Code of Business Conduct and Ethics - Micron

Q
I want to send certain
products to a country on
the restricted list. Is it OK if
I arrange to transfer them
to a company in a country
without these restrictions
who will then sell them to
the restricted country?
14
A
No. As is true with many laws,
what might seem like a clever
way around the law is also
illegal.
i
If you need further
information on international
bribery laws, contact your
Department Manager or
the Legal Department. In
addition, as a general
matter, if you are involved in
international business, contact
the Legal Department to
make sure you understand the
standards that may apply to
your business activities.
trade or commercial transactions with any of these countries without the approval
of the Logistics/Traffic Department or the Legal Department. When dealing with
a new country, customer or supplier, you always should check to determine if any
restrictions apply. You should also check export requirements regarding transfers of
any technology or shipping of any products to another country.
Transfer of Restricted Information
An “export” is not only the transfer of a physical commodity, but can also include
the transfer of restricted information to a person who is a national of another
country (e.g., persons who are not entitled to a U.S. passport, even when such
persons are Company team members) by:
• E-mail;
• Face-to-face discussions; or
• Visits to a Micron facility.
In all international dealings, be sure you know and comply with all export controls
and trade restrictions.
U.S. Antiboycott Act.
Under U.S. law, Micron is required to report to the U.S. Government, and not to
cooperate with, any request concerning boycotts or related restrictive trade practices.
Team members may not take any action, furnish any information or make any
declaration that could be viewed as participation in an illegal foreign boycott. Such
laws were originally designed to respond to the boycott of Israel by certain Middle
Eastern countries, but they apply to any boycott of countries friendly to the U.S.
There are severe penalties for violation of these laws.
According to the U.S. Government, the following countries may require cooperating
with an international boycott:
• Bahrain
• Bangladesh
• Syria
• Republic of Yemen
• Qatar
• Kuwait
• Libya
You should notify the Legal Department immediately, and before taking any action, if
you receive any boycott-related requests for information or compliance, whether oral
or written. This includes requests that are part of an actual order and those that do
not concern a specific transaction.
• Iran
• Oman
• Pakistan
• United Arab Emirates
• Lebanon
• Saudi Arabia
Customs
As a general rule, importation is subject to various customs, fiscal laws and
regulations. In particular, physical importation of products into a country must usually
comply with either: