Discussions of integrity have become increasingly
important in today's business environment. But these discussions
are not new to Cisco – ethics, most especially integrity
– have always been a significant part of both our culture
and the way we conduct business. Operating with a strong sense
of integrity is critical to maintaining trust and credibility
with our customers, partners, employees, and shareholders. Our
continued emphasis on ethics and integrity is one reason why Cisco
is considered a leader in our industry and why we are consistently
rated one of the best places to work in our industry.
Our code has traditionally embodied such
rules regarding individual and peer responsibilities, as well
as responsibilities to our employees, customers, suppliers, shareholders,
the public and other stakeholders, and includes:
- Prohibiting conflicts
of interest (including protecting corporate opportunities)
- Protecting Cisco’s
confidential and proprietary information and that of our customers’
and vendors’
- Treating Cisco’s
employees, customers, suppliers and competitors fairly
- Protection and
proper use of company assets
- Compliance with
laws, rules and regulations (including insider trading laws)
- Encouraging the
reporting of any unlawful or unethical behavior
The information below are those portions of our code of conduct,
which address the issues listed above.
Overview of Business Ethics
The collection of policies and guidelines
established in the Code of Business Conduct applies to all Cisco
employees and board members. We believe that long-term, trusting
business relationships are built by being honest, open and fair.
We promise to uphold the highest professional standards in all
global business operations. We also expect that those with whom
we do business (including suppliers, customers or re-sellers)
will adhere to Cisco's Code of Business Conduct standards.
Outstanding employees are key to Cisco's
success. Everyone is part of the company team, and each of us
deserves to be treated with dignity and respect. In addition,
every employee is responsible for his/her own conduct. No one
has the authority to make another employee violate Cisco's Code
of Business Conduct, and any attempt to direct or otherwise influence
someone else to commit a violation is unacceptable.
Managers, in particular, set an example
for other employees and are often responsible for directing the
actions of others. Cisco requires all employees, including managers,
to know and understand the Code of Business Conduct, as it applies
personally to the employee or manager and to those under his/her
supervision.
The fundamental principle that underlies
the way we do business at Cisco is good judgment. An understanding
of our legal and ethical parameters enhances that judgment. Cisco
has a responsibility to pay constant attention to all legal boundaries
and to comply with all applicable laws and regulations in all
of its operations worldwide. We have the same obligation to the
communities in which we do business and to the customers with
whom we do business. For everyone at Cisco, this means following
the spirit of the law and doing the right, ethical thing even
when the law is not specific.
This code outlines the broad principles
of legal and ethical business conduct embraced by Cisco. It is
not a complete list of legal or ethical questions an employee
might face in the course of business, and therefore, this code
must be applied using common sense and good judgment. Additionally,
under certain circumstances local country law may establish requirements
that differ from this code. Cisco employees worldwide are expected
to comply with all local country laws and Cisco business conduct
policies in the area in which they are conducting Cisco business.
Although we realize that no two situations
are alike, we aim for consistency and balance when encountering
any ethical issues. It is essential that we all keep an eye out
for possible infringements of Cisco's business ethics - whether
these infringements occur in dealings with the government or the
private sector, and whether they occur because of oversight or
intention. Cisco employees who have questions regarding business
conduct or possible violations should contact their local HR representative,
the Legal Department, or Sylvia Allen, Cisco’s Ethics’
Officer at Ethics Program Office. The Company will not tolerate
retaliation for reports made in good faith.
