply.<\/p>\n

If you have knowledge of a possible violation of Apple’s Business Conduct
\nPolicy or principles, other Apple policies, or legal or regulatory requirements,
\nyou are required to notify either your manager (provided your manager is not
\ninvolved in the violation), Human Resources, Legal, Internal Audit, Finance, or
\nthe Business Conduct Helpline. If you have knowledge of a potential violation
\nand fail to report it, you may be subject to disciplinary action.<\/p>\n

When facing a tough decision:<\/p>\n

Use good judgment.<\/strong> Apply Apple’s principles of business
\nconduct, review our policies, review legal requirements, and then decide what to
\ndo.<\/p>\n

Need some help?<\/strong> When in doubt about how to proceed,
\ndiscuss pending decisions with your manager, your Human Resources
\nrepresentative, or the Legal Department. If you need more support, contact the
\nBusiness Conduct Helpline.<\/p>\n

Retaliation is Not Tolerated<\/p>\n

Apple will not retaliate:and will not tolerate retaliation:against any
\nindividual for filing a good-faith complaint with management, HR, Legal,
\nInternal Audit, Finance, or the Business Conduct Helpline, or for participating
\nin the investigation of any such complaint.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Contents<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\nCustomer and Business Relationships<\/strong><\/td>\n<\/tr>\n
\n

4<\/p>\n<\/td>\n

<\/td>\n\n

Customer Focus<\/p>\n<\/td>\n<\/tr>\n

\n

4<\/p>\n<\/td>\n

<\/td>\n\n

Customer and Third-Party Information<\/p>\n<\/td>\n<\/tr>\n

\n

4<\/p>\n<\/td>\n

<\/td>\n\n

Nondisclosure Agreements<\/p>\n<\/td>\n<\/tr>\n

\n

4<\/p>\n<\/td>\n

<\/td>\n\n

Obtaining and Using Business Intelligence<\/p>\n<\/td>\n<\/tr>\n

\n

4<\/p>\n<\/td>\n

<\/td>\n\n

Third-Party Intellectual Property<\/p>\n<\/td>\n<\/tr>\n

\n

4<\/p>\n<\/td>\n

<\/td>\n\n

Copyright-Protected Content<\/p>\n<\/td>\n<\/tr>\n

\n

5<\/p>\n<\/td>\n

<\/td>\n\n

Giving and Receiving Business Gifts<\/p>\n<\/td>\n<\/tr>\n

\n

5<\/p>\n<\/td>\n

<\/td>\n\n

Kickbacks<\/p>\n<\/td>\n<\/tr>\n

\n

5<\/p>\n<\/td>\n

<\/td>\n\n

Side Deals or Side Letters<\/p>\n<\/td>\n<\/tr>\n

\n

6<\/p>\n<\/td>\n

<\/td>\n\n

Competition and Trade Practices<\/p>\n<\/td>\n<\/tr>\n

\n

6<\/p>\n<\/td>\n

<\/td>\n\n

Endorsements<\/p>\n<\/td>\n<\/tr>\n

\n

6<\/p>\n<\/td>\n

<\/td>\n\n

Open Source Software<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\nGovernments and Communities<\/strong><\/td>\n<\/tr>\n
\n

7<\/p>\n<\/td>\n

<\/td>\n\n

Governments as Customers<\/p>\n<\/td>\n<\/tr>\n

\n

7<\/p>\n<\/td>\n

<\/td>\n\n

Gifts to U.S. Officials<\/p>\n<\/td>\n<\/tr>\n

\n

7<\/p>\n<\/td>\n

<\/td>\n\n

Gifts to Non-U.S. Officials<\/p>\n<\/td>\n<\/tr>\n

\n

7<\/p>\n<\/td>\n

<\/td>\n\n

No Bribery or Corruption<\/p>\n<\/td>\n<\/tr>\n

\n

7<\/p>\n<\/td>\n

<\/td>\n\n

Political Contributions<\/p>\n<\/td>\n<\/tr>\n

\n

8<\/p>\n<\/td>\n

<\/td>\n\n

Charitable Donations<\/p>\n<\/td>\n<\/tr>\n

\n

8<\/p>\n<\/td>\n

<\/td>\n\n

Hiring Government Employees<\/p>\n<\/td>\n<\/tr>\n

\n

8<\/p>\n<\/td>\n

<\/td>\n\n

Trade Restrictions and Export Controls<\/p>\n<\/td>\n<\/tr>\n

\n

8<\/p>\n<\/td>\n

<\/td>\n\n

Environment, Health, and Safety<\/p>\n<\/td>\n<\/tr>\n

\n

8<\/p>\n<\/td>\n

<\/td>\n\n

Community Activities<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\nResponsibilities to Apple<\/strong><\/td>\n<\/tr>\n
\n

9<\/p>\n<\/td>\n

<\/td>\n\n

Protecting Apple’s Assets and Information<\/p>\n<\/td>\n<\/tr>\n

\n

9<\/p>\n<\/td>\n

<\/td>\n\n

Confidential Apple Information<\/p>\n<\/td>\n<\/tr>\n

\n

9<\/p>\n<\/td>\n

<\/td>\n\n

The Apple Identity and Trademarks<\/p>\n<\/td>\n<\/tr>\n

\n

9<\/p>\n<\/td>\n

<\/td>\n\n

Apple Inventions, Patents, and Copyrights<\/p>\n<\/td>\n<\/tr>\n

\n

10<\/p>\n<\/td>\n

<\/td>\n\n

Activities Related to Technical Standards<\/p>\n<\/td>\n<\/tr>\n

\n

10<\/p>\n<\/td>\n

<\/td>\n\n

Accuracy of Records and Reports<\/p>\n<\/td>\n<\/tr>\n

\n

10<\/p>\n<\/td>\n

<\/td>\n\n

Business Expenses<\/p>\n<\/td>\n<\/tr>\n

\n

10<\/p>\n<\/td>\n

<\/td>\n\n

Establishing Bank Accounts<\/p>\n<\/td>\n<\/tr>\n

\n

10<\/p>\n<\/td>\n

<\/td>\n\n

Loans, Advances, and Guarantees<\/p>\n<\/td>\n<\/tr>\n

\n

10<\/p>\n<\/td>\n

<\/td>\n\n

Money Laundering<\/p>\n<\/td>\n<\/tr>\n

\n

11<\/p>\n<\/td>\n

<\/td>\n\n

Document Retention and Legal Hold<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\nIndividual Conduct<\/strong><\/td>\n<\/tr>\n
\n

12<\/p>\n<\/td>\n

<\/td>\n\n

Conflicts of Interest<\/p>\n<\/td>\n<\/tr>\n

\n

12<\/p>\n<\/td>\n

<\/td>\n\n

Outside Employment and Inventions<\/p>\n<\/td>\n<\/tr>\n

\n

13<\/p>\n<\/td>\n

<\/td>\n\n

Personal Investments<\/p>\n<\/td>\n<\/tr>\n

\n

13<\/p>\n<\/td>\n

<\/td>\n\n

Workplace Relationships<\/p>\n<\/td>\n<\/tr>\n

\n

13<\/p>\n<\/td>\n

<\/td>\n\n

Buying and Selling Stock<\/p>\n<\/td>\n<\/tr>\n

\n

13<\/p>\n<\/td>\n

<\/td>\n\n

Harassment and Discrimination<\/p>\n<\/td>\n<\/tr>\n

\n

14<\/p>\n<\/td>\n

<\/td>\n\n

Confidential Employee Information<\/p>\n<\/td>\n<\/tr>\n

\n

14<\/p>\n<\/td>\n

<\/td>\n\n

Privacy<\/p>\n<\/td>\n<\/tr>\n

\n

14<\/p>\n<\/td>\n

<\/td>\n\n

Public Speaking and Press Inquiries<\/p>\n<\/td>\n<\/tr>\n

\n

14<\/p>\n<\/td>\n

<\/td>\n\n

Publishing Articles<\/p>\n<\/td>\n<\/tr>\n

\n

14<\/p>\n<\/td>\n

<\/td>\n\n

Substance Abuse<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\nTaking Action<\/strong><\/td>\n<\/tr>\n
\n

15<\/p>\n<\/td>\n

<\/td>\n\n

Your Obligation to Take Action<\/p>\n<\/td>\n<\/tr>\n

\n

15<\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct Helpline<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\nAdditional Resources<\/strong><\/td>\n<\/tr>\n
\n

16<\/p>\n<\/td>\n

<\/td>\n\n

Policies and References<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

<\/p>\n

Business Conduct <\/strong><\/p>\n

The way we do business worldwide <\/strong><\/p>\n

July 2010<\/p>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Customer and Business<\/strong><\/p>\n

Relationships<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n4<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Customer Focus<\/p>\n

Every product we make and every service we provide is for our customers.
\nFocus on providing innovative, high-quality products and services and on
\ndemonstrating integrity in every business interaction. Always apply Apple’s
\nprinciples of business conduct.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
\n

To what extent may I use an existing customer list to market other
\nApple products or services?<\/strong><\/p>\n

Before using a customer list for marketing, sales, or other activities, talk
\nto your manager or the Legal Department. Using an existing customer list may or
\nmay not be appropriate.<\/p>\n<\/td>\n

<\/td>\n\n

Customer and Third-Party Information<\/p>\n

Customers, suppliers, and others disclose confidential information to Apple
\nfor business purposes. It is the responsibility of every Apple employee to
\nprotect and maintain the confidentiality of this information. Failure to protect
\ncustomer and third-party information may damage relations with customers,
\nsuppliers, or others and may result in legal liability. See the Apple Customer
\nPrivacy Policy.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
\n

Where can I learn more about information protection and nondisclosure
\nagreements?<\/strong><\/p>\n

View the Apple policy on Confidential, Proprietary, and Trade Secret
\nInformation.<\/p>\n

Where can I get a nondisclosure agreement?<\/strong><\/p>\n

In the U.S., see the forms Apple provides for nondisclosure agreements.
\nOutside the U.S., consult your local Apple Legal representative.<\/p>\n<\/td>\n

<\/td>\n\n

Nondisclosure Agreements<\/p>\n

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

<\/td>\n<\/td>\n<\/tr>\n
\n

As long as the information helps Apple, why is the source of business
\nintelligence an issue?<\/strong><\/p>\n

Obtaining information illegally or unethically could damage Apple’s
\nreputation and in some cases could subject Apple to legal liability. For
\nexample, using illegally or unethically obtained information in a bid to the
\ngovernment could result in disqualification from future bidding and in criminal
\ncharges.<\/p>\n<\/td>\n

<\/td>\n\n

Obtaining and Using Business Intelligence<\/p>\n

Apple legitimately collects information on customers and markets in which we
\noperate. Apple does not seek business intelligence by illegal or unethical
\nmeans, and competitors may not be contacted for the purpose of obtaining
\nbusiness intelligence. Sometimes information is obtained accidentally or is
\nprovided to Apple by unknown sources. In such cases, it may be unethical to use
\nthe information, and you should immediately contact your manager, the Legal
\nDepartment, or the Business Conduct Helpline to determine how to proceed.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Third-Party Intellectual Property<\/p>\n

It is Apple’s policy not to knowingly use the intellectual property of any
\nthird party without permission or legal right. If you are told or suspect that
\nApple may be infringing an intellectual property right, including patents,
\ncopyrights, trademarks, or trade secrets owned by a third party, you should
\ncontact the Legal Department.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
\n

May I keep my personal music on my computer at work?<\/strong><\/p>\n

If you are authorized to make copies of the music for personal use (for
\nexample, you own the original CD or you purchased the music on iTunes), you may
\nkeep the music on your computer.<\/p>\n<\/td>\n

<\/td>\n\n

Copyright-Protected Content<\/p>\n

Never use or copy software, music, videos, publications, or other
\ncopyright-protected content at work or for business purposes unless you or Apple
\nare legally permitted to use or make copies of the protected content. Never use
\nApple facilities or equipment to make or store unauthorized copies.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Customer and Business<\/strong><\/p>\n

Relationships<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n5<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Are business meals, travel, and entertainment considered
\ngifts?<\/strong><\/p>\n

Yes. Anything of value given or received is considered a gift.<\/p>\n

Can I avoid these rules if I pay for gifts to customers or business
\nassociates myself?<\/strong><\/p>\n

No. If the gift is given for business reasons and you are representing Apple,
\nthe gift rules apply.<\/p>\n<\/td>\n

<\/td>\n\n

Giving and Receiving Business Gifts<\/p>\n

Employees may not give or receive gifts or entertainment to or from current
\nor potential vendors, suppliers, customers, or other business associates unless
\nall of the following conditions are met:<\/p>\n

Nominal value.<\/strong> The value of the gift is less than US$150.
\nExceptions must be approved by your Vice President (for Vice President:level
\nemployees, exceptions must be approved by your manager).<\/p>\n

