Connecting with
Our Values
Cisco Code of
Business Conduct
Contents
Message from John Chambers,
Chairman and CEO
3
4
7
11
14
18
22
Cisco Systems, Inc. Code of Business Conduct
I Am Ethical
• Connect with Our Values
• Make Good Choices
• Ethics Decision Tree
I Know the Code
• Cracking the Code
• Waivers
• Annual Certification
I Share My Concerns
• My Obligation
• How to Voice My Concerns
I Respect Others
• Harassment
• Discrimination
• Retaliation
• Accommodation for Individuals with
Disabilities
• Drugs and Alcohol
• Workplace Safety
• Personal Information
• Corporate Social Responsibility
• Quality
I Use Resources Responsibly
• Company Assets
• Electronic Communication
• Cisco Community Mailers
• Records Management
• Social Media
I Avoid Conflicts of Interest
• Serving on Outside Boards,
Committees, or Associations
• Investments and Interests in Other
Businesses
• Inventions, Books, and Publications
• Speaking Engagements
• Endorsements and Providing
References
• Mixing Work and Family
Relationships
28I Understand Policies Related
to Gifts, Hospitality and
Entertainment
38
43
• Commercial Companies
• Government Officials and
Agencies
• Internal Employees
• Raffles and Giveaways
• Local Customs
• Expense Reports
I Protect What Is Ours
• Proprietary Information
• Information Security
I Follow the Law
• Antitrust and Competition Laws
• Insider Trading
• Global Anti-Corruption Policy
• Government Business and Political
Contributions
• Using Copyrighted Material
• Privacy Laws
• Export, Reexport, and Transfer
50I Am Accurate and Ethical
with Our Finances
• Financial Officer Code of Ethics
• Violations
53Additional Resources
2
Dear Cisco Employees,
When you think about what makes a company successful, culture is always an essential
component. At Cisco, our culture is the foundation of everything we do, and it is based on the set
of core values that each of us wears on our Cisco badge. Several of these values, including trust,
integrity, inclusion, empowerment, and open communication, remind us that preserving an ethical
workplace is critical to our long-term success as a company. The message for each employee is
clear: Any success that is not achieved ethically is no success at all. At Cisco, we hold ourselves to
the highest ethical standards, and we will not accept anything less.
While collaboration and teamwork play an important role in our company’s growth and innovation,
it is the responsibility of the individual, of every Cisco employee, to uphold high standards of
conduct. The Cisco Code of Business Conduct (COBC) is a valuable tool to help you do just that.
With information about our policies and procedures, guidelines for ethical decision making, and
real-life examples of situations you may encounter on the job, the COBC serves as an important
resource to guide you in applying our core values to specific situations of day-to-day business. If
you are unsure of what to do in a particular situation or suspect that our COBC is being violated,
you have an obligation to speak up. Please talk to your manager or also feel free to contact the
Ethics Office or the Legal Department. You may also voice your concerns anonymously through
the Cisco EthicsLine. All of these options are described in detail in this COBC.
Our commitment to our customers, our partners, our fellow employees, and the broader
global community, requires us to be not only the “Best in the World,” but also the “Best for the
World.” Together, we demonstrate by our actions that Cisco is a company with strong values
and a commitment to always do the right thing. Our standing as an ethical company, just like
our reputation as the leader in communications and IT, is a critical asset, as important as the
technology we create, and we are all responsible for protecting it. I expect it of myself; I expect it of
my leadership team; and I expect it of every one of you. Thank you for being part of the Cisco Family and for your pledge to uphold these important
values.
Sincerely,
John Chambers
Chairman and CEO
Cisco Systems, Inc. Code of Business Conduct
3
I Am Ethical
Innovative ideas, emerging technologies, strategic acquisitions - I work in an
industry where the pace is fast and change is constant. But there are some
things that do not change, like the commitment to doing business honestly,
ethically, and with respect for one another. I think Cisco has been successful
as a company because we put core values like these into practice on the job
every day; doing the right thing is just part of our DNA.
Cisco Says...
Connect
with the
Code...
• Observe and preserve
our core values of
open communication,
empowerment, inclusion,
integrity, and trust.
Cisco Systems, Inc. Code of Business Conduct
Cisco was founded in an environment of open communication, empowerment,
inclusion, integrity, and trust.
These values remain at the forefront of our culture and our business decisions. We must
maintain our commitment to these values and continue building a culture that understands what
is acceptable and what is not. We will never compromise on issues of integrity. Our Code of
Business Conduct (COBC) reinforces our core values and is a guide to help you make the right
ethical decisions and resolve issues you may encounter.
Make good choices.
When you are faced with an ethical dilemma, you have a responsibility to take action. A decision
tree can help. It may seem easier to say nothing or look the other way, but taking no action is, in
itself, an action that can have serious consequences. Let the decision tree guide your actions.
Speak up if you see or suspect activity that violates our COBC. As we continue to grow and
innovate, you will be helping to further our mission and preserve our core values.
4
Connect
with the
Code...
• Make decisions that are
consistent with these core
values.
• Comply with all applicable
laws and regulations in
each country where we do
business.
Our continued success depends on your ability to make decisions that are
consistent with our core values.
Regardless of the situation, exercise total honesty and integrity in everything you do. As an
employee, you are responsible for complying with all applicable laws and regulations in each
country in which we do business and for knowing and complying with our COBC and other
policies of the company. Violations of law or this COBC or other policies of the company are
subject to discipline, which may include termination of employment. Your commitment to doing
the right thing will strengthen our team and our reputation as a global leader.
What if...
What if I’m not sure whether a particular action is a violation of our COBC?
Check the guidelines here in the COBC for an answer. If the answer is still not clear, use the
decision tree to help you determine the right course of action and whom to contact for help.
Cisco Systems, Inc. Code of Business Conduct
5
Ask yourself:
Ethics
Decision
Tree
A decision tree can be
a useful tool when you
are faced with a difficult
decision. Ask yourself:
Cisco Systems, Inc. Code of Business Conduct
Not sure?
Contact Legal
for guidance
Not sure?
Check Cisco Policy Central
for more information.
Talk to your manager,
your Human Resources
representative, or
Legal for guidance
Not sure?
Check the Ethics Office
website or contact your
manager or
Ethics Office for guidance
Not sure?
Talk to your manager,
Legal, or the
Ethics Office
for guidance
?
?
?
?
Is it legal?
Does this
comply with
Cisco policy?
Does this
reflect Cisco
values and
culture?
Could this
adversely affect
company
stakeholders?
Yes
Yes
Yes
No
No
No
No
The action may
have serious
consequences;
do not do it
The action may
have serious
consequences;
do not do it
The action may
have serious
consequences;
do not do it
?
Would I feel
concerned if
this appeared
in a news
headline?
Not sure?
Talk to your manager,
Legal, or the
Ethics Office
for guidance
?
The action may
have serious
consequences;
do not do it
Yes
The action may
have serious
consequences;
do not do it
No
Could this
adversely
affect Cisco if
all employees
did it?
Not sure?
Talk to your manager,
Legal, or the
Ethics Office
for guidance
Yes
No
Yes
The action may
have serious
consequences;
do not do it
The decision
to move forward
appears appropriate.
6
I Know the Code
I would never knowingly violate a law or policy, but sometimes situations
arise where the right thing to do is not clear, so I refer to the COBC for
clarification.
Cisco says...
It is easy to “crack” the code; our COBC is user-friendly.
We believe that long-term, trusting business relationships are built by being honest, open, and
fair. Our COBC reflects this belief. It is a resource that you can rely on to help determine what is
appropriate, and what is not when it comes to acting with integrity in the workplace. The COBC
promotes: Connect
with the
Code…
• Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of
interest between personal and professional relationships
• Full, fair, accurate, timely, and understandable disclosure in reports and documents that we file
with, or submit to governmental agencies and in other public communications
• Protection of confidential and proprietary information about Cisco and our employees,
contractors, customers, partners, and vendors
• Read, understand, and
comply with the COBC.
• Compliance with applicable governmental directives, laws, rules, and regulations
• Seek help if you have
questions about the COBC.
• Accountability for adherence to the COBC by every Cisco employee
• Certify annually that
you have reviewed and
understand the COBC and
complete any associated
COBC training.
Cisco Systems, Inc. Code of Business Conduct
• Prompt internal reporting of any violations of the COBC
The COBC applies to everyone at Cisco worldwide.
The COBC applies to all Cisco employees, subsidiaries, and members of our Board of Directors.
We also seek to do business with suppliers, customers, and resellers who adhere to similar ethical
standards. The COBC is monitored by our Ethics Office and is affirmed yearly by every employee
through an annual certification proces.
7
As an employee, you are required to review, understand, and abide by the COBC. Remember,
you are in charge of your decisions and your actions, so when in doubt, check it out. No one has
the authority to make you engage in behavior that violates the COBC, and any attempt to do so
is unacceptable. You also have a responsibility to watch for potential violations of the COBC and
to report them, whether they occur inside Cisco or through external dealings with our customers
or other persons, businesses, or governments. Refer to the COBC section entitled “I Share My
Concerns” for guidance on how to report your concerns.
If you are a manager, you hold a leadership role and are responsible for setting a good example
for your employees, encouraging open and honest communication, and taking action when ethical
issues are brought to your attention. Work to ensure that those who report to you understand
the requirements of the COBC, and to support employees who, in good faith, raise questions
or concerns. You are responsible for taking action to address conduct that is in violation of the
COBC and to seek help from the Ethics Office if the proper course of action is not clear.
The COBC is extensive…but not exhaustive.
You will find that the COBC provides detailed guidance, but cannot address every situation you
may possibly face in the course of your workday. We rely on you to exercise good judgment
in your decision making and to seek help when you have questions or concerns that are not
addressed in the COBC.
We continually monitor laws and regulations as they apply to our operations worldwide, but, again,
we trust our employees to follow the spirit of the law and to do the right, ethical thing even when
the law is not specific. In some cases, a country’s local laws may establish requirements different
from our COBC. If a local law conflicts with our COBC, we follow the local law; if a local business
practice conflicts with our COBC, we follow our COBC. When in doubt, ask for help.