Business Ethics
It is essential that we all keep an eye
out for possible infringements of Cisco’s business ethics--whether
these infringements occur in dealings with the government or the
private sector, and whether they occur because of oversight or
intention. Cisco employees who have knowledge of possible violations
should notify Human Resources, the Legal Department or the “Ethics
at Cisco” website, which includes a direct link to the Audit
Committee of the Board of Directors for financial matters. To
assist employees in the day-to-day protection of our business
ethics, we’ve compiled a list of some areas where breaches
may occur:
- Improper or excessive
payments of any of the following:
- Consulting fees
-Director & officer payments
- Agents’
fees -Advertising fees
- Miscellaneous
expenses -Insurance premiums
- Nondeductible
expenses -Employee loans
- Public relations
fees -Legal fees
- Commissions
-Other professional fees
- Expense reports
-Employee bonuses or compensation agreements
- Questionable payments
to agents, consultants, or professionals whose backgrounds haven’t
been adequately investigated, who don’t have signed contracts
or letters of engagement, or whose association with Cisco would
be embarrassing if exposed
- Payroll-related
expenditures, bonuses, awards, and non-cash gifts given to or
by Cisco employees without proper approval and adequate documentation
- Payments made in
cash or checks drawn to Cash or Bearer or bank accounts/property
titles not in Cisco’s name
- Transfers to or
deposits in the bank account of an individual, rather than in
the account of the company with which we are doing business
- Billings made higher
or lower than normal prices for fees, at a customer’s
request
- Payments made for
any purpose other than that described in supporting documents
- Payments made to
employees of customers or agencies through intermediary persons
or organizations, or that seem to deviate from normal business
transactions
- Any large, abnormal,
unexplained, or individually approved contracts, or expenditures
made without review of supporting documentation
- Unusual transactions
occurring with nonfunctional, inactive, or shell subsidiaries
or undisclosed or unrecorded assets or liabilities
- Use of unethical
or questionable means to obtain information, including information
about competitors, information concerning government acquisition
plans, or any procurement decision or action
- An employment, consulting,
or business relationship between a Cisco employee and another
company, especially in the same or related business
- Frequent trading
(buying and selling over short intervals) in Cisco stock or
the stock of a company with which we do business.
These are examples of possible infringements
that Cisco employees need to avoid. Employees should feel free
to discuss any concerns about this policy with their manager,
HR representative or the Legal Department.
Conflicts of Interest
Employees are expected to make or participate
in business decisions and actions in the course of their employment
with Cisco based on the best interests of the company as a whole,
and not based on personal relationships or benefits. Conflicts
of interest can compromise employees' business ethics. Employees
are expected to apply sound judgment to avoid conflicts of interest
that could negatively affect Cisco or its business. At Cisco,
a conflict of interest is any activity that is inconsistent with
or opposed to Cisco's interests, or gives the appearance of impropriety.
Employees should avoid any relationship
that would cause a conflict of interest with their duties and
responsibilities at Cisco. Employees are expected to disclose
to us any situations that may involve inappropriate or improper
conflicts of interests affecting them personally or affecting
other employees or those with whom we do business. Waivers of
conflicts of interest involving executive officers require the
approval of the Board of Directors or an appropriate committee.
Members of Cisco’s Board of Directors
have a special responsibility because our Directors are prominent
individuals with substantial other responsibilities. To avoid
conflicts of interest, Directors are expected to disclose to their
fellow Directors any personal interest they may have in a transaction
upon which the Board passes and to recuse themselves from participation
in any decision in which there is a conflict between their personal
interests and the interest of Cisco.
Set forth below is specific guidance for
some areas of potential conflict of interest that require special
attention. It is not possible to list all conflicts of interest.
These are examples of the types of conflicts of interest that
Cisco employees are expected to avoid. Ultimately, it's the responsibility
of each individual to avoid any situation that could appear to
be a conflict of interest. Employees are urged to discuss any
potential conflicts of interest with their manager, HR Representative,
the Ethics Program Office, or the Legal Department.
Interest in Other Businesses: Cisco
employees and members of their immediate families must avoid any
direct or indirect financial relationship with other business
that could cause divided loyalty. Cisco employees must receive
written permission from the Cisco vice president for their organization
before beginning any employment, business, or consulting relationship
with another company. This doesn't mean that family members are
precluded from being employed by one of Cisco's customers, competitors,
or suppliers. However, Cisco employees must avoid conducting Cisco
business with members of their families--or others with whom they
have a significant personal relationship--unless they have prior
written permission from the Cisco vice president of their organization.
Outside Directorships and Membership
in Technical Advisory Boards ("TAB"s): Cisco encourages
its employees to be active in industry and civic associations,
including membership in other companies' Boards of Directors and
TABs. Employees who serve on outside boards of a profit making
organization are required, prior to acceptance, to obtain written
approval from a Review Board which includes the Chief Financial
Officer, Senior Vice President of Human Resources and General
Counsel. As a rule, employees may not accept a position as an
outside director or TAB member of any current or likely competitor
of Cisco. Furthermore, in the absence of an overriding benefit
to Cisco and a procedure to avoid any financial conflict (such
as refusal of compensation and recusal from involvement in the
company's relationship with Cisco), approval is likely to be denied
where the Cisco employee either directly or through people in
his or her chain of command has responsibility to affect or implement
Cisco's business relationship with the other company. Approval
of a position as a director or TAB member of a company that supports
or promotes a competitor's products or services is also likely
to be denied.