Customary.<\/strong> The item is a customary business gift and would
\nnot embarrass Apple if publicly disclosed. Cash is never an acceptable gift.
\nGiving or receiving cash is viewed as a bribe or kickback and is always against
\nApple policy.<\/p>\n

No favored treatment.<\/strong> The purpose of the gift is not to
\nobtain special or favored treatment.<\/p>\n

Legal.<\/strong> Giving or accepting the gift is legal in the
\nlocation and under the circumstances where given.<\/p>\n

Recipient is not a government official.<\/strong> Never provide a
\ngift, including meals, entertainment, or other items of value, to a U.S. or
\nforeign government official without checking with Government Affairs in advance.
\nSee page 7 for more information on gifts to government officials.<\/p>\n

This policy does not preclude Apple as an organization from receiving and
\nevaluating complimentary products or services. It is not intended to preclude
\nApple from giving equipment to a company or organization, provided the gift is
\nopenly given, consistent with legal requirements, and in Apple’s business
\ninterests. The policy also does not preclude the attendance of Apple employees
\nat business-related social functions, if attendance is approved by management
\nand does not create a conflict of interest.<\/p>\n

Important Note: <\/strong>Certain departments (e.g., Operations and
\nRetail) have more restrictive gift policies, which may prohibit giving or
\nreceiving gifts altogether. Employees in those departments must adhere to those
\nstricter policies.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
\n

What is an example of a kickback?<\/strong><\/p>\n

Apple provides discounts to certain customers. However, if a customer gets an
\ninappropriate discount, and a sales representative gets a payment in return,
\nthis is a kickback.<\/p>\n

What is an example of a side deal?<\/strong><\/p>\n

In a sales environment, a side deal may involve a guarantee to accept back
\nunsold products or other special agreements to encourage certain customers to
\nplace larger orders. Such a side deal, whether written or oral, can impact
\nApple’s potential liability with respect to that transaction and may make it
\ninappropriate for Apple to recognize revenue on the products sold, affecting the
\naccuracy of Apple’s books and records. Side deals or side letters made outside
\nof Apple’s formal contracting and approvals process are strictly prohibited.\n<\/p>\n<\/td>\n

<\/td>\n\n

Kickbacks<\/p>\n

Kickbacks are payments or items of value given to individuals in connection
\nwith the purchase or sale of products or services, typically for providing a
\ndiscount in a sales agreement. Employees are prohibited from giving or receiving
\nkickbacks.<\/p>\n

Side Deals or Side Letters<\/p>\n

All of the terms and conditions of agreements entered into by Apple must be
\nformally documented. Contract terms and conditions define the key attributes of
\nApple’s rights, obligations, and liabilities and can also dictate the accounting
\ntreatment given to a transaction. Making business commitments outside of the
\nformal contracting process, through side deals, side letters, or otherwise, is
\nunacceptable. You should not make any oral or written commitments that create a
\nnew agreement or modify an existing agreement without approval through the
\nformal contracting process. In particular, all commitments must have visibility
\nto Finance so Apple can ensure it is properly accounting for each transaction.
\nIf you have knowledge of any side deal, side letter, or agreement made outside
\nof the formal contracting process, you should report it immediately to your
\nmanager, your Human Resources representative, or the Legal Department. You may
\nalso contact the Business Conduct Helpline.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Customer and Business<\/strong><\/p>\n

Relationships<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n6<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

What can I do if a reseller complains to me about low prices at
\nanother reseller?<\/strong><\/p>\n

Advise the reseller that you can’t discuss or attempt to influence pricing of
\nother parties, since this could violate antitrust laws.<\/p>\n

How should I handle customer inquiries about resellers and service
\nproviders?<\/strong><\/p>\n

Apple resellers and service providers are key members of the Apple family.
\nThey promote and sell Apple products, and they provide service and support to
\nApple customers. Accordingly, you should never make disparaging remarks to
\ncustomers about resellers or service providers.<\/p>\n<\/td>\n

<\/td>\n\n

Competition and Trade Practices<\/p>\n

Laws regulating competition and trade practices vary around the world, but
\ncertain activities, such as price fixing and agreeing with a competitor to
\nallocate customers, are almost always illegal and are absolutely prohibited
\nunder Apple policy.<\/p>\n

You should not:<\/p>\n

Agree with competitors or exchange information with competitors on prices,
\npolicies, contract terms, costs, inventories, marketing plans, or capacity
\nplans.<\/p>\n

Agree with a competitor that the competitor will sell goods and services to
\nCustomer A (and you will not), and that you will sell goods and services to
\nCustomer B (and your competitor will not).<\/p>\n

Agree with resellers on the resale pricing of Apple products without Legal
\nDepartment approval.<\/p>\n

Require vendors to purchase Apple products in order to sell products or
\nservices to Apple.<\/p>\n

Describe the products or services of competitors inaccurately to promote
\nApple products or services.<\/p>\n

Engage in any pricing or other practices that could defraud a supplier or
\nothers.<\/p>\n

Violate fair bidding practices, including bidding quiet periods, or provide
\ninformation to benefit one vendor over other vendors.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
\n

What is an example of an endorsement?<\/strong><\/p>\n

A friend writes a great book on software design and asks you to endorse the
\nbook by making a statement on the back cover. If you make such an endorsement,
\ndon’t include your job title or affiliation with Apple.<\/p>\n<\/td>\n

<\/td>\n\n

Endorsements<\/p>\n

When representing Apple, never endorse a product or service of another
\nbusiness or an individual, unless the endorsement has been approved by your
\nmanager and Corporate Communications. This does not apply to statements you may
\nmake in the normal course of business about third-party products that are sold
\nby Apple.<\/p>\n

Open Source Software<\/p>\n

Open source software is software for which the source code is available
\nwithout charge under a free software or open source license. Before using or
\nmodifying any open source software for Apple infrastructure or as part of an
\nApple product or service development effort, you must review Apple’s Open Source
\nPolicy and contact the Legal Department for approval using the forms referenced
\nin that policy.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Governments and<\/strong><\/p>\n

Communities<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n7<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/tr>\n
Tell me more about pricing products that are sold to
\ngovernments.<\/strong><\/td>\n		<\/td>\n\n

Governments as Customers<\/p>\n<\/td>\n<\/tr>\n

\n

Governments shouldn’t be charged more for our products or services than Apple
\ncharges other customers for the same products or services. There are laws that
\nmake it a crime to overcharge the U.S. government. Some other countries have
\nsimilar laws.<\/p>\n<\/td>\n

