EMC 2004 Annual Report Download - page 113

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You may not use EMC funds to give gifts to fellow employees. However, awards may be given under an EMC-sponsored recognition program, contest or
promotion.
AVOID CONFLICTS OF INTEREST
An employee's activities can, intentionally or unintentionally, create a conflict of interest or an appearance of impropriety. As set forth in your Key Employee
Agreement, you are to devote your full time and efforts to EMC. In general, you must avoid any activity or personal interest that creates or appears to create a
conflict between your interests and the interests of EMC or that might impair, or appears to impair, your ability as an EMC employee to perform your work
objectively and effectively. Some guidelines for avoiding such actual or apparent conflicts follow:
Do not, either directly or indirectly, become involved in any activity or business that in any way competes with EMC or might advance a competitor's
interest.
Do not acquire a financial interest in, or engage in any activity or business with any supplier, competitor, customer, distributor, or other organization
that could create a conflict of interest or compromise your loyalty to EMC.
Be particularly cautious if a friend or relative is employed by a competitor or supplier of EMC. Even where the risk to EMC's interests from such a
relationship seems remote, you must exercise particular care not to disclose confidential information inadvertently.
Do not accept any personal benefits from EMC that have not been duly authorized and approved pursuant to EMC policy and procedure, including any
loans or guarantees of personal obligations by EMC.
Do not participate individually in any business or investment opportunity of which you learned through your position at EMC. You should direct any
such opportunities to EMC by informing your manager.
Do not associate EMC with, or indicate EMC support for, any civic, religious, political or professional association without approval from EMC. In
addition, you are not authorized to speak on any public issues or to make any kind of campaign contribution as a representative of EMC.
If you are involved with selecting a supplier, be sure to do so only on the basis of price, quality, performance and suitability of the product or service.
Do not favor a supplier for reasons which could imply improper conduct or conflict of interest.
Because the facts of any such situation may differ, you must seek clarification from your manager or the Office of the General Counsel before proceeding
with any activity that might be construed as creating a conflict of interest. The activities of your immediate family members may also be construed as creating
a conflict of interest. You should seek guidance from your manager or the Office of the General Counsel with respect to these activities also.
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