If the committee approves an outside directorship
or TAB membership, employees may keep compensation earned from
that directorship unless the terms of the committee's approval
state otherwise. Generally, however, employees may not receive
any form of compensation (including stock options, IPO stock or
cash) for service on a board of directors of a company if the
service is at the request of the company or in connection with
Cisco's investment in, or a significant relationship exists with,
that company and the directorship is as a consequence or in connection
with that relationship. Any company that is a vendor, supplier,
partner or customer of Cisco has a "relationship" with
Cisco. "Significant" is broadly defined to include a
sole-source vendor/supplier, or one in which Cisco is responsible
for generating five percent or more of the outside company's revenues.
When membership on a Board of Directors or TAB is other than at
Cisco's request, and even if no compensation is received, a potential
for conflict of interest exists, and therefore the Cisco employee
is expected to recuse him- or herself from any involvement in
Cisco's relationship with that company. It is therefore important
that Cisco employees recognize that their membership should be
an opportunity to provide expertise and to broaden their own experience,
but they should not be put in a position where the other company
expects to use the person's board membership as a way to get access
or to influence Cisco decisions.
Cisco may at any time rescind prior approvals
in order to avoid a conflict or appearance of a conflict of interest
for any reason deemed to be in the best interests of the company.
In addition, Cisco will periodically conduct an inquiry of employees
to determine the status of their membership on outside boards.
Investments in Public Companies:
Passive investments of not more than one percent of total outstanding
shares of companies listed on a national or international securities
exchange, or quoted daily by NASDAQ or any other board, are permitted
without Cisco's approval--provided the investment is not so large
financially either in absolute dollars or percentage of the individual’s
total investment portfolio that it creates the appearance of a
conflict of interest. Any such investment must not involve the
use of confidential "inside" or proprietary information,
such as confidential information that might have been learned
about the other company on account of Cisco's relationship with
the other company. Investments in diversified publicly traded
mutual funds are not deemed subject to these conflict of interest
guidelines, provided confidentiality requirements are observed.
Investments in Private Companies.
Cisco employees will occasionally find themselves in a position
to invest in Cisco partners or customers. It is imperative that
employees presented with such opportunities understand the potential
conflict of interest that may occur in these circumstances. Cisco
employees must always serve our shareholders first. Investing
in companies that Cisco has an actual or potential business relationship
with may not be in our shareholders' best interests. The following
guidelines are intended to cover such circumstances:
Cisco employees may not invest in privately
held companies that are Cisco customers, partners or suppliers
without disclosure to the Cisco senior vice president for their
organization and to the Review Board. Where the employee either
directly or through people in his/her chain of command has responsibility
to affect or implement Cisco's relationship with the other company,
approval of the Review Board is required; however, in such cases
approval is likely to be denied. Examples of employees having
such responsibilities include:
- Employees in a position
to select a particular chip for a given product and owning shares
in that chip vendor
- Employees in a position
to recommend a particular software or hardware vendor partner
to a customer while owning shares in that vendor or reseller
- Employees whose responsibilities
include sales of Cisco products to a customer or reseller while
owning shares in the customer or reseller
Such situations may put the Cisco employee
in a conflict of interest between furthering their personal interests
versus the interests of Cisco, hence the likelihood of denial.
Employees in those circumstances should not invest in the company
in question.
If an investment is made and/or approval
is granted, and the employee subsequently finds him- or herself
in a potentially conflicted position due to his or her job responsibilities
or those of others in his or her chain of command, the Cisco employee
is expected to recuse him- or herself from any involvement in
Cisco's relationship with that company. (If the conflict is so
fundamental as to undermine the employee's ability to undertake
an important job activity, a discussion of possible divestiture
may be required). Furthermore, with respect to any investment
or financial interest in a third party, employees should be extremely
cautious to avoid activities such as recommending or introducing
the company to other parts of the Cisco organization unless there
is a clear disclosure of the financial interest.