<\/td>\n\n

Governments are unique customers for Apple. Governments often place special
\nbidding, pricing, disclosure, and certification requirements on firms with which
\nthey do business. Discuss these requirements with Government Affairs or your
\nlocal Apple Legal representative before bidding for government business. For
\nexample, Apple may have to certify that it is supplying the government with the
\nlowest price charged to Apple’s commercial customers. Apple may also have to
\ncertify that its prices have been arrived at independently:that is, without
\ncollaboration with a third party.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
Can I avoid a gift limitation by paying for a gift,
\nsuch as lunch or golf, myself?<\/strong><\/td>\n		<\/td>\n\n

Gifts to U.S. Officials<\/p>\n<\/td>\n<\/tr>\n

\n

No. If you are representing Apple, any gift to a government employee would be
\nviewed as coming from Apple.<\/p>\n

What is considered a gift to a U.S. or<\/strong><\/p>\n

foreign official?<\/strong><\/p>\n

In most cases, anything of value that is given is considered a gift. This
\nincludes items such as meals, golf, entertainment, and product samples. Cash is
\nnever an acceptable gift. Typically, giving cash is viewed as a bribe or
\nkickback and is against Apple policy.<\/p>\n

Who is considered a government official?<\/strong><\/p>\n

Any official or employee of a government, a public international organization
\n(such as the European Commission), any department or agency thereof, or any
\nperson acting in an official capacity. It can also include employees of a
\nstate-run or state-owned business, such as a public utility or university.<\/p>\n<\/td>\n

<\/td>\n\n

It may be illegal to give a gift, even an inexpensive meal or a T-shirt, to a
\ngovernment employee. The rules vary depending on the location and job position
\nof the government employee (for example, rules may vary by state, school
\ndistrict, and city, and there may be different rules for various elected and
\nnonelected officials).<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n\n

To prevent violations, review planned gifts to government officials with
\nGovernment Affairs in advance of giving a gift.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n\n

Gifts to Non-U.S. Officials<\/p>\n

In many countries it is considered common courtesy to provide
\ntoken\/ceremonial gifts to government officials on certain occasions to help
\nbuild relationships. Check local requirements and review any such gifts
\nexceeding US$25 in advance with the Legal Department. For meals, the US$25 limit
\ndoes not necessarily apply. Check here for value limits by country on meals to
\nnon-U.S. public officials and employees. Meals at any value should be avoided
\nwith officials from government agencies where Apple has a pending application,
\nproposal, or other business.<\/p>\n

No Bribery or Corruption<\/p>\n

Offering or giving anything of value to a government official for the purpose
\nof obtaining or retaining business or to secure any improper advantage is
\nillegal. Apple personnel shall not offer or accept bribes or use other
\ninappropriate means to obtain an undue or improper advantage, or otherwise
\nviolate U.S. or international anticorruption laws and regulations (e.g., the
\nU.S. Foreign Corrupt Practices Act).<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n\n

For additional information, see Apple’s Foreign Corrupt Practices Act Policy.\n<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n\n

Political Contributions<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n\n

Apple contributes selectively to political candidates and committees. All
\ncorporate political contributions, whether monetary or in-kind (such as the
\ndonation\/lending of equipment or technical services to a campaign), must be
\napproved in advance by Apple Government Affairs. Employees may not use Apple
\nassets (including employee work time, or use of Apple premises, equipment, or
\nfunds) to personally support candidates and campaigns. It is illegal for Apple
\nto reimburse an employee for a contribution. For more information, see the Apple
\nCorporate Political Compliance Policy and the Political Contributions and
\nExpenditures Policy.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Governments and<\/strong><\/p>\n

Communities<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n8<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Charitable Donations<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Employees are encouraged to support charitable causes of their choice, as
\nlong as that support is provided without the use or furnishing of Apple assets
\n(including employee work time, or use of Apple premises, equipment, or funds).
\nAny charitable donations involving Apple assets require the approval of the
\nChief Executive Officer or Chief Financial Officer. For additional information,
\nsee Finance Policy 1.10.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
\n

What should I do if I’m interested in hiring a current or recent
\ngovernment employee?<\/strong><\/p>\n

Contact Government Affairs before beginning any negotiations to hire a
\ncurrent or recent government, military or other public sector employee as an
\nApple employee or consultant.<\/p>\n<\/td>\n

<\/td>\n\n

Hiring Government Employees<\/p>\n

Laws often limit the duties and types of services that former government,
\nmilitary or other public sector employees may perform as employees or
\nconsultants of Apple. Employment negotiations with government employees are
\nprohibited while the employees are participating in a matter involving Apple’s
\ninterests.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Trade Restrictions and Export Controls<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Many countries periodically impose restrictions on exports and other dealings
\nwith certain other countries, persons, or groups. Export laws may control
\ntrading of commodities or technologies that are considered to be strategically
\nimportant because they have the potential to be used for military purposes. Laws
\nmay cover travel to or from a sanctioned country, imports or exports, new
\ninvestments, and other related topics. Certain laws also prohibit support of
\nboycott activities. See Apple’s Export Control policy for more information.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

If your work involves the sale or shipment of products, technologies, or
\nservices across international borders, check with the Export Department to
\nensure compliance with any laws or restrictions that apply.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
\n

How do I get more information regarding Apple’s environmental,
\nhealth, and safety programs?<\/strong><\/p>\n

Visit the Environment+Safety site.<\/p>\n<\/td>\n

<\/td>\n\n

Environment, Health, and Safety (EHS)<\/p>\n

Apple operates in a manner that conserves the environment and protects the
\nsafety and health of our employees. Conduct your job safely and consistent with
\napplicable EHS requirements. Use good judgment and always put the environment,
\nhealth, and safety first. Be proactive in anticipating and dealing with EHS
\nrisks.<\/p>\n

In keeping with our commitment to the safety of our people, Apple will not
\ntolerate workplace violence. For additional information, review Apple’s
\nWorkplace Violence policy.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/tr>\n
<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/tr>\n
\n

What if I want to get more involved in community activities?<\/strong>\n<\/p>\n

Contact Community Affairs. This group promotes, supports, and facilitates
\nemployees’ involvement in community volunteer activities. Outside the U.S.,
\ncheck with your local Public Relations team.<\/p>\n<\/td>\n

<\/td>\n\n

Community Activities<\/p>\n

At Apple, we comply with all laws and regulations and operate in ways that
\nbenefit the communities in which we conduct business. Apple encourages you to
\nuphold this commitment to the community in all your activities.<\/p>\n

