I Follow the Law

Which laws are reinforced by the COBC?

• Market Competition and Doing Business Ethically

  Market Competition and Doing Business Ethically

  Antitrust and competition laws keep the marketplace thriving.

  Most countries have laws prohibiting business practices that interfere with competition. These include, among other things, any agreement with a competitor as to pricing (either to a reseller or an end user), or agreement to not bid on a project or asking a competitor or reseller not to bid on a project. Cisco abides by these laws wherever we do business, and we avoid conduct that might even suggest or make it appear that we are violating these laws. If you ever have a question, contact Cisco Legal or Ethics Office for help.

• Insider Trading and Corporate Confidentiality

  Insider Trading and Corporate Confidentiality

  Do not trade on “inside” information.

  If you have material, nonpublic information relating to Cisco or our business, it is our policy that neither you, nor any other person or entity, may buy or sell Cisco securities or engage in any other action to take advantage of, or pass on to others, that information. This also applies to trading in the securities of another company (for example, Cisco customers, suppliers, vendors, subcontractors, and business partners), if you have material, nonpublic information about that company that you obtained by virtue of your position at Cisco. Even the appearance of an improper transaction must be avoided. Please note that trading patterns are closely monitored, and Cisco cooperates fully with government investigations of potential illicit trading.

  Even a “tip” is unlawful.

  Cisco employees also are prohibited from tipping off others; that is, passing along inside information to friends or family under circumstances that suggest that the Cisco employee was trying to help someone make a profit or avoid a loss. Besides being a form of insider trading, tipping is also a serious breach of corporate confidentiality. For this reason, you should avoid discussion of sensitive information anywhere that others may hear it, such as in Cisco cafes, on public transportation, or in elevators.

  Derivatives and hedging transactions are not permitted.

  Cisco employees are also prohibited from trading in any Cisco derivative securities, such as put and call options, regardless of whether the employee has material, non-public information. Cisco's policy also prohibits short selling or engaging in any other forms of hedging transactions in Cisco securities, such as collars or forward sale contracts, because of the divergence it could create between objectives of employees and other shareholders.

• Official Disclosures

  Official Disclosures

  Information we disclose about our company must be full, fair, accurate, timely and understandable.

  It is critical that our filings with the Securities and Exchange Commission and other governmental agencies are done properly. You may be called upon to provide information for Cisco's public reports. If so, make sure the information is accurate, complete, objective, relevant, timely and understandable to help ensure full, fair, accurate, timely and understandable disclosure in the reports and documents that we file with or submit to government agencies and in other public communications.

• Global Anti-Corruption and Bribery

  Global Anti-Corruption and Bribery

  Cisco has zero tolerance of bribery and corruption.

  It is paramount to act with the utmost integrity, honesty and transparency, and comply with regional and national anti-corruption laws. It is paramount to act with the utmost integrity, honesty and transparency, and comply with regional and national anti-corruption laws, including the Foreign Corrupt Practices Act (FCPA).

  Specifically, we do not promise, offer, demand, give or accept any advantage (which can include anything of value, not just cash) as an improper inducement for an action that is illegal, unethical or a breach of trust. Check Cisco's Global Anti-Corruption Policy or contact legalcompliance@cisco.com for assistance.

  Gifts and Guest Events

  Regarding acceptable versus prohibited business gifts, refer to the “I Understand our Gifts and Entertainment Policies” section. For guest travel and events expenses, follow the GTET policies and procedures.

  Our Partners’ Behavior

  Cisco also seeks business partners who share our values for transparency and honesty in all business dealings. We require our business partners adhere to our anti-corruption policy for partners. Cisco has training available for its partners. If you engage or work with suppliers, you should be aware that they are expected to abide by our Supplier Code of Conduct and Supplier Ethics Policy, as well as any relevant guiding principles, to help ensure compliance.

