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Developing a Social MediaGovernance Strategy

21 21 February 2012

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Developing a Social Media

Governance Strategy

Peter RichardsCustomer Intelligence Manager

Echo Entertainment Group


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Included in this document are three exmples of Social Media Policies / Guidelines from three different large organisations.

These documents may provide some valuable insight as to how other organisations handle their Social Media Governance.

They also demonstrate how Social Media Governance varies greatly and is heavily dependant of the culture of the organisation.

Other resources you may find helpful

Queensland Government

Official use of social media policyhttp://www.qgcio.qld.gov.au/SiteCollectionDocuments/Architecture%20and%20Standards/QGEA%202.0/Use%20of%20social%20m

edia%20policy.pdf

Official use of social media guidelineshttp://www.qgcio.qld.gov.au/SiteCollectionDocuments/Architecture%20and%20Standards/QGEA%202.0/Social%20media%20guideli

ne.pdf

Western Australian GovernmentSocial Media Guidelines - Website Governance Frameworkhttp://www.google.com.au/url?sa=t&rct=j&q=social%20media%20governance%20%2B%20australia&source=web&cd=8&ved=0CIIBEBYwBw&url=http%3A%2F%2Fwww.publicsector.wa.gov.au%2FSiteCollectionDocuments%2FSocial%2520Media%2520Guidelines

.doc&ei=C8k5T-ykB8qzrAfHuMTRCA&usg=AFQjCNFMLk3LoLbagM-vmDgwGifDl5lePw&sig2=e_DlRu7LmPH3Ja4NF2HINw

Victorian Government

Guidance for use of social media in the Victorian public sectorhttp://www.egov.vic.gov.au/victorian-government-resources/website-practice-victoria/web-2-0-victoria/guidance-for-use-of-social-

media-in-the-victorian-public-sector.html

Intranet Governance 2012 - Blog post by @Tobywardhttp://www.intranetblog.com/intranet-governance-ownership-management-policy-2/2012/01/23/

List of 40 Social Media Staff Guidelines

http://laurelpapworth.com/enterprise-list-o f-40-social-media-staff-guidelines/

81 Intranet Governance Questions to Ask Yourselffrom @ThoughtFarmer

http://www.thoughtfarmer.com/blog/2011/07/25/81-intranet-governance-questions-to-ask-yourself

IBM Social Computing Guidelines

http://www.ibm.com/blogs/zz/en/guidelines.html

Why internal culture is much more important than employee social media guidelines

http://www.freshnetworks.com/blog/2012/01/employee-social-media-guidelines-are-useful-internal-culture-is-more-important/

The Process of Creating a Social Media Policy

http://socialmediaclub.org/blogs/from- the-clubhouse/process-creating-social-media-policy

9 Steps for Creating Corporate Social Media Governance

http://www.business2community.com/social-media/9-steps- for-creating-corporate-social-media-governance-0105524


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Social Media Governance Linkedin Group

http://www.linkedin.com/groups/Social-Media-Governance-3874367

Social Networking, Microblogs and other Third Party Websites:Personal Use

Guidance in Full1. Introduction

2. Basic Principles

3. Hybrid Sites

4. Social Networking Sites

5. Open Access Online Encylopaedias

6. Blogging and Microblogging

Introduction

The Internet provides a number of benefits in which BBC staff may wish to participate. From rediscovering

old school friends on Facebook to keeping up with other people's daily lives onTwitteror helping to maintain

open access online encyclopaedias such as Wikipedia.

However, when someone clearly identifies their association with the BBC and/or discusses their work, they

are expected to behave appropriately when on the Internet, and in ways that are consistent with the BBC's

editorial values and policies.

This editorial guidance note sets out the principles which BBC staff are expected to follow when using the

Internet and gives interpretations for current forms of interactivity. It applies to blogs, to microblogs

like Twitterand to other personal webspace.

The Internet is a fast moving technology and it is impossible to cover all circumstances. However, the

principles set out in this document should always be followed.