If you hold an elected or appointed public office while employed at Apple,
\nadvise Government Affairs. Excuse yourself from involvement in any decisions
\nthat might create or appear to create a conflict of interest.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/tr>\n
<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n
\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Responsibilities to Apple<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n9<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

What are assets?<\/strong><\/p>\n

Assets include Apple’s extremely valuable proprietary information (such as
\nintellectual property, confidential business plans, unannounced product plans,
\nsales and marketing strategies, and other trade secrets); as well as physical
\nassets like cash, equipment, supplies, and product inventory.<\/p>\n

Where can I learn more about information protection and nondisclosure
\nagreements?<\/strong><\/p>\n

View the Apple policy on Confidential, Proprietary, and Trade Secret
\nInformation.<\/p>\n<\/td>\n

<\/td>\n\n

Protecting Apple’s Assets and Information<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n\n

As an Apple employee you must protect Apple’s property and abide by the
\nfollowing guidelines:<\/p>\n

Follow all security procedures and be on the lookout for any instances you
\nbelieve could lead to loss, misuse, or theft of company property.<\/p>\n

Protect physical assets such as equipment, supplies, cash, and charge
\ncards.<\/p>\n

Use extreme care to protect Apple’s proprietary information from improper
\ndisclosure to third parties. This information includes technical product
\ninformation, information related to current and future products and services,
\nconfidential market research, sales and marketing plans, nonpublic earnings or
\nfinancial data, and organizational charts and information.<\/p>\n

Follow procurement policies and procedures when acquiring goods or services
\non behalf of Apple, avoiding any real or apparent conflict of interest. For more
\ninformation on procurement policies and procedures, talk to your manager or
\nvisit Apple Procurement.<\/p>\n

Use Apple’s assets in a manner that prevents damage, waste, misuse, or
\ntheft. Use assets only for legal and ethical purposes.<\/p>\n

Dispose of assets only with appropriate approval and in compliance with
\napplicable policies. Before disposing of assets, discuss your plans with your
\nmanager.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
If I believe that it is appropriate to disclose
\nconfidential proprietary information to a vendor or other third party, what
\nshould I do?<\/strong><\/td>\n		<\/td>\n\n

Confidential Apple Information<\/p>\n

One of Apple’s greatest assets is information about our products and
\nservices, including future product offerings. Never disclose confidential
\noperational, financial, trade secret, or other business information without
\nverifying with your manager that such disclosure is appropriate. Typically,
\ndisclosure of this information is very limited, and the information may be
\nshared with vendors, suppliers, or other third parties only after a
\nnondisclosure agreement is in place. Even within Apple, confidential information
\nshould be shared only on a need-to-know basis. The Intellectual Property
\nAgreement you signed when you joined Apple defines your duty to protect
\ninformation.<\/p>\n<\/td>\n<\/tr>\n

\n

First, verify that there is a business need for the disclosure. Second,
\nobtain your manager’s approval for the disclosure. Third, be sure that a
\nnondisclosure agreement is in place with the vendor or third party, and that you
\nforward the original copy of the agreement to the Legal Department. If you are
\nstill unsure, check with the Legal Department before making the disclosure.<\/p>\n<\/td>\n

<\/td>\n<\/tr>\n
\n

How do I identify confidential Apple information in
\ndocuments?<\/strong><\/p>\n

Mark these documents “Apple Confidential.”<\/p>\n

What if I have a specific question on the use of the Apple name,
\nnames of products or services, or the Apple logo?<\/strong><\/p>\n

Please direct questions about the Apple corporate identity to
\ncorpID@apple.com.<\/p>\n

How can I find out more about patents?<\/strong><\/p>\n

Visit Apple’s Patent Information site.<\/p>\n<\/td>\n

<\/td>\n\n

The Apple Identity and Trademarks<\/p>\n

The Apple name, names of products (such as iPhone), names of services (such
\nas AppleCare), tag lines (such as “Don’t steal music”), and logos (such as the
\nfamiliar Apple logo) collectively create the Apple identity. Before publicly
\nusing the Apple name, product names, service names, tag lines, or the Apple
\nlogo, review Apple’s corporate identity guidelines on how names and logos can be
\nused and presented (for example, the size of the Apple logo and the amount of
\nwhite space surrounding the logo). Before using the product names, service
\nnames, tag lines, or logos of third parties, check with the Legal Department.\n<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n\n

Apple Inventions, Patents, and Copyrights<\/p>\n

Apple’s practice is to consider for patenting the inventions of its
\nemployees, regardless of whether the inventions are implemented in actual
\nproducts. If you are involved in product development, you should contact the
\nLegal Department regarding the patentability of your work. Be alert to possible
\ninfringement of Apple’s patents and bring any possible infringements directly to
\nthe Legal Department.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

If you create original material for Apple that requires copyright protection,
\nsuch as software, place Apple’s copyright notice on the work and submit a
\ncopyright disclosure form to the Legal Department. For more information, visit
\nthe Apple Copyright Information site.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Responsibilities to Apple<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n10<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Activities Related to Technical Standards<\/p>\n

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

Accuracy of Records and Reports<\/p>\n

Accurate records are critical to meeting Apple’s legal, financial, and
\nmanagement obligations. Ensure that all records and reports, including customer
\ninformation, technical and product information, correspondence, and public
\ncommunications, are full, fair, accurate, timely, and understandable.<\/p>\n

Never misstate facts, omit critical information, or modify records or reports
\nin any way to mislead others, and never assist others in doing so.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
How can I learn more about procedures for meals and
\ntravel?<\/strong><\/td>\n		<\/td>\n\n

Business Expenses<\/p>\n<\/td>\n<\/tr>\n

\n

See Apple’s Travel policy or talk to your manager.<\/p>\n<\/td>\n

<\/td>\n\n

All employees must observe policies and procedures regarding business
\nexpenses, such as meal and travel expenses, and submit accurate expense
\nreimbursement requests. Guidelines on daily meal expenses vary worldwide.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Establishing Bank Accounts<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

All Apple bank accounts must be approved and established by Apple’s Treasury
\nDepartment. All payments must be made by recordable and traceable methods. For
\nmore information, contact the Treasury Department.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Loans, Advances, and Guarantees<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Other than through established corporate programs, such as programs for
\nemployee relocation and the cashless exercise of stock options, Apple does not
\nprovide loans or advances of corporate funds to its employees, officers, Board
\nmembers, or their families and does not guarantee their obligations.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
If I suspect money laundering, what should I
\ndo?<\/strong><\/td>\n		<\/td>\n\n