For additional information on the Cisco Ethics Program, visit the Ethics Office website.
Waivers of a provision of this COBC must be submitted to and approved by the
Ethics Office.
Waivers for any Cisco executive officer or member of Cisco’s Board of Directors must be
submitted to the Ethics Office and approved by the Board of Directors. Waivers granted to
executive officers and members of Cisco’s Board of Directors, along with the reasons for granting
Cisco Systems, Inc. Code of Business Conduct
8
the waiver, will be publicly disclosed by appropriate means.
Annual certification of the COBC and other supplemental code(s) and
guidelines is required.
Chairman and CEO John Chambers requires all employees to review and understand the COBC.
You will be sent notification and reminder emails directing you to complete your certification
of the COBC. Employees must also complete any associated COBC training as a part of their
certification.
At the same time that you annually review and certify the COBC, if you fall into any of the
subcategories below, you are also required to annually review and certify the following
supplemental code(s) and guidelines:
• Work with Government Officials in the U.S. - If you support Cisco’s business with the U.S.
Public Sector market [federal, state or local government(s)], read and acknowledge Cisco’s U.S.
Public Sector Ethics Code and complete the online training “Working with U.S. Public Sector
Customers.”
• Work with Schools and Libraries - If you support Cisco’s business regarding the U.S. E-Rate
Program, read and acknowledge Cisco’s E-Rate Program Guidelines.
• Work in Global Sales/Marketing - If you are in the sales or marketing organization (including
Service Sales) outside the United States, or if you are in sales or marketing in the United States
and support global accounts, complete the online training “Doing Business With Integrity; AntiCorruption Laws in a Global Market.”
As part of the on-boarding process, new hires are required to complete the COBC certification (and
the other above-referenced supplemental codes, guidelines, and mandatory online training that are
relevant to them) when they join Cisco. Thereafter, new hires will be required to participate in the
annual certification campaign.
Cisco Systems, Inc. Code of Business Conduct
9
What if...
What if I have a concern with a section of the COBC or have reservations about
completing my COBC annual certification?
If you have an issue with a section of the COBC or with the COBC certification, you should
discuss your concerns with your manager, your Human Resources representative, or the Ethics
Office. Even if you fail to complete your certification of the COBC, you are still obligated to follow
the policies contained in it. Failure to complete the annual COBC certification may result in
disciplinary action, up to and including termination of employment.
Cisco Systems, Inc. Code of Business Conduct
10
I Share My Concerns
I understand my responsibility as a Cisco employee to do the right thing
when it comes to my own actions and to share my concerns when I see or
suspect something that could harm the company. I like knowing that there
are places to turn when I have a question or concern.
Cisco says...
You have an obligation to speak up.
Connect
with the
Code...
All employees have a responsibility for promptly reporting any issue or concern that they
believe, in good faith, may constitute a violation of the COBC or any other Cisco policy. We also
encourage you to come forward if you encounter a situation that “just does not feel right.” Open
communication and empowerment are two of our core values, and your commitment to take
action to share your concerns will help ensure an ethical workplace for everyone.
You have several options available to you for voicing your concerns.
• Share your concerns about
known or suspected COBC
violations.
• Know the options available
to you for voicing your
concerns.
Maybe you have a question about the COBC or want more details about a particular policy, or
maybe you have seen or suspect someone has violated the COBC. Whom do you contact?
• Start by talking with your manager or Human Resources representative. Since they may be
your closest link to an issue, they can act as a good resource to resolve your issue. They have a
responsibility to listen and to help. Cisco managers have a duty to promote an open and honest
environment where members of their teams can feel comfortable about voicing their concerns
without fear of retaliation.
• If you do not feel comfortable initially discussing your concern with your manager or Human
Resources representative, or after seeking assistance, you do not feel the outcome resolved
your issue, please contact the Ethics Office. The Ethics Office is responsible for administering
the COBC and is available to all employees, customers, partners, shareholders and other
Cisco Systems, Inc. Code of Business Conduct
11
Connect
with the
Code…
• Understand that all reported
concerns will be promptly
addressed.
• Cooperate with
investigations into ethical
misconduct.
• Understand that retaliation
for disclosing ethical
concerns made in good faith
will not be tolerated.
stakeholders who wish to raise concerns or an alert about potential violations. The Ethics Office
manages all inquiries promptly and confidentially, to the extent possible by law.
You can contact the Ethics Office by e-mail, Web Form, or by calling the Cisco EthicsLine,
available 24 hours a day, 7 days a week. The EthicsLine is a confidential option, provided by The
Network, a leading third-party reporting service. You have the option to remain anonymous*
when you use this service; however, the investigation of the alleged incident may be hindered
if the investigator is unable to contact you for further information. Your concern is documented
by a highly trained interview specialist and is disseminated to appropriate Cisco management,
who will promptly address the matter.
*Please note: Some countries in which Cisco does business do not allow such concerns to be
reported anonymously. Visit the EthicsLine website for country-specific guidelines on how to
share concerns about suspected violations of the COBC.
• Questions and concerns regarding legal issues can be submitted to Legal.
• Questions and concerns regarding accounting, internal accounting controls, or auditing
matters (or other related issues) can be submitted to the Governance, Risk, and Controls
(GRC) group. Another option is to contact the Audit Committee of the Board of Directors or if
you are concerned about maintaining anonymity, you may send correspondence to the Audit
Committee at the following private mailbox (PMB) address at: Cisco Systems, Audit Committee,
105 Serra Way, PMB #112, Milpitas, CA 95035.
Whatever reporting method you choose, your concern will be promptly
addressed.
Depending on the nature of an alleged violation, the Ethics Office, Legal, GRC, or another
applicable organization will promptly address the concern and seek accurate and reliable
information in order to discover the truth about reported alleged violations of a COBC policy. Cisco will attempt to address each COBC violation in a consistent manner that is appropriate to
the nature of the violation, including termination of employment if warranted by the circumstances.
Cisco employees have an obligation to cooperate with investigations into alleged ethical
misconduct. Failure to cooperate and provide honest and truthful answers or information could
result in disciplinary action, up to and including termination of employment.
Cisco Systems, Inc. Code of Business Conduct
12
What if...
What if my manager tells me to do something that is dangerous and possibly
illegal? I know I should tell someone, but I’m afraid that my manager will make
my job difficult for me if I do.
The best place to raise your concerns would typically be with your manager, but because it is
your manager’s request that concerns you, calling the Cisco EthicsLine is a good option. If you
report your concerns to the Ethics Office, you will have the assurance that Cisco is looking into the
situation and that retaliation by your manager or others will not be tolerated.
What if I reported a concern but never heard anything about it?
Consider whether the matter was reported anonymously. If so, to the extent that outcomes can
be reported, there may not be a mechanism for getting back to you. Also, all matters will be
investigated appropriately, but it may not be appropriate for the results of the investigation to
be communicated back to you, the original reporting party, in light of privacy and confidentiality
issues.
What if I did not report any concerns but am asked to cooperate in an
internal investigation by HR, Employee Relations (ER), GRC, or someone in
management? Must I participate?
Yes. As a Cisco employee, you are obliged to cooperate in internal investigations. Failure to do so
may result in disciplinary action, up to and including termination of employment.
Cisco Systems, Inc. Code of Business Conduct
13
I Respect Others
My vision of the ideal workplace? One that is positive, creative and
rewarding…an environment that promotes individual expression, innovation
and achievement. That’s the kind of workplace we have here at Cisco. I’m
offered opportunities to grow personally and professionally, and my manager
encourages me to succeed. I’m treated with respect and dignity. In return, I
recognize my duty to act responsibly, be a team player, always do my best,
and treat others with respect and dignity.
Cisco Says...
Connect
with the
Code...
• Do your part to make Cisco a
great place to work.
• Treat others with respect and
dignity.
• If you know or suspect that
others are being harassed or
discriminated against, report
it immediately.
Cisco Systems, Inc. Code of Business Conduct
You are free to do your job without fear of harassment.
Cisco prohibits conduct that singles out an employee or group of employees in a negative way
because of their gender, race, color, national origin, ancestry, citizenship, religion, age, physical
or mental disability, medical condition, sexual orientation, gender identity or gender expression,
veteran status, or marital status. Harassment can take many forms, including offensive remarks;
unwelcome advances; requests for sexual favors; jokes; and ethnic, racist, or sexual slurs. Any
form of harassment is a violation of Cisco philosophy and policies.
We do not discriminate.
We are proud of our diversity and our commitment to maintaining a diverse workforce. In
recruiting, hiring, developing, and promoting employees - all employment processes - decisions
are made without regard to gender, race, color, national origin, ancestry, citizenship, religion, age,
physical or mental disability, medical condition, sexual orientation, gender identity or gender
expression, veteran status, or marital status. We are passionate about preserving our positive
culture and ensuring that each individual is treated with respect and dignity as a valued member
of the Cisco team.
14
Retaliation will not be tolerated.
Connect
with the
Code...
• Speak out against acts of
retaliation.
• Know and abide by Cisco
policies regarding drugs and
alcohol.
• Report any unsafe
conditions, violent acts, or
threats.
• Protect and use others’
personal information
appropriately.
• Actively engage with
programs which support
Cisco’s commitment to CSR.
• Be accountable for quality
in delivering an unrivaled
customer experience.
Taking action against anyone who brings a discrimination, harassment, or ethics issue forward is
strictly forbidden. We take reports of retaliation seriously. Anyone found to have retaliated against
another individual will face disciplinary action and possible termination of employment.
Our workplace accommodates individuals with disabilities.
We are committed to working with and providing reasonable accommodations for employees and
applicants with physical or mental disabilities. Disabled employees are encouraged to provide
notification from their doctor describing any restrictions on their ability to perform the essential
duties or functions of their job.
We have a strict drug and alcohol policy.
