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transactions. All employees, whether located in
the U.S. or abroad, are responsible to ensure compliance with
the FCPA and the Company's FCPA Compliance Policy. Any question
or uncertainty regarding compliance with the FCPA should be
brought to the attention of the Company Ethics Office or Legal
Department.
PROTECTION AND USE OF COMPANY ASSETS
Proper protection and use of Company assets, including proprietary
information, is a fundamental responsibility of each employee.
Employees should protect and promote the efficient use of Company
assets. Theft, carelessness and waste have a direct impact on
the Company's profitability and success. Company assets should
be used for legitimate business purposes.
Internal Controls
The Company has established internal control standards and
procedures to ensure that assets are protected and properly
used and that records and reports are accurate and reliable.
Employees share the responsibility for maintaining and complying
with required internal controls.Confidential and Proprietary
Information
Company employees are required to protect the Company's
confidential and proprietary information, and act responsibly
with the sensitive information of customers and other stakeholders.
Information created by the Company in the conduct of its business
– such as customer or supplier information, employee data,
financial data, research data, strategic plans, statistical
information and trade secrets – is considered Company confidential
and proprietary. Information of a private and sensitive nature
must be controlled and protected to prevent arbitrary and careless
disclosure. Company confidential information should not be disclosed
to persons outside the Company, including family members, and
should only be shared with other Company employees or representatives
who have a "need to know." Company confidential or
proprietary information gained from your employment should not
be used for personal purposes or for the benefit of persons
outside the Company. You should take adequate care to ensure
that confidential and proprietary information is not misused.
Employees must not transfer outside the Company confidential
electronic mail messages or any message intended for internal
use. Company confidential information should not be sent over
the Internet without proper security measures in place.
Intellectual Property
Among the Company's most valuable assets is its intellectual
property such as patents, trademarks, trade secrets, copyrights
and other proprietary information. The Company's policy is to
establish, protect, maintain and defend its rights in all commercially
significant intellectual property and to use those rights in
responsible ways. All employees must take steps to safeguard
these assets.
In addition to protecting the Company's intellectual property
rights, the Company respects the valid intellectual property
of others. Unauthorized use of the intellectual property rights
of others may expose the Company to civil law suits and damages.
In many countries, theft and misappropriation of trade secrets,
proprietary information or other intellectual property may result
in significant fines and criminal penalties to both the Company
and to the individual. New Company products, services, processes
and software, and any proposed use of the intellectual property
of others, should be timely and reasonably reviewed for infringement.
Employees must avoid the unauthorized use of copyrighted materials
of others and should confer with the Company Legal Department
if they have any questions regarding the permissibility of photocopying,
excerpting, electronically copying or otherwise using copyrighted
materials. In addition, simply because material is available
for copying, such as matter downloaded from the Internet, does
not mean that it is automatically permissible to copy or re-circulate
(by, for example, email or posting to an intranet facility).
All copies of work that is authorized to be made for ultimate
distribution to the public, including all machine readable works
such as computer software, must bear the prescribed form of
copyright notice.
The Company is legally entitled to all rights in ideas, inventions
and works of authorship relating to the business that are made
by employees during their scope of employment with the Company
or while using the resources of the Company. As a condition
of employment, employees are required to promptly disclose all
such employee developments to the Company to evidence ownership,
or to obtain legal protection for them.
Record Retention
Each employee should preserve and maintain all business
records in accordance with applicable Company records retention
policies. Records should be maintained and destroyed according
to these policies. Records should not be improperly altered.
In no case may documents involved in a pending or threatened
litigation, governmental inquiry or under subpoena or other
information request be discarded or destroyed, regardless of
the periods specified in the Company's record retention policies.
Electronic Information
Company data transmitted and/or stored electronically are
assets requiring unique protection. Each employee throughout
the Company is responsible for compliance with Company policies
related to electronic information security. In order to protect
and maintain the confidentiality and integrity of information
contained in our information systems, each employee must keep
passwords and personal security codes confidential. Employees
should not share passwords or let others use them.
It is a violation of this Code to access sexually-oriented and
other inappropriate material using Company assets. Inappropriate
use of Company electronic communication resources, regardless
of the medium, is prohibited. Isolated accidental access to
inappropriate material does not constitute misconduct.
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