Seagate 2007 Annual Report Download - page 193

Each Employee and Director owes a duty to the Company to act with integrity. Integrity requires, among other things, being honest and
ethical. This includes the ethical handling of actual or apparent
conflicts of interest between personal and professional relationships. A conflict of
interest occurs when the private interest of an employee or director interferes—or appears to interfere—in any way with the interests of the
Company. Conflicts of interest can occur when an Employee or Director takes action or has interests that could reasonably be expected to make
it difficult to make objective decisions on behalf of the Company or to perform his or her duties effectively. Conflicts of interest also arise when
an Employee or Director, or a member of his or her family, receives improper personal benefits as a result of his or her position with the
Company. An Employee or Director will not be deemed to have a conflict of interest solely on the basis of his service on the board of directors
of a company that is under common ownership, or has a business relationship, with the Company.
As a matter of corporate policy, Employees and Directors must avoid business and personal situations that may give rise to a conflict of
interest. Employees who become aware of a conflict or potential conflict, or who have a question about whether a conflict exists, should bring it
to the attention of the Company’s General Counsel or the Company’s Chief Executive Officer. Directors who become aware of a conflict or
potential conflict, or have questions about whether a conflict exists should bring it to the attention of the Chairman of the Board.
Receiving personal benefits as a result of one’s position with the Company may also create a conflict of interest. The acceptance of gifts
from individuals or organizations that do business or are seeking to do business with the Company is discussed below under “Gifts and
Gratuities.”
Employees and Directors are prohibited from taking for themselves personally any potential business opportunities that the Company may
have an interest in or that arise through the use of corporate property, information, or position. The use of corporate property, information, or
position for personal gain is also prohibited. Employees and Directors are further prohibited from competing with the Company directly or
indirectly. Employees and Directors owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises.
Employees and Directors may learn information about the Company that is not known to the general public or to competitors. Confidential
information includes all non-public information that might be of use to competitors, or harmful to the Company or its customers if disclosed, or
information that associates of the Company have entrusted to it.
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3.
Conflicts of Interest and Ethical Conduct.
4.
Corporate Opportunities.
5.
Confidentiality.