EMC 2002 Annual Report Download - page 104

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Requests for personnel references or employment Human Resources
verifications, or other requests about current 900-555-0170
or former EMC employees.
Requests for salary verification Payroll Department
must be made in writing (mail or fax) to: (fax: 508-614-6769)
DO NOT GIVE OR ACCEPT QUESTIONABLE GIFTS
With respect to non-government personnel, gift giving is proper only to create
good will. It is improper to give a gift to influence the recipient or to
obligate the recipient to do business with the giver. For example, it is
improper to seek special favors by offering to provide use of accommodations
(including lodges, resorts, homes or condominiums), use of transportation
(including vehicles, boats or aircraft), lavish gifts or entertainment,
assistance in securing loans or cash payments.
Unless prohibited by the customer's own policies, it is appropriate to pay for a
customer's meals and entertainment or to invite a customer to a sporting event
or outing, provided the expenses of doing so are reasonable. It is permissible
to give a customer a gift on special occasions, as long as the gift does not
seek, and does not create the appearance of seeking special favors. It is also
appropriate to invite customers to education or training seminars sponsored by
EMC, subject to management approval. On such occasions, EMC may pay the
customer's reasonable travel expenses and give the customer a business-related
gift of reasonable value as a memento of the occasion.
With respect to government personnel, it is improper and illegal, either
directly or indirectly, to provide or pay for any meal, travel, entertainment,
lodging or gift. The giving of any gratuity to a government employee could
subject both you and EMC to civil and criminal penalties.
Any payment or gift to a person acting in an official capacity for a foreign
government designed to influence that individual's acts or decisions is improper
and could subject you and EMC to substantial criminal liability for violation of
the Foreign Corrupt Practices Act of 1977, as amended.
Do not solicit or accept any money. Do not solicit or accept any gift which
would create the appearance that you will be influenced or obligated to do
business with the giver. If a customer or supplier offers or gives you any money
or a gift which would create such an appearance, reject the offer, return the
money or gift and promptly inform your manager and the Office of the General
Counsel.
You may not use EMC funds to give gifts to fellow employees. However, awards may
be given under an EMC-sponsored recognition program, contest or promotion.
AVOID CONFLICTS OF INTEREST
An employee's activities can, intentionally or unintentionally, create a
conflict of interest or an appearance of impropriety. As set forth in your Key
Employee Agreement, you are to devote
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