Employees are not permitted to use, possess, sell, transfer, manufacture, distribute, or be under
the influence of illegal drugs on Cisco-owned or leased property, during working hours, while
on company business, or while using company property. In addition, no employee may report
for work, go on or remain on duty while under the influence of or impaired by alcohol or illegal
drugs or substances. Alcohol use at company-sponsored events is allowed only with prior written
approval of the department Senior Vice President. Violation of this policy will result in disciplinary
action, up to and including termination of employment. Alcohol consumption guidelines for Cisco
employee events can be found in the Drug and Alcohol in the Workplace policy.
We are committed to providing a safe and nonthreatening workplace.
Employees should be familiar with and follow all safety guidelines and report any unsafe
conditions or accidents. Any acts or threats of violence toward another person or company
property should also be reported immediately. We want to foster the kind of environment where
people feel safe and are treated with courtesy and professionalism at all times.
We provide safeguards for your personal information.
Cisco respects the privacy rights and interests of all its employees and provides safeguards for
the protection of its employees’ personal information that is collected, held, and used. Everyone
Cisco Systems, Inc. Code of Business Conduct
15
must respect the privacy rights of coworkers and handle all employees’ personal information in
accordance with Cisco’s Global HR-related Data Protection Policy.
Corporate Social Responsibility (CSR) is an important part of our culture.
The company’s CSR programs and initiatives use responsible business practices and
social investments to create long-term value for our business. Our CSR focus areas include:
transforming societies, creating a thriving employee experience, governing our business,
developing products responsibly, and protecting the environment. I have a responsibility to act
in a manner consistent with our CSR philosophy. Cisco leaders encourage all employees to be
engaged in the community and learn about conserving limited environmental resources.
Cisco values human rights.
Our policies incorporate ethical principles presented in the United Nations Universal Declaration
of Human Rights. These principles, such as: freedom of association, nondiscrimination, privacy,
compulsory and child labor, immigration, wages, and working hours, continue to serve as a guide
for how we conduct our business and how we interact with our suppliers and business partners.
Also, Cisco supports the United Nations Global Compact and its ten principles.
Read more in the annual CSR Report.
I am accountable for quality in delivering an unrivaled customer experience.
We at Cisco are committed to delivering unprecedented value and opportunity for our
customers because customer success is an important part of our culture and a core value. These commitments align with our quality objectives to provide world-class products and
services, understand and enhance the customer experience, and drive continuous improvement
throughout Cisco.
As individuals, we agree to adhere to the Cisco Quality Policy and the Cisco Business
Management System which describe our commitment to quality. We also help ensure quality
by following our respective organizations’ processes and proactively meeting and exceeding
customer needs.
For more information about Cisco’s commitment to quality, please visit the Corporate Quality
homepage.
Cisco Systems, Inc. Code of Business Conduct
16
What if...
What if the person harassing me is my supervisor? If I complain, couldn’t I lose
my job?
No. You are a valued member of the Cisco team, and you are entitled to work in an environment
free from intimidating, hostile, or offensive behavior - from anyone. Contact Human Resources, the
Ethics Office, or Legal for help (see the COBC section entitled, “I Share My Concerns”).
What if I received an email that I was not supposed to receive and it included
very offensive jokes? If it was not meant for me to read, is that harassment?
Offensive jokes sent through company email, regardless of their intended recipient, have no place
in a workplace that values dignity and respect for every employee. You may respond directly to
the coworker, notifying him or her that you found the email offensive. Ask the individual to refrain
from sending out such email in the future, and say that you will escalate the matter if it continues.
What if I believe that I was passed up for a promotion because of my age?
What should I do?
Cisco policy requires that employment decisions be made without regard to any candidate’s age.
If you feel you were treated unfairly, contact Human Resources for assistance or call the Cisco
EthicsLine.
What if I receive a telephone call from someone requesting information about
one of my coworkers and I am not certain that the caller is a Cisco employee?
You should not disclose any personal information about your coworkers to anyone if you are
uncertain as to whether the caller is a Cisco employee. Employee phone numbers and email
addresses, and reporting structures from the Cisco Employee Connection (CEC) directory should
never be provided to unknown callers.
Cisco Systems, Inc. Code of Business Conduct
17
I Use Resources Responsibly
Cisco counts on me to act responsibly and use good judgment to conserve
and safeguard company resources, such as computers, telephones, Internet
access, fax machines, and copiers. I am committed to using these resources
frugally and helping to ensure that Cisco receives the best value for its
money because I know it is critical to our bottom line.
Cisco Says...
Company assets are provided for business use.
Connect
with the
Code...
• Use company assets
responsibly, as if you were
paying for them yourself.
• Treat what is ours with care
and guard against waste and
abuse.
Company assets should be used first and foremost for business purposes and to advance our
strategic objectives. We each have a responsibility to use and maintain our assets with care and to
guard against waste and abuse. Our assets include not only the physical space in which we work,
but also other physical assets such as securities and cash, office equipment, and information
systems. They even include things that are not of a physical nature, such as software, patents,
trademarks, copyrights, and other proprietary information. For example, Cisco trademarks should
not be used on non-company materials or as part of any domain name that is not registered, used,
and controlled by the company. Similarly, Cisco’s copyrighted works, such as documentation,
graphics, images, videos, audio recordings, and software, should only be used only for business
purposes pursuant to Cisco’s policies. You have no expectation of privacy when using company
resources for personal reasons, as those resources belong to Cisco and therefore material
transmitted may be retained or reviewed.
Get written approval when you use company assets for non-company
purposes.
We trust you to use good judgment to conserve company resources. Do not borrow or remove
them from company premises without proper authorization, and never use company assets to
support a personal business or consulting effort or outside fundraising activity. This includes
Cisco Systems, Inc. Code of Business Conduct
18
Connect
with the
Code...
• Obtain authorization (through
policy, procedure, or express
written approval from your
manager) before using Cisco
assets for non-company
purposes.
• Use electronic
communications
technology responsibly and
professionally.
• Retain and manage
Cisco company records
responsibly.
Cisco resources that have been identified as “scrap”, garbage or destined for recycling. Except
incidental use of a company-supplied computer and related applications as described in
the following paragraph, using company resources to support political activity or lobbying is
prohibited unless written permission is obtained from the Senior Vice President of Worldwide
Government Affairs.
Use email, computer, and other communications systems lawfully and
professionally.
Occasional use of company assets for personal reasons is permitted, within reason, as long as
it does not compromise Cisco’s interests or adversely affect job performance (yours or that of
your coworkers). Your use of company resources should never result in significant added costs,
disruption of business, or any disadvantage to Cisco. Be conscientious and responsible; do
not access, distribute, download, or upload material that is prohibited by law or contains sexual
content; or distribute or upload material containing offensive language, third party copyright
protected materials without permission from the owner, anything that would negatively reflect on
Cisco, or derogatory comments about race, gender, sexual orientation, age, or religion.
Use Cisco community mailers responsibly.
Cisco community mailers are intended to let employees network and engage in group activities
that will enhance peer relationships inside and outside the workplace. Mailers may not be used
to solicit illegal or fraudulent activity or enable or encourage another to breach a contract. Cisco
mailers may not be used for political activities without the written permission of the Senior Vice
President of Worldwide Government Affairs. Mailer usage should be consistent with the Cisco
values of trust, integrity, inclusion, and respect for others. If you are unsure whether the content
you intend to post is appropriate, please contact the Ethics Office for clarification. Postings to
mailers containing content that violates these core values will result in disciplinary action, up to
and including termination of employment. For further guidance, refer to the Policy on Use of Cisco
Assets for Activities Relating to Employees’ Personal Beliefs.
Know the policies related to management and retention of records and email.
At Cisco, we collaborate and exchange information in various forms, whether it is an email, a video
Cisco Systems, Inc. Code of Business Conduct
19
or audio recording, or an electronic document. We have policies in place to help us effectively
and efficiently manage our company’s documentation and email systems so that we are compliant
with legal and business requirements. In general, employees should retain all information that
relates to a Cisco business record, legal matter (pending or anticipated), or audit. If you receive
a document retention directive from Cisco Legal, you must follow it and retain all documents
specified in that directive.
Be respectful and professional when using video and social media tools.
With the rise of new media and next-generation communications tools, the way in which Cisco
employees can communicate internally and externally continues to evolve. These emerging
media tools include: video, blogs, wikis, podcasts, virtual worlds, and social networking. Cisco
encourages employees to learn about and use these social media tools because they can
promote teamwork and collaboration. Policies and guidelines regarding the use of these tools
can be found in the Social Media Policy and in the IWE Global Social Media Community and they
emphasize the need to:
• Communicate in a respectful and professional manner
• Avoid disclosing proprietary information or misusing Cisco’s intellectual property
• Keep applicable policies and regulations in mind
• Understand that the same rules about communicating Cisco information ‘offline’, also apply in
the ‘online’ world
What if...
What if I write a personal letter or surf the Internet or call a family member on
my office phone? Are these types of activities OK?
Generally, limited personal use of company resources is permitted as long as a significant cost is
not assumed by Cisco and your work is not disrupted.
Cisco Systems, Inc. Code of Business Conduct
20
What if I operate a small side business from home? Both my manager and the
Ethics Office have determined that the business does not represent a conflict
of interest with my Cisco work. Is it OK for my customers to leave messages on
my Cisco voicemail?
No, unless it is purely incidental. Even though there is no conflict of interest, you have an obligation
to use Cisco company assets (including the communications system and voicemail) only for Cisco
business. Employees are not permitted to use assets to support a second job, self-employment
venture, or consulting effort. If you anticipate regular communications from such an activity, you
are responsible for setting up your own telecommunications modalities.
May I use a Cisco community mailer to offer to other mailer recipients the use of
my subscription-based account for a paid service?
No, you may not offer the use of your subscription account to others via Cisco community mailers. Doing so may violate the terms of the subscription and possibly create legal ramifications.
What if I have recently completed a project…can I throw out or delete all the
project documentation?
