Apple 2011 Annual Report Download - page 96

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Responsibilities to Apple
Business Conduct
The way we do business worldwide
July 2011
11
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.