Apple 2003 Annual Report Download - page 151

This is not intended to preclude Apple from receiving or evaluating appropriate complimentary products and services. It is also not intended to
preclude Apple from making a gift of equipment to a company or an organization, provided that the gift is given openly, with full knowledge
by the company or organization, and is consistent with applicable law and Apple’s business interests. It is also not intended to preclude
Apple’s attendance at social functions, provided such attendance is approved by management and does not present a conflict of interest or the
appearance of a conflict of interest.
In some circumstances, local custom in countries other than the United States may call for the exchange of gifts having more than nominal
value as part of a business relationship. In these situations, gifts may be given or received only if they comply with written guidelines that have
been approved by Apple’s managing director for the country and the Apple Law Department. Such gifts may be accepted only on behalf of
Apple (not an individual) and must be turned over to the Human Resources Department for appropriate disposition. In all cases, the exchange
of gifts must be conducted so there is no appearance of impropriety.
No
“kickbacks” of any type may be given to any customer’s or vendor’s employees or representatives. No kickback of any type may be
received by any Apple employee, particularly those involved in any Apple business transaction, including purchasing goods or services for
Apple.
Outside vendors (including temporary agencies and contractors). When dealing with any outside vendors or potential vendors, Apple
employees must maintain the highest ethical standards. Only arm’s-length transactions should be conducted. Employees of outside vendors
are also expected to maintain the highest ethical standards, including maintaining the confidentiality of any Apple and third-party information
that they receive.
Honoraria.
Speaking at events, when it is determined to be in Apple’s best interests, is considered part of an employee’s normal job
responsibilities. Because employees will be compensated by Apple for most or all of their time spent preparing for, attending, and delivering
presentations approved by management, employees should not request or negotiate a fee or receive any form of compensation from the
organization that requested the speech, unless the employee first receives express written authorization from the Apple Vice President for his or
her organization.
These examples above do not list all possible conflicts, but do illustrate some of the conflicts of interest Apple employees must avoid.
Ultimately, it is the responsibility of each individual to avoid any situation that would even appear to be a conflict of interest or to be improper.
Each employee should feel free to discuss any potential conflict of interest situations with his or her manager or Human Resources, as
appropriate, or the Apple Law Department.
F. It
’s a matter of record
Records count. They are a vital part of maintaining a high level of ethical business transactions. Apple records must be maintained and
disposed of properly, in accord with established procedures and Apple policies. All business and accounting transactions must be fully and
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