GameStop 2010 Annual Report Download - page 130

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• Soliciting monetary political contributions from any Associate;
• Soliciting any contribution of services or resources for political purposes from any Associate;
• Taking any personnel action or making any promise or threat of action with regard to any Associate because of the giving or the withholding of a
political contribution or service; and
• Engaging in solicitation or politically motivated behavior that is harassing or discriminatory.
Lobbying/Campaign Funding Restrictions
Federal and state lobbying and campaign funding laws restrict GameStop from engaging in certain types of political activities. To guard against inadvertent
violations, Associates are subject to the following restrictions:
• Political communications — Associates are prohibited from using GameStop's name, letterhead, or facilities (see below) in connection with any
partisan political communications.
• Use of GameStop facilities — The use of GameStop's resources in connection with partisan political activities can constitute an illegal contribution
to a political party or candidate. Accordingly, Associates are not permitted to spend scheduled work time involved in campaign activities. Associates
also are prohibited from using GameStop facilities in connection with campaign or other political activities. GameStop facilities include, but are not
limited to, telephones, e-mail, fax machines, interoffice mail, voice mail, photocopiers, and office supplies.
• Contact with government officials — Any Associate whose regular duties do not include contact with federal or state regulatory agencies or other
government officials should consult with GameStop's Chief Financial Officer or the Legal Department before responding to any inquiry from
government officials. Associates also should contact the Chief Financial Officer or the Legal Department before initiating contact with a government
agency with respect to any non-routine or nontrivial compliance matter.
Foreign Corrupt Practices Act (FCPA)
The FCPA prohibits the making of a payment and/or the offering of anything of value to any foreign government official, government agency, political party
or political candidate in exchange for a business favor or when otherwise intended to influence the action taken by any such individual or agency or to gain
any competitive or improper business advantage. It is very important to know that the prohibitions of the FCPA apply to actions taken by all Associates and
by all outside parties engaged directly or indirectly by GameStop (e.g., consultants, professional advisers, etc.). Given the complexity of the FCPA and the
severe penalties Associated with its violation, all Associates are urged to contact the Legal Department at all times with any questions concerning their
obligations and GameStop's obligations under and in compliance with the FCPA.
Associates Seeking Public Office
Associates must disclose their intention to run for public office to their supervisor and the Human Resources Department. These Associates must agree in
writing to the following requirements:
9