Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
Contents 3
TABLE OF CONTENTS
Click for BS&P Resource Guide Click for Appendix – Giving and Receiving Gifts Click for Appendix – Prevention of Improper
and Entertainment Policy Payments Policy
5
1 ACTING WITH INTEGRITY:
THE PURPOSE BEHIND OUR CODE
BS&P SECTION CONTACT(S)
Continuing Our Legacy of Trust Access the Resource Guide for team info
• Integrity & Compliance Office
/ Live Our Code
From the start, BlackBerry showed We must all follow our Code of Business Standards You must review, understand and comply with the
the world that we could safeguard and Principles (the “BS&P”). But it is more than BS&P and all relevant policies and procedures.
and securely deliver e-mail to our just a set of rules and guidelines. It is a reflection You are required, as a condition of employment,
customers, and committed ourselves to of who we are as a company. to complete all assigned training and annually
conducting business with integrity. As acknowledge that you will comply. If you have
a result, customers know us for secure Know What Is Expected of You
questions, you must seek clarification.
communication and reliable business The BS&P is a statement of principles designed to
dealings marked by honesty and respect. help us do our jobs in a legal and ethical manner. Choose Integrity
It is why they choose BlackBerry. We You can rely on it for guidance about what it means Our success depends on your commitment to
do the right thing every day to build this to conduct BlackBerry business with integrity. integrity. Be honest, fair and trustworthy. Select
reputation. It is our legacy of trust. The BS&P does not address every situation or ethical business partners who share our commitment
rule; instead, it outlines expected behaviors and to integrity.
illustrates examples of how you must take Never compromise on integrity. There is no excuse
personal responsibility. If you violate the BS&P or for cutting corners when it comes to this, no matter
other policies, you are subject to disciplinary action what the situation is. No one can make you act
up to and including termination of employment. unethically, unlawfully, or in a way that contradicts the
letter and spirit of the BS&P or our policies.
Contents 7
Make Decisions with Integrity
It is your responsibility to exercise good judgment and act ethically. The diagram below provides guidance
on ethical decision-making when you are unsure. If you can answer “no” to all the following questions, then
the decision to move forward is probably appropriate. If you answer “yes” to any question or continue to
be unsure, then stop and seek appropriate guidance from your manager, Human Resources, Legal, or the
Integrity & Compliance Office if you would like to proceed.
Is it illegal?
Is it unethical or in violation of
Does it violate any applicable the BS&P?
law or regulation? Could it harm the company or others?
Is it dishonest or untrustworthy?
Is it otherwise inconsistent
Does it put BlackBerry or me in a compromised position?
with BlackBerry’s values, BS&P or
other policies? Does it create a conflict of interest between BlackBerry and my personal affairs?
Would it be improper for me to act Does it jeopardize workplace safety or the environment?
or fail to act?
Does it disrespect any work colleague, customer, business partner or
community?
Contents 9
Q: How can I have a say in Q: Why are certain written disclosures
the Integrity & Compliance and approvals required?
program? A: Written disclosure and approval is required for Improper Payments
A: Here are a few ways that you can activities that are high risk and can often benefit from
• In addition, keep in mind, speaking publicly for
provide your ideas and suggestions: the guidance of someone with specialized expertise
BlackBerry is the job of individuals designated
about the law or application of BlackBerry policies,
• Discuss them with your manager, in our Corporate Disclosure Policy. You must
in addition to a manager’s oversight. Disclosures
Human Resources or the Integrity not respond to questions about BlackBerry,
provide documentation that is useful in any internal
& Compliance Office. even informally, from the investment community
or external investigation that may occur later.
• Comment on integrity messages (including financial analysts and investors),
In addition, criminal sentencing guidelines and
posted to BlackBerry Square. regulators and the media, without proper
industry best practices dictate that we document
• Submit them on BlackBerry Ideas, authorization. See Remember that We Speak
a portal for providing ideas about all our integrity and compliance activities.