There is business value in storing records related to a project, however, we should only keep
necessary information. Retention guidelines will differ from project to project. Cisco has a
legal obligation to retain records as provided in the Cisco Record Retention Schedule, which
incorporates applicable laws and regulations, and an obligation to prevent the disposition of
information related to an investigation, claim, or lawsuit. Contact the Enterprise Records &
Information Management (ERIM) team for retention and disposition guidelines.
Cisco Systems, Inc. Code of Business Conduct
21
I Avoid Conflicts of Interest
When I am faced with a situation and am not sure what to do, I ask myself: Am
I doing what’s right for the company? Avoiding conflicts of interest means
avoiding situations that create or appear to create a conflict between my
personal interests and Cisco’s interests.
Cisco Says...
Avoid activities or relationships that might affect your objectivity.
Connect
with the
Code...
• Always ask yourself: Am I
doing what is right for the
company?
• If a conflict of interest (or
the appearance of one)
develops, ask for help from
the Ethics Office or Cisco
Legal.
Cisco Systems, Inc. Code of Business Conduct
A conflict of interest may exist when you, a member of your family, or a close personal friend
is involved in an activity that could affect your objectivity in making decisions as a Cisco
employee. Examples of activities that might create a conflict of interest include accepting outside
employment with a Cisco customer, supplier, or competitor, or having a significant financial
interest in their enterprise. Conflicts of interest can also arise when you, a member of your family,
or a close personal friend use your position for personal gain. It is important to remember that
even the appearance of a conflict of interest must be avoided.
Be sure to obtain written approval before serving on outside directorships,
Technical Advisory Boards (TABs), or government-affiliated boards.
Employees who wish to serve on outside Boards of Directors, TABs of a profit-making
organization, or any government-affiliated board are required, before accepting, to obtain
written approval using the External Board Participation tool. Membership on boards of industry
associations generally does not present a financial conflict of interest; however, you should be
sensitive to possible conflicts with Cisco’s business interests if, for example, the association takes
a position that is contrary to Cisco’s interests or those of our primary customers. In addition, if
you do such service, you are prohibited from introducing the other venture to Cisco for business
purposes or in any way engaging in a relationship with the other entity on behalf of Cisco. 22
Connect
with the
Code...
• Check Cisco policies for
guidance when investing
in a company that has a
connection to Cisco.
• Know the circumstances
under which you must obtain
written permission from the
Cisco vice president for your
organization.
• Do not accept compensation
for speaking engagements.
• Report potential conflicts
of interest as they relate
to employment of family
members or close personal
friends either as employees,
competitors, contractors, or
vendors.
Participating on boards that are affiliated with governments requires review by Legal. Contact the
Ethics Office for approval prior to joining the board or management of a non-profit organization.
Investing in other companies may present a conflict of interest.
At some point in your employment, you may find yourself in a position to invest in a company that
is (or is reasonably likely to be) a Cisco partner, customer, supplier, competitor, or candidate for
acquisition by Cisco. It is important that you understand the potential conflict of interest that may
occur in these circumstances. The most important consideration is to serve our shareholders
first. Cisco has developed detailed policies to address specific investment scenarios and the
necessary written approval processes associated with each. For more information on specific
investments and the necessary approvals, please visit the websites listed in the “Learn More”
section or contact the Ethics Office for guidance on how to proceed.
Written permission is required in some instances.
If you, a member of your immediate family or a close personal friend enters into any kind of
employment, business, or consulting relationship with a Cisco vendor, supplier, competitor
or customer that is affiliated with your work responsibilities, you must receive prior written
permission from the Ethics Office, the Cisco vice president of your organization, and your HR
Manager. After permission has been received, a copy of this written permission will be maintained
by Human Resources and kept in the employee’s file. This does not mean that family members
or close personal friends are precluded from working for one of Cisco’s vendors, suppliers,
competitors or customers. The aforementioned approval process is simply a precaution that
we have in place to help ensure that Cisco employees avoid conducting Cisco business with
members of their families or close personal friends and are not put into a position where Cisco
confidential information might be compromised.
Development of new products also requires written permission.
Cisco employees must obtain written permission from the Ethics Office, the Cisco vice president
for their organization and their HR Manager before developing, outside of Cisco, inventions,
Cisco Systems, Inc. Code of Business Conduct
23
products, books, software, publications, or intellectual property that is or may be related to
Cisco’s current or potential business. After permission has been received, a copy of this written
permission will be maintained by Human Resources and kept in the employee’s file.
Do not provide endorsements without prior approval from Public Relations.
Cisco and its employees are frequently asked to provide endorsements. These requests may
take many forms (articles, press releases, case studies, testimonials, branding, etc.) and may come
from many different parties (vendors, distributors, customers, etc.). Providing these endorsements
may not always be in Cisco’s best interest. Casual or indiscriminate endorsements can dilute the
Cisco brand; upset vendor or channel relations; and in some cases, increase the risk of Cisco
liability for the misdeeds of others. Please consult the Cisco Endorsement Guide and contact
Public Relations prior to making any endorsements. Employees are permitted to provide personal
references for current or former Cisco employees but only in accordance with the References
and Verification of Employment policy. This policy contains disclaimers which must be included
with any personal references for current or former employees.
Do not accept compensation for speaking engagements on behalf of Cisco.
Speaking at events where you are identified as speaking in your capacity as a Cisco employee,
when it is determined to be in Cisco’s best interests, is considered part of your normal job
responsibilities. Because you will be compensated by Cisco for the time spent preparing
for, attending, and delivering the presentation, you should not request or accept any form of
compensation, unless:
• The compensation is some type of “acceptable” novelty, favor, or entertainment, as defined
in the COBC section entitled “I Understand Policies Related to Gifts, Hospitality and
Entertainment”
• The Cisco vice president for your organization first provides written authorization; or
• The fee is donated to the Cisco Foundation or other nonprofit charitable organization.
Cisco Systems, Inc. Code of Business Conduct
24
Mixing family or personal relationships with work relationships can create special
workplace challenges.
Personnel decisions can become difficult if the employee whom you supervise is also a member
of your immediate or extended family or is someone with whom you have a significant personal
relationship. Even if you are careful and work to remain objective in your business dealings, the
very fact that you share a personal relationship with this individual can suggest the appearance
of a conflict of interest. As a result, employees must avoid a direct or indirect-vertical reporting
relationship with any member of their immediate or extended family or others with whom they have
a significant relationship. If such a relationship exists or occurs, you must report it, in writing, to your
Human Resources representative and the Ethics Office. In addition Cisco employees should not
use their positions to give an unfair advantage to family members or close personal friends who are
seeking a contractor or vendor relationship, internship, or other employment opportunity with Cisco.
Please consult the Employee Referral Program for information on the proper channels to refer
someone for employment at Cisco.
Outside business activities involving selling or servicing Cisco equipment are
considered a conflict of interest.
Cisco employees are not permitted to engage in outside-business-related activities that involve
the sale, resale, marketing, or repair of Cisco equipment (or any consulting activities related to the
above) for profit.
If a conflict of interest (or the appearance of one) develops, report it immediately.
If there is any chance that a conflict of interest or the appearance of a conflict of interest may exist,
please contact the Ethics Office. If your situation concerns an outside-of-Cisco employment or
consulting opportunity, complete and submit the Consulting and Outside Employment Approval
form. Once a potential conflict is reported, the Cisco Ethics Office or Legal will determine whether a
conflict of interest exists and advise you of your options for resolving it.
Cisco Systems, Inc. Code of Business Conduct
25
What if...
What if I develop a product that I think would be beneficial for Cisco? Does
Cisco prohibit employees from becoming suppliers to Cisco?
Because this situation could cause divided loyalty, or at least the appearance of a conflict of
interest, Cisco does not traditionally purchase products or services from its employees. Our
reputation for impartiality and fair dealing with suppliers could be damaged by routinely acquiring
products or services from employees, even with full and open competition. Before considering
such an arrangement, you must obtain written permission from the Cisco vice president for your
organization.
What if one of my relatives or a close personal friend works for a Cisco
customer or supplier?
Cisco needs to know so that appropriate action can be taken to prevent potential conflicts from
affecting (or appearing to affect) company decisions. For example, if your sister works for a
supplier and has been involved in procurement activities, and your manager has just informed you
that she wants you to join a proposal team looking at bids from various companies, including the
one that employs your sister, you must disclose it.
What if my best friend’s daughter just graduated from college and would like to
apply for a position two levels below me in my reporting chain? Can I forward
her resume directly to the hiring manager (my direct report)?
Some of our best new hires come from employee referrals, and there is nothing the matter with
this referral if you know the applicant yourself and are confident of the individual’s capability. If you
don’t know the individual, you should evaluate whether a referral will be seen as pressure to hire; it
may be best to allow your best friend’s daughter to apply through the general application process. Refer to the Employee Referral Program and contact the Ethics Office or your Human Resources
representative for more specific guidance.
Cisco Systems, Inc. Code of Business Conduct
26
What if the local school system is looking for someone skilled in IT architecture
to develop an information system? Is it OK to engage in an activity or business
on the side that competes in a similar, but not identical, product market to
Cisco’s?
It depends. Public schools and other “public” entities use taxpayer dollars; as a result, they are
required by law to follow certain laws and regulations, and are subject to public review of their
expenditures and other activities. In order to avoid any potential conflict of interest issues, it is
critical to first check with Legal to determine if your activity will be consistent with such laws. You
can also contact Public Sector Compliance or the Ethics Office for help.
What if I am not sure about whether an activity outside of work poses a conflict
of interest?
Unfortunately, it is not possible to list all the circumstances that might signal potential conflicts of
interest. One of the best ways to gauge whether the activity creates a conflict of interest is to ask
yourself a series of questions: Does the activity interfere (or give the appearance of interfering)
with the duties that you perform at, or owe to, Cisco? Are you, a member of your family, or a close
personal friend receiving improper personal benefits through the activity because of your position
with the company? Does the activity compete against the interests of Cisco? If you answer
“yes” to any of these questions, the activity may indeed create a conflict of interest and must be
disclosed. If you are not sure, contact the Ethics Office for assistance.