• Individuals’ Political Contributions

  Individuals’ Political Contributions

  Under United States election laws, some employees, including Cisco corporate directors and officers, may be required to obtain pre-approval via Cisco's U.S. Political Contribution Tool before making certain kinds of campaign contributions. See Cisco's U.S. Public Sector Ethics Code for more information. For policies regarding use of company assets for political activities, refer to the “I Use Resources Responsibly” section.

• Copyrights

  Copyrights

  Be sure that you have authorization before you use third-party copyrighted material.

  It is against Cisco policy—and, in fact, may be unlawful—to copy, reproduce, digitize, distribute, broadcast, use, or modify third-party copyrighted material in the development or as part of Cisco products, promotional materials, written communications, and blogs and other social media, unless you first obtain written permission from the copyright holder.

  This requirement may apply regardless of whether the end product is for personal use, Cisco internal use, or other use. It is also against our policy for employees to use Cisco facilities, equipment, and networks to make, obtain or distribute unauthorized copies of third-party copyrighted material (including acquiring or sharing third party movies, TV programs, software and music through the Internet and peer-to-peer sites). Improper use of copyrighted material can lead to civil and criminal actions. If you have questions, please contact Legal.

• Personal Data Privacy

  Personal Data Privacy

  Many countries have privacy or personal data protection laws.

  We are committed to protecting the reasonable privacy expectations of everyone with whom we do business, including our customers, vendors/partners, visitors to our websites, and employees. If you have access to personal data (including data hosted by a third party) as part of your work, it is important that you collect, access, use, or share such data only to the extent necessary and relevant to fulfill your assigned job responsibilities and in accordance with Cisco policies, local laws and regulations. If questions arise, consult the Privacy Team.

• Export Regulations

  Export Regulations

  All employees are responsible for abiding by export laws.

  The export of Cisco products, with appropriate licenses, is permissible to most civilian/commercial end users located in all territories except embargoed destinations and countries designated as supporting terrorist activities. For additional information on how you can support Cisco's compliance obligations, please visit the Global Export Trade (GET) group website.

• We exercise our legal rights when necessary

  We exercise our legal rights when necessary.

  Cisco reserves the right to contact legal authorities when there is a reasonable belief that a crime has been committed by a current or former employee connected to the Cisco workplace.

• What If...

  What If...

  What If...

  What if I become aware of Cisco's quarterly earnings results before they have been publicly announced? May I purchase company stock, knowing that information?

  No. This information is considered “material, nonpublic information,” and the purchase of Cisco stock would be a violation of Cisco policy and a potential violation of federal securities laws.

  A vendor presented a new product it plans to introduce soon. My team agreed the product would not be useful for Cisco, but I think it will be a real breakthrough for other industries. Can I buy stock in the vendor's company before the product launch?

  No, you may not buy this stock until information about the new product is known to the public. Otherwise, it would be considered insider trading, which is illegal.

  A consultant we use to facilitate government relations in a particular locale added a significant ‘facilitation' fee to her charges to Cisco. I am concerned she may intend to pass along this extra money to local officials. What should I do?

  Cisco does not condone the bribing of government officials, either directly or through a third party, and in fact Cisco can be legally liable if there are “red flags” that bribery may be occurring. If you suspect this consultant may pass along this payment inappropriately, contact the Ethics Office or Legal.

  What if I am forced to make a decision between obeying a local law and complying with the COBC?

  The law always takes precedence over the COBC. If in doubt, check with the Ethics Office or Legal for help.

  Have another question? Post it on the Ethics Discussion Forum or contact the Ethics Office for assistance.

• Tools / Resources

  Tools / Resources

  Tools / Resources

  Anti-Corruption:

  Global Anti-Corruption Training

  Cisco Guest Travel and Event Tool (GTET)

  Cisco U.S. Public Sector:

  U.S. Federal Sales (Ethics Code and Compliance Guide)

  Gift Rules

  U.S. Political Contribution Tool

  Export Resources:

  Cisco Global Export and Technology Control Group

  Export Compliance Contract

  Privacy Resources:

  Privacy Team

  Privacy Central

• 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