with One Clear Voice
aspects of BlackBerry (go/ideas). Here are routine activities that require disclosure and
• You have an obligation to disclose to BlackBerry
proper written approval before they can proceed:
in writing any development of IP. This includes
Q: A vendor just called and • Engaging in something that poses an actual or any IP that you develop and believe should
claims that under a certain potential conflict of interest, such as starting a be considered an “excluded development”
law we are responsible for a business, hiring afamily member to do work for that does not belong to BlackBerry. See
problem that must be remedied BlackBerry, or investing in a supplier BlackBerry Understand the Implications of Intellectual
quickly. What do I do? uses. See Avoid Conflict of Interest Situations Property Rights and Developments
A: Legal furnishes advice on all legal
• Requesting a waiver of BS&P requirements. See
issues arising in the course of your
• Giving or receiving anything of value to or from a Waivers Must Be Provided in Writing
BlackBerry work, including advising
public official, including giving a device or other
on legal claims that third parties make. Please refer to the BS&P for more information about
BlackBerry product.
Information on the various legal teams the requirements for engaging in these activities and
and contact information can be found • Giving a gift valued at more than $50. others that require disclosures. Disclosures for written
at go/legal. approval can be made as directed in the BS&P or at
• Retaining or hiring a third party to represent
integrity@blackberry.com.
BlackBerry before any government or to
distribute or sell BlackBerry products and
services. See Do Not Allow Bribes or Other
BlackBerry Managers Have Access the Resource Guide for team info
• Integrity & Compliance Office
Additional Responsibilities
Managers at all levels are expected to lead Make Integrity Central to Your Leadership Keep ethical behaviors in mind when interviewing
through example. As a manager, you have a special Make sure your team members are familiar with candidates. Seek individuals who exhibit a
responsibility to lead with integrity. You must do the BS&P and the laws and policies that apply to commitment to integrity.
more than behave legally and ethically yourself. your team.
Dedicate yourself to making sure that your team
members do as well. This requires affirmative, Complete required compliance training,
visible steps on your part. conscientiously and on time, and ensure that
your team members do too.
Lead with Integrity
Show your team lawful behavior. Show them ethics. Cultivate Integrity
Act with unyielding commitment to integrity day-in An important part of maintaining an ethical culture
and day-out. Speak truthfully always. Never abandon is promoting an environment in which your team
our standards and principles. Stay faithful to our members are comfortable asking questions and
culture of integrity – our legacy of trust. raising concerns about potentially unethical behavior.
Set the right tone from the top. Listen to concerns Create this environment. Strive to have your team
and respond. Discuss how to make good choices members regularly bring you their concerns. Answer
in the face of the challenges your team faces. their questions. Remediate or, as necessary, escalate
Instill in your team a belief that conducting identified issues. Ensure activities and disclosures
business with integrity is our only path to receive the appropriate review and approvals.
success. Seek opportunities to explain the serious Never retaliate or tolerate retaliation against anyone
consequences that arise from cutting corners who in good faith reports a concern or cooperates
when it comes to integrity. with a BlackBerry investigation or audit.
Contents 11
Reward Integrity Q: We have company-wide policies, so why do I have a managerial
Recognize and encourage ethical conduct. Call out responsibility to implement my own processes and controls?
situations where integrity won the day – prevented A: The requirement is that you manage the time to discuss the challenges that your
financial loss, protected or built our reputation, or activities of your team to deliver against team faces as it conducts business with
avoided other serious consequences. your team objectives and prevent fraud, integrity, perhaps during a monthly team
corruption and other violations of the BS&P meeting.
Do Not Tolerate Behavior Lacking Integrity or the law.
Please contact the Integrity & Compliance
You have a special responsibility to report illegal
The BS&P does not cover every situation Office if you would like assistance or
behavior and violations of the BS&P. You must
or spell out each specific process or suggestions.
stop misconduct with quick, appropriate action.
control your team must follow to promote
You must inform your manager or the appropriate
lawfulness and integrity. Determine the legal
representative of Legal, Human Resources, Finance
and ethical risks your team faces and then
or the Integrity & Compliance Office of potential
develop ways to address them. Identify and
breaches that you observe or have reported to you.
capture the information and reporting that
will allow you to monitor compliance with
Closely Manage Spending
your requirements, and set aside a regular
As a manager, you are responsible for the money
spent and expenses incurred by your reports. You
must fully understand the Management Approval
Process (“MAP”) and assure your team does as well.
You must carefully review such spend and expenses
before approving. If you don’t understand what you
are approving or do not have complete information,
don’t approve. Get the information you need or seek
help.
