Apple 2003 Annual Report Download - page 154

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Apple has proved to be a leader in technology, and we believe that a comprehensive environmental health and safety program is an essential
component of our forward-looking business approach. Our goal of providing a safe work environment depends on a conscientious effort and
commitment to excellence from all Apple employees.
4. Responsibilities to the Public
A. Buying and selling Apple stock
Apple’s Insider Trading Policy prohibits Apple employees from making transactions ( i.e.
, buying or selling) in Apple stock, including options
and derivatives like puts and calls, at any time when the employee may possess material information about Apple that has not been publicly
disclosed. United States securities laws dictate this policy, and it applies to all executive officers, members of the Board of Directors,
employees, consultants and contractors, including members of their immediate families, and members of their households, who receive or have
access to material nonpublic information regarding Apple
In addition, members of Apple’s Board of Directors, executive officers and other individuals with access to material nonpublic information are
subject to additional restrictions on the trading of stock, including mandatory “blackout periods” during which they may not engage in any
Apple securities transactions.
Apple employees should review Apple’s Insider Trading Policy for more information, and to determine if they are restricted from trading
during blackout periods. A copy of this policy is available to Apple employees on the HR Web Site or may be requested from Apple’s Law
Department. We strongly urge all Apple employees to read the Insider Trading Policy, paying particular attention to the specific policies and
the potential criminal and civil liability and/or disciplinary action for insider trading violations which may include termination of employment.
Any questions about buying or selling Apple stock should be directed to the Apple Law Department.
B. Meeting export requirements
Export laws that control commodities that various governments consider to be strategically important, usually because the information and
products have the potential to be used for military purposes, regulate most of Apple’s confidential information and products. Compliance with
export controls is critical to maintaining our good reputation in the international business community. All Apple employees, temporary
employees, independent contractors and business partners must comply with Apple’s policies when exporting Apple products, working with
technical data, traveling overseas, developing new products, and exporting third-party products.
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