Apple 2011 Annual Report Download - page 92

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Governments and
Communities
Business Conduct
The way we do business worldwide
July 2011
7
Tell me more about pricing products that are sold
to governments.
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.
Can I avoid a gift limitation by paying for a gift,
such as lunch or golf, myself?
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.