Being a good corporate citizen includes legal compliance. As a global company, we stay on top of laws and regulations as they apply to doing business around the world.
Antitrust laws around the world prohibit business practices that reduce competition. For example, antitrust rules forbid agreements between competitors that agree on the prices or other terms on which they will sell products or services or divide customers or markets. Antitrust laws also set rules regarding exclusive dealing, bundling and tying, below cost pricing, preventing or discouraging resellers from discounting, or (in a few countries) discriminating between similarly situated resellers with respect to pricing and promotional payments. The most serious antitrust violations, for example agreements between competitors regarding pricing, can result in criminal penalties for Cisco and the individuals involved, including fines and imprisonment. Violation of other antitrust rules can lead to high fines and damages, reputational damage, and the possibility of government monitoring of Cisco’s business decisions. Cisco is fully committed to competing fairly and complying with antitrust and competition laws in every country where we do business. If you have questions relating to antitrust and competition laws, or if you believe that Cisco, a partner, or a competitor is not in compliance with those laws, you should immediately contact Cisco Legal.
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.
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.
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.
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.
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). We will forgo business opportunities rather than pay bribes, and we will support our employees when faced with losing sales owing to refusal to pay bribes.
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 and Bribery Policy or contact firstname.lastname@example.org for assistance.
Regarding acceptable versus prohibited business gifts, refer to the “I Understand our Gifts and Entertainment Policies” section. Offers to pay for guest travel or hospitality must be made in accordance with the Anti-Corruption and Bribery and Gifts, Travel and Entertainment policies.
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.
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.
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.
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.
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.
All employees are responsible for abiding by import laws. The import of products on behalf of Cisco, with appropriate customs declarations and licenses, and adhering to destination customs regulations, Cisco policies and procedures, is permissible in most territories. Exceptions include personal effects, shipments to embargoed destinations and countries designated as supporting terrorist activities. For additional information on how you can support Cisco’s import compliance obligations, including additional country-specific restrictions, please visit the Global Customs website.
Cisco and its subsidiaries are committed to participating in international efforts to combat money laundering and the funding of terrorist and criminal activities. This is also embedded in Cisco’s legal obligations across various jurisdictions. In some countries Cisco employees are personally liable to contribute to the prevention of money laundering and they should note the importance of adhering to Cisco’s Anti-Money Laundering (AML) and Terrorist Financing policies and procedures where relevant. Some of Cisco’s obligations in this regard include: maintaining AML policies and procedures and conducting customer screening to ensure Cisco is not transacting with individuals or entities on U.S. and international sanctions lists.
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.
If a local law conflicts with our COBC, we follow the local law; however, if a local business practice
conflicts with our COBC, we follow our COBC. When in doubt, ask for help.
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.
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.
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 Cisco Legal.
The law always takes precedence over the COBC. If in doubt, check with the Ethics Office or Legal for help.
Have another question, contact the Ethics Office for assistance.
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.
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