The intention of this note is not to stop BBC staff from conducting legitimate activities on the Internet, but

serves to flag-up those areas in which conflicts can arise.

Basic Principles

The BBC's reputation for impartiality and objectivity is crucial. The public must be able to trust the integrity of

BBC programmes and services. Our audiences need to be confident that the outside activities of our


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presenters, programme makers and other staff do not undermine the BBC's impartiality or reputation and

that editorial decisions are not perceived to be influenced by any commercial or personal interests.

To this end when identified as a BBC staff member or BBC talent, people:

? Should not engage in activities on the Internet which might bring the BBC into disrepute;

? Should act in a transparent manner when altering online sources of information;

? Should not use the Internet in any way to attack or abuse colleagues;

? Should not post derogatory or offensive comments on the Internet.

Even if they are not identified as a BBC staff member, editorial staff and staff in politically sensitive areas

should not be seen to support any political party or cause.

Any online activities associated with work for the BBC should be discussed and approved in advance by a

line manager.

(Note that 'editorial staff' includes any member of staff who may influence our editorial output from

researchers in News and Current Affairs or factual programming to members of the Executive Board. Being

'identified as a BBC staff member' includes at its most obvious, for example, displaying a bbc.co.uk e-mail

address or joining the BBC Network on Facebook (which displays the words "British Broadcasting

Corporation" after the person's name).

Hybrid Sites

It should be clear to users whether the site they are interacting with is a BBC page run by the BBC for BBC

purposes or whether this is a personal page run by an individual for their own purposes.

We should avoid creating or endorsing "hybrid" sites which contain elements of both and which are likely to

cause confusion, editorial problems and brand damage. For example, a presenter's personal profile should

not have a URL or username or avatar which contains a BBC brand or programme name.

For guidance on BBC use of third party sites, see the separate Guidance note below.

(See Guidance: BBC use of Social Networking and Other Third Party Websites)


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Social Networking Sites

Social networking sites provide a great way for people to maintain contact with friends. However, through the

open nature of such sites, it is also possible for third parties to collate vast amounts of information.

For example, The Shawshank Redemption was the most popular film amongst the

11,899 members of the BBC network on Facebook in February 2008 and 8% listed their political views as

"liberal". (Note: information from www.facebook.com on 25 February 2008).

All BBC staff should be mindful of the information they disclose on social networking sites. Where they

associate themselves with the Corporation (through providing work details or joining a BBC network) they

should act in a manner which does not bring the BBC into disrepute.

When a staff member is contacted by the press about posts on their social networking site that relate to the

BBC they should talk to their manager before responding. The relevant BBC press office must be consulted.

Political Activities on Social Networking sites

Editorial staff and staff in politically sensitive areas should never indicate a political allegiance on social

networking sites, either through profile information or through joining political groups. This is particularly

important for all staff in News and Current

Affairs, Nations and Regions and factual programming and applies regardless of whether they indicate that

they are employed by the BBC or not.

Any rare exception to this must be agreed in advance by a line manager. For instance, it may be appropriate

to join Facebook groups related to political causes for reasons of political research. Where this is agreed we

should be transparent and should consider how membership of the group can be balanced.

For example, if a Political Correspondent were to join the Facebook group "Labour History" it may also be

appropriate also to join "Conservative History" and the equivalents for the Liberal Democrats and the

Nationalists. In such circumstance, the specific post held at the BBC should be given in the work details on

the Facebook profile.

Editorial staff and staff in politically sensitive areas should also be careful about joining campaigning groups.

They should discuss this in advance with their line manager.

Non-Editorial Staff are free to engage in political activity, in line with the Section 15 of the Editorial Guidelines

on Conflicts of Interest. However, on social networking sites, when they identify themselves as BBC staff


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members they must make clear that they are not a member of editorial staff. This can be achieved by stating

the position (or type of position) they hold at the BBC in their work details. If non-Editorial Staff associate

themselves with the BBC and do not make clear they have no editorial input then this could give rise to

questions about the Corporation's impartiality.

Consideration towards other members of staff when using social networking sites

Social networking sites allow photographs, videos and comments to be shared with thousands of other

users. However, it may not be appropriate to share work-related information in this way.

