GameStop 2010 Annual Report Download - page 126

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CONFLICT OF INTEREST
Associates must not engage in any activities, transactions, or relationships that are incompatible with the impartial, objective, and effective performance of
their duties.
Examples of matters and relationships that could create a conflict of interest or a potential conflict, include, but are not limited to, an Associate or a member
of the Associate's immediate family or household:
• Accepting or soliciting extravagant gifts, favors, or services from an individual, business, or other party involved, or potentially involved, in a contract or
transaction with GameStop;
• Accepting, agreeing to accept, or soliciting money or other tangible or intangible benefit in exchange for the exercise of official powers or the
performance of official responsibilities;
• Accepting employment or compensation or engaging in any business or professional activity that might require disclosure of GameStop's confidential
information;
• Accepting other employment or compensation that could reasonably be expected to impair the individual's independence of judgment in the performance
of official duties;
• In performance of official duties, purchasing goods or services from an individual or business with a significant ownership interest known to be held by a
GameStop Associate or a member of a GameStop Associate's immediate family or household; or
• Making personal investments that are contrary to GameStop's interests.
Members of an Associate's immediate family or household may work for GameStop, provided that one family member does not directly or indirectly
supervise another. Relatives of GameStop Associates applying for employment at GameStop will be considered for employment using the same selection
criteria as is applied to all other candidates. No person may be hired or employed by GameStop if that individual has a relative or household member currently
employed by GameStop in the Human Resources, Loss Prevention or Payroll departments.
Permitted Investments
Associates must avoid any investments in the businesses of GameStop's customers, suppliers, or competitors that could cause divided loyalty, or even the
appearance of divided loyalty.
Associates who have investments in the businesses of customers, suppliers, other Associates or competitors or who plan to make such investments must file a
disclosure form (see below). As a general rule, an Associate's investment in securities traded on a recognized stock exchange does not create a conflict of
interest as long as the securities are purchased on the same terms and with the same information available to the general public. A disclosure form need not be
filed for acquisitions of securities traded on a recognized stock exchange.
Investments that are never considered conflicts of interest include mutual funds, blind trusts, or debt instruments of publicly held companies that are traded on
a recognized stock exchange.
Disclosure of Interested Transactions
Associates are required to file a Conflict of Interest Disclosure Form (see Appendix A) with their department head as soon as they have knowledge of a
transaction or proposed transaction
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