Actively Seek Guidance and Access the Resource Guide for team info • EthicsLink
• Integrity & Compliance Office
Report Concerns
We Respect Confidentiality • Your manager/team-lead or senior managers using BlackBerry EthicsLink. A team will conduct an
If you report a concern, we will keep your identity (usually the best place to start) investigation, using the portal to provide the reporter
with updates on the case and to ask for further
confidential to the extent possible consistent with • Your Human Resources Business Partner
information. The reporter can access the case details
law and the need to investigate.
• Legal (legal@blackberry.com or refer to go/ at any time accessing www.BlackBerryEthicsLink.
legal for a resource) com and selecting “Follow-up on a report.
Retaliation Is Not Tolerated
• Finance BlackBerry EthicsLink is available 24 Horus a day,
Retaliating against anyone who makes a good faith seven days a week, and provides multiple ways to
report of suspected unethical or illegal conduct is • Integrity & Compliance Office (integrity@
report concerns or questions:
a violation of the BS&P and will not be tolerated by blackberry.com)
Online
BlackBerry. The same is true of anyone participating • BlackBerry EthicsLink (see next below)
Concerns can be logged at
in the investigation of a report. It does not matter
You should take care to not report a violation to www.BlackBerryEthicsLink.com.
whether the specific circumstances reported actually
someone that you believe may be involved in the
amount to misconduct. Phone
matter.
Call 1 (877) 281-5509 if you prefer phone.
There Are Multiple Ways to Raise Issues This is a toll free number for Canada and
BlackBerry EthicsLink
and Ask Questions the United States. For other countries, visit
You can make reports of any type of ethics or
www.BlackBerryEthicsLink.com for toll
You can turn to any of the following resources with compliance concern directly to the Audit Committee
free dialing instructions in your region.
questions or concerns: of the Board and the Integrity & Compliance Office
Contents 14
Q: How can I learn more about Q: I have loyalty to my team. Won’t Q: How can I find someone to help me
the results of investigations? making a report disrupt our work? with an issue I’ve never encountered
A: You should not factor potential disruption into before?
A: Follow messaging on BlackBerry
Square about integrity and policies. your decision of whether to report. Ask yourself A: The BS&P Resource Guide identifies internal
Many of these messages are the whether a wrongdoer deserves that you turn a blind stakeholders and experts in particular areas, as well
result of investigation findings and eye, sacrificing your and the Company’s integrity. as places to find procedure and policy information.
recommendations. If you make a report The financial losses, reputation damage, and serious But don’t worry so much about finding the right
and use BlackBerry EthicsLink, you will legal consequences of ongoing wrongful behavior person on your own; any of the resources identified
receive update information from the would be vastly more disruptive to BlackBerry and here can help send you in the right direction, whether
investigation team. your team than a report and subsequent efforts it is your manager, Human Resources, Legal, Finance
to address ethical concerns and gaps in our or Integrity & Compliance.
procedures.
Q: Confidentiality is protected
“to the extent consistent with
law and the need to
investigate.” What does that
mean to me if I make a report?
A: We will rigorously protect your
confidentiality, only disclosing a
reporter’s identity when absolutely
necessary, such as if we are compelled
by law.
16
3 PERFORMING WITH INTEGRITY
FOR BLACKBERRY
BS&P SECTION CONTACT(S) POLICY OR PROCEDURE
Protect BlackBerry’s Assets Access the Resource Guide for team info • BlackBerry Corporate Security Policy
• Security • BlackBerry Acceptable Use Policy
and Information
• Privacy
Make Appropriate Use of BlackBerry Assets • Other trade secrets. with your work or overburden BlackBerry systems.
BlackBerry assets and information are valuable This includes a prohibition on using BlackBerry
Our assets also include physical property, like:
resources intended to make our performance more assets in support of outside business, political or
• Cash. charitable interests. You must never use BlackBerry
efficient. It is important that we protect these assets
and never allow our personal use of them to interfere • Equipment. assets to access or share information inappropriate
with our job responsibilities. BlackBerry assets for a workplace setting. This includes content of a
• Facilities. sexual nature, inappropriate or derogatory humor, or
include:
• Supplies. discriminatory or harassing comments.
• Intellectual property.
• Product inventory.
