Blackberry 2012 Annual Report Download - page 260

government such as a mayor, minister, police officer and judge. They can also be employees of government-owned or controlled
companies and agencies. In all cases, we are not permitted to make, promise or authorize improper payments to these individuals or
other persons that we deal with in the course of our daily business.
What Constitutes a “Bribe”?
A “bribe” is an offer or promise to provide cash payments, gifts, travel, entertainment, favors, business courtesies or anything of
value. Bribes are offered or provided with the intent of improperly influencing business decisions.
For detailed information about public officials and improper payments, please see our Prevention of Improper Payments Policy.
We Comply with International Trade Control Laws and Regulations
As a global company, RIM has offices around the world that engage in a wide variety of activities including sales, marketing,
research and development and manufacturing. In addition, we also deliver hardware, software, services and technical information
around the world to our partners and customers. As a result of this global presence and business, our Company needs to abide by all
laws and regulations that apply to the import and export of hardware, software, services and technical information.
An “export” can occur through the physical delivery, email, or download from a network of a product, software, or technology from
one country to another. An export can also occur when we disclose or provide software, services or technical information to a citizen
of another country, regardless of where the person is located. Before engaging in an export activity, you must verify the eligibility of
both the location of delivery and the recipient. You must also make sure all required licenses and permits are obtained prior to the
export.
An “import” is the transfer of goods into a country through physical or intangible means from a foreign or external source or another
RIM location. Imports are also subject to various laws and regulations, and may require the payment of duties and taxes, as well as
the submission of certain filings including an import permit.
From time to time, governments use economic sanctions and trade embargoes to further various foreign policy and national security
objectives. RIM complies with applicable sanction or embargo orders. If you are unsure whether a transaction complies with all
applicable sanction and trade embargo programs, contact the Legal Department at [e-mail].
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