Money Laundering<\/p>\n<\/td>\n<\/tr>\n

\n

Advise your manager or contact the Apple Legal Department.<\/p>\n<\/td>\n

<\/td>\n\n

Money laundering is the process by which individuals or organizations try to
\nconceal illicit funds or make these funds look legitimate. If you are in a
\nposition to deal directly with customers or vendors, the following examples may
\nbe indications of potential money laundering:<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Attempts to make large payments in cash<\/p>\n

Payments by someone who is not a party to the contract<\/p>\n

Requests to pay more than provided for in the contract<\/p>\n

Payments made in currencies other than those specified in the contract<\/p>\n

Payments from an unusual, nonbusiness account<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Responsibilities to Apple<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n11<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Tell me more about “legal holds.”<\/strong><\/p>\n

In a litigation case or other legal matter, Apple may be required to produce
\ndocuments. In these cases the Legal Department may put a “legal hold” on certain
\ndocuments to prevent the documents from being destroyed, altered, or modified.
\nIf it is found that Apple has failed to retain or produce required documents,
\npenalties or adverse rulings may result. Adverse rulings in major litigation
\ncases can cost Apple a significant amount of money. Failure of employees to
\nretain and preserve documents placed on a legal hold may result in discipline or
\ndischarge.<\/p>\n<\/td>\n

<\/td>\n\n

Document Retention and Legal Hold<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n\n

As an Apple employee, you have a responsibility to manage documents and make
\ndecisions on document retention. The definition of “document” is extremely
\nbroad. For example, every email or other electronic file, every customer record,
\nand every transaction involves the creation of a document. Different documents
\nhave different retention periods. Check with your manager or contact Records
\nManagement to determine the appropriate retention period for documents in your
\narea.<\/p>\n

At times, Apple may need to retain documents beyond the period they would
\nnormally be retained. The most common reasons are litigation or other legal
\nmatters. In these situations, retention and preservation of documents is
\ncritical. If you have documents that may be required for litigation or other
\nlegal matters, the Legal Department will place those documents on a “legal
\nhold,” meaning the documents cannot be altered, destroyed, deleted, or modified
\nin any manner. Legal will notify the individuals most closely identified with
\nthe documents about the legal hold and will provide instructions for retaining
\nthe documents. Recipients of a legal hold must ensure that these instructions
\nare followed. A legal hold remains in effect until you are notified by the Legal
\nDepartment in writing.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Individual Conduct<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n12<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Can you give an example of conflicts of interest or potential divided
\nloyalty?<\/strong><\/p>\n

Your brother-in-law owns a business, that business is being considered as a
\nvendor for Apple, and you are one of the decision makers.<\/p>\n<\/td>\n

<\/td>\n\n

Conflicts of Interest<\/p>\n

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

Do not conduct Apple business with family members or others with whom you
\nhave a significant personal relationship. In rare cases where exceptions may be
\nappropriate, written approval from the Senior Vice President for your
\norganization is required.<\/p>\n

You shouldn’t use your position at Apple to obtain favored treatment for
\nyourself, family members, or others with whom you have a significant
\nrelationship. This applies to product purchases or sales, investment
\nopportunities, hiring, promoting, selecting contractors or suppliers, and any
\nother business matter. This does not apply to special purchase plans offered by
\nApple. If you believe you have a potential conflict involving a family member or
\nother individual, disclose it to your manager.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
Am I allowed to develop outside iPhone or iPad apps on
\nmy own time?<\/strong><\/td>\n		<\/td>\n\n

Outside Employment and Inventions<\/p>\n<\/td>\n<\/tr>\n

\n

No. Employees are not permitted to have any involvement in the development of
\noutside iPhone or iPad apps, either alone or jointly with others.<\/p>\n<\/td>\n

<\/td>\n\n

Full-time Apple employees must notify their manager before taking any other
\nemployment. In addition, any employee (full-time or part-time) who obtains
\nadditional outside employment, has an outside business, or is working on an
\ninvention must comply with the following rules.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
\n

May I occasionally use my Apple email address for my outside
\nbusiness?<\/strong><\/p>\n

Limited personal use of your Apple email is permitted for activities such as
\nsending a brief message to a friend. You may never use your Apple email for an
\noutside business.<\/p>\n

I’m working on an invention on my own time. Does Apple need to
\nknow?<\/strong><\/p>\n

If your invention relates to your job at Apple or could compete with current
\nor reasonably anticipated future products or services of Apple, disclose the
\ninvention to your manager.<\/p>\n

May I serve on the board of directors of an outside enterprise or
\norganization?<\/strong><\/p>\n

If you plan to serve on a board, you must obtain approval from your manager
\nand the Senior Vice President for your organization. In addition, Vice
\nPresidents and Executive Team members must obtain the approval of their manager
\nand the CEO before they can accept a position on the board of directors of a
\nprivate or publicly traded company (other than nonprofit entities).<\/p>\n<\/td>\n

<\/td>\n\n

Do not:<\/p>\n

Use any time at work or any Apple assets for your other job, outside
\nbusiness, or invention. This includes using Apple workspace, telephones,
\ncomputers, Internet access, copy machines, and any other Apple assets or
\nservices.<\/p>\n

Use your position at Apple to solicit work for your outside business or
\nother employer, to obtain favored treatment, or to pressure others to assist you
\nin working on your invention.<\/p>\n

Use confidential Apple information to benefit your other employer, outside
\nbusiness, or invention.<\/p>\n

Participate in an outside employment activity that could have an adverse
\neffect on your ability to perform your duties at Apple.<\/p>\n

Participate in an outside business or outside employment, or develop an
\ninvention, that is in an area of Apple’s present or reasonably anticipated
\nfuture business.<\/p>\n

Before participating in inventions or businesses that are in the same area as
\nyour work for Apple or that compete with or relate to present or reasonably
\nanticipated Apple products or services, you must have written permission from
\nyour manager, an Apple product law attorney, and the Senior Vice President of
\nyour organization. For additional information, see Apple’s policy on Conflicts
\nof Interest.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Individual Conduct<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n13<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

I have stock in companies that do business with Apple. Is this a
\nproblem?<\/strong><\/p>\n

It’s unlikely that this is a problem. However, it could be a concern if (1)
\nyou’re influencing a transaction between Apple and the company, and (2) the
\ntransaction is significant enough to potentially affect the value of your
\ninvestment.<\/p>\n<\/td>\n