• Confidential and proprietary information, Expect Monitoring of BlackBerry Assets
including personal information or data of and Systems
customers that was provided to BlackBerry in Only Legitimate Business Use Is Permitted
Where allowed by local law, our Company may
confidence. BlackBerry assets and information should only monitor your use of any BlackBerry assets to ensure
• Sales, marketing and other business strategies be used for legitimate, lawful, business purposes. it is in line with the principles set forth in the BS&P.
and plans. Limited personal use of assets such as BlackBerry® BlackBerry assets include computers, tablets, or
smartphones, company e-mail or Internet company provided or subsidized mobile devices,
• Financial data. connections is permitted. However, you must limit and includes any e-mail, including personal e-mail,
• Technology and software. such personal use, and cannot allow it to interfere sent to or from a BlackBerry server.
Contents 18
Q: Why does BlackBerry monitor
telephones, printers, desktop or laptop
computers, tablets and smartphones?
A: Laws or legal processes may require BlackBerry
to preserve, search or access information from
BlackBerry systems (for example, to conduct
compliance investigations, to address misconduct or
misuse of BlackBerry systems, or to respond to court
orders, warrants or other lawful requests or legal
processes). BlackBerry systems may also be subject
to ongoing maintenance and scanning to ensure they
are operating properly, to promote safety and protect
the integrity and security of the information, and to
ensure continuity of business operations.
Contents 20
BS&P SECTION CONTACT(S) POLICY OR PROCEDURE
Do Not Disclose BlackBerry Access the Resource Guide for team info • BlackBerry Information Classification Policy
• Security
Confidential Information
• Non-Disclosure Agreement Team
Much of the information available to you as a Avoid Inadvertent Disclosure • There is a signed and valid non-disclosure
BlackBerry employee is confidential or proprietary. You must be extremely careful to avoid disclosure of agreement in place (be sure to follow the
This is information not generally available to the BlackBerry’s confidential or proprietary information. instructions on go/nda for completing and
public, which includes BlackBerry technical You should not discuss such information in public then submitting the original signed copy of the
information, business and marketing data and places where others may overhear you, or on agreement to the NDA Mailbox).
plans, financial data, internal e-mail communications, blogs or social media networks. You must never • You have marked the documents disclosed as
information about customers, product information leave it unattended.
“BlackBerry Confidential”.
and any other information generally considered
confidential in our industry. If you fail to properly Intentional Disclosure Must Be Authorized
protect and secure BlackBerry confidential or Report “Leaks” Immediately
You must exercise extreme caution before
proprietary information, you could be subject to intentionally disclosing any confidential or proprietary You must immediately report any unauthorized
discipline up to and including termination. If you have information. When disclosing such information within disclosure of BlackBerry confidential or proprietary
any questions on whether information is confidential BlackBerry, you should be sure you are authorized information – even inadvertent – and other
or proprietary, or how to protect it, you should to do so and then only share it with colleagues who security incidents to Corporate Security, as well
consult your manager or Corporate Security. truly need to know the information to do their jobs. as your manager.
You should not disclose confidential or proprietary
Note: Nothing in this BS&P, or any other information to anyone outside of BlackBerry unless This Is a Lasting Obligation
BlackBerry policy, is meant to preclude all of the following are met: Your obligation to safeguard BlackBerry confidential
or discourage you from lawfully reporting • You have obtained your manager’s approval or or proprietary information continues after you are
violations of law or instances of fraud, waste, or already have the authority to do so. no longer a BlackBerry employee. You may never
abuse, to appropriate government authorities
• The disclosure is limited only to such disclose BlackBerry confidential or proprietary
or law enforcement agencies.
information as is necessary to fulfill BlackBerry’s information after you leave, unless you have
particular business purpose. BlackBerry’s consent to do so.
Contents 22
BS&P SECTION CONTACT(S) POLICY OR PROCEDURE
Protect and Respect Access the Resource Guide for team info • BlackBerry Employee/Consultant Confidentiality
• Integrity & Compliance Office (for excluded and Intellectual Property Agreement
Intellectual Property Rights development disclosures) • BlackBerry Open Source Software Policy
and Open Source Software • Your Human Resources Business Partner
• Open Source Team
Understand the Implications of Intellectual you develop and believe should be considered
Property Rights and Developments an “excluded development” that does not belong
Among our most valuable assets is our intellectual to BlackBerry. If you would like to make a written
property (“IP”)—inventions, patents, trade secrets, disclosure, have any questions about the use and
trademarks, copyrights, design rights, know- disclosure of BlackBerry’s and third parties’ IP or
how and other proprietary information. You are have questions relating to “excluded developments”,
accountable to establish, protect, maintain and contact the Integrity & Compliance Office.