If an employee happens to have an investment
in a company and transitions into a role that would place him/her
in a conflict of interest position (such as those described above),
the employee should disclose the situation in writing to his/her
manager and HR Representative. Efforts will be made to resolve
the situation equitably on a case-by-case basis.
Where Cisco has made an investment in a
company, permission must be obtained before an employee invests
in that company. When a Cisco employee is placed on a boards of
director or advisory board to represent Cisco, such employee cannot
make an investments in that company without Review Board approval;
and they may not receive compensation for such participation at
Cisco's request.
Investments in Venture Funds. Just
as investments in publicly traded mutual funds are not deemed
to pose a conflict of interest since such investors do not control
the timing of fund investments or dispositions, there is no general
restriction on Cisco employees investing in private venture funds
that, in turn, invest in start-ups. Given that investors in venture
funds are "limited partners" and do not have influence
in the decision making of the funds, we have deemed these investments
appropriate from the standpoint of conflicts with the venture
firm itself. At the same time, general conflict of interest rules
outlined above apply to the employee's relationship with known
portfolio companies of private venture capital funds in which
employees have invested. Just as in the case of investments in
private companies described above, employees should not invest
in funds where it is likely that the employee will be responsible
for recommending, reviewing or transacting business with a known
portfolio company of the fund. Employees will be expected to not
participate in Cisco's relationship with that company if such
a situation arises after the investment commitment has been made.
Honoraria: Speaking at events, when
it is determined to be in Cisco's best interests, is considered
part of an employee's normal job responsibilities. Because employees
will be compensated by Cisco for most or all of their time spent
preparing for, attending, and delivering presentations approved
by management, employees should not request or negotiate a fee
or receive any form of compensation (excepting the novelties,
favors or entertainment described in the Favors, gifts, and entertainment
section) from the organization that requested the speech, unless
the employee first receives express authorization from the Cisco
vice president for their organization; alternatively, a fee can
be accepted provided it is donated to the Cisco Foundation or
other non-profit charitable organization.
Inventions, books, and publications:
Cisco employees must receive written permission from the Cisco
vice president for their organization before developing, outside
of Cisco, any products, software, or intellectual property that
is or may be related to Cisco's current or potential business.
Proper payments: All Cisco employees
should pay for and receive only that which is proper. Cisco employees
should not make payments or promises to influence another's acts
or decisions, and Cisco employees must not give gifts beyond those
extended in normal business. Cisco employees must observe all
government restrictions on gifts and entertainment. Employees
will not receive payments of any kind from Cisco customers.
Favors, gifts, and entertainment:
Cisco employees and members of their families must not give or
receive valuable gifts (including gifts of equipment or money,
discounts, or favored personal treatment) to or from any person
associated with Cisco vendors or customers. This includes accepting
the opportunity to buy "directed shares" (also called
"friends and family shares") from a company where the
Cisco employee is now or is likely to become involved in the evaluation,
recommendation, negotiation or approval of current or prospective
business with that company.
This is not intended to preclude Cisco from
receiving or evaluating appropriate complimentary products or
services. Nor is it intended to preclude Cisco from making a gift
of equipment to a company or organization, provided that the gift
is openly given, with full knowledge by the company or organization,
and is consistent with applicable law. In rare circumstances,
local customs in some countries may call for the exchange of gifts
having more than nominal value as part of the business relationship.
In these situations, gifts may be accepted only on behalf of Cisco
(not an individual) with the approval of the employee's managing
director and the Cisco Legal Department. Any gifts received should
be turned over to Human Resources for appropriate disposition
or donated to the Cisco Foundation or other nonprofit, charitable
organization. In all cases, the exchange of gifts must be conducted
so there is no appearance of impropriety. Gifts may only be given
in accordance with applicable laws, including the U.S. Foreign
Corrupt Practices Act.
Advertising novelties, favors, and entertainment
are allowed when the following conditions are met:
- They are consistent with
Cisco's business practices
- They do not violate any
applicable law, such as state and federal procurement laws and
regulations
- They are of limited value
($50 U.S. or less)
- Public disclosure would
not embarrass Cisco
Industry Associations. Membership
on boards of industry associations generally do not present financial
conflicts of interest. However, employees should be sensitive to
possible conflicts with Cisco's business interests, if, for instance,
the association takes a position adverse to Cisco's interests or
those of key customers.
