Seagate 2007 Annual Report Download - page 196

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, Employees and Directors must comply with the Foreign Corrupt Practice Act. The Foreign Corrupt Practices Act is a U.S. law
that 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.
Actions taken on behalf of the Company should be free from any suggestion that favorable treatment was sought by, received from, or
given to individuals or organizations that do business or seek to do business with the Company. Employees and Directors may not solicit or
accept, or permit any member of their immediate family to solicit or accept, gifts money, services, or anything else of value when doing so may
influence, or be perceived as influencing, a decision or action. Similarly, Employees and Directors may not offer or give gifts, money, services,
or anything else of value when doing so may influence, or be perceived as influencing, a decision or action. Gifts of nominal value, business
meals, celebratory events, and entertainment are permitted, provided that they are not frequent or excessive, consistent with reasonable
marketplace practices and Company policy.
Compliance standards and procedures
No code of business conduct and ethics can replace the thoughtful behavior of ethical Employees and Directors or provide definitive
answers to all questions that may arise. Accordingly, this Code is intended to highlight areas of ethical risk, provide guidance in recognizing and
dealing with ethical issues, and establish mechanisms to report unethical conduct. Employees and Directors are responsible for adhering to the
standards in this Code, for raising questions if they are in doubt about the best course of action, and for reporting possible misconduct promptly
after it comes to their attention.
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.
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12.
Gifts and Gratuities.
1.
Designated Ethics Officer.