defend BlackBerry’s rights in all commercially
significant intellectual property and to use those Be Compliant in Open Source Development
rights in responsible ways. Open source software is free of charge and made
You must likewise respect the valid, exclusive IP available as source code, but under licenses that
rights or copyrighted materials of third parties. impose certain legal obligations. Non-compliant
use of open source software can have significant
As part of the BlackBerry Employee/Consultant
Confidentiality and Intellectual Property consequences for BlackBerry, our suppliers, our
Agreement you previously signed or acknowledged, distributors and even our customers. Prior to using,
virtually all IP developed in the course of your modifying or distributing open source software,
employment belongs to BlackBerry. You also have you must obtain approval in accordance with the
an obligation to disclose to BlackBerry in writing BlackBerry Open Source Software Policy.
any development of IP. This includes any IP that
Contents 24
BS&P SECTION CONTACT(S) POLICY OR PROCEDURE
Avoid Conflict of Access the Resource Guide for team info • Giving and Receiving Gifts and Entertainment
• Integrity & Compliance Office (for conflict of Policy
Interest Situations interest disclosures) • Travel & Expense Policy
• Your Human Resources Business Partner
Performing with integrity for BlackBerry means Outside Activities Cannot Compete or • Use BlackBerry assets, facilities, services or
acting in BlackBerry’s best interests and avoiding any Interfere with Your Work resources, including BlackBerry IP, confidential
situation where you could be said to have divided Outside activities, such as participating on a board of or proprietary information or your time during
loyalty or to be using your position at BlackBerry to directors or advisory board, conducting an outside the work day, on your outside activities.
obtain favorable treatment for yourself or someone business or engaging in part-time employment while • Use your position at BlackBerry to gain an
close to you. working in your current position at BlackBerry should advantage in your outside activities.
not interfere with the work you do for BlackBerry. • Place yourself in a position where your outside
You must avoid any situation that creates even the
You may not work or engage in business for a interests could place you or a product, service
appearance of a conflict of interest, unless and until
different company or entity – with or without or business on which you are working in
you have made full written disclosure of all facts and
compensation – unless you receive a properly competition with BlackBerry.
circumstances, and obtained the written approval
described below. authorized exception in writing as described below.
Do Not Take Personal Advantage of
A volunteer role for a charitable organization only
The following sections outline some of the more Corporate Opportunities
needs to be disclosed and approved as described
common situations where a conflict may arise, You must never take personal advantage of a
below if the activity will infringe on company time or
how to determine whether you need to disclose business or investment opportunity that you become
pose any other conflict of interest (such as accepting
a potential conflict, and how to make a written aware of that could benefit BlackBerry. You must
a duty of loyalty to a board of directors for a non-
disclosure. When in doubt, ask for guidance. obtain written approval as described below before
profit organization).
acting on such an opportunity yourself. Unless and
In addition, even if you have disclosed the outside until BlackBerry has been able to evaluate such an
activity and received approval to proceed, you may opportunity and has chosen not to pursue it, you
not: must avoid it.
Contents 28
4 TREATING OUR CUSTOMERS AND BUSINESS
PARTNERS WITH INTEGRITY
BS&P SECTION CONTACT(S) POLICY OR PROCEDURE
Do Not Allow Bribes or Other Access the Resource Guide for team info • Prevention of Improper Payments Policy
• Integrity & Compliance Office • Giving and Receiving Gifts and Entertainment
Improper Payments Policy
• Providing BlackBerry Products to Public Officials
Policy (covers device and software seeding)
• Providing BlackBerry Products to a Third Party
Who is Not a Public Official Policy (covers device
and software seeding)
BlackBerry competes in the marketplace through as elected officials, appointed officials and civil to maintain accurate books and records, as well as
the quality of our products, the skills of our people servants. a system of internal controls designed to detect and
and our ability to provide goods and services prevent improper payments.
