Contents – What should I do if:

1. A supplier, potential supplier, or supplier’s agent offers me a gift? 2

2. A supplier, potential supplier, or supplier’s agent invites me to a meal or entertainment?..................................... 3

3. I want to give a gift to a supplier, potential supplier, or supplier’s agent?................................................... 3

4. I want to give a gift to a government official?...... 3

5. I learn confidential information about the supplier or its other customers?................................................... 3

6. I learn confidential information about an employee?.. 4

7. A non-Apple employee asks me for confidential Apple information? 4

8. I am asked to communicate with the public or the press? 4

9. A conflict of interest arises between what is in the best interest of Apple and what is in the best interest of myself, a friend, or a relative?................................................... 4

What should I do if:

A best practice is not to accept any gifts. In any case, do not accept the gift unless it meets all of the following conditions below. If this is not possible (for example, the gift is delivered to you without your prior permission), return the gift to the giver. If this is not possible (for example, the gift is delivered anonymously), donate it to Apple’s Human Resources Department.

Ø For Apple SER Staff: All gifts offered or received must be reported to the Apple SER Senior Manager.

Ø For Third-Party SER Auditors: All gifts offered or received must be reported to the most senior Apple SER representative involved with the audit, or any Apple SER representative if no Apple SER representative is involved with the audit.

Acceptable gifts meet all four conditions below:

· Nominal value. The value of the gift is less than US$100.

Ø For Apple SER Staff: Exceptions must be approved by your Vice President (for Vice President–level employees, exceptions must be approved by your manager).

Ø For Third-Party SER Auditors: Exceptions must be approved by the most senior Apple SER representative involved with the audit, or any Apple SER representative if no Apple SER representative is involved with the audit.

· Customary. The item is a customary business gift and would not embarrass Apple if publicly disclosed. Cash or cash equivalents are never acceptable gifts.

· No favored treatment. The purpose of the gift is to build a business relationship, not to obtain special or favored treatment.

· Legal. Giving or accepting the gift is legal in the location and under the circumstances where given.

A best practice is not to accept meals or entertainment. In any case, the conditions above for accepting gifts also apply to meals and entertainment. If the combined value of the meal, entertainment, and other gifts would exceed the $100 limit, decline the gift or get approval from your vice president (for Apple SER staff) or an Apple SER representative (for Third-Party SER auditors). If you pay for the meal and entertainment yourself, Apple’s rules for business expenses would still apply. Meals and entertainment under the $100 limit must still be reported to the SER Senior Manager (for Apple SER staff) or an Apple SER representative (for Third-Party SER Auditors).

The same conditions that apply for accepting gifts apply to giving gifts; any gifts that you give (including meals and entertainment) must meet all four conditions required for receiving gifts. Please note that even if you pay for the gift yourself (instead of being reimbursed), the same four conditions apply.

For Third-Party SER auditors: Do not give gifts to government officials.

For Apple SER staff: Special limits and disclosure requirements may exist for gifts to government officials. Please observe the following restrictions in addition to the four conditions that apply to giving gifts to suppliers:

· For gifts to a U.S. government official, review the planned gift with Apple Government Affairs in advance of giving the gift.

· For gifts to a non-U.S. government official, review the planned gift with Apple Government Affairs or the regional Apple attorney in advance of giving the gift.

· For facilitating payments to a non-U.S. government official, ensure that the value does not exceed US$25, and ask your manager or finance representative for information on how to report the gift.

Maintain the confidentiality of the information. Unless the information is directly relevant to the work that you are doing, do not keep records of it. Do not use or disclose any third party information unless you are authorized to do so by the third party.

Maintain the confidentiality of the information. Unless the information is directly relevant to the work that you are doing, do not keep records of it. Disclose the information to other Apple employees or agents only if there is a business need to share the information. Disclose the information outside of Apple only if there is a legal or business reason to share the information and only with the prior permission of your manager.

Verify with your manager (for Apple SER staff) or an Apple SER representative (for Third-Party SER auditors) that such disclosure is appropriate. Generally, such information should only be shared on a need-to-know basis and if the other party has signed a nondisclosure agreement. Original copies of nondisclosure agreements must be forwarded to Apple’s Legal Department. Always limit the amount of confidential information shared to the minimum necessary to address the business need.

All public communications must be referred to Apple Corporate Communications or Investor Relations.

Avoid conflicts of interest, including any situation that gives the appearance of impropriety or divided loyalty. In cases of a real or perceived conflict of interest, talk to your manager, Human Resources, or the Business Conduct Helpline (for Apple SER staff) or an Apple SER representative (for Third-Party SER auditors).