Cisco Systems, Inc. Code of Business Conduct
27
I Understand Policies Related
to Gifts, Hospitality and
Entertainment
I strive to promote successful working relationships and goodwill with our
business partners, who are vital to our success. From time to time, I may
consider offering or accepting a gift, hospitality or entertainment with a
business partner, but recognize that I should be careful not to create a
situation that would suggest a conflict of interest, divided loyalty, or the
appearance of an improper attempt to influence business decisions.
Connect
with the
Code...
• Know the rules for accepting
and offering gifts, hospitality
and entertainment.
• Be able to distinguish
between what is
“acceptable,” “inappropriate,”
and “questionable.”
• Be aware that the rules for
government employees are
much more stringent.
Cisco Systems, Inc. Code of Business Conduct
Cisco Says...
“Gifts, hospitality and entertainment” means anything of value. It can include the
following (a non-exhaustive list):
• meals
• lodging
• discounts
• loans
• cash
• services
• equipment
• prizes
• transportation
• use of vehicles or vacation facilities
• home improvements
• tickets to entertainment/sport events
• gift cards or certificates
• stocks
• opportunity to buy direct shares (“friends and family
shares”) in a company with a connection to Cisco
• favorable terms on a product or service
• products
28
Connect
with the
Code...
• Accurately report
expenditures for gifts,
hospitality or entertainment.
• If you need more
information or are in doubt
about whether to give or
accept gifts, hospitality,
entertainment, prizes, or
giveaways, contact the Ethics
Office or Legal for help.
The following ground rules apply for any kind of gift, hospitality or
entertainment that is exchanged between a Cisco employee or his or her family
member and a business partner:
• No obligation: The gift, hospitality or entertainment does not place the recipient under any
obligation.
•No expectations: The giver does not create any stated or implied expectations of getting
reciprocal or resulting actions from the recipient(s).
•Made openly. The gift, hospitality or entertainment is transparently provided.
•Reasonable value: The size of the gift, hospitality, or entertainment is within Cisco’s dollar
limits (outlined below) and for travel-related expenses must conform with Cisco’s travel
expense policies,
•Appropriate: The nature of the gift, hospitality or entertainment is appropriate to the
business relationship and local customs.
•Conforms to the recipient’s rules: The gift, hospitality or entertainment is permitted by
the recipient’s organizational policies.
•Infrequent: The giving or receiving of the gift, hospitality or entertainment is not overtly
frequent between the giver and recipient.
•Legal: The gift, hospitality or entertainment is legal, per relevant law.
•Documented: The expense is accurately documented, pursuant to the Global Expense
and other related policies.
Know the policies regarding gifts, hospitality and entertainment between Cisco
and the following:
Commercial companies. The exchange of gifts, hospitality and entertainment between
commercial company business partners and Cisco employees (or their family members) fall into
the three following categories. Before offering or accepting a gift, hospitality or entertainment,
evaluate the offer using the above basic ground rules and the following guidelines:
Cisco Systems, Inc. Code of Business Conduct
29
• Acceptable*: The following guidelines describe what is considered generally acceptable
and requires no approval:
–N
ominal gifts with a combined market value of US$100 or less, to or from a single
source per year, are acceptable.
–O
ccasional meals with a business associate should follow the Global Expense Policy Meals and Entertainment guidelines.
– Occasional entertainment (for example, attendance at sports, theater, or other cultural
events) valued at less than US $200, per source, per year, are acceptable.
– When offering Cisco-branded equipment (e.g. Linksys routers) to a non-Cisco party
that has a market value that exceeds the gift threshold, you must obtain approval from
both the Ethics Office and the vice president of your organization (vice presidents must
obtain their supervisor’s approval).
*Please note: The above rules covering commercial organizations are not necessarily
applicable to Cisco marketing programs, promotions, or Cisco-sponsored events, which may
be subject to other guidelines. Please contact your Cisco marketing representative or Legal
for more information.
• Inappropriate: Some types of gifts, hospitality, or entertainment are simply wrong, either
in fact or in appearance, and are never permissible. With respect to Cisco employment,
employees (as well as members of their immediate families and close personal friends)
may never:
– Offer or accept gifts, hospitality or entertainment that would be illegal
– Offer or accept cash or a cash equivalent (including loans, stock, stock options, bank
checks, travelers’ checks, Visa or other type of check or cash cards, money orders,
investments securities, or negotiable instruments)
– Offer or accept gifts, hospitality or entertainment during a tender or competitive bidding
process
– Incur an expense on behalf of a customer that is not recorded properly on the
company’s books
Cisco Systems, Inc. Code of Business Conduct
30
– Offer, accept, or request anything (regardless of value) as part of an agreement to do
anything in return for gifts, hospitality or entertainment
– Use their own money or resources to pay for gifts, hospitality or entertainment for a
customer, vendor, or supplier
– Participate in an activity that would cause the person giving or receiving the gifts,
hospitality or entertainment to violate his or her own employer’s standards
– Offer, accept, or participate in gifts, hospitality or entertainment that is unsavory or
otherwise violate our commitment to diversity and mutual respect; any situation that
would cause a customer, employee or other third party to feel uncomfortable or that
would embarrass Cisco by its public disclosure (for example, adult entertainment), is
inappropriate.
• Questionable: For anything that does not fall into the Acceptable or Inappropriate category,
or that exceeds the dollar limit noted above, ask your manager and the Ethics Office for
guidance. You will then need to obtain written approval from your department vice president*
and your Human Resources manager before offering or accepting whatever is offered.
*Please note: If you are a vice president or higher, you need to obtain permission from your
supervisor.
Government employees and agencies. Keeping in mind the above basic ground rules, stricter
and more specific rules and company policies apply when we interact with government entities
and their employees and representatives. If you are unsure whether or not an entity is government
-affiliated, contact Public Sector Compliance for help. Nothing of value should ever be promised,
offered or provided to a government employee either directly or indirectly in an attempt to influence
the government employee to act or refrain from acting in connection with obtaining or retaining any
business advantage. • Before offering any gift, hospitality or entertainment to a U.S. federal, state, or local
government employee, carefully review Cisco’s U.S. Public Sector Ethics Code and gift/
hospitality policy limits.
• Gifts are banned to U.S. Congress and staff: The U.S. federal lobbying disclosure law (2007)
bans, almost completely, giving gifts of any kind to Congressional officials, U.S. Senators, and U.S.
Cisco Systems, Inc. Code of Business Conduct
31
Representatives and their staffs from Cisco or Cisco employees. The law forbids us from buying
meals and event tickets and giving any sort of product discounts. Even courtesy gifts such as
flowers, candy, or any small token that you might send to thank an official for help of some kind are
banned. The law requires these restrictions because Cisco uses registered lobbyists to represent
us before the Congress of the United States. If you have any questions about this law or about
compliance with government ethics and lobby laws in general, please contact Global Policy &
Government Affairs or the Public Sector Compliance Group.
• When considering a gift to a government employee associated with a government
outside of the United States, follow Cisco’s policy regarding global anti-corruption, addressed
in the “I Follow the Law” section of the COBC. Under a majority of anti-corruption laws, government
entities can include many government-owned or controlled organizations, such as public
universities, hospitals, sovereign wealth funds, and telecom service providers, as well as public
international organizations, such as the United Nations, World Bank, or African Union.
• Follow Cisco’s process for inviting any government employee to Cisco-sponsored
business meetings and events. The Cisco Guest Travel and Event Tool (GTET) is Cisco’s online
tool that Cisco employees are required to use to obtain requisite pre-approvals for inviting any
government guest to a Cisco business event or meeting when Cisco is to pay for any portion of the
government guest’s travel and/or hotel accommodations.
Internal employees. There are specific policies that address giving gifts internally to Cisco
employees. Please refer to the Global Expense Policies for specific guidance.
Contingent Workforce (Contractors and Temporary Employees). Gifts to contractors or
temporary employees are not reimbursable through Cisco’s reimbursement tools. Please refer to
Global Expense Policy for specific guidance.
Third-party offers for Cisco employee travel. Employees must adhere to the Employee Travel
Policy before accepting offers by third parties to pay for Cisco employees’ travel.
There are special rules relating to raffles and giveaways.
Raffles and giveaways that are fair, nondiscriminatory, and conducted in a public forum for all to
see and understand are typically permitted unless the prize is worth more than US$500. Gifts
worth more than US$500 must be disclosed to a manager, who will consult with the Ethics Office
Cisco Systems, Inc. Code of Business Conduct
32
to determine whether the gift should be accepted.
–W
hen Cisco hosts the raffle or giveaway and only Cisco employees participate, the
US$500 limit does not apply, but frugality should be observed.
– When Cisco hosts the raffle or giveaway and opens it to non-Cisco employees, it is
subject to the US$500 limit unless written approval from your department vice president is
obtained (and keeping in mind any specific and applicable gift laws or rules that may apply to
any government-related personnel). Also, consider whether the raffle prize or giveaway would
cause the recipient to violate his or her respective company’s or entity’s related policies.
– When an outside party hosts the raffle or giveaway, Cisco employees may accept
the prize as long as the process appears to be fair and unbiased. The drawing should take
place in a public forum, and the prize must be disclosed to the recipient’s manager. Written
approval from your manager and the Ethics Office is necessary if the prize exceeds the
US$500 limit.
Local customs in some countries may call for the exchange of expensive gifts
as part of the business relationship.
In these situations, gifts may be accepted only on behalf of Cisco (not an individual) with the
written approval of your department vice president and your Human Resources manager. Any
gifts received should be immediately given to Human Resources for appropriate disposition
or donated to the Cisco Foundation or other nonprofit, charitable organization. The foreign
company’s gift policy regulations must be observed. In all cases, the exchange of gifts must be
conducted so that there is no appearance of impropriety. Gifts may be given only in accordance
with all applicable laws, including the U.S. FCPA (see the COBC section entitled “I Follow the Law”.)
Employee-to-employee gifts have specific guidelines.
There are specific policies that address giving gifts internally to Cisco employees. Please refer to
the Global Expense Policy for guidance.
Cisco Systems, Inc. Code of Business Conduct
33
Expense report records must accurately reflect gifts, hospitality and
entertainment that you provide to customers.
