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Code of Business Conduct and Ethics - Micron

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i<br />

If you need further<br />

information on authorized<br />

political activities contact<br />

the Director <strong>of</strong> Government<br />

Affairs.<br />

34<br />

Q<br />

I am running for the local<br />

school board. I want to use<br />

the <strong>of</strong>fice copier to make<br />

copies <strong>of</strong> my campaign flyer.<br />

Is that OK?<br />

A<br />

No. Company property <strong>and</strong><br />

equipment may not be used for<br />

a political purpose. Running for<br />

a public <strong>of</strong>fice, even the school<br />

board, is a political purpose.<br />

• Strictly follow specified procedures <strong>and</strong> notify your supervisor, local environmental<br />

or facilities representative, the Corporate Environmental Manager, the<br />

Legal Department or the Compliance Hotline <strong>of</strong> potential environmental concerns<br />

or potential non-compliance, <strong>and</strong>, where appropriate, <strong>of</strong>fer ideas for continuous<br />

performance improvement.<br />

Political Activity<br />

The laws <strong>of</strong> the U.S. <strong>and</strong> some other countries set strict limits on<br />

contributions by corporations to political parties <strong>and</strong> c<strong>and</strong>idates.<br />

Specifically, federal law prohibits corporations from making political<br />

contributions or expenditures in connection with any election to federal<br />

<strong>of</strong>fice. Violators are subject to serious penalties, so it is important that all<br />

team members adhere to Company policy.<br />

Corporate Political Activity. As a corporation, the Company is strictly<br />

prohibited from making contributions or expenditures in connection with<br />

any election to any federal <strong>of</strong>fice. Company team members may not make<br />

any direct or indirect political contribution to federal c<strong>and</strong>idates or committees on<br />

behalf <strong>of</strong> the Company. In addition, team members may never identify their own<br />

personal political contributions as being made on behalf <strong>of</strong> the Company. Under no<br />

circumstances may team members seek reimbursement for any political contribution.<br />

For purposes <strong>of</strong> these restrictions, contributions include such things as:<br />

• Buying tickets for a political fundraising event;<br />

• Providing goods or services;<br />

• Loaning personnel during working hours for fundraising activities;<br />

• Using Company resources (e.g., telephones, <strong>of</strong>fice space, staff support, or other<br />

assets) to facilitate or support a c<strong>and</strong>idate’s political activities;<br />

• Paying for advertisements <strong>and</strong> other campaign expenses; or<br />

• Providing air transportation.<br />

Many states also prohibit corporate contributions to state <strong>and</strong> local c<strong>and</strong>idates. To<br />

ensure compliance with these laws, team members may not make any direct or<br />

indirect political contribution on behalf <strong>of</strong> <strong>Micron</strong> unless authorized by the Company’s<br />

Compliance Officer <strong>and</strong> General Counsel (or their designees) in writing. Political<br />

contributions or expenditures over $5,000 also require the written approval <strong>of</strong> the<br />

Chief Executive Officer (or designee).<br />

Personal Political Activity. <strong>Micron</strong> does not discourage political activity by team<br />

members in support <strong>of</strong> c<strong>and</strong>idates or parties, but team members should only engage<br />

in the political process on their own time <strong>and</strong> with their own resources. Never use<br />

Company time, property or equipment for personal political activities.

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