GameStop 2010 Annual Report Download - page 127

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between them and an outside individual, business, or other organization that would create a conflict of interest or the appearance of one. Specifically, the
Associate is required to disclose any:
Remuneration the Associate, or an immediate family or household member, received or is expected to receive from the individual/organization;
Investments or ownership interests the Associate or an immediate family or household member has or will have in the outside organization;
Offices or positions the Associate or an immediate family or household member holds or will hold in the outside organization; and
Other relationships with the individual/organization that actually or potentially may create a conflict of interest.
All disclosures required under this policy must be directed in writing to the Associate's department head. The department head will promptly review the
disclosure and determine which interests are in conflict and which, if any, can be resolved.
Officers of GameStop and any Associates who purchase goods or services for GameStop or who enter into and administer contracts on behalf of GameStop
must complete and file an annual Conflict of Interest Disclosure Form. Associates who are responsible for confidential information related to GameStop, its
customers, vendors, employees and applicants may also be required to complete and file an annual Conflict of Interest Disclosure Form.
Confidentiality of Non-Disclosure Information
To encourage the full disclosure of potential conflicts, disclosures are treated confidentially. Information provided on Conflict of Interest Disclosure Forms is
available only on a need-to-know basis.
Withdrawal from Decisions
Associates are prohibited from exercising decision-making authority or exerting influence concerning any organization or transaction in which they or a
family or household member have a personal interest. Associates must disclose such interest by filing a Conflict of Interest Disclosure Form with the
appropriate department head (see Appendix A) and have such department head approve any arrangement for resolving the conflict, including the Associate's
withdrawal from decision-making in the matter.
Work with Professional Organizations/Associations
An Associate's work with or for an outside professional organization or association does not create a conflict of interest if such work:
Is related to the legitimate professional interest and development of the Associate;
Does not interfere with the Associate's regular duties;
Does not use GameStop's materials, facilities, or resources except as provided in GameStop's policies or practices pertaining to personal use of Company
resources;
Does not compete with the work of GameStop and is not otherwise contrary to the best interests of GameStop; and
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