Business Conduct: The Way We Do Business
Business Conduct: The Way We Do Business
Business Conduct: The Way We Do Business
11 App Creation
5 Workplace Behaviors 11 Board Positions
13 Political Contributions
6 Protecting Apple 13 Personal Political Activities
6 Non-Disclosure/Confidentiality Agreements
9 Endorsements
Introduction Behaviors Protecting Apple Accountability Integrity Resources
Apple expects its suppliers, contractors, consultants, and other business partners to follow these principles when providing
goods and services to Apple or acting on our behalf. Apple also requires its suppliers to comply with the Apple Supplier
Code of Conduct.
The Business Conduct Policy applies to all full and part-time employees of Apple and its subsidiaries, and provides a
standard guide for what is required of everyone at Apple. Relevant sections also apply to members of Apple’s Board of
Directors. The Business Conduct Policy also provides information on additional resources available to employees, including
the Business Conduct Helpline and the Business Conduct website, which contains guidance and frequently asked
questions to assist employees in understanding Apple’s approach to Business Conduct.
All employees are required to complete annual, online Business Conduct training, and review and certify their
understanding of the Business Conduct Policy. Employees are also required to complete online Respect at Apple and
Privacy trainings, and depending on job responsibilities and location, may be required to participate in additional mandatory
online trainings on specific topics, such as anti-corruption. Focused live training is also arranged periodically on Business
Conduct and other relevant topics.
On rare occasions, local laws may impose requirements on Apple and its employees that differ from those set out in the
Business Conduct Policy. Contact a local People Business Partner for more information on how these laws may apply to
you.
Any waiver of this Policy for our directors, executive officers, or principal accounting officer may be made only by our Board
of Directors, and will be disclosed as required by law or applicable listing rules.
• Follow the Policy. Comply with the letter and spirit of Apple’s Business Conduct Policy and all applicable legal
requirements.
• Speak up. If you see or hear of any violation of Apple’s Business Conduct Policy, other Apple policies, or legal or
regulatory requirements, you must notify either your manager, People Team, Legal, or Business Conduct.
• Use good judgment and ask questions. Apply Apple’s principles of business conduct, and review our policies and legal
requirements. When in doubt about how to proceed, discuss it with your manager, your People Business Partner, Legal,
or Business Conduct. Any failure to comply with Apple’s Business Conduct Policy—or failure to report a violation—may
result in disciplinary action, up to and including termination of employment.
You are also required to fully cooperate in any Apple investigation, and keep any information shared with you confidential to
safeguard the integrity of the investigation.
Reporting a Concern
To report a concern or ask a question about Apple’s Business Conduct Policy, you can contact Business Conduct by phone,
email, or web form. For contact details, visit the Business Conduct website or the Resources section at the end of this
policy. Apple’s external helpline (apple.ethicspoint.com) also allows employees and external parties to report concerns with
the option of remaining anonymous, where permissible under applicable laws. The external helpline provides local, toll-free
phone numbers that connect employees and external parties to a multilingual reporting service.
Your information will be shared only with those who have a need to know to help answer your questions or investigate
concerns, ensure the prompt enforcement of this Policy, and, if appropriate, determine disciplinary action. If your
information involves accounting, finance, or auditing, the law may require that necessary information be shared with the
Audit and Finance Committee of the Board of Directors. Apple’s Business Conduct Policy is administered by the Business
Conduct organization, under the oversight of Apple’s Chief Compliance Officer, who provides regular updates to the Audit
and Finance Committee of the Board of Directors. The Business Conduct team is available to support all employees and
answer questions on business conduct issues, policies, regulations, and compliance with legal requirements.
No Retaliation
Apple will not retaliate—and will not tolerate retaliation—against any individual for reporting a good-faith concern or
complaint to a manager, People, Legal, Business Assurance and Audit, Finance, or Business Conduct, or for participating in
the investigation of a concern or complaint. We do not tolerate knowingly false reporting.
