Seagate 2002 Annual Report Download - page 122

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9.
Interaction with public officials
When dealing with public officials, employees and directors must avoid any activity that is or appears illegal or unethical. The
giving of gifts, including meals, entertainment, transportation, and lodging, to government officials in the various branches of U.S. government,
as well as state and local governments, is restricted by law. Employees and directors must obtain pre-approval from the Company’s General
Counsel before providing anything of value to a government official or employee. The foregoing does not apply to personal lawful political
contributions.
In addition, the U.S. Foreign Corrupt Practices Act prohibits giving anything of value, directly or indirectly, to officials of foreign
governments or foreign political candidates in order to obtain or retain business. Illegal payments to government officials of any country are
strictly prohibited.
Compliance standards and procedures
No code of business conduct and ethics can replace the thoughtful behavior of an ethical employee or director or provide definitive
answers to all questions. Since we cannot anticipate every potential situation, certain policies and procedures have been put in place to help
employees and directors approach questions or problems as they arise.
1.
Designated Ethics Officer
The Company’s General Counsel has been designated as the Company’s Ethics Officer with responsibility for overseeing and
monitoring compliance with the Code. The Ethics Officer reports directly to the Chief Executive Officer and also will make periodic reports to
the Company’s Audit Committee regarding the implementation and effectiveness of this Code as well as the policies and procedures put in
place to ensure compliance with the Code.
2.
Seeking Guidance
Employees and directors are encouraged to seek guidance from supervisors, managers or other appropriate personnel when in doubt
about the best course of action to take in a particular situation. In most instances, questions regarding the Code should be brought to the
attention of the Company’s General Counsel.
3.
Reporting Violations
If an employee or director knows of or suspects a violation of the Code, or of applicable laws and regulations, he or she must report
it immediately to the Company’s General Counsel or the Chief Executive Officer. If the situation requires it, the reporting person’
s identity will
be kept anonymous. The Company does not permit retaliation of any kind for good faith reports of violations or possible violations.
4.
Investigations
Reported violations will be promptly investigated. It is imperative that the person reporting the violation not conduct an
investigation on his or her own. However, employees and directors are expected to cooperate fully with any investigation made by the
Company into reported violations.
5.
Discipline/Penalties
Employees and directors who violate this Code may be subject to disciplinary action, up to and including discharge. Employees and
directors who have knowledge of a violation and fail to move promptly to report or correct it and employees and directors who direct or
approve violations may also be subject to disciplinary action, up to and including discharge. Furthermore, violation of some provisions of this
Code are illegal and may subject the employee or director to civil and criminal liability.
Exhibit 23.1
Consent of Ernst & Young LLP, Independent Auditors
We consent to the incorporation by reference in the Registration Statements (Form S-8’s No. 333-101848 and 333-101789) pertaining to the
Seagate Technology Amended and Restated 2001 Share Option Plan and the Seagate Technology Employee Stock Purchase Plan of Seagate
Technology of our report dated July 15, 2003 (except for note 17, as to which the date is July 30, 2003), with respect to the consolidated
financial statements of Seagate Technology included in the Annual Report (Form 10-K) for the year ended June 27, 2003.
/s/ E
RNST
& Y
OUNG
LLP
EXHIBIT 31.1
San Jose, California
August 19, 2003
CERTIFICATION
I, Stephen J. Luczo, Chief Executive Officer of Seagate Technology, certify that:
1. I have reviewed this annual report on Form 10-K of Seagate Technology;
2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to
make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period
covered by this report;
3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material
respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;