ASK list

Maintaining Our
Shareholders’ Trust

Just as we build our co-workers’ trust by living up to high standards for how we treat each other, we earn our shareholders’ trust by holding ourselves to, and meeting, extremely high standards in the areas explained in this chapter. Although some of the concepts below may sound unfamiliar, it is important that we get to understand what they really mean and uphold them every day.

Records

Be accurate and transparent

We need to make sure that all our company records and reports are full, fair, accurate, timely and understandable. We should never misstate facts, omit critical information or modify records or reports in any way to mislead others, and never assist others in doing so.

If you believe information our company has provided is somehow incomplete, inaccurate or otherwise misleading, you should report it to the Legal Department immediately.


Manage them

Creating and maintaining the company’s records in the right way is key to protecting the integrity of our business. Record management is especially important when it comes to legal holds.

Remember not to talk about litigation matters with anyone inside or outside the company unless you have gotten an okay from our friends in the Legal Department. If you have questions about record management, please see the policy or procedure that applies to you. Or, you can always feel free to reach out to our friends in the Legal Department.

Find out more Policy for the Reporting of Questionable Accounting, Internal Accounting Control, Financial Reporting or Other Auditing Matters.

Insider trading:
don’t do it

It’s never okay to buy or sell stock while you have “material, nonpublic information” about our Company, companies we do business with or any publicly traded company. You may think that only senior management has access to this type of information, but that’s not the case.

Check out some examples of things that might be material, nonpublic information to the right of this text.

We keep this information confidential before it’s released to the public – we never trade on this information, and we don’t share it with anyone else, even close friends or family. Some of us are subject to trading blackout periods. This is another way of protecting you and our company. Please see the Policy on Insider Trading and Tipping.

Find out more Policy on Insider Trading and Tipping.

Money laundering: watch for it

Money laundering can take many shapes and forms. If you’re working directly with distributors, vendors, or other business partners, raise a flag if someone:

  • tries to make large payments in cash
  • who is not mentioned in the contract makes a payment
  • wants to pay more than the contractual sum
  • tries to make payments in other currencies than those specified in the contract
  • makes payments from an unusual, nonbusiness account

If you have any questions, feel free to contact our friends in the Legal Department.

Anti-corruption: business without bribery

Bribery is never an option. We do not:

  • offer, pay or accept bribes or kickbacks in any form, whether it involves a public official or a private party, or
  • tolerate corruption as part of our business dealings

Our relationships with public officials must be transparent and businesslike. There are laws that prohibit or limit the gifts, entertainment and travel that a public official can accept. And offering any of these things to a public official, no matter how small, may be prohibited because it can create negative consequences for you and the company. Please see the Gifts & Entertainment Policy and Anti-Bribery & Anti-Corruption Policy.

Find out more Gifts & Entertainment Policy
Anti-Bribery & Anti-Corruption Policy.

Doing business internationally: follow the rules

Being a global player means there are some extra rules and regulations that we need to follow. A few of these are:

  • laws about the import and export of products and technical data
  • laws that prohibit the delivery of products, data or information to certain nations, organizations or individuals
  • economic sanctions and trade embargoes
  • laws that prohibit companies from getting involved in any international boycott that isn’t approved by the applicable government

If you’re unsure whether one of these laws apply to the work you do, if you wish to report an issue about one of the above laws, or you receive a request to be part of an international boycott, please immediately contact our friends in the Legal Department.

Remember. The ASK list is your
go-to if you have questions.