Human Rights
Apple is committed to respecting internationally recognized human rights. Apple’s approach to respecting human rights
is based on the United Nations Guiding Principles on Business and Human Rights, the global standard on business and
human rights. For more information, see the Human Rights Policy.
Workplace Behaviors
Drugs and Alcohol
Apple cares about the health and safety of our employees. You are expected to comply with Apple’s guidelines regarding
alcohol, drugs, and smoking, whether it is in the workplace, at Apple-sponsored events, or while conducting Apple
business. You are not permitted to be under the influence of any legal or illegal drug that impairs your ability to perform
your job, and employees are prohibited from manufacturing, soliciting, distributing, possessing, or using any illegal drugs or
substances in the workplace, or while working. Use good judgment and keep in mind that you are expected to perform to
your full ability at work. For more information, see the Alcohol, Drugs and Smoke-Free Environment Policy.
Apple’s EH&S team provides guidance on how to conduct your job while meeting or exceeding all applicable
environmental, health, and safety requirements. Use good judgment and always put the environment, health, and safety
first. Work proactively with the EH&S team to anticipate and manage EH&S risks in a timely manner.
For more information on the EH&S team, policies, training, and programs, visit the EH&S website.
We are dedicated to maintaining a creative, culturally diverse, and supportive work environment, and do not tolerate
discrimination or harassment of employees or non-employees with whom we have a business, service, or professional
relationship. This applies to all interactions where you represent Apple, including interactions with employees, customers,
suppliers, and applicants for employment.
If you have been harassed or discriminated against, or have witnessed such behavior, report the incident to anyone on the
People Team, a supervisor or manager at any level, or Business Conduct. For more information, see the Equal Employment
Opportunity Policy and People policies for your region.
We also do not tolerate workplace violence of any kind. For more information, see the Workplace Violence Policy.
Protecting Apple
Protecting Apple’s Assets and Information
You play a key role in helping us protect Apple. Assets include Apple’s proprietary information (such as intellectual
property, confidential business plans, unannounced product plans, sales and marketing strategies, and other trade
secrets), as well as physical assets such as cash, equipment, supplies and product inventory.
• Watch what you say. Being aware of where you are, who is around you, and what they might see or overhear is an
important way we all protect Apple’s secrets.
• Protect our assets. Keep track of the assets and information Apple has entrusted to you, and prevent loss, misuse,
waste, or theft.
• Set an example. Model behavior that protects our assets and information at all times.
Non-Disclosure/Confidentiality Agreements
Never share confidential information about Apple’s products or services without your manager’s approval. When there is a
business need to share confidential information with a supplier, vendor, or other third party, never volunteer more than what
is necessary to address the business at hand. Any confidential information shared outside Apple should be covered by a
non-disclosure/confidentiality agreement (NDA). Contact Legal in your region to obtain an NDA. In the United States, you
can find NDA information and support on the Legal website.
Do not misstate facts, omit critical information, or modify records or reports in any way to mislead others, and never assist
others in doing so. Intentional manipulation of Apple records is a form of fraud.
Employees are responsible for managing and protecting information and records in accordance with the Global Records
and Information Management (RIM) Policy. Privacy laws may dictate how long these records can be retained. At times,
Apple will need to retain records and information beyond the normal retention period for legal reasons or audits. If you have
records and information that are categorized as under a “legal hold” you should not alter, destroy, or delete them in any
way. Legal will notify you of any legal holds you may be subjected to and what is required.
For more information, see the Global Records & Information Management website or contact the Global Records &
Information Management team.
Copyright-Protected Content
Never use or copy software, music, videos, publications, or other copyright-protected content at work or for business
purposes unless you or Apple are legally permitted to use or make copies of the protected content. You should never use
Apple facilities or equipment to make or store unauthorized copies. For more information about personal content on Apple-
owned devices, see the Employee Use of Electronic Systems and Communications Policy.
