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IBM Business Conduct Guidelines

Business Conduct Guidelines IBM Business Conduct Guidelines1 ContentsLetter from the Chairman Guiding Principles Commitment to Integrity and Business Ethics Using the Business Conduct Guidelines Importance of Compliance Speaking Up Raising Concerns and Reporting Violations Non-Retaliation Policy In the Work pl ac e Work Environment IBM s Information and Property Proprietary and Confidential Information Inadvertent Disclosure External Inquiries and Contacts Intellectual Property IBM Intellectual Property Third Party Software Open Source Software Trademarks External Standards Organizations Use of IBM Assets and Premises IBM s Right to Access and Use Leaving IBM IBM s Handling of Your Personal Information Making Commitments and Obtaining Approvals Reporting, Recording and Retaining Information Financial Controls and Reporting Retaining Records In the Marketplace Working with Organizations Outside of IBM Working with Suppliers Working with Resellers and Other Complementary Third Parties Working with Competitors IBM Business Conduct Competing Fairly Statements About Competitors Selling Against Competitive Orders Acquiring and Using Information Information About Others Personal Information About Individuals Proprietary and Confidential Information Owned by Others Gifts, Amenities and Bribes Receiving

IBM Business Conduct Guidelines 4 2.0 Speaking Up 3.0 In the Workplace 4.0 In the Marketplace 5.0 On Your Own Time 6.0 Further Guidance 1.0 Guiding Principles

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