Because of tax and other legal reporting rules, it is essential that you accurately report
expenditures for gifts, hospitality or entertainment that you give in connection with your Cisco
employment. Reports should accurately state the purpose of the expenditures and the identities
of the individuals receiving the gifts, hospitality or entertainment. Reports must also identify
whether the gift, hospitality or entertainment was given to a public sector official or employee.
Corporate charitable donations to a non-profit and/or non-government entity
must comply with Cisco’s Charitable Donations policy. Corporate charitable donations of product
or cash are subject to specific legal requirements and Cisco must ensure proper due diligence
and documentation for every corporate charitable donation made on behalf of Cisco. Please refer
to the policy for specific guidance and instructions on making a corporate charitable donation to a
non-profit and/or non-government entity.
What if...
What if we want to provide a catered lunch during a meeting with a major Cisco
customer?
It is acceptable to provide lunch if it is offered in the spirit of our gift-giving policy and complies
with the monetary guidelines for what is considered “acceptable.” For government-affiliated
customers, review the customer’s relevant gift rules first, before offering any meals, or contact
Public Sector Compliance for guidance.
Cisco Systems, Inc. Code of Business Conduct
34
We have worked closely with a commercial customer on a large system
implementation that is now complete. What if we want to recognize our
customer’s employees by giving each member of its team a Cisco-branded
laptop sleeve commemorating completion of the project? Would this be a
violation of our gift policy?
No. You may offer these items as long as the monetary value does not exceed the limits outlined
in our policy. That said, you should propose the idea to one of the customer’s representatives
beforehand to help ensure that the gift is in compliance with that company’s policy. We do not want
to put our customers in the awkward position of having to return the gifts. Although you do not need
to obtain written approval for gifts considered “acceptable,” it is always a good practice to discuss
such offerings in advance with your manager or the Ethics Office.
What if I have a friend who works for a major Cisco customer? Does Cisco
policy prohibit me from buying a Christmas present for this person that
exceeds the limits in our gift policy?
Not necessarily. Cisco policy applies to gifts offered in the course of doing business, not the
exchange of gifts between friends and family. If the dollar value of the gift is substantial, however,
contact your manager or the Ethics Office to avoid the perception of an attempt to influence your
friend.
What if we are hosting a meeting with both commercial customers and
customers from the U.S. Navy in attendance? Can we offer them transportation
from the airport to the hotel?
In this instance, you would need to know and follow Cisco’s gift policies for the commercial
customers and the U.S. federal government gift policies for the U.S. government customers.
You may provide transportation for the commercial customers as long as: (1) the value of the
transportation falls within the guidelines for gifts and hospitality, and (2) the recipients’ policy
allows them to accept this type of business courtesy. With respect to the U.S. Navy, the U.S.
federal government has strict rules that limit or prohibit gift giving. As a general rule, we may not
offer or provide transportation to the U.S. Navy (or other military or U.S. federal employees), unless
the recipients pay Cisco the fair market value of the transportation.
Cisco Systems, Inc. Code of Business Conduct
35
What if a supplier knows that I am a big boxing fan and offers me two great
tickets to a match? I know that Cisco policy would not allow me to accept the
tickets as a gift because the dollar value exceeds our gift policy limit, but what if
I buy them from him?
You may accept the tickets if you pay for them, unless the tickets are to a “sold-out” event. Under
those circumstances, you would be accepting the gift of an opportunity to buy tickets that are not
generally available for purchase, and that would be inappropriate.
What if I have been offered a discount on a product sold by a Cisco supplier?
May I take advantage of it?
You may accept the discount only if it is clearly available to all Cisco employees and approved by
the company. A discount offered to you personally would be inappropriate.
What if I receive a gift that I know is inappropriate? What should I do?
Return it to the donor with a polite explanation that Cisco policy prohibits you from keeping it. In
some circumstances, such as a gift from an official of another country, other alternatives may be
considered, such as displaying the gift in a public area or donating it to a charitable organization.
Check with your manager or the Ethics Office for guidance.
What if I speak to a user group or at a professional meeting? May I accept
reimbursement of travel expenses?
Cisco policy requires that all suppliers and vendors be treated fairly and impartially. Therefore,
do not accept anything from a supplier or vendor that could suggest even the appearance of
favoritism. Normally, it is inappropriate to accept payment of expenses by a current or prospective
supplier or vendor to speak at its user conferences. On the other hand, you can usually accept
reimbursement for expenses from associations and professional groups because they are not
vendors and would not be using the speaking invitation as a way to gain favorable treatment. Refer to the Global Travel policy for specific guidance on third party offers of travel expense
reimbursement.
Cisco Systems, Inc. Code of Business Conduct
36
What if one of my customers is holding a raffle where the prize to be awarded
is a trip valued at US$2,000? May I participate?
Yes, you may participate, as long as the raffle process is fair, unbiased, and held in a public place.
If you win the prize, you must disclose it to your manager, and, because the prize is valued at more
than US$500, you must obtain written approval from your manager and the Ethics Office.
What if I want to offer a giveaway to the first 50 customers and resellers who
participate in our online training that showcases new Cisco products and
services? May I do that?
Yes, but with caution. Offering incentives that conform to Cisco’s Gifts and Entertainment policies
as well as the policies of those company representatives who will participate in the training is
acceptable. Please keep in mind that we do not want to put our customers and resellers in a
position of violating their own gift-related policies if they accept the giveaway offered by Cisco.
Also be aware that inviting public sector employees to participate in such giveaways may violate
our COBC, as well as the law.
Cisco Systems, Inc. Code of Business Conduct
37
I Protect What Is Ours
We are the leader in world-changing technology. Protecting our financial
base, our knowledge base, our information systems, our competitive
advantage, and our brand keeps us at the forefront.
Cisco Says...
Do not provide information regarding Cisco to outside parties without securing
the required approvals and putting in place an appropriate written agreement.
Connect
with the
Code...
• Do not provide confidential
information regarding Cisco
to outside parties without an
appropriate NDA or other
agreement.
• If your job requires you
to provide information for
reports about Cisco, make
sure that the information
you provide is accurate and
complete.
Cisco Systems, Inc. Code of Business Conduct
What may appear to be an innocent request for information could result in serious harm to our
company. Be alert to requests for information from anyone outside of Cisco regarding:
• Overall business trends
• Business in our geographic theaters
• Product bookings or shipments
• Customer information
• Lead times
• Pricing
• Suppliers
• New products, solutions, business strategies or • Lawsuits or intellectual property disputes technology (intellectual assets)
• Internal organization charts
If you are contacted by a member of the financial community, please refer the individual to a
member of the Cisco Investor Relations team. If you are contacted by a member of the press,
please refer the individual to the Cisco Corporate Public Relations group. Violation of this policy
is serious and may result in disciplinary action, including immediate termination and possible
prosecution for violation of securities laws.
Information we disclose about our company must be full, fair, accurate, and
understandable.
As a public company, it is critical that our filings with the Securities and Exchange Commission
38
Connect
with the
Code...
• Protect our intellectual
property and intellectual
assets.
• Follow the policies to
protect our intellectual
property and intellectual
assets, including Cisco’s
proprietary information and
the proprietary information
of others with whom we do
business.
Cisco Systems, Inc. Code of Business Conduct
and other governmental agencies be accurate and timely. Depending on your position with Cisco,
you may be called upon to provide information to ensure that Cisco’s public reports are complete,
fair, and understandable. If you are called upon, make sure that the information is accurate,
complete, objective, relevant, timely, and understandable to ensure full, fair, accurate, timely, and
understandable disclosure in reports and documents that we file with, or submit to, government
agencies and in other public communications.
Proprietary information is one of our most important assets.
Cisco proprietary information is information that Cisco owns or has the right to use, and it
represents the product of our hard work. It includes, but is not limited to:
• software programs and subroutines
• source and object code
• trade secrets
• engineering drawings
• customer lists
• customer information
• copyrighted works
• ideas
• techniques
• know-how
• inventions (whether patentable or not)
• any other information of any type relating to designs
• product specifications
• new product roadmaps
• configurations
• tooling
• schematics
• algorithms
• flowcharts
• circuits
• mask works
• works of authorship
• formulas
• mechanisms
• research
• manufacturing
• assembly
• installation
• marketing
• pricing
• salaries and terms of compensation for
company employees
• costs or other financial data including unannounced press releases, information regarding the company’s business transactions or operations, and acquisitions and merger information
39
Each of us is responsible for protecting the confidentiality, integrity, and
availability of proprietary information.
This responsibility not only applies to safeguarding Cisco’s proprietary information, but it also
extends to the proprietary information of our customers, vendors, partners and others with whom
we do business:
• Confidentiality: Only authorized persons or processes are allowed to have access to the
proprietary information.
• Integrity: The accuracy and reliability of the proprietary information is maintained by
preventing the unauthorized modification of the information, either accidentally or intentionally.
• Availability: Reliable and timely access to the proprietary information is maintained for
authorized individuals and processes.
Our ability to compete fairly in the marketplace depends on protecting the confidentiality, integrity,
and availability of proprietary information. Cisco employees are required to sign a nondisclosure
agreement as soon as they are hired (and may need to sign additional agreements depending
upon the nature of the job). In addition to the obligations outlined in the agreement, all employees
must comply with the following requirements:
• Requests for confidential, proprietary information and the disclosure of confidential, proprietary
information with third parties require a written agreement. Please visit Non-Disclosure
Agreement (NDA) Central for further information.
• Confidential or proprietary information should be disclosed only to those Cisco employees
with a legitimate business purpose, who need the information in order to do their jobs.
• Proprietary information of a customer, partner, supplier, vendor, or other third party should not
be used or copied by a Cisco employee unless it is authorized in writing by the appropriate
Cisco representative and the third party.
• Any unsolicited, third-party proprietary information should be refused or, if inadvertently
received by an employee, returned unopened or transferred to Cisco Legal.
• Employees must refrain from using, or sharing with Cisco, proprietary information belonging to
former employers (unless the information has been acquired by Cisco).
