Visa 2008 Annual Report Download - page 329

and applicable policies of the Company. You should always consult with the legal department before disclosing any such information, even if you believe
disclosure might be authorized. Confidential information includes all non-public information, including personal account information of cardholders, that
might be of use to competitors, or harmful to the Company, if disclosed. It also includes information that suppliers, clients and other third parties have
entrusted to us. The obligation to preserve confidential information continues even after employment ends.
12. Protection and Proper Use of Company Assets
All employees have an obligation to safeguard the Company's assets, protect them from loss, and ensure their efficient use. Theft, carelessness, and waste
have a direct impact on the Company's profitability. Any suspected incident of fraud or theft should be immediately reported for investigation to the
Company's Compliance Officer. Company equipment should not be used for non-Company business, though incidental personal use may be permitted.
The obligation of employees to protect the Company's assets includes its proprietary information. Proprietary information includes intellectual property as
well as business, marketing and service plans, novel ideas, databases, records, salary information and any unpublished financial data and reports.
Unauthorized use or distribution of this information would violate Company policy. It could also be illegal and result in civil or even criminal penalties. All
employees should do their best to make sure that Company property under their control is properly used and protected by adequate controls and safeguards.
13. Payments to Government Personnel
The U.S. Foreign Corrupt Practices Act and foreign laws that may apply to the Company prohibit giving or offering anything of value, directly or indirectly,
to foreign government officials (a broad term that includes employees at all levels of government, as well as employees of state-owned or state-controlled
commercial enterprises and foreign political candidates) in order to obtain or retain business or any improper advantage. It is strictly prohibited to make illegal
payments or offers to government officials of any country, or to make payments to third parties where there is a likelihood that the third party will use any of
the funds to make a prohibited payment to such an official. In the rare circumstances where it is lawful and appropriate to make a nominal "facilitating"
payment to a foreign government official to perform a non-discretionary function that is part of his or her assigned duties, the regional Controller and Global
Compliance Officer must approve the payment in advance.
In addition, the U.S. government has a number of laws and regulations regarding business gratuities which may be accepted by U.S. government personnel.
The promise, offer or delivery to an official or employee of the U.S. government of a gift, favor or other gratuity in violation of these rules would not only
violate Company policy but could also be a criminal offense. State and local governments, as well as foreign governments, may have similar rules. The
Company's Legal Department can provide guidance to you in this area.
14. Political Involvement and Contributions
The Company respects your right to be involved in, and to participate in, the political process as you see fit. However, you must do so on your own time,
using your own resources.
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