For example, there may be an expectation that photographs taken at a private BBC event will not appear

publicly on the Internet, both from those present and perhaps those not at the event. Or the BBC may have

objections. Staff should be considerate to their colleague in such circumstance and should not post

information when they have been asked not to. They should also remove information about a colleague if

that colleague asks them to do so.

Under no circumstance should offensive comments be made about BBC colleagues on the Internet. This

may amount to cyber-bullying and could be deemed a disciplinary offence.

Open Access Online Encyclopaedias

In the course of BBC work, staff may find errors in online encyclopaedias. If staff members edit online

encyclopaedias at work the source of the correction will be recorded as a BBC IP address. The intervention

may therefore look as if it comes from the BBC itself. BBC staff should therefore act in a manner that does

not bring the BBC into disrepute and should not post derogatory or offensive comments on any online

encyclopaedias.

When correcting errors about the BBC, we should be transparent about who we are. We should never

remove criticism of the BBC. Instead, we should respond to legitimate criticism. We should not remove

derogatory or offensive comments but must report them to the relevant administrators for them to takeaction.

Before editing an online encyclopaedia entry about the BBC, or any entry which might be deemed a conflict

of interest, BBC staff should consult the house rules of the site concerned and, if necessary, ask permission

from the relevant wikieditor. They may also need to seek advice from their line manager.


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Blogging and Microblogging

Many bloggers, particularly in technical areas, use their personal blogs, and increasingly their microblogs

like Twitter, to discuss their BBC work in ways that benefit the BBC, and add to the "industry conversation".

This editorial guidance note is not intended to restrict this, as long as confidential information is not revealed.

Blogs, microblogs or other personal websites which do not identify the blogger as a

BBC employee, do not discuss the BBC and are purely about personal matters would normally fall outside

this guidance.

Staff members who already have a personal blog, microblog or website which indicates in any way that they

work at the BBC should discuss any potential conflicts of interest with their line manager.

Similarly, staff members who want to start blogging or microblogging, and wish to say that they work for the

BBC, should discuss any potential conflicts of interest with their line manager.

If a blog makes it clear that the author works for the BBC, it should include a simple and visible disclaimer

such as "these are my personal views and not those of the BBC".

Unless there are specific concerns about the nature of their role (for instance because they are a member of

editorial staff), staff members are free to talk about

BBC programmes and content on their blogs or microblogs. If in doubt, staff members should consult their

line manager.

Personal blogs, microblogs and websites should not reveal confidential information about the BBC. This

might include aspects of BBC policy or details of internal BBC discussions. If in doubt about what might be

confidential, staff members should consult their line manager.

Personal blogs, microblogs and websites should not be used to attack or abuse colleagues. Staff members

should respect the privacy and the feelings of others.

Remember also that if they break the law on a blog or microblog (for example by posting something

defamatory), they will be personally responsible.


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If a staff member thinks something on their blog, microblog or website gives rise to concerns about a conflict

of interest, and in particular concerns about impartiality or confidentiality, this must be discussed with their

line manager.

If a staff member is offered payment to produce a blog or microblog for a third party this could constitute a

conflict of interest and must be discussed with their line manager.

When a staff member is contacted by the press about posts on their blog or tweets on their microblog that

relate to the BBC they should talk to their line manager before responding. The relevant BBC press office

must be consulted.

Staff members are allowed to update their personal blog or microblog from a BBC computer at work, under

the BBC's Acceptable Use Policy for Internet and Email (see here. Link only available to internal BBC users)

Guidance for Managers on Blogging and Microblogging

Under this Guidance Note, managers in each area will decide what is appropriate.

They should not adopt an unnecessarily restrictive approach. Managers should ensure that any special

instructions on blogging or microblogging are reasonable and explained clearly to staff.

Managers should bear in mind concerns about impartiality, confidentiality, conflicts of interest or commercial

sensitivity. In some cases individuals may be dealing with matters which are so sensitive that rules may have

to be set on what they can and cannot talk about on their personal blog or microblog.