Cisco Systems, Inc. Code of Business Conduct
40
Know the policies related to protecting our intellectual assets.
Information security policies are integral to the COBC. Cisco has developed stringent policies to
protect our electronic intellectual assets and to minimize the risk of information loss or exposure.
We expect every employee to abide by these policies as they relate to data classification and
protection, password protection, remote access and the appropriate use of computing devices
and networks. Cisco has the right to require security controls on all electronic and computing
devices used to conduct Cisco business or interact with internal networks and business systems,
whether owned or leased by Cisco, the employee or a third party. Cisco also has the right to
inspect at any time, all messages, files, data, software, or other information stored on these
devices or transmitted over any portion of the Cisco network.
What if…
What if my former employer was one of Cisco’s competitors? Is it okay to talk
with my Cisco work group about some of its sales strategies?
No. You have an obligation to protect the proprietary information of your former employer,
and that obligation does not end when you leave its employ. You should disclose the fact that
you formerly worked for a Cisco competitor to your manager and be sure to abide by all the
obligations of confidentiality owed to your former employer.
I was waiting in the hall prior to a government proposal meeting. What if I
overheard a conversation that a procurement officer had with one of our
competitors where product specifications and costs were discussed? May I
still participate in the bid process, and, if so, can I use the information to write a
similar proposal and send it in with a lower bid?
The answer is “no” to both questions. You may not capitalize on this information in any way. You
should politely excuse yourself from the meeting, contact the Ethics Office or Legal, and avoid
disclosure of the information to anyone connected with the program or the proposal. It is likely
that you will have to withdraw from the Cisco bid team as a means of protecting Cisco’s ability to
participate fairly in the bid process.
Cisco Systems, Inc. Code of Business Conduct
41
What if I just realized that some inaccurate information was provided to a
customer after price and terms were already agreed upon? Will I be following
proper procedures if I notify the customer right away?
Yes. It would be important for you to contact your finance and legal sales support team and to
work with them to help ensure timely disclosure of the error to the customer.
What if I receive a letter in the mail from an unidentified source that contains
a competitor’s pricing data? I can find no indication that it has been sent or
received through authorized channels. What should I do?
Do not read the document and do not share it with coworkers. The letter should be immediately
sealed and transferred to Cisco Legal.
What if I am about to engage on a potential new technology development
project which will involve exchange of confidential information with a third
party? Do I need to put an NDA in place before beginning the conversation
with the third party?
Yes - an NDA or another appropriate agreement, such as one governing ownership rights with
respect to technology developed in the project, should be put in place at the beginning of any
new business relationship. Check NDA Central to determine if Cisco already has an adequate
NDA in place. We need to protect Cisco’s confidential information provided to the third party
and we need to protect the third party’s information by only using it for the purposes for which is
was provided. It is your responsibility to ensure an NDA is put in place and that we manage an
effective exchange of confidential information.
Cisco Systems, Inc. Code of Business Conduct
42
I Follow the Law
I like the fact that Cisco is a good corporate citizen. As a global company, we
stay on top of laws and regulations as they apply to doing business around
the world.
Cisco Says...
Antitrust and competition laws keep the marketplace where we operate
thriving and competitive.
Most countries have laws prohibiting business practices that interfere with competition. Cisco
abides by these antitrust and competition laws wherever we do business, and we avoid conduct
that might even suggest or make it appear that we are violating these laws.
Connect
with the
Code...
• Know and comply with
antitrust and competition
laws.
• To comply with Cisco’s policy
on insider trading, do not buy
or sell Cisco securities when
in possession of material,
nonpublic information about
Cisco.
Cisco Systems, Inc. Code of Business Conduct
Each of us should be familiar with antitrust and competition laws.
These laws touch upon and affect almost every aspect of our operations, so it is important that you
are familiar with them while doing your job. Remember, violations can carry serious penalties, not
only for Cisco and its executives, but also for you. If you ever have a question about a particular
activity or practice, contact Cisco Legal or Ethics Office for help.
Do not trade on “inside” information.
If you have material, nonpublic information relating to Cisco or our business, it is our policy that
neither you nor any other person or entity may buy or sell Cisco securities or engage in any other
action to take advantage of, or pass on to others, that information. This also applies to trading in the
securities of another company (for example, Cisco customers, suppliers, vendors, subcontractors,
and business partners), if you have material, nonpublic information about that company that you
obtained by virtue of your position at Cisco. Even the appearance of an improper transaction must
be avoided to prevent potential prosecution of Cisco or the individual(s) involved in the trade.
43
Even a “tip” is unlawful.
Connect
with the
Code...
• Understand the provisions
of Cisco’s Global AntiCorruption Policies and,
if your position requires,
attend online anti-corruption
training.
• Use the online Cisco Guest
Travel and Event Tool (GTET)
for Cisco sponsorship of
travel and other related
expenses associated
with attendance at Ciscosponsored business
events by any government
employees (any level),
including employees of
any government-owned or
controlled entities.
Cisco employees are prohibited not only from buying and selling Cisco securities when they are in
possession of material, nonpublic information, but also from tipping off others; that is, passing along
information to friends or family under circumstances that suggest that the Cisco employee was
trying to help someone make a profit or avoid a loss. Besides being considered a form of insider
trading, tipping is also a serious breach of corporate confidentiality. For this reason, you should be
very careful to avoid discussion of sensitive information anywhere that others may hear it, such as in
Cisco cafes, on public transportation, or in elevators.
Cisco’s Global Anti-Corruption Policy. Cisco has a zero tolerance of bribery
and corruption.
It is paramount to our way of doing business to act with the utmost integrity, honesty and
transparency. Bribery and corruption hurt people and are harmful to societies in which such acts
occur. We aspire to act responsibly in all of our business dealings to ensure that we comply with
regional and national anti-corruption laws. We will forgo business opportunities rather than pay
bribes and we will support our employees when faced with losing sales owing to refusal to pay
bribes.
We do not promise, offer, demand, give or accept any advantage (which can include anything of
value, not just cash) as an improper inducement for an action that is illegal, unethical or a breach of
trust. We also require that our business partners adhere to these same principles, outlined in our
policy for partners.
Cisco also seeks to select and retain business partners who share its values for transparency
and honesty in all business dealings, and otherwise act consistently with the principles set forth
in Cisco’s policy, “Compliance with Global Anti-Corruption Laws By Cisco’s Partners.” Cisco has
made anti-corruption e-learning training available for its partners online.
All Cisco sales employees who work with either global or non-U.S. partners and customers, or who
engage with non-U.S. government officials and employees, are required annually to take Cisco’s
online training, “Doing Business with Integrity: Anticorruption Laws in a Global Market”. Check
Cisco’s Global Anti-Corruption Policies or contact Public Sector Compliance for more information
and support.
Cisco Systems, Inc. Code of Business Conduct
44
Connect
with the
Code...
• Do not use Cisco assets for
political purposes.
• Follow Cisco’s records
management policy to
support business operations,
regulatory and legal
compliance requirements.
Follow Cisco’s process for inviting any government employee to Ciscosponsored business events.
The Guest Travel & Event Tool (GTET) is the online tool that Cisco employees are required to
use to request review and approval of Cisco sponsorship of travel or other related expenses
associated with the attendance by any government employee (at any level) to a Cisco-sponsored
business event or meeting (such as an Executive Briefing Conference). All submissions to the
GTET must be complete and accurate so that Cisco can properly determine whether to pay for
such costs. Any GTET-approved costs are paid by Cisco directly to the Cisco-approved thirdparty vendor of travel-related services.
Follow Cisco’s expense-reporting policies.
For other non-GTET-related expenses, Cisco employees are required to comply with Cisco’s
travel and expense-reporting policies, and, in particular, to submit all expenses in iExpenses, and
to accurately categorize expenses. Failing to report a transaction or the mischaracterization of a
transaction or creation of false or inaccurate documentation is strictly prohibited.
You may not use Cisco assets for political purposes.
No assets, including time at work, use of Cisco premises or equipment, or direct monetary
payments, may be contributed to a political candidate, political action committee, or ballot
measure without the written permission of the Senior Vice President of Worldwide Government
Affairs. Of course you may participate in political activities on an individual basis, with your own
money and on your own time. Additionally, under United States election laws, some employees
may be required to obtain pre-approval via Cisco’s U.S. Political Contribution Tool before making
certain kinds of campaign contributions. See Cisco’s U.S. Public Sector Ethics Code for more
information.
Manage company records responsibly to support business operations and
regulatory/legal compliance requirements.
Company records are important information assets. Electronic records should be managed in
Company-approved repositories. They should not be retained on the hard drive of your laptop or
desktop system, or other personal devices. Paper and other physical records should be stored
Cisco Systems, Inc. Code of Business Conduct
45
Connect
with the
Code...
• Obtain authorization before
using third-party copyrighted
material.
• Follow Cisco policies for
export, reexport, and transfer
of controlled technology,
operational data, products,
and other technology.
• Comply with customs laws,
regulations, and policies for
shipping.
• Comply with local data
protection laws, regulations,
and policies for handling of
personal information.
in a company-authorized offsite location, or secured in onsite file cabinets or access-controlled
file rooms. They should not be kept on bookshelves or your cubicle countertop. Proper storage
helps prevent records from being lost, inadvertently destroyed, or made available to unauthorized
persons, thus limiting the impact of intellectual property loss.
Be sure that you have authorization before you use third-party copyrighted
material.
It is against Cisco policy - and, in fact, may be unlawful - to copy, reproduce, digitize, distribute,
broadcast, use, or modify third-party copyrighted material in the development or as part of Cisco
products, promotional materials, written communications, and blogs and other social media,
unless you first obtain written permission from the copyright holder. Third-party copyrighted
material can cover written works, diagrams, drawings, images, video, music, software, and audio
recordings, whether it be the entire work or just portions of it. Additionally, third-party copyright
protection can extend to such materials whether or not they bear copyright notices. This
requirement may apply regardless of whether the end product is for personal use, Cisco internal
use, or other use. It is also against our policy for employees to use Cisco facilities, equipment, and
networks to make, obtain or distribute unauthorized copies of third-party copyrighted material
(including acquiring or sharing third party movies, TV programs, software and music through the
internet and peer-to-peer sites). Improper use of copyrighted material can subject both Cisco
and the individual(s) involved to possible civil and criminal actions. If you have questions, please
contact Legal.