Supervisory Relationships with Family
Members: Supervisory relationships with family members present
special workplace problems, including a conflict of interest,
or at least the appearance of conflict, in various personnel decisions
that the supervisor makes. Accordingly, Cisco employees must avoid
a direct reporting relationship with any member of their family
or others with whom they have a significant relationship. If such
a relationship exists or occurs, the employee must report it in
writing to the HR Representative.
Special Ethics Obligations For Employees
With Financial Reporting Responsibilities
As a public company it is of critical importance
that the Cisco's filings with the Securities and Exchange Commission
be accurate and timely. Depending on their position with Cisco,
employees may be called upon to provide information to assure
that the Company's public reports are complete, fair and understandable.
Cisco expects all of its personnel to take this responsibility
very seriously and to provide prompt and accurate answers to inquiries
related to the Company's public disclosure requirements.
The Finance Department bears a special responsibility
for promoting integrity throughout the organization, with responsibilities
to stakeholders both inside and outside of the Cisco. The Chief
Executive Officer and Finance Department personnel have a special
role both to adhere to these principles themselves and also to
ensure that a culture exists throughout the company as a whole
that ensures the fair and timely reporting of Cisco's financial
results and condition.
Because of this special role, the Chief
Executive Officer and all members of Cisco's Finance Department
are bound by the following Financial Officer Code of Ethics, and
by accepting the Code of Business Conduct, each agrees that he
or she will:
- Act with honesty and integrity,
avoiding actual or apparent conflicts of interest in personal
and professional relationships.
- Provide information that
is accurate, complete, objective, relevant, timely and understandable
to ensure full, fair, accurate, timely, and understandable disclosure
in reports and documents that Cisco files with, or submits to,
government agencies and in other public communications.
- Comply with rules and
regulations of federal, state, provincial and local governments,
and other appropriate private and public regulatory agencies.
- Act in good faith, responsibly,
with due care, competence and diligence, without misrepresenting
material facts or allowing one's independent judgment to be
subordinated.
- Respect the confidentiality
of information acquired in the course of one's work except when
authorized or otherwise legally obligated to disclose. Confidential
information acquired in the course of one's work will not be
used for personal advantage.
- Share knowledge and maintain skills important
and relevant to stakeholder's needs.
- Proactively promote and be an example of ethical
behavior as a responsible partner among peers, in the work environment
and the community.
- Achieve responsible use of and control over
all assets and resources employed or entrusted.
- Promptly report to the Director of Internal
Control Services and/or the Chairman of the Audit Committee
any conduct that the individual believes to be a violation of
law or business ethics or of any provision of the Code of Conduct,
including any transaction or relationship that reasonably could
be expected to give rise to such a conflict.
Violations of this Financial Officer Code of Ethics, including
failures to report potential violations by others, will be viewed
as a severe disciplinary matter that may result in personnel action,
including termination of employment. If you believe that a violation
of the Financial Officer Code of Ethics has occurred, please contact
Cisco's General Counsel, Mark Chandler, at machandl@cisco.com.
You may also contact the Audit Committee of the Board of Directors
at:
- auditcommittee@external.cisco.com,
or
- if you are concerned about maintaining anonymity,
you may send correspondence to the following outside private
mail box (pmb) address at: Cisco Systems, Audit Committee, 105
Serra Way, PMB #112, Milpitas, CA 95035.
It is against Cisco policy to retaliate against any employee
for good faith reporting of violations of this Code.
Laws, Regulations, and Government Related Activities
As an international U.S. based company,
Cisco is subject to laws and regulations both in the U.S. and
abroad. Violation of governing laws and regulations is both unethical
and subjects Cisco to significant risk in the form of fines, penalties
and damaged reputation. It is expected that each employee will
comply with applicable laws, regulations and corporate policies.