<\/td>\n\n

Personal Investments<\/p>\n

Many Apple employees have investments in publicly traded stock or privately
\nheld businesses. These personal investments may give rise to a conflict of
\ninterest if you are involved in or attempt to influence transactions between
\nApple and a business in which you are invested. If a real or apparent conflict
\narises, disclose the conflict to your manager. The manager will help determine
\nwhether a conflict exists and, if appropriate, the best approach to eliminate
\nthe conflict.<\/p>\n

Workplace Relationships<\/p>\n

Personal relationships in the workplace may present an actual or perceived
\nconflict of interest where one individual in the relationship may be in a
\nposition to make or influence employment decisions regarding the other. If you
\nfind yourself in such a relationship, you must notify Human Resources so they
\nmay assist you in resolving any potential conflicts. Employees should not allow
\ntheir relationships to disrupt the workplace or interfere with their work or
\njudgment. For additional information, see Apple’s policy on Personal
\nRelationships.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
\n

How do I know whether information is material?<\/strong><\/p>\n

Determining what constitutes material information is a matter of judgment. In
\ngeneral, information is material if it would likely be considered important by
\nan investor buying or selling the particular stock.<\/p>\n

Does Apple’s policy apply to buying or selling stock in other
\ncompanies?<\/strong><\/p>\n

Yes. For example, say you learn about a customer’s nonpublic expansion plans
\nthrough discussions about hardware purchases. If you purchase stock in the
\ncustomer’s company or advise others to do so, it could be viewed as insider
\ntrading.<\/p>\n<\/td>\n

<\/td>\n\n

Buying and Selling Stock<\/p>\n

Never buy or sell stock while you are in possession of information obtained
\nthrough your employment at Apple that has not been publicly announced and could
\nhave a material effect on the value of the stock. This applies to decisions to
\nbuy or sell Apple securities and to investments in other companies. It is also
\nagainst Apple policy and may be illegal to give others, such as friends and
\nfamily, tips on when to buy or sell stock while you are in possession of
\nmaterial, nonpublic information concerning that stock.<\/p>\n

In addition, employees are prohibited from investing in derivatives of
\nApple’s securities. This includes, but is not limited to, trading in put or call
\noptions related to securities of the company.<\/p>\n

Members of Apple’s Board of Directors, executive officers, and certain other
\nindividuals are subject to blackout periods during which they are prohibited
\nfrom trading in Apple stock. If you are subject to these restrictions, you will
\nbe notified by the Legal Department. Even if you are subject to blackout
\nperiods, you may never buy or sell stock while you are in possession of
\nmaterial, nonpublic information.<\/p>\n

Review Apple’s Insider Trading policy. Specific questions on buying and
\nselling stock should be referred to the Legal Department.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
\n

What is harassment?<\/strong><\/p>\n

Harassment can be verbal, visual, or physical in nature. Specific examples of
\nprohibited harassing conduct include, but are not limited to: slurs, jokes,
\nstatements, notes, letters, electronic communication, pictures, drawings,
\nposters, cartoons, gestures, and unwelcome physical contact that are based on an
\nindividual’s protected class.<\/p>\n

Need more information?<\/strong><\/p>\n

In the U.S., refer to Apple’s Harassment policy. Outside the U.S., contact
\nHuman Resources.<\/p>\n<\/td>\n

<\/td>\n\n

Harassment and Discrimination<\/p>\n

Apple encourages a creative, culturally diverse, and supportive work
\nenvironment. Apple does not tolerate harassment or discrimination based on
\nfactors such as race, color, sex, sexual orientation, gender identity
\ncharacteristics or expression, religion, national origin, age, marital status,
\ndisability, medical condition, veteran status, or pregnancy. Additional
\nrestrictions may apply based on regional laws and regulations.<\/p>\n

These requirements apply to interactions with employees, customers,
\nsuppliers, and applicants for employment and any other interactions where you
\nrepresent Apple.<\/p>\n

If you feel that you have been harassed or discriminated against or have
\nwitnessed such behavior, report the situation to a manager or to Human
\nResources. You may also contact the Business Conduct Helpline.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Individual Conduct<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n14<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
Where can I learn more about policies on confidential
\nemployee information?<\/strong><\/td>\n		<\/td>\n\n

Confidential Employee Information<\/p>\n<\/td>\n<\/tr>\n

\n

View the Apple Safe Harbor Privacy Policy.<\/p>\n<\/td>\n

<\/td>\n\n

As part of your job, you may have access to personal information regarding
\nother Apple employees or applicants, including information regarding their
\nemployment history, personal contact information, compensation, health
\ninformation, or performance and disciplinary matters. This information is
\nconfidential and should be shared only with those who have a business need to
\nknow. It should not be shared outside Apple unless there is a legal or business
\nreason to share the information and you have approval from your manager.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
Is personal information on my computer system
\nprivate?<\/strong><\/td>\n		<\/td>\n\n

Privacy<\/p>\n<\/td>\n<\/tr>\n

\n

Limited personal use of Apple equipment and systems is allowed, but subject
\nto local regulations, Apple may monitor equipment and systems. If in doubt,
\ncheck with the Legal Department.<\/p>\n<\/td>\n

<\/td>\n\n

Subject to rules or regulations affecting an employee’s rights, Apple may
\nmonitor or search its work environments, including equipment, networks, mail,
\nand electronic systems, without notice. Apple monitors facilities and equipment
\nto promote safety, prevent unlawful activity, investigate misconduct, manage
\ninformation systems, comply with legal guidelines, and for other business
\npurposes.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
If I make a presentation on my own time, may I accept a
\npayment?<\/strong><\/td>\n		<\/td>\n\n

Public Speaking and Press Inquiries<\/p>\n<\/td>\n<\/tr>\n

\n

That depends. If you are representing Apple, you may not accept payment. If
\nyou are on your own time and are not representing Apple, you may be allowed to
\naccept payment. Before accepting this type of opportunity, check with your
\nmanager, Human Resources, or the Business Conduct Helpline.<\/p>\n<\/td>\n

<\/td>\n\n

All public speaking engagements that relate to Apple’s business or products
\nmust be preapproved by your manager and Corporate Communications. If you receive
\napproval to make a public presentation at a business meeting or conference, you
\nmay not request or accept any form of personal compensation from the
\norganization that requested the presentation. This does not prohibit accepting
\nreimbursement for expenses, if approved by your manager.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

All inquiries from the press or the financial analyst community must be
\nreferred to Corporate Communications or the Investor Relations Department.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Publishing Articles<\/p>\n