You may pursue, for your own personal ownership, inventions that (a) are not developed using Apple equipment, supplies,
facilities, or proprietary information; (b) did not result from and were not suggested by work performed by you, Apple, or
Apple proprietary information; and (c) are not related to Apple’s current or anticipated business, products, research or
development.
Be alert to possible infringement of Apple’s patents and notify Legal of any possible infringements. If you create original
material for Apple that requires copyright protection, such as software, place Apple’s copyright notice on the work and
submit a copyright disclosure form to Legal. For more information, see the Copyright Policy.
Publishing Articles
If you want to contribute an article or other type of submission to a publication or blog on a topic that relates to
Apple’s business or products or could be seen as a conflict of interest, you must first request approval from Corporate
Communications. If your contribution is technical or academic and relates to Apple, complete the Academic and Industry-
Related Activities Questionnaire to obtain review from Legal and Business Conduct. If your contribution is determined to
be a conflict of interest, you will need to get senior vice president approval. For additional information, see the Social Media
and Online Communications guidelines.
Employees in the Machine Learning organization should follow the Guidelines for Academic Activities of Apple Employees
in Machine Learning.
Endorsements
You should never endorse a product or service of another business or individual in your role as Apple employee, unless
the endorsement has been approved by your manager and Corporate Communications. This does not apply to statements
made in the normal course of business about third-party products sold by Apple. If you want to provide a personal
reference, review the Employment Reference Guidelines.
Individual Accountability
Avoiding Conflicts of Interest
A conflict of interest is any activity that may damage Apple’s reputation or financial interests, or gives the appearance
of impropriety or divided loyalty. Avoid any situation that creates a real or perceived conflict of interest. If you are unsure
about a potential conflict, talk to your manager, Business Conduct, or your People Business Partner.
Members of Apple’s Board of Directors should follow the requirements and procedures described in the Guidelines
Regarding Director Conflicts of Interest.
The following are common situations employees may encounter that could present a conflict of interest.
Significant personal relationships include, but are not limited to, spouses, domestic partners, family members,
dating or physical relationships, close friends, and business relationships outside of Apple. Apple business
relationships include, but are not limited to, vendors, customers, suppliers, contractors, temporary agency
workers, or similar relationships.
Do not conduct Apple business with family members or others with whom you have a significant personal
relationship. Do not use your position at Apple to obtain favored treatment for yourself, family members, or
others with whom you have a personal relationship. This applies to product purchases or sales, investment
opportunities, hiring, promoting, selecting contractors or suppliers, and any other business matter.
If you believe that you have a potential conflict involving a family member or other individual, disclose it to your
manager and your People Business Partner to review and work through any potential conflicts.
You should not allow any relationship to disrupt the workplace or interfere with your work or judgment.
In rare cases where exceptions may be appropriate, written approval from the senior vice president of your
organization is required.
• Is for a company or organization that makes or sells competing products or services to Apple, or that Apple is
reasonably anticipated to create. This includes but is not limited to: Apple hardware products (e.g., computers,
mobile devices, headphones), financial services, original content, health services, cloud services, any
distribution of video, music or eBooks, and any software or app.
• Generates or exposes you to intellectual property that competes with or relates to Apple’s present or
reasonably anticipated business, products, or services.
• Would require you to disclose or use confidential Apple information.
• Is the same work you do for Apple.
• Arises from your role in Apple’s business relationship with the organization.
Work with your manager and Business Conduct to evaluate a potential conflict of interest. If an outside activity
presents a conflict of interest, you must partner with a People Business Partner, and obtain written approval
from your manager, Legal (if applicable), and the senior most person reporting to the CEO of both your and any
relevant organizations. Contact Business Conduct to assist with Legal review.
Any employee, full or part-time, who is participating in an outside activity, must comply with the following rules.
Do not:
• Use any time at work or any Apple assets for your outside activity. This includes Apple’s workspace, phones,
computers, Internet access, photocopiers, and any other Apple assets or services.