Our retention and use of third parties who represent
at competitive prices. You must comply with all
us or perform services on our behalf creates For more detailed information about BlackBerry’s
applicable anticorruption laws. You may never make,
significant anticorruption risk, especially where the policy regarding anticorruption compliance, please
promise, offer, fund or authorize a bribe, kickback,
third party interacts with public officials. You must refer to the Prevention of Improper Payments Policy.
facilitation payment or other improper payment in
seek guidance and obtain written approval from
connection with BlackBerry’s business with a public
the Integrity & Compliance Office before retaining or
official, government entity or any other third party.
hiring a third party to represent BlackBerry before
A “public official” is interpreted broadly and includes any government or to distribute or sell BlackBerry
anyone serving in or employed by a national, state, products or services.
provincial or local government body or agency, such
BlackBerry is required by relevant anticorruption laws
Adhere to Competition Laws Access the Resource Guide for team info
• Integrity & Compliance Office
Contents 30
Q: I am attending an industry conference on behalf of BlackBerry, and have
met up with an old college friend who now works for a major competitor. My
friend has told me that if BlackBerry charges a certain price for its newest
Enterprise software product, she will ensure her company charges the same
price for its competing product. I know I can’t agree to this, but I am not sure
what I should do in this situation. What actions should I take?
A: First, you must make it very clear to your friend that you will have nothing to do with this
discussion. Price-fixing is an anti-competitive topic, even the discussion of which could lead to
serious consequences for you and BlackBerry – as well as for your friend and her company. Then,
you must promptly report the incident to the Legal Department or Integrity & Compliance Office.
31 Contents
BS&P SECTION CONTACT(S)
Participate in the Larger Access the Resource Guide for team info
• Integrity & Compliance Office
Security and Software
Community
As a security software technology leader, BlackBerry associations and technology standards bodies that
possesses a unique perspective and valuable seek to drive innovation and promote access to our
expertise. We exchange ideas and knowledge with technologies for people across the globe. In doing
our stakeholders and other industry participants, so, we abide by competition laws. See Adhere to
where appropriate. This includes actively engaging Competition Laws
with regulatory bodies and participating in industry
Market Our Products Access the Resource Guide for team info
• Marketing
with Integrity
Contents 32
BS&P SECTION CONTACT(S)
Comply with International Trade Control Access the Resource Guide for team info
• International Trade Controls
Laws and Regulations
As a global company, BlackBerry is subject to and another BlackBerry location. Imports may require
complies with numerous trade control laws and the payment of duties and taxes, as well as the
regulations governing the export and import of submission of certain filings and receipt of import
hardware, software, services and technology. authorizations such as a license, permit or other
approval.
Export and Import Controls
Generally speaking, BlackBerry hardware, software Economic Sanctions and Other Trade
and technology that contain or make use of Restrictions
encryption may be subject to export control unless From time to time, governments use economic
an exclusion or exception applies. sanctions and other restrictions to further various
foreign policy and national security objectives.
An “export” can occur through physical delivery, Economic sanctions are directed towards specific
e-mail, download or other transmission of a product, countries and/or specific end-users. Any appropriate
software or technology from one country to another. screening must be completed prior to an export.
Transferring software, services or technology to
Any requisite licenses and permits for items
a citizen of another country, regardless of where subject to export control must be obtained and
the person is located, may also be deemed an any appropriate destination country and/or end-
export. Where the item is subject to export control, user screening must be completed prior to an
BlackBerry must obtain a license or a permit or be export. If you are unsure whether a transaction is
able to rely on another export authorization prior to in compliance with all applicable trade control laws
an export. and regulations, contact the Legal Department by
An “import” is the transfer of goods into a country sending an email to
ExportControls@blackberry.com prior to
through physical or intangible means from a
export.
foreign or external source, which can include
Contents 34
BS&P SECTION CONTACT(S)
Money Laundering and Access the Resource Guide for team info
• Integrity & Compliance Office
Terrorist Financing
BlackBerry maintains contract review policies and use of our technology for illicit or illegal purposes.
procedures to guard against money laundering, a Only do business with reputable customers and
process whereby transactions with a legitimate vendors, and never provide inaccurate information
business are used to conceal funds generated by about our business partner and potential business
illegal activities to make them appear to be legitimate. partners.