If you author an article or other publication, do not identify yourself in
\nthe publication as an employee of Apple without prior approval from Corporate
\nCommunications. This could be viewed as an endorsement by Apple.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/tr>\n
\n

What if I have a substance abuse issue?<\/strong><\/p>\n

Help yourself and Apple by taking action. Talk to your Human Resources
\nrepresentative or, in the U.S., view information on the Employee Assistance
\nProgram.<\/p>\n<\/td>\n

<\/td>\n\n

Substance Abuse<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n\n

Employees are prohibited from manufacturing, distributing, dispensing,
\npossessing, using, or being under the influence of illegal drugs in the
\nworkplace. Use of alcohol or medications on the job or before work can cause
\nsafety issues, damage customer relations, and hurt productivity and innovation.
\nUse good judgment and keep in mind that you are expected to perform to your full
\nability when working for Apple. View Apple’s policy on Drugs in the Workplace.\n<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Taking Action<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n15<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Your Obligation to Take Action<\/p>\n

Always apply Apple’s principles of business conduct, follow Apple policies,
\nand comply with laws and regulations. When you are unsure, take the initiative
\nto investigate the right course of action. Check with your manager, Human
\nResources, Legal, Internal Audit, or Finance, and review our policies on
\nAppleWeb. If you would like to talk with someone outside your immediate area,
\nconsider contacting the Business Conduct Helpline.<\/p>\n

If you know about a possible violation of Apple’s Business Conduct Policy or
\nlegal or regulatory requirements, you are required to notify your manager
\n(provided your manager is not involved in the violation), Human Resources,
\nLegal, Internal Audit, Finance, or the Business Conduct Helpline. Failure to do
\nso may result in disciplinary action.<\/p>\n

Employees must cooperate fully in any Apple investigation and must keep their
\nknowledge and participation confidential to help safeguard the integrity of the
\ninvestigation.<\/p>\n

Business Conduct Helpline<\/p>\n

The Business Conduct Helpline is available 24\/7 to all employees worldwide to
\nhelp answer your questions on business conduct issues, policies, regulations,
\nand compliance with legal requirements. It also allows you to advise Apple of
\nsituations that may require investigation or management attention.<\/p>\n

The Business Conduct Helpline is committed to keeping your issues and
\nidentity confidential. If you would be more comfortable doing so, you may
\ncontact the Helpline anonymously. Your information will be shared only with
\nthose who have a need to know, such as those involved in answering your
\nquestions or investigating and correcting issues you raise. Note that if your
\ninformation involves accounting, finance, or auditing, the law may require that
\nnecessary information be shared with the Audit and Finance Committee of Apple’s
\nBoard of Directors.<\/p>\n

Due to legal restrictions, anonymous use of the Business Conduct Helpline is
\nnot encouraged in certain countries (e.g., France).<\/p>\n

Apple will not retaliate:and will not tolerate retaliation:against any
\nindividual for their good-faith use of the Business Conduct Helpline.<\/p>\n

Information on contacting the Business Conduct Helpline:including via email,
\ntoll-free telephone, and web access:is available on AppleWeb.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Additional Resources<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n16<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Policies and References<\/p>\n

Alcohol in the Workplace<\/p>\n

Books and Publications<\/p>\n

Business Conduct Helpline<\/p>\n

Buying and Selling Stock: Blackout Periods<\/p>\n

Buying and Selling Stock: Insider Trading<\/p>\n

Community Affairs<\/p>\n

Confidential, Proprietary, and Trade Secret Information<\/p>\n

Copyright Information<\/p>\n

Copyright Policy<\/p>\n

Corporate Identity Guidelines<\/p>\n

Customer Privacy Policy<\/p>\n

Diversity<\/p>\n

Employee Assistance Program (U.S. only)<\/p>\n

Environment+Safety<\/p>\n

Equal Employment Opportunity<\/p>\n

Export Control<\/p>\n

Foreign Corrupt Practices Act Policy<\/p>\n

Government Affairs<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Additional Resources<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Business Conduct<\/strong><\/p>\n

The way we do business worldwide<\/strong><\/p>\n

July 2010<\/p>\n<\/td>\n

<\/td>\n17<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Policies and References (continued)<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Harassment<\/p>\n

Information Security<\/p>\n

Intellectual Property<\/p>\n

Legal Department Contacts<\/p>\n

Mail and Electronic Communications<\/p>\n

Name and Logo Use Questions: corpID@apple.com<\/p>\n

Nondisclosure and Confidentiality Agreements<\/p>\n

Open Communication<\/p>\n

Open Source Software<\/p>\n

Outside Business Activities<\/p>\n

Patent Information<\/p>\n

Patent Policy<\/p>\n

Personal Relationships<\/p>\n

Political Compliance<\/p>\n

Procurement<\/p>\n

Reasonable Accommodation<\/p>\n

Records Management<\/p>\n

Safe Harbor Privacy Policy<\/p>\n

Standards Legal Policy<\/p>\n

Trademarks<\/p>\n

Travel Policy<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n\n

<\/sup> 2010 Apple Inc. All rights reserved. Apple, the Apple logo,
\niPhone, iPad, and iTunes are trademarks of Apple Inc., registered in the U.S.
\nand other countries. AppleCare is a service mark of Apple Inc., registered in
\nthe U.S. and other countries.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n","protected":false},"template":"","meta":{"_acf_changed":false,"_stopmodifiedupdate":true,"_modified_date":"","_cloudinary_featured_overwrite":false},"corporate_contracts_companies":[6722],"corporate_contracts_industries":[9508],"corporate_contracts_types":[9613],"class_list":["post-42114","corporate_contracts","type-corporate_contracts","status-publish","hentry","corporate_contracts_companies-apple-computer-inc","corporate_contracts_industries-technology__hardware","corporate_contracts_types-operations"],"acf":[],"_links":{"self":[{"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/corporate_contracts\/42114","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/corporate_contracts"}],"about":[{"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/types\/corporate_contracts"}],"wp:attachment":[{"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/media?parent=42114"}],"wp:term":[{"taxonomy":"corporate_contracts_companies","embeddable":true,"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/corporate_contracts_companies?post=42114"},{"taxonomy":"corporate_contracts_industries","embeddable":true,"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/corporate_contracts_industries?post=42114"},{"taxonomy":"corporate_contracts_types","embeddable":true,"href":"https:\/\/corporate.findlaw.com\/legal-api\/wp-json\/wp\/v2\/corporate_contracts_types?post=42114"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}