GameStop 2010 Annual Report Download - page 128

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• Does not violate federal or state law.
Corporate Opportunities
No Associate of GameStop shall, for personal gain or for the gain of others, use, release or publish any information not available to the public that was
obtained as a result of service to GameStop. No Associate of GameStop shall compete directly with GameStop. No Associate shall personally exploit any
business opportunity in which the Associate knows or reasonably should know GameStop is or would be interested, unless GameStop first consents thereto in
writing. All Associates owe a duty to GameStop to advance GameStop's interests when the opportunity to do so arises.
CONTRACTS
All contracts made on behalf of GameStop must be signed by a GameStop department head or officer. A Contract Review Form must be completed for all
contracts and legal agreements (regardless of amount and including any addendums or schedules) in support of GameStop's business worldwide, except for
marketing co-op, store leases, and merchandise purchase orders that are reviewed under a separate process. No contract or legal agreement over $100,000 may
be signed until it has been reviewed by GameStop's Financial and Legal Departments. No contract over $500,000 may be signed until it is approved by
GameStop's Chief Financial Officer. No contract may be signed until all financial commitments contained within the contract have been verified to have been
budgeted for the fiscal year(s) covered by the contract. Completed Contract Review Forms, along with a copy of all executed contracts and agreements, must
be submitted to [email protected].
VENDOR RELATIONS
It is a core value of GameStop's business practices to enter into and maintain relationships with its vendors, suppliers and service providers based solely on
thorough cost-benefit analysis and conducted in such a way as to avoid any implication of favoritism or impropriety. GameStop Associates entering into
business relationships on GameStop's behalf must ensure their conduct is fully congruent with these values.
Fair Dealing
All GameStop Associates shall deal fairly with GameStop's vendors, suppliers, service providers, and fellow GameStop Associates. No GameStop Associate
shall take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other
unfair-dealing practice.
Receiving Gifts and Favors
In business, Associates often are entertained or receive gifts, favors, or gratuities from companies seeking to strengthen business relationships or create new
ones. Generally, such activities and gifts are harmless; however, questions of impropriety arise when these gifts depart from normal business courtesies and
take on the appearance of attempts to influence Associates in business decisions they may make as employees of GameStop. Extravagant gifts or
entertainment can be seen as bribes. In addition, there can be tax implications for GameStop and the Associate for giving or receiving entertainment, gifts,
favors, and gratuities.
Therefore, no Associate shall solicit or accept for personal use, or for the use of others, any gift, favor, loan, gratuity, reward, promise of future employment,
or any other item of monetary value
7