This may include: terrorist financing; and the potential
Red Flags
You have an obligation to report unusual or characteristics for the proposed transaction. documentation or requests for information that
suspicious activities or transactions that could • Unusual transaction structure, including overly does not seem related to the transaction.
indicate improper conduct. Be on the lookout for complex or unnecessary routing. • Involvement of unnamed parties or undisclosed
the following, which could indicate a potential trade locations.
• Requests that an inaccurate monetary value or
control, money laundering or improper financing product description be applied to a shipment or • Resistance to correcting inaccurate or
issue: provision of goods or services. incomplete documentation.
• customer or vendor seeking to make an
A • Reluctance or refusal to respond to reasonable Seek guidance from the Legal Department or the
abnormal payment such as a large payment in requests for information about the distribution Integrity & Compliance Office if you encounter
cash, through someone outside the transaction chain, end users, intermediate consignees or such “red flags.”
or via unusual accounts or sources of financing. delivery locations.
• A new customer with questionable • Questionable requests surrounding
Comply with All Government Access the Resource Guide for team info • Prevention of Improper Payments Policy
• Integrity & Compliance Office • Providing BlackBerry Products to Public
Contracting Requirements Officials Policy
• Giving and Receiving Gifts and Entertainment
Policy
Contents 36
Q: During a recent meeting Q: BlackBerry recently submitted a bid on a procurement by a government
with my contact at a agency. Would it be permissible for the sales representative primarily
government customer, the responsible for the account to pay for a lunch with his counterpart at the
agency representative offered agency?
to disclose information about
A: Even if the agency otherwise permits a vendor agency official could be construed as an effort
a competitor’s bid on an active to improperly influence the bidding process.
to pay for a business lunch, the agency’s rules
procurement. applicable to the bidding and vendor selection The sales representative must obtain advance
Can I obtain that information process may limit the type or amount of contact approval from the Integrity & Compliance Office
and use it to improve BlackBerry can have with agency representatives before paying for any meal of, or providing
BlackBerry’s bid on the same during the active procurement process. The any other thing of value such as a gift or
procurement? fact that BlackBerry does have a bid pending entertainment to, any government official.
A: No. We cannot seek confidential with the agency heightens the risk that its
information about a government provision of a thing of value such as a meal to an
procurement—or any other
procurement for that matter—where
we know or have reason to believe Q: It appears that certain documentation submitted to a government customer
disclosure of the information is not
by a subcontractor is not accurate. Do I have an obligation to report this matter
authorized. This includes information
internally, to the subcontractor or to the customer?
internal to the government or relating
to a competitor such as bid, proposal
or pricing information. You must A: Whether the inaccuracy is erroneous
contact the Legal Department in or purposeful, BlackBerry expects all
circumstances where such an offer to documentation submitted by its employees and
disclose information is made to you, or business partners to government customers
where such information is inadvertently to be accurate and complete. You should, at a
disclosed to you, whether the offer or minimum, report the matter internally so that
disclosure is made by the government, appropriate steps can be taken to confirm
a competitor or some other third party. whether there is an issue and if so to ensure that
it is appropriately resolved.
37 Contents
BS&P SECTION CONTACT(S) POLICY OR PROCEDURE
Obtain and Use Third-Party Access the Resource Guide for team info • Privacy Policy
• Integrity & Compliance Office
Information Appropriately
• Privacy
Just as we expect others to respect our Intellectual If you obtain third-party IP or confidential information
Property (IP) and confidential information, we have by accident, or if you are not sure if a disclosure is
a similar obligation to respect the IP and confidential authorized, you should contact the Legal Department
information of our customers, competitors, vendors, for guidance before you use the information or share
suppliers or any other third party. This means you it with anyone else.
should not accept such information unless you
Protect the Privacy of Personal Information
are sure the person providing it is authorized to do
so. When you receive third-party IP or confidential Protecting information is at the core of what we do.
information, you are responsible for determining if the We earn our customers’ and other third parties’ trust
information is subject to a non-disclosure agreement by keeping their personal information secure. The
and, if it is, for knowing its requirements and same applies to confidential information concerning
complying with them. You must use such information BlackBerry employees. You must never access
only for the purpose it was provided, and limit any anyone’s personal information without a proper
disclosure to others who have a need to know and business reason. You should also be sure to keep
are authorized to receive the information. Failure the information safe and secure, store it in secure
to protect third-party information could not only locations and systems only, and comply with the
damage our relationships and harm our reputation, data protection and privacy laws of the country (or
but it could also expose you and BlackBerry to countries) where you work or do business.
potential liability.