• Use your position at Apple to solicit resources or any other benefit for your outside activity, obtain favored
treatment, or pressure others to assist you.
• Participate in an activity that could have an adverse effect on your ability to perform your duties at Apple.
• Use confidential Apple information.
App Creation
You can only create apps for personal or educational purposes. You cannot join the Developer Program or
share, sell, or distribute apps, stickers, or other media (for iOS, Android, or any other operating system), unless
required for Apple business purposes. Some exceptions apply for employees who created apps before joining
Apple or who are joining Apple for a short period of time. If this applies to you, contact Business Conduct to
understand what is permitted.
Board Positions
You may not serve as a director, trustee, officer, or advisory board member without prior approval from Apple.
Apple has pre-approved positions in certain organizations like residential boards (i.e., HOAs) and local sports
and arts organizations, provided their activities do not conflict with Apple’s interests. Contact Business Conduct
if you have any questions or if you would like to seek approval from Apple for a position that is not in a pre-
approved category. A board position that presents a potential or actual conflict of interest is unlikely to be
approved.
The rule above relates to serving on a board in your individual capacity. If you have been asked to serve on a
board as a representative of Apple, you should work with your manager, Legal, and any impacted business
teams to determine if Apple should participate, and whether you are the best person to represent Apple on that
board. If the position is on a public sector advisory board, work with Business Conduct to assess whether your
participation would impact Apple’s ability to interact with that government agency. You should also consult with
Corporate Communications, if applicable.
Personal Investments
You should avoid investing in companies that are Apple competitors or business partners when the investment
presents a conflict of interest. When determining whether a personal investment creates a conflict of interest,
consider if you are in a position to influence transactions between Apple and a business in which you have
invested. If a real or apparent conflict arises, disclose the conflict to your manager. Your manager will help
determine whether a conflict exists and, if appropriate, the best approach to eliminate the conflict. If you still
need help, contact Business Conduct.
Insider Trading
Never buy or sell Apple securities, including Apple stock, if you are aware of information that has not been publicly
announced and that could have a material effect on the value of the securities. It is illegal and against Apple policy
to give anyone, including friends and family, tips on when to buy or sell securities when aware of material nonpublic
information concerning that security. This applies to decisions to buy or sell Apple stock or the stock of an Apple supplier,
manufacturer, vendor, or customer, such as cellular network carriers or other channel partners.
Information is material if it would likely be considered important by an investor who is deciding whether to buy or sell a
security, or if the information is likely to have a significant effect on the market price of the security. Both positive and
negative information may be considered material. Examples of potential material information include financial results,
information about new products or significant features, timing of significant product announcements or new product
introductions, news of a pending or proposed acquisition or other corporate transaction, significant changes in sources
or availability of supplies, changes in dividend policy, significant product defects or modifications, and significant
cybersecurity, or other data protection or privacy incidents.
Short sales, transactions that hedge or offset, or are designed to hedge or offset any decrease in the value of Apple
securities and transactions in derivatives of Apple stock, are prohibited at all times, including transactions involving prepaid
variable forward contracts, equity swaps, collars, options, warrants, puts, calls, or similar instruments related to shares of
Apple stock.
For more information about restrictions on trading in securities as well as answers to FAQs, see the Insider Trading Policy or
email Insider Trading.
Charitable Donations
You are encouraged to support charitable causes of your choosing as long as you do not use or furnish Apple assets
(including your work time or use of Apple premises, equipment, or funds). Any charitable donations involving Apple
assets are managed by the Corporate Donations team and must be approved by the VP of Environment, Policy, & Social
Initiatives. Any donation of 100K USD or more also requires the approval of the Chief Executive Officer or Chief Financial
Officer. For additional information, see the Finance Policy on charitable donations. This policy does not prevent you from
taking advantage of the Apple Matching Gifts Program to contribute to a nonprofit organization of your choice, or from
participating in our Global Volunteer Program.
