Code of Business Conduct and Ethics - Micron

For potential conflict issues, team members are not responsible for learning about the
activities of friends or the activities of family members who do not reside with that
team member. Team members need only be concerned with circumstances that they
actually know about.
Investments
Team members and their close relatives and friends need to be careful that their
investments do not create conflicts of interest, impairing the team member’s ability
to make objective decisions on behalf of Micron. Any “substantial interest” in a
competitor, supplier or customer requires prior approval as described in the section
on “Obtaining Approval When A Conflict Of Interest Is Involved.” A “substantial
interest” means any economic interest that might influence or appear to influence
a team member’s judgment. Publicly-traded mutual funds, index funds, and similar
poolings of securities, when the individual investor has no say in which investments
are included, usually do not present conflicts.
Some investments are always wrong:
• Never invest in a supplier if you have any involvement in the selection or assessment
of, or negotiations with, the supplier, or if you supervise anyone who has such
responsibility; and
• Never invest in a customer if you are responsible for dealings with, or are involve in
negotiations with, that customer or supervise anyone with such responsibility.
Usually, however, whether an investment creates a conflict of interest is a matter of
good judgment. When deciding whether an investment might create a conflict, ask
yourself these questions:
• Would the investment potentially affect any decisions I make for the Company?
• How would the investment appear to others inside the Company, such as my
coworkers (i.e., would they think it might affect how I do my job)?
• How would the investment look to someone outside the Company, such as a
customer, shareholder or even the newspaper?
Obtaining Approval When A Conflict of Interest
Is Involved
Conflicts of interest are prohibited as a matter of Company policy unless approved in
advance. Any team member aware of, or involved with, a potential conflict of interest
is expected to:
• Disclose the nature and details of the potential conflict of interest to his or her
Department Manager, Vice President (or Site Manager), the Human Resources
Department or the Compliance Officer; and
• Obtain prior approval from his or her Department Manager, Vice President (or Site
Manager) or the Compliance Officer.
i
Since conflicts of interest
may not always be clearly
identifiable, team members
should consult with their
Department Managers,
Vice President (or Site
Manager), the Human
Resources Department or
the Compliance Officer, as
appropriate.
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