Those involved in editorial or production areas must take particular care to ensure that they do not

undermine the integrity or impartiality of the BBC or its output on their blogs or microblogs. For example

those involved in News and Current Affairs or factual programming should not advocate a particular position

on high profile controversial subjects relevant to their areas.

Managers can consult Section 15 of the Editorial Guidelines on Conflicts of Interest Guidelines and the

BBC's Acceptable Use Policy for Internet and Email (see here . Link only available to internal BBC users.)

News and Current Affairs Staff, Blogging and Microblogging

Impartiality is a particular concern for those working in News and Current Affairs. Nothing should appear on

their personal blogs or microblogs which undermines the integrity or impartiality of the BBC. For example,

News and Current Affairs staff should not:


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? advocate support for a particular political party;

? express views for or against any policy which is a matter of current party political debate;

? advocate any particular position on an issue of current public controversy or debate.

If News and Current Affairs staff are in doubt, they should refer immediately to their line manager.

BBC http://www.bbc.com/


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Intel Social Media Guidelines

Social media is changing the way we work, offering a new model to engage with customers, colleagues, and the world atlarge. We believe this kind of interaction can help you to build stronger, more successful business relationships. And it'sa way for you to take part in global conversations related to the work we are doing at Intel and the things we careabout.

These are the official guidelines for participating in social media for Intel. If youre an Intel employee or contractorcreating or contributing to blogs, wikis, social networks, virtual worlds, or any other kind of social media, theseguidelines are for you. They will evolve as new social networking tools emerge, so check back regularly to make sureyoure up to date.

Participation in social computing on behalf of Intel is not a right but an opportunity, so please treat it seriously and withrespect. If you want to participate on behalf of Intel, take the Social Media@Intel training and contact the Social MediaCenter of Excellence. Please know and follow the Intel Code of Conduct . Failure to abide by these guidelines and theIntel Code of Conduct could put your participation at risk. Contact [email protected] for more information. Pleasealso follow the terms and conditions for any third-party sites.

1. DiscloseYour honestyor dishonestywill be quickly noticed in the social media environment. Please represent Intel ethicallyand with integrity.

? Be transparent: Use your real name, identify that you work for Intel, and be clear about your role.

? Be truthful: If you have a vested interest in something you are discussing, be the first to point it out and bespecific about what it is.

? Be yourself: Stick to your area of expertise; write what you know. If you publish to a website outside Intel,

please use a disclaimer something like this: The postings on this site are my own and don't necessarily represent Intelspositions, strategies, or opinions.


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2. ProtectMake sure all that transparency doesnt violate Intels confidentiality or legal guidelines for commercial speechor yourown privacy. Remember, if youre online, youre on the recordeverything on the Internet is public and searchable. Andwhat you write is ultimately your responsibility.

? Don't tell secrets: Never reveal Intel-classified or confidential information. If youre unsure, check with IntelPR or Global Communications Group. Off-limit topics include: litigation, non-published financials, and unreleased productinfo. Also, please respect brand, trademark, copyright, fair use, and trade secrets. If it gives you pausepause rather

than publish.

? Don't slam the competition (or Intel): Play nice. Anything you publish must be true and not misleading,and all claims must be substantiated and approved. Product benchmarks must be approved for external posting by theappropriate product benchmarking team.

? Don't overshare: Be careful out thereonce you hit "share," you usually cant get it back. Plus being judiciouswill help make your content more crisp and audience-relevant.

3. Use Common SensePerception is reality and in online social networks, the lines between public and private, personal and professional are

blurred. Just by identifying yourself as an Intel employee, you are creating perceptions about your expertise and aboutIntel. Do us all proud.

? Add value:There are millions of words out theremake yours helpful and thought-provoking. Remember, itsa conversation, so keep it real. Build community by posting content that invites responsesthen stay engaged. You canalso broaden the dialogue by citing others who are writing about the same topic and allowing your content to be shared.

