Blackberry 2015 Annual Report Download - page 160

10 BlackBerry Code of Business Standards and Principles Contents
Q: How can I have a say in the
Integrity & Compliance program?
A: Here are a few ways that you can
provide your ideas and suggestions:
• Discuss them with your manager,
Human Resources or the Integrity
& Compliance Oce.
• Comment on integrity messages
posted to BlackBerry Square.
• Submit them on BlackBerry Ideas,
a portal for providing ideas about all
aspects of BlackBerry (go/ideas).
Q: A vendor just called and claims
that under a certain law we are
responsible for a problem that
must be remedied quickly.
What do I do?
A: Legal furnishes advice on all legal issues
arising in the course of your BlackBerry
work, including advising on legal claims
that third-parties make. Information
on the various legal teams and contact
information can be found at go/legal or by
contacting [email protected].
Q: Why are certain written disclosures and
approvals required?
A: Written disclosure and approval is required for
activities that are high risk and can often benefit from
the guidance of someone with specialized expertise
about the law or application of BlackBerry policies,
in addition to a manager’s oversight. Disclosures
provide documentation that is useful in any internal
or external investigation that may occur later.
In addition, criminal sentencing guidelines and
industry best practices dictate that we document
our integrity and compliance activities.
Here are routine activities that require disclosure and
proper written approval before they can proceed:
• Engaging in something that poses an actual or
perceived conflict of interest, such as starting
a business, hiring a family member to do work
for BlackBerry, or investing in a supplier
BlackBerry uses.
• Giving or receiving anything of value to or from
a public ocial, including giving a device or other
BlackBerry product.
• Giving a gift valued at more than $50 ($100 for
meals and entertainment).
• Giving a gift of a BlackBerry product to someone
who is not a public ocial as a business courtesy
to reflect esteem or gratitude, or as part of
promoting, demonstrating, or explaining a
BlackBerry product or service.
• Retaining or hiring a third party to represent
BlackBerry before any government or to distribute
or sell BlackBerry products and services.
• Speaking publicly for BlackBerry is the job of
individuals designated in our Corporate
Disclosure Policy. You must not respond to
questions about BlackBerry, even informally,
from the investment community (including
financial analysts and investors), regulators
and the media, without proper authorization.
• You have an obligation to disclose to BlackBerry
in writing any development of IP. This includes
any IP that you develop and believe should be
considered an “excluded development” that
does not belong to BlackBerry.
• Requesting a waiver of BS&P requirements.
Please refer to the BS&P for more information about
the requirements for engaging in these activities and
others that require disclosures. Disclosures for written
approval can be made as directed in the BS&P or at
[email protected].