Specific areas with which employees are expected to comply include:
- Anti-Trust
- Insider Trading
- Foreign Corrupt
Practices Act
- Government Business
- Political Contributions
- Using Third-Party
Copyrighted Material
- Export, Re-export
and Transfer Policy
- Customs Compliance
for International Shipping
Anti-Trust
The economy of the United States, and of
most nations in which Cisco does business, is based on the principle
that competition and profit will produce high-quality goods at
fair prices. To ensure that this principle is played out in the
marketplace, most countries have laws prohibiting certain business
practices that could inhibit effective competition. The antitrust
laws are broad and far-reaching. They touch upon and affect virtually
all aspects of Cisco's operations. Cisco supports these laws not
only because they are the law, but also because we believe in
the free market and the idea that healthy competition is essential
to our long-term success. Cisco fully embraces all antitrust laws
and avoids conduct that may even give the appearance of being
questionable under those laws. Whether termed antitrust, competition,
or free trade laws, the rules are designed to keep the marketplace
thriving and competitive. In all cases where there is question
or doubt about a particular activity or practice, employees should
contact the Legal Department or Sylvia Allen, Cisco’s Ethics
Officer at the Ethics Program Office before proceeding.
Insider Trading
If an employee has material, non-public
information relating to Cisco, it is Cisco's policy that neither
the employee, nor any person related to the employee, may buy
or sell securities of Cisco or engage in any other action to take
advantage of, or pass on to others, that information. This policy
also applies to trading in the securities of any other company,
including our customers or suppliers, if employees have material,
non-public information about that company which the employee obtained
in the course of their employment by Cisco.
Transactions that may be necessary or justifiable
for independent reasons, including emergency expenditures and
transactions planned before the employee learned the material
information, are not exceptions. Even the appearance of an improper
transaction must be avoided to prevent any potential risk to Cisco
or the individual trader. Violations of insider trading laws may
be punishable by fines and/or imprisonment.
Besides the obligation to refrain from trading
while in possession of material, non-public information, employees
are also prohibited from "tipping" others. The concept
of unlawful tipping includes passing on information to friends
or family members under circumstances that suggest that employees
were trying to help them make a profit or avoid a loss. Besides
being considered a form of insider trading, of course, tipping
is also a serious breach of corporate confidentiality. For this
reason, employees should be careful to avoid discussing sensitive
information in any place (for instance, at lunch, on public transportation,
in elevators) where others may hear such information.
Foreign Corrupt Practices Act
Cisco requires full compliance with the
Foreign Corrupt Practices Act (FCPA) by all of its employees,
consultants, agents, distributors, and resellers. The anti-bribery
and corrupt payment provisions of the FCPA make illegal any corrupt
offer, payment, promise to pay, or authorization to pay any money,
gift, or anything of value to any foreign official, or any foreign
political party, candidate or official, for the purpose of:
- Influencing any act, or
failure to act, in the official capacity of that foreign official
or party
- Inducing the foreign official
or party to use influence to affect a decision of a foreign
government or agency, in order to obtain or retain business
for anyone, or direct business to anyone.
Payments, offers, promises or authorizations
to pay any other person, U.S. or foreign, are likewise prohibited
if any portion of that money or gift will be offered, given or
promised to a foreign official or foreign political party or candidate
for any of the illegal purposes outlined above.
All Cisco employees, whether located in
the United States or abroad, are responsible for FCPA compliance
and the procedures to ensure FCPA compliance. All managers and
supervisory personnel are expected to monitor continued compliance
with the FCPA to ensure compliance with the highest moral, ethical
and professional standards of the company.
Any action in violation of the FCPA, or
any of the ethical and business standards as outlined in Cisco's
Resource Guide is prohibited. All Cisco employees who become aware
of apparent FCPA violations should notify the Legal Department
or the Ethics office immediately. Any question or uncertainty
regarding compliance with this policy should be brought to the
attention of the Legal Department or Sylvia Allen, Cisco’s
Ethics Officer at the Ethics Program Office.
Government Business
Cisco employees should understand that special
requirements might apply when contracting with any government
body (including national, state, provincial, municipal, or other
similar government divisions in local jurisdictions). Because
government officials are obligated to follow specific codes of
conduct and laws, special care must be taken in government procurement.
Some key requirements for doing business with a government are:
- Accurately representing which Cisco products
are covered by government contracts
- Not offering or accepting kickbacks,
bribes, gifts, gratuities or anything else of value with the
intent of obtaining favorable treatment from the recipient (a
gift that is customary in the business sector may be perceived
as a bribe by a government official)
- Not improperly soliciting or obtaining
confidential information, such as sealed competitors' bids,
from government officials prior to the award of a contract
- Hiring present and former government
personnel may only occur in compliance with applicable laws
and regulations (as well as consulting the Legal Department
and Human Resources).