? Keep it cool: There can be a fine line between healthy debate and incendiary reaction. Try to frame what youwrite to invite differing points of view without inflaming others. And you dont need to respond to every criticism or barb.Be careful and considerate.

? Did you screw up? If you make a mistake, admit it. Be upfront and be quick with your correction. If you'reposting to a blog, you may choose to modify an earlier postjust make it clear that you have done so.

Contractors and EndorsementsAs the Intel Social Media Guidelines describe, we support transparency and are committed to clear disclosure ofrelationships and endorsements. If you are contracted, seeded, or in any way compensated by Intel to create social

media, please be sure to read and follow the Intel Sponsored, Seeded, or Incentivized Social Media PractitionerGuidelines. As part of these guidelines, you need to disclose that you have been seeded or otherwise compensated byIntel. Your blog will be monitored for compliance with our guidelines and accurate descriptions of products and claims.

ModerationModeration (reviewing and approving content) applies to any social media content written on behalf of Intel by peopleoutside the company, whether the site is on or off intel.com. We do not endorse or take responsibility for content postedby third parties, a.k.a. user-generated content (UGC). This includes text input and uploaded files, including video,images, audio, executables, and documents. While we strongly encourage user participation, there are some guidelineswe ask third parties to follow to keep it safe for everyone.

? Post-moderation:Even when a site requires the user to register before posting, simple user name and emailentry doesn't really validate the person. So to ensure least risk/most security, we require moderation of all UGC posts.

The designated moderator scans all posts to be sure they adhere to Inte ls guidelines.

? Community moderation (a.k.a. reactive moderation): For established, healthy communities, groupmoderation by regular users can work well. This will sometimes be allowed to take the place of post -moderationbut itmust be applied for and approved.

? The house rules: Whether content is post -moderated or community moderated, we use this rule of thumb:the Good, the Bad, but not the Ugly. If the content is positive or negative and in context to the conversation, then it canbe approved, regardle ss of whether its favorable or unfavorable to Intel. But if the content is ugly, offensive,denigrating, and/or completely out of context, then we ask our moderators and communities to reject the content.

Intel Sponsored, Seeded, or Incentivized Social Media Practitioner GuidelinesIntel supports transparency. We are committed to ensuring that our social media practitioners (SMPs) clearly discloserelationships and endorsements, and that statements about Intel products are truthful and substantiated. If you are a

social media practitioner who has been seeded with product, incentivized, or otherwise has an ongoing relationship withIntel, these guidelines apply to you. If you have any questions or concerns about them, get in touch with your Intelsponsor.


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Please keep in mind that Intel monitors social media related to our business, including the activities of our sponsored,seeded, or incentivized SMPs. If we find any non-disclosed relationships or statements that are false or misleading, wewill contact you for correction. If, as a sponsored SMP, you are found to repetitively make inaccurate statements aboutIntel, Intel products, or Intel services, we may discontinue our relationship with you.

Rules of Engagement for Intel Sponsored, Seeded, or Incentivized SMPs? Be transparent: Please clearly and conspicuously disclose your relationship to Intel, including any incentives

or sponsorships. Be sure this information is readily apparent to the public and to readers of each of your posts.

? Be specific: Do not make general claims about Intel products, but talk specifically aboutwhat you experienced.

? Be yourself:We encourage you to write in the first person and stick to your area of expertise as it relates toIntel technology.

? Be conscientious: Keep in mind that what you write is your responsibility and failure to abide by theseguidelines could put your Intel sponsorship or incentive at risk. Also please always follow the terms and conditions forany third-party sites in which you participate.

Intel - http://www.intel.com/content/www/us/en/homepage.html


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Apple Retail Blogging and Online Social Media Guidelines

Whether or not you as an Apple employee choose to create or participate in a blog, wiki, online social

network or any other form of online publishing or discussion is your own choice. In general, what you

do on your own time is your business. However, activities that affect your job performance, the

performance of other Apple employees, or Apples business interests are still covered by company

policies and guidelines. This applies whether you engage in these activities in or outside of work, and

whether or not you identify yourself as an Apple employee.

