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Code of Business Conduct and Ethics - Micron

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i<br />

For more information<br />

on record retention <strong>and</strong><br />

management policies, see the<br />

Records Management site on<br />

the MERC.<br />

32<br />

Investor Relations And The Media<br />

Shareholders, financial analysts, the media, customers, vendors, creditors <strong>and</strong> others<br />

count on <strong>Micron</strong> to provide reliable information on the Company’s operations,<br />

performance <strong>and</strong> outlook.<br />

To protect the integrity <strong>of</strong> the information:<br />

• Only those team members specifically authorized to do so may respond to inquiries<br />

from members <strong>of</strong> the media or the investment community (e.g., shareholders,<br />

brokers, financial analysts, etc.). All such inquiries must be forwarded promptly to<br />

the Strategic Communications Department.<br />

• Personnel who are authorized to speak to investors <strong>and</strong> analysts on behalf <strong>of</strong><br />

<strong>Micron</strong> may not provide “special” or favored treatment to some. We must<br />

provide all members <strong>of</strong> the public equal access to the same honest <strong>and</strong><br />

accurate information.<br />

Records Management<br />

Maintaining documents <strong>and</strong> other records is essential to the work <strong>of</strong> our Company,<br />

<strong>and</strong> care must be taken to ensure that all records are managed properly. The following<br />

principles should guide team members:<br />

Maintain records specifically required by law or business needs. Some laws<br />

have specific record-keeping requirements. <strong>Micron</strong> maintains a Records<br />

Management policy to ensure that the Company meets business <strong>and</strong> legal retention<br />

obligations. Under this policy, information is defined by function <strong>and</strong> assigned the<br />

appropriate retention times. We must faithfully maintain all records as required.<br />

Be alert to the need for accuracy – especially when documents are produced<br />

for an <strong>of</strong>ficial purpose. Team members should always try to ensure the accuracy<br />

<strong>of</strong> records, but this becomes especially important when documents <strong>and</strong> other<br />

records or documents are produced for an <strong>of</strong>ficial purpose, such as litigation, a<br />

government inquiry or regulatory review. Providing false or misleading records is<br />

wrong under any circumstances. In particular, doing so when records are produced<br />

or maintained for <strong>of</strong>ficial purposes is a serious violation <strong>of</strong> law <strong>and</strong> can lead to civil<br />

<strong>and</strong> criminal liability.<br />

Retain any records related to litigation or an investigation. If there is an<br />

investigation or litigation, or one is anticipated, it is essential to retain any related<br />

records – including all electronic records. Be sure that automatic disposal or<br />

deletion systems are stopped as necessary to preserve such records.<br />

Keep only what is required under Company record retention policies. While<br />

records must be maintained, every business needs an orderly process for retaining<br />

records <strong>and</strong> documents. The cost <strong>of</strong> physical <strong>and</strong> electronic storage increases<br />

dramatically over time when records are kept unnecessarily. Consult Company record<br />

retention policies for guidance on the proper retention <strong>of</strong> documents.

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