Contents 38
5 RESPECTING OUR
COLLEAGUES
BS&P SECTION CONTACT(S) POLICY OR PROCEDURE
Create and Maintain a Access the Resource Guide for team info • Equal Employment Opportunity
• Human Resources • Anti-Discrimination and Anti-Harassment Policy
Positive Environment
Respect and Foster Diversity At BlackBerry, we recognize that the ever-changing work and live. By fully utilizing the rich experience
BlackBerry’s success in capturing and maintaining requirements of a diverse market and customer and skills of our diverse workforce, we deliver results
a competitive global market share depends on our base require us to cultivate an agile, inclusive for our diverse global customers.
ability to understand and anticipate the needs of our culture where we can share a broad spectrum of
existing and potential customers, partners, investors perspectives and ideas. This environment enables a Do Not Tolerate Discrimination or Harassment
and suppliers. Our customers – as well as our own high level of employee engagement and satisfaction. You may never make any employment-related
high standards – require that we have the best Our inclusive culture also helps us attract and retain decisions based upon a person’s race, color, gender,
talent working together to innovate, make the right a workforce that understands the diverse range of national origin, age, religion, citizenship, disability,
decisions, and deliver superior products and services. customers we serve and communities where we medical condition, sexual orientation, gender identity,
Value Workplace Health Access the Resource Guide for team info • Environment, Health, Safety and Sustainability
• Global Environment, Health & Safety Policy
and Safety • Workplace Violence Prevention Policy
• Human Resources
gender expression, marital status or any other Do Not Tolerate Bullying or Violence Value Workplace Health and Safety
basis protected by law. None of us should ever feel threatened by We are committed to maintaining an environment
You must also help ensure that our workplace is free anyone, regardless of our tenure or position within that is healthy and safe for everyone. Therefore,
from harassment. While the definition of harassment BlackBerry. BlackBerry makes every effort to you must comply with the occupational health and
varies by location, at BlackBerry it includes any foster an environment of responsible, respectful safety laws that apply to BlackBerry. You must
unwelcome conduct that has the purpose (or can be communication. We strive to create a workplace follow BlackBerry operational health and safety
reasonably construed to have the effect) of creating in which all team members have the opportunity policies and procedures that apply to your work,
an intimidating, offensive or hostile work environment. to actively encourage and contribute new ideas by which have been designed to prevent injuries and
Unwelcome conduct can take the form of physical, empowering each other to think, share and discuss illnesses.
written or spoken remarks, videos or pictures. Sexual our visions in an appropriate manner. With this in
BlackBerry implemented the Global Environment
harassment can include such acts as unwelcome mind, it is never acceptable to belittle a BlackBerry
Health and Safety Policy to reflect our commitment
sexual advances, requests for sexual favors or other colleague because of their ideas, beliefs or
to environmental protection and the health and
physical or verbal conduct of a sexual nature. No appearance or for any other reason. Our Company
safety of our people and communities. Know and
matter what form the harassment takes, it negatively maintains a strict zero-tolerance policy in respect
adhere to this policy, as it forms the foundation of
affects work performance and morale, and is a of any verbal or nonverbal attacks, intimidation or
our Company’s proactive approach to reducing
violation of the BS&P. threats of violence.
injury and illness in the workplace, with the goal of
If you experience or become aware of any act of If you feel that someone is acting in a threatening optimizing employee health and safety.
discrimination or harassment, you must report manner, you are strongly encouraged to bring
it to your manager, HR Business Partner or to all relevant information to the attention of your
Report Your Concerns
HR Employee Relations (hremployeerelations@ manager or your Human Resources Business
If you experience, become aware of or have
blackberry.com ) so that BlackBerry may address Partner.
questions or concerns regarding actual or potential
it. Rest assured that as long as your report is made violations of the foregoing policies, you must report
in good faith, you will not face any retaliation. them so that BlackBerry can address them.
Contents 40
“We are committed to
maintaining an environment
that is healthy and safe for
everyone”
Make Accurate and Access the Resource Guide for team info • Actively Seek Guidance and Report Concerns
• Corporate Secretary
Timely Disclosures
• Investor Relations
Keep Accurate Financial Access the Resource Guide for