Code of Business Conduct
I Avoid Conflicts of Interest
Doing what's right for Cisco is important. It means avoiding situations that create – or appear to create – a conflict between my personal benefit and Cisco's interests.
What’s a conflict of interest?
A conflict of interest occurs when an employee's personal activities or relationships interfere with his or her objectivity in doing what is best for the company. Conflicts of interest, in fact or appearance, can also decrease shareholder value and expose Cisco to legal and/or reputational liability. Cisco employees are expected to diligently avoid such conflicts.
The five most common situations that can lead to a Conflict of Interest (COI) are:
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Outside Business Interests
- External paid projects or outside employment (disclosure tool)
- Developing new products, including inventions and writings (disclosure tool)
- Outside selling or servicing of Cisco equipment (not approved)
- Ownership or investing in a company that has a connection to Cisco (investment disclosure)
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Family and Friends
- Interacting with them as Cisco suppliers, contractors, consultants, customers or competitors
- Hiring them into Cisco
Contact the Ethics Office about these situations (cobc@cisco.com).
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External Boards
- For-profit, technical and government boards (board disclosure tool)
- Professional association and non-profit boards (contact cobc@cisco.com)
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Communications
- Speaking engagements (check with your manager)
- Endorsements (guidelines)
- Personal references for current or former Cisco employees (see the Social Media Policy)
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Gifts and Entertainment
Since there are a variety of business gift/entertainment situations and related laws around the world, there is a specific “I Statement” and policy for these cases (see pages 18-20). (gifts and entertainment disclosure tool)
Descriptions and required actions for the first four COI categories are detailed in the Cisco Conflict of Interest Policy and Investment policy.
Details about gifts, entertainment and hospitality are provided in the Cisco Gifts and Entertainment Policy. Refer to these policies if your outside activity, situation or relationship has the potential of creating a conflict of interest or the appearance of one.
It’s not possible to list every potential COI situation. If you are not sure, contact the Ethics Office for assistance.
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What If...
What If...
What If...
What if I develop a product I think would be beneficial for Cisco? Can I become a supplier to Cisco?
Under every Cisco employee's Proprietary Information and Inventions Assignment Agreement, Cisco owns the rights to any invention that relates to Cisco's current or anticipated research and development interests, and employees are required to disclose all such inventions to Cisco. If the situation involves a product developed prior to Cisco employment, because this situation could cause divided loyalty or the appearance of a conflict of interest, Cisco will generally not purchase products or services from our employees, with rare exceptions. Before considering such an arrangement, you must obtain written permission from both the Ethics Office and the Cisco vice president for your organization.
What if one of my relatives or a close friend works for a Cisco customer or supplier? Do I need to notify someone about this relationship?
Even if you do not directly work with your family member or friend, any situation that has even the appearance of a conflict of interest should be disclosed to Cisco. If your relative / friend's job and your job responsibilities have the potential of intersecting, you need to disclose this relationship to your manager and the Ethics Office.
What if my friend's daughter wants to apply for a position in my reporting chain? Can I forward her resume directly to the hiring manager (who is my direct report)?
Some of our best hires come from employee referrals. However, to eliminate the appearance of a conflict of interest, tell your friend's daughter to apply through the general application process -- you simply don't want the hiring manager to feel any pressure to hire an individual for any reason other than the belief that the person is the best fit for Cisco. Contact the Ethics Office or Human Resources for more guidance, if needed.
What if a local non-profit is looking for someone to develop an information system? Is it OK for me to volunteer or work “on the side” for them?
It depends on the non-profit organization and the type of information system work that you would be performing. To avoid any potential conflict of interest issues, contact the Ethics Office for help.
Have another question? Post it on the Ethics Discussion Forum or contact the Ethics Office for assistance.
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Tools / Resources
Tools / Resources
Tools / Resources
Gifts and Entertainment Disclosure
Outside Business Interest Disclosure
External Board Participation Disclosure
(for-profit, technical advisory or public/government boards) -
Ask / Report
Ask / Report
Ask / Report
E-mail
- Ethics Office: ethics@cisco.com or COBC@cisco.com
- Audit Committee of the Board of Directors: auditcommittee@external.cisco.com
Online
- Anonymous Web Form
- Ethics Disclosure Tools - Gifts, Entertainment or an Outside Business Interest
- A secure, internal online case reporting/management tool (called CITE)
Phone
The multi-lingual Cisco Ethics Line is available 24 hours a day, 7 days a week, worldwide, with country-based toll-free phone numbers. The Ethics Line is staffed by a leading third-party reporting service. You have the option to remain anonymous* when you call; however, the investigation may be hindered if the investigator is unable to contact you for further information.
*Please note: Some countries do not allow such concerns to be reported anonymously.
Regular Mail
Questions and concerns regarding accounting, internal accounting controls, or auditing matters (or other related issues) can be submitted — confidentially or anonymously — to the Audit Committee of the Board of Directors. at the following private mailbox (PMB):
Cisco Systems, Audit Committee
105 Serra Way, PMB #112, Milpitas, CA 95035