If you choose to participate in these types of online activities it is important that you understand what

is recommended, expected and required, whether at work or on your own time. Accordingly, we have

developed the following guidelines for you to follow when posting to a blog or some other form of

social media like Facebook, MySpace, Twitter or Linkedin.

Be thoughtful about how you present yourself in online social networks. The lines between public and

private, and personal and professional are blurred in online social networks. If you identify yourself as

an Apple employee or are known to be one, you are now connected to your co-workers, Leaders and

even Apples customers. You should ensure that content associated with you is consistent with Apple

policies.

Respect your audience and your coworkers. Remember that Apple is a global organization whose

employees and customers reflect a diverse set of customs, values and points of view. Dont be afraid to

be yourself, but do so respectfully. This includes not only the obvious (no ethnic slurs, personal insults,

obscenity, etc.) but also topics that may be considered offensive or inflammatory. Use your best

judgment, but if you need further guidance regarding what constitutes inappropriate communications

please consult with HR, your Leader or Apples Harassment policy.

Respect the privacy of your coworkers. Blogs, wikis, social networks and other tools should not be used

for internal communications among fellow employees. It is fine for Apple employees to disagree, but

please dont use your external blog or other online social media to air your differences. Do not discuss

your co-workers without their permission, and ask permission before posting their picture. By

respecting your coworkers privacy you will be helping to maintain the professional work

environment at Apple.

Respect the privacy of our customers. It is a priority that we respect the privacy of our customers. Do

not use or discuss any information regarding customers for any purpose. This includes contacting

customers for social reasons or soliciting outside business. If you need further guidance in this area,

please refer to Apples policy regarding customer private information.

Use a disclaimer. When Apple wishes to communicate publicly as a company it has well established

means to do so. Only those individuals officially designated by Apple have the authority to speak on

behalf of the company. If you identify yourself as an Apple employee, however, people may confuse

your opinions with those of the company. In order to avoid this problem you must make clear that you

are writing for yourself and on your own behalf, and not for Apple. At a minimum, we strongly


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recommend that you include a disclaimer similar to the following: the postings on this site are my

own and do not represent Apples opinions or positions.

Protect Apples confidential information. As an Apple employee you have an obligation to protect the

confidential, proprietary and trade secret information of the company. This obligation is laid out in

several places including the Intellectual Property Agreement you signed when hired and in Apples

Confidential Information Policy. For example, do not discuss any Apple confidential informationincluding your stores financial or business performance, and the timing, pricing or design of Apples

products. Also, do not post pictures of the inside of the Apple Store including the back of house as

those are not generally made public. Finally, do not post or disclose the contents of any Apple policy.

These documents are intended for the use of Apple employees, and not for public distribution.

Respect copyright, fair use laws. For Apples protection as well as your own, it is critical that you

comply with all laws governing copyright and fair use of copyrighted material owned by others. For

example, this means you should not be using Apple logos or images for your own personal use. Also,

you may not copy, digitize, alter or distribute any part of a copyrighted work without first obtaining

written permission from the copyright owner. For more information please refer to Apples copyrightpolicy.

Dont use your Apple email for personal use. Your Apple email address has been given to you for use at

work. Therefore you should not use your Apple email address on your personal blog or when posting

on social network sites. You have been given a

free .mac/.me email address to use for non-work related emails. Please use that email or another

personal email address for those types of communications.

In sum, use your best judgment. Remember there may be consequences to what you post or publish

online including discipline if you engage in conduct that Apple deems inappropriate or violates anyApple policies. If youre about to post something and you are concerned whether you are following

these guidelines or any Apple policy, please discuss it with your Leader or HR before posting.

Confidential, Proprietary, and Trade Secret Information:

Apple recognizes that its confidential, proprietary, and trade secret information and that of third

parties constitute our competitive advantage in the marketplace. Apple takes steps to protect its own

confidential information and respects the confidential information of others. As a result, Apple expects

all employees to take responsibility for protecting these sources of confidential information. Apple

identifies, classifies, and protects all of its valuable business information from intentional or

inadvertent disclosure, loss, modification, destruction, and copying. You may not disclose Apple

confidential information to an outside party unless a written agreement or license has been previously

signed and approved by the division vice president.

