Blackberry 2012 Annual Report Download - page 256

Q: Richard has worked for RIM for many years in its procurement department. His wife, Annabelle, is about to make an investment
in a company that is a current supplier to RIM. The investment will use up much of Richard’s and Annabelle’s savings. Does Richard
have a responsibility to disclose this information to RIM?
A: Yes. Annabelle’s potential investment in a supplier creates a potential conflict of interest situation for Richard. This is particularly
the case since the nature of Richard’s work puts him in a position to interact frequently with RIM suppliers. Added to this, much of
his savings will be involved. However, it is not always the size of the investment that matters. The nature of the investment is often
more likely to create conflict. Richard should disclose the fact that he and his wife are about to invest in this company.
Disclosing Actual or Potential Conflicts
Keep in mind that simply having a conflict of interest is not a violation of our Code—but failure to disclose and obtain the appropriate
approvals for the conflict is a violation. If you have any questions about whether something may be a conflict of interest, raise it with
your manager, team lead and the Legal Department at [e-mail].
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