Political Contributions
No Cisco assets--including employees' work
time, use of Cisco premises, use of Cisco equipment, or direct
monetary payments--may be contributed to any political candidate,
political actions committees (aka "PACs"), party, or
ballot measure without the permission of the General Counsel.
Of course, Cisco employees may participate in any political activities
of their choice on an individual basis, with their own money and
on their own time.
Using Third-Party Copyrighted Material
Cisco employees may sometimes need to use
third-party copyrighted material to perform their jobs. Before
such third-party material may be used, appropriate authorization
from the copyright holder must be obtained. The need for such
permission may exist whether or not the end product containing
third-party material is for personal use; for Cisco internal or
other use. It is against Cisco policy and it may be unlawful for
any employee to copy, reproduce, scan, digitize, broadcast, or
modify third-party copyrighted material when preparing Cisco products
or promotional materials, unless written permission from the copyright
holder has been obtained prior to the proposed use. Improper use
could subject both Cisco and the individuals involved to possible
civil and criminal actions for copyright infringement. It is against
Cisco policy for employees to use Cisco's facilities for the purpose
of making or distributing unauthorized copies of third-party copyrighted
materials for personal use or for use by others.
Export, Re-Export, and Transfer
Policy
Design, Development, and Production
Technology
Export of design, development, and production
technology is subject to national security, foreign policy, and
anti-terrorism laws and regulations. Employees must obtain written
authorization from Cisco's Export Compliance and Regulatory Affairs
(ECRA) group before providing design, development, or production
technology to nationals or territories of countries that have
not ratified global weapon non-proliferation treaties. Non-Disclosure
Agreements do not constitute written authorization to transfer
design, development, or production technology.
Use technology and technology that has been
made publicly available, with the exception of cryptography, may
be exported to all foreign nationals and territories except those
embargoed or sanctioned by the United States.
Products & Technology
Under no circumstances shall employees or
agents engage in marketing, service, or sales of products or technology
to embargoed or sanctioned territories without written authorization
from ECRA.
Violation & Suspicious Activities
Reporting
Employees should contact ECRA if they know
or have reason to believe that any party (e.g. Partners, Users,
Employees) has or intends to violate United States or local country
laws or regulations.
Customs Compliance for International
Shipping
Cisco's policy is to comply fully with customs
laws, regulations and policies in all countries where Cisco does
business. Accurate customs information on shipping documents is
required for all international shipments. Employees should not
initiate shipping documents outside approved automated shipping
systems or non-production shipping group.
Proprietary Information
Proprietary information is defined as information
that was developed, created, or discovered by the company, or
that became known by or was conveyed to the company, that has
commercial value in the company's business. It includes but is
not limited to software programs and subroutines, source and object
code, trade secrets, copyrights, ideas, techniques, know-how,
inventions (whether patentable or not), and any other information
of any type relating to designs, configurations, toolings, schematics,
master works, algorithms, flowcharts, circuits, works of authorship,
formulae, mechanisms, research, manufacture, assembly, installation,
marketing, pricing, customers, salaries and terms of compensation
of company employees, and costs or other financial data concerning
any of the foregoing or the company and its operations generally.
Cisco's business and business relationships
center on the confidential and proprietary information of Cisco
and of those with whom we do business– customers, vendors,
and others. Each employee has the duty to respect and protect
the confidentiality of all such information. The use of confidential
and proprietary information–whether Cisco's or a third party's–is
usually covered by a written agreement. In addition to the obligations
imposed by that agreement, all employees should comply with the
following requirements:
- Confidential information
should be received and disclosed only under the auspices of
a written agreement.
- Confidential information
should be disclosed only to those Cisco employees who need to
access it to perform their jobs for Cisco
- Confidential information
of a third party should not be used or copied by any Cisco employee
except as permitted by the third-party owner (this permission
is usually specified in a written agreement)
- Unsolicited third-party
confidential information should be refused or, if inadvertently
received by a Cisco employee, returned unopened to the third
party or transferred to the Legal Department for appropriate
disposition
Employees must refrain from using any confidential
information belonging to any former employers, and such information
must never be brought to Cisco or provided to other Cisco employees.