Likewise, Apple respects the confidential information of others. You may not use or disclose any such

third-party information unless you are authorized by the third party to do so and until you have signed

a confidentiality agreement with Apple.

Examples of Apple confidential information include, but are not limited to the following:

? sales and financial information of any kind including store and individual metrics


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? product availability and constraints

? information shared through store meetings, corporate meetings, RNN,BulletNews, Kbase,

or any other internal

? Apple resource

? hiring and training information including salaries and bonus programs

? Apple policies and procedures

? Retail Store Websites

? As an Apple employee, you may not create store websites displaying storerelated

activities. This includes but is not limited to theater presentations, storeopenings, posting

schedules or other store events.

Employee Personal Websites:

As an Apple employee, you are often the first on the block to see and touch new Apple products. While you maycreate personal websites, you may not display photographs, articles, or commentary about Apple products,

services, or initiatives.

Posting Messages on Mac-Related Websites:

As an Apple employee, you represent the Apple brand. While you are free to view any website on your

own time, you may not post messages or commentary on Mac and Apple -related websites, whether

you identify yourself as an Apple employee or not.

Speculating on Rumors:

Refrain from speculating on anything Apple has not officially announced, even if a customer presses

you for a personal opinion or indicates an interest in making a substantial purchase. Information leaks

can potentially damage Apples interests, and Apple has zero tolerance for those who leak information.

When you began working for Apple, you agreed to keep Apples confidential information within the

workplace, including any information you receive from an internal Apple source. Be cautious of

conversations with other employees on the salesfloor. Customers often overhear these conversations

which can lead to misinformation.

Do not confirm or deny any information, even if customers pressure you by saying they are about to

make or influence a substantial purchase or refer to non-Apple websites as sources of information.Refer to the following speaking points:

? Apple does not comment on rumors about decisions, products, programs, or promotions

that have not been officially announced by Apple.

? By withholding comment, Apple hopes to protect customers from making decisions based

on information that is incomplete, inaccurate, or subject to change before the formal

announcement.

? Apple believes this is the best way to ensure that all customers are treated fairly.


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? In addition to the above, speculating on rumors with internal Apple colleagues is strictly

prohibited. Only those individuals on the Companys official disclosure list are entitled to

receive and discuss information pertaining to unannounced Company information.

The Way We Do Business Worldwide:

Apple conducts business ethically, honestly, and in full compliance with all laws and regulations. Thisapplies to every business decision in every area of the company worldwide.

Apples Principles of Business Conduct:

Apples success is based on creating innovative, high-quality products and services and on

demonstrating integrity in every business interaction. Apples principles of business conduct define the

way we do business worldwide.

These principles are:

? Honesty. Demonstrate honesty and high ethical standards in all business dealings.

? Respect. Treat customers, suppliers, employees, and others with respect and courtesy.

? Confidentiality. Protect the confidentiality of Apples information and the information of

our customers, suppliers, and employees.

? Community. Conduct business in a way that benefits the communities in which we

operate.

? Compliance. Ensure that business decisions comply with all applicable laws andregulations.

Making the Right Decisions:

When facing a tough decision:

? Use good judgment. Apply Apples principles of business conduct, review our policies,

review legal requirements, and then decide what to do.

? Need some help? When in doubt about how to proceed, discuss pending decisions with

your Store Leader, your Human Resources representative, or the Legal Department. If you

need more support, contact the Business Conduct Helpline.

Your Responsibilities:

Apples business conduct policy and principles apply to employees, independent contractors,

consultants, and others who do business with Apple. All such individuals are expected to comply with

Apples business conduct policy and principles and with all applicable legal requirements. Apple retains

the right to discipline (up to and including termination of employment) or end working relationships

with those who do not comply.

Please see details of the Apples Business Conduct policy on the HR Web. Apple Retail may have

policies that supplement what is communicated in this link for our employees.


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Apple http://www.apple.com/