Apple 2011 Annual Report Download - page 98

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Individual Conduct
Business Conduct
The way we do business worldwide
July 2011
13
I have stock in companies that do business
with Apple. Is this a problem?
It’s unlikely that this is a problem. However, it
could be a concern if (1) you’re influencing a
transaction between Apple and the company,
and (2) the transaction is significant enough to
potentially affect the value of your investment.
Personal Investments
Many Apple employees have investments in publicly traded stock or privately held
businesses. These personal investments may give rise to a conflict of interest if you are
involved in or attempt to influence transactions between Apple and a business in which you
are invested. If a real or apparent conflict arises, disclose the conflict to your manager. The
manager will help determine whether a conflict exists and, if appropriate, the best approach
to eliminate the conflict.
Workplace Relationships
Personal relationships in the workplace may present an actual or perceived conflict of interest
where one individual in the relationship may be in a position to make or influence
employment decisions regarding the other. If you find yourself in such a relationship, you
must notify Human Resources so they may assist you in resolving any potential conflicts.
Employees should not allow their relationships to disrupt the workplace or interfere with their
work or judgment. For additional information, see Apple
’
s policy on Personal Relationships.
How do I know whether information is
material?
Determining what constitutes material
information is a matter of judgment. In general,
information is material if it would likely be
considered important by an investor buying or
selling the particular stock.
Does Apple’s policy apply to buying or
selling stock in other companies?
Yes. For example, say you learn about a
customer’
s nonpublic expansion plans through
discussions about hardware purchases. If you
purchase stock in the customer’s company or
advise others to do so, it could be viewed as
insider trading.
Buying and Selling Stock
Never buy or sell stock while you are in possession of information obtained through your
employment at Apple that has not been publicly announced and could have a material effect
on the value of the stock. This applies to decisions to buy or sell Apple securities and to
investments in other companies. It is also against Apple policy and may be illegal to give
others, such as friends and family, tips on when to buy or sell stock while you are in
possession of material, nonpublic information concerning that stock.
In addition, employees are prohibited from investing in derivatives of Apple’s securities. This
includes, but is not limited to, trading in put or call options related to securities of the
company.
Members of Apple’s Board of Directors, executive officers, and certain other individuals are
subject to blackout periods during which they are prohibited from trading in Apple stock. If
you are subject to these restrictions, you will be notified by the Legal Department. Even if you
are not subject to blackout periods, you may never buy or sell stock while you are in
possession of material, nonpublic information.
Review Apple’s Insider Trading policy. Specific questions on buying and selling stock should
be referred to the Legal Department.
What is harassment?
Harassment can be verbal, visual, or physical
in nature. Specific examples of prohibited
harassing conduct include, but are not limited
to: slurs, jokes, statements, notes, letters,
electronic communication, pictures, drawings,
posters, cartoons, gestures, and unwelcome
physical contact that are based on an
individual’s protected class.
Need more information?
In the U.S., refer to Apple’
s Harassment policy.
Outside the U.S., contact Human Resources.
Harassment and Discrimination
Apple encourages a creative, culturally diverse, and supportive work environment. Apple
does not tolerate harassment or discrimination based on factors such as race, color, sex,
sexual orientation, gender identity characteristics or expression, religion, national origin, age,
marital status, disability, medical condition, veteran status, or pregnancy. Additional
restrictions may apply based on regional laws and regulations.
These requirements apply to interactions with employees, customers, suppliers, and
applicants for employment and any other interactions where you represent Apple.
If you feel that you have been harassed or discriminated against or have witnessed such
behavior, report the situation to a manager or to Human Resources. You may also contact
the Business Conduct Helpline.