Many countries have implemented, or are planning to implement, privacy or
personal data (any information that can be used to identify, contact, or locate an
individual) protection laws that set requirements for the appropriate collection
and handling of personal data.
We respect privacy and are committed to protecting the reasonable privacy expectations of
everyone with whom we do business with, including our customers, consumers, visitors to our
websites, and employees. As part of your work, you may have access to personal data, or this data
may be hosted with a third party. It is important that you access, use, or share such data only to
Cisco Systems, Inc. Code of Business Conduct
46
the extent necessary to fulfill your assigned job responsibilities and in accordance Cisco privacy
and information security policies as well as local laws and regulations.
We believe that responsible safeguarding of personal data, especially sensitive personal
information, is a critical component in building and maintaining trust in the Cisco brand. Therefore,
we each have a responsibility to collect only personal information that is relevant and necessary,
and to safeguard, and appropriately use, the personal data in our possession or under our control.
When questions, issues, or concerns arise, consult the Privacy Team.
All employees are responsible for abiding by export laws.
The Global Export Trade (GET) group directs and counsels all parties involved in Cisco’s Exports.
Its goal is to facilitate and expedite worldwide trade in the most effective and efficient manner by
proactively observing all international rules and regulations regarding export.
Each Cisco employee is responsible for safeguarding Cisco’s design, development, and
production technology (“controlled technology”) to prevent unauthorized access by nationals
of countries that are subject to export controls. Employees may not electronically, verbally, or
physically transfer controlled technology to individuals in or from these countries unless they
obtain written authorization from Cisco’s GET group. Nondisclosure agreements do not constitute
“written authorization.”
Cisco products, software and technology are subject to the export, re-export, and transfer
restrictions. Cisco products, software and technology may be exported or re-exported to most
civilian/commercial end users located in all territories except the embargoed destinations and
countries designated as supporting terrorist activities.
Contact the GET group if you know or have reason to believe that a party (including partners,
users, or employees) has or intends to violate U.S. or local country laws or regulations as they
relate to export, re-export, or transfer issues.
We comply fully with customs laws, regulations, and policies.
Accurate customs information on shipping documents is required for all international shipments.
Employees must not initiate shipping documents outside of the approved, automated shipping
systems or nonproduction shipping tool.
Cisco Systems, Inc. Code of Business Conduct
47
We exercise our legal rights when necessary.
Cisco reserves the right to contact legal authorities when there is a reasonable belief that a crime
has been committed by a current or former employee connected to the Cisco workplace.
What if...
What if I become aware of Cisco’s quarterly earnings release results before
they have been publicly announced? May I purchase company stock, knowing
that information?
No. This information would be considered material, nonpublic information, and the purchase of
Cisco stock would be a violation of Cisco policy and a potential violation of federal securities laws.
You may purchase company stock only after such information is made known to the public.
My organization reviewed a pitch by one of our vendors about a new product
that it plans to introduce on the market soon. We agreed that the product
would not be useful for Cisco, but I think it will be a real breakthrough for other
industries and will increase the vendor’s stock price. What if I want to buy stock
in the vendor’s company? Does that violate Cisco’s policy on insider trading?
Yes, it does. You may not buy this stock until information about the new product is known to the
public. The fact that the new product is not significant to Cisco is irrelevant; what is relevant is
that you have information about the new product (and its potential impact on the earnings of the
vendor) that the general public does not yet have.
What if Cisco offers me a stock option that allows me to buy Cisco stock at a
good price? Am I limited by the insider trading policy as to when I can exercise
the option?
Open market trading (buys or sells), including shares acquired upon exercise of stock options,
may not be made while you possess material, nonpublic information. However, if you wish to
exercise stock options, you may do so with a cash payment without the concurrent sale of the
Cisco Systems, Inc. Code of Business Conduct
48
purchased shares. If the stock option is being exercised in connection with a same-day sale
program or other concurrent sale of Cisco stock, the exercise and sale must occur while you are
not in possession of material, nonpublic information.
What if I am forced to make a decision between obeying a local law or
complying with the COBC?
The law always takes precedence over the COBC, but if in doubt, check with the Ethics Office or
Legal for help.
Cisco Systems, Inc. Code of Business Conduct
49
I Am Accurate and Ethical
with Our Finances
As an employee of Cisco, I have an obligation to promote integrity
throughout the organization, with responsibilities to stakeholders inside
and outside of Cisco. There are also special ethical obligations that apply to
employees with financial reporting responsibilities.
Cisco Says...
Connect
with the
Code...
• All employees must adhere
to financial policies
• The Cisco CEO, CFO and
Finance Department must
comply with the Cisco
Financial Officer Code of
Ethics
Cisco Systems, Inc. Code of Business Conduct
All Cisco employees must adhere to all internal financial and accounting
policies.
The timely and accurate handling and reporting of financial information is not only required by
law, but it is also at the core of our commitment to our stakeholders to do business honestly and
ethically.
Financial policies which must be followed include the Global Bookings Policy which defines
criteria that must be met before sales transactions can be recorded as booked. Exceptions to and
deviations from revenue recognition controls must be approved by the appropriate governing
body. Violations of these controls, such as with unauthorized side commitments or “soft” or
“invalid” bookings, are a serious matter.
All Cisco employees must be aware of the financial policies within their job responsibilities. Seek
help if you have any questions about a financial policy.
50
Connect
with the
Code...
• Report violations of financial
policies and the Financial
Officer Code of Ethics
promptly.
Special Ethics Obligations for Employees with Financial Reporting
Responsibilities
Our CEO, CFO and Finance Department employees have a special responsibility. These
individuals must adhere to the following principles and also foster a culture throughout the
company as a whole that helps to ensure the fair and timely reporting of Cisco’s financial results
and condition. Because of their special role, the CEO, CFO and all members of the Cisco Finance
Department in particular are bound by the following Financial Officer Code of Ethics, and each
agrees that he or she will, in his or her capacity as an employee of Cisco:
• Act with honesty and integrity, avoiding actual or apparent conflicts of interest in personal and
professional relationships.
• Provide information that is accurate, complete, objective, relevant, timely, and understandable
to help ensure full, fair, accurate, timely, and understandable disclosure in reports and
documents that Cisco files with, or submits to, governmental agencies and in other public
communications.
• Comply with the rules and regulations of federal, state, provincial, and local governments, and
of other appropriate private and public regulatory agencies
• Act in good faith, responsibly, and with due care, competence, and diligence, without
misrepresenting material facts or allowing his or her independent judgment to be subordinated
• Respect the confidentiality of information acquired in the course of doing his or her work,
except when authorized or otherwise legally obligated to disclose information; confidential
information acquired in the course of his or her work will not be used for personal advantage
• Share knowledge and maintain skills important and relevant to stakeholders’ needs
• Proactively promote and be an example of ethical behavior as a responsible partner among
peers, in the work environment and the community
• Achieve responsible use of and control over all assets and resources employed by or
entrusted to him or her
• Promptly report to the Vice President of the Governance, Risk, and Controls (GRC) Group and/
or the chairman of the Audit Committee any conduct that they believe to be a violation of law
or business ethics or of any provision of the COBC, including transactions or relationships that
Cisco Systems, Inc. Code of Business Conduct
51
reasonably could be expected to give rise to such a conflict
Violations of the Financial Officer Code of Ethics are serious. A violation, including a failure
to report potential violations by others, will be viewed as a severe disciplinary matter and may
result in personnel action, including termination of employment. If you believe that a violation of
the Financial Officer Code of Ethics has occurred, please contact Cisco Legal, the Ethics Office,
or the Audit Committee of the Board of Directors. Remember, it is against Cisco policy to retaliate
against an employee for good-faith reporting of any potential or actual code violations.
What if...
What if my manager is exerting pressure to “make the numbers work”?
Your responsibility is to be honest and accurate. If you feel pressured to do otherwise, speak with
someone in the Ethics Office or consult with Legal or Human Resources. You may also contact
the Audit Committee of the Board of Directors. If you feel uncomfortable going through internal
channels, you can call the Cisco EthicsLine anytime, night or day.
Cisco Systems, Inc. Code of Business Conduct
52
Resources to Make the Ethics Connection
Cisco has many resources available to help you in ethical situations. Make the ethics connection by referring to
these resources to obtain detailed information or to ask a question or report a concern.
Report Ethical Concerns
Cisco Investor Relations Team
Cisco Ethics Office
Cisco Corporate Public Relations
[email protected]
Cisco Audit Committee of the Board of Directors
Cisco EthicsLine
Email: [email protected]
Visit the EthicsLine webpage for country-specific dialing information
and guidelines on how to speak up about suspected violations of the
COBC.
Regular Mail: Cisco Systems, Audit Committee
Cisco Policy Central
Ethics Resources for Managers
Cisco Human Resources
Global Public Sector Compliance Office
105 Serra Way, PMB #112
Milpitas, CA 95035
Cisco Information Security and Corporate Security Programs
Organization
[email protected]
We welcome input on any aspect of the Code of Business Conduct.
Please send email comments to: [email protected]
[email protected]
Cisco General Counsel
[email protected]
We welcome input on any aspect of the Code of Business Conduct. Please send email comments to: [email protected]
Cisco Systems, Inc. Code of Business Conduct
53
© 2007, 2009, 2010, 2011 Cisco Systems, Inc. All rights reserved. Cisco, the Cisco logo, Cisco Systems, and the Cisco
Systems logo are trademarks or registered trademarks of Cisco Systems, Inc. and/or its affiliates in the United States
and certain other countries. All other trademarks mentioned in this document or Website are the property of their
respective owners. The use of the word partner does not imply a partnership relationship between Cisco and any
other company. (0812R)