Political Contributions
Apple does not make political contributions to individual candidates or political parties. All corporate political contributions,
whether monetary or in-kind (including lending or donating equipment or technical services), must be approved in
advance by Apple’s CEO, and processed by Government Affairs and Political Compliance to ensure compliance with
legal requirements and Apple policy. You may not use Apple resources, including employee work time, Apple premises,
equipment, or funds, to personally support candidates and campaigns. It is also illegal for Apple to reimburse an employee
for a political contribution. For more information, see the Corporate Political Compliance Policy and the Apple Public Policy
Advocacy website.
• Do not represent or give the impression that you are representing Apple during any political activities or in campaign
materials.
• Do not make public comments that could be misconstrued as being made on behalf of Apple, or give the impression that
Apple is endorsing any particular legislation, position, or issue.
• Do not use Apple work time, equipment, or resources for political or campaign activities.
• If holding a public office, you may need to recuse yourself from any matters involving Apple.
Gifts
Giving or accepting business gifts can create a real or perceived conflict of interest and can lead to a perception of
favoritism and an expectation of reciprocity that could compromise an employee’s objectivity, even inadvertently. Apple
employees are under either a zero gift rule or a $150 gift rule, depending on their organization. Refer to the Gifts page
on the Business Conduct website to determine your rule. Employees under a zero gift rule may not give or accept gifts to or
from current or potential vendors, suppliers, customers, or other business associates, regardless of the value, unless one
of the key exceptions below applies. Employees under the $150 gift rule may only give or accept gifts if the value is under
$150, unless one of the key exceptions below applies. Gifts must not reflect poorly on Apple if publicly disclosed, and must
be legal in the location and under the circumstances where given. Gifts given with the purpose of influencing a decision are
always prohibited.
A gift is considered anything of value, including a meal, travel, entertainment (including tickets), Apple logo items,
equipment or loans, and employee discounts. Gifts that are cash or cash equivalents, such as gift cards, are never allowed.
In addition, paying for a gift without getting reimbursement from Apple does not remove the requirement to comply with
the gift policy. Gifts between employees are not considered business gifts.
Key Exceptions
Gifts that fall under one of the following exceptions are permissible for most employees, regardless of gift rule (additional
approval requirements may be noted):
• Business meals. With the exception of Apple Store employees, employees may provide and accept reasonable and
appropriate business-related meals, provided they are limited in frequency and expense. Any meals paid for by Apple
must comply with Apple’s Travel and Expense Reimbursement Finance Policy. Employees in Operations must obtain
approval from their manager to accept business meals. Approval should occur beforehand when possible.
• Commemorative items. With the exception of Operations and Apple Store employees, employees may accept
commemorative items of nominal value, such as inexpensive and infrequent vendor promotional items like pens,
calendars, and t-shirts.
• Business-related event attendance. With the exception of Operations and Apple Store employees, free tickets for
sporting events and other forms of entertainment where participation is directly related to an employee’s job function
and part of legitimate Apple business are not considered a gift under Apple’s policy. If you are unsure if attendance
at an event is directly related to your role, check with your manager. For high-value or high-profile events, you should
review your attendance with your manager and your vice president. Employees should never use relationships built
through Apple business for their personal advantage, such as obtaining tickets that are difficult to access, since that is
preferential treatment and could be considered a conflict of interest.
• Conferences. With the exception of Operations and Apple Store employees, free tickets to conferences that are offered
by a vendor, supplier or other third party are permissible if the tickets are free to all attendees, offered as part of a
contract with Apple, or offered to all customers of a particular vendor. Tickets outside of those parameters do not fall
under an exception, and require approval if the value is over your gift limit. Conference tickets purchased by Apple are
not a gift.
• Vendor-supplied local ground transportation. Operations employees may accept reasonable local ground
transportation provided by vendors to and from work locations.
Any other exceptions must be approved by your vice president. For vice president–level employees, exceptions must be
approved by your manager.
Samples
Current and potential vendors and suppliers may provide product samples to Apple for business evaluation purposes.
These samples are not gifts and may not be used for personal purposes. Receipt of samples should be documented
according to any internal division policies, and where appropriate, returned to the vendor and supplier when the evaluation
is complete.
Business Integrity
Governments as Customers
Governments are unique customers for Apple. They often have unique bidding, pricing, disclosure, and certification
requirements. When dealing with government customers, make sure to partner with Legal when bidding for business, and
contact Business Conduct with questions relating to compliance requirements.
Facilitating payments are a type of bribe generally used to facilitate or expedite the performance of routine, non-
discretionary government action. These payments are not permissible and are strictly prohibited by Apple. Exceptions may
be made in circumstances that involve an imminent threat to health or safety, and such situations must be immediately
reported to Business Conduct.
Apple can be found responsible for bribes, kickbacks, and/or facilitating payments made by third parties in connection with
Apple’s business. Before engaging a third party that will be interacting with the government or public officials on Apple’s
behalf, contact Business Conduct to evaluate whether we need to conduct additional due diligence.
For more information, see the Anti-Corruption Policy and other resources available on the Business Conduct and Global
Compliance website.
Money Laundering
Money laundering occurs when individuals or organizations try to conceal illicit funds or make those funds look legitimate.
Money laundering is illegal and strictly prohibited by Apple. In certain countries, we are required to report suspicious
activity. If you deal directly with customers or vendors, the following examples may signal potential money laundering:
• Agree with or exchange information with competitors regarding price, policies, contract terms, costs, inventories,
marketing plans, capacity plans, or other competitively significant data.
• Agree with competitors to divide or assign sales territories, products, or dedicate customers.
• Agree with resellers on the resale pricing of Apple products without legal approval. Resellers are free to determine their
own resale pricing.
• Violate fair bidding practices, including bidding quiet periods, or provide information to benefit one vendor over other
vendors.
• Remember: Always consult the Competition Law Team whenever you have a question. For more information, see
the Antitrust and Competition Law Policy.
As an Apple employee, you should understand that subject to local laws and regulations and in accordance with Apple’s
review process, we may do one of the following when you access Apple’s network or systems, or use any device,
regardless of ownership, to conduct Apple business:
• Access, search, monitor, and archive all data and messages sent, accessed, viewed, or stored (including those from
iCloud, Messages, or other personal accounts).
• Conduct physical, video, or electronic surveillance, search your workspace (e.g. file cabinets, desk drawers, and offices,
even if locked), review phone records, or search any non-Apple property (e.g. backpacks, handbags) while on company
premises.
• Disclose to law enforcement, without prior notice, any information discovered during a search that may indicate unlawful
behavior
While limited personal use of Apple equipment and systems is allowed, Apple may monitor equipment and systems. You
should not have any expectation about the privacy of content or personal information on Apple systems or networks,
including VPN. To learn more, read our Information Security Policies and guidance on Personal Information Privacy on
the People site, which explain Apple’s rights and your rights when conducting Apple business or using Apple-provided
equipment. For more information, contact the Privacy team.
Human Trafficking
Apple is committed to treating everyone in our business and supply chain with dignity and respect, to upholding human
rights across our global network of suppliers, and to protecting the planet we all share. Human trafficking and the use of
involuntary labor are strictly prohibited in Apple’s supply chain and our own business operations. If you become aware of
human trafficking or behavior supporting human trafficking, you must report this activity to Business Conduct as soon as
possible. Some Apple employees who interact with the U.S. government must abide by additional requirements set for
government contractors. For more information, see the Anti-Human Trafficking Policy.
Resources
Anti-Corruption Policy Business Conduct Helpline
(web form and telephone options)
Apple Antitrust and Competition Law Policy Statement
External Helpline for China:
Apple Customer Privacy Policy 400-602-9612
Intellectual Property
Investor Relations
Trademark List