Code of Business Conduct and Ethics - Micron

Conflicts Of
Interest, Gifts
& Entertainment,
Participation
in Outside
Organizations
16
Conflicts Of Interest
Micron team members have many activities in their lives outside the Company.
A conflict of interest arises when a team member’s private or personal activities,
investments or associations interfere with (or potentially interfere with):
• His or her loyalty or objectivity to the Company;
• His or her work performance; or
• The interests of the Company.
For purposes of evaluating conflicts of interest, a “supplier,” “customer” or
“competitor” includes both actual and potential suppliers, customers and
competitors. Conflicts of interest, whether actual or perceived, may cloud or interfere
with a team member’s judgment and can be harmful to the Company. Accordingly,
team members must avoid conflicts of interest except as provided in this Code.
Described below are some ways that conflicts of interest can arise.
Outside Employment and Affiliations
If you engage in part-time or other employment, including consulting arrangements,
with a competitor, customer or supplier of the Company, you may have a conflict of
interest with the Company. Any such relationships with competitors, customers or
suppliers are not permitted without approval as described below.
Competition: It is never appropriate to compete, or to prepare to compete, with
the Company while a team member.
Close Relatives and Friends: The work activities of close relatives and friends also
can create conflicts of interest (for these purposes, “close relatives” include a
spouse, parents, stepparents, children, stepchildren, siblings, step siblings, nephews,
nieces, aunts, uncles, grandparents, grandchildren and in-laws). Conflicts of
interest with close relatives or friends arise when a team member’s loyalty becomes
divided (or may appear to be divided) between loyalty to the close relative or
friend, who has one set of interests, and loyalty to Micron, which may have
different interests.
Except as described in the section on “Obtaining Approval When A Conflict Of
Interest Is Involved”:
• A team member should not cause the Company to engage in business transactions
with close relatives or friends or with organizations whose officers or board
members include close relatives or friends;
• A team member’s close relatives or friends should not have any business dealings
with the team member, with anyone working in the team member’s department, or
with anyone who reports to the team member; and
• Team members must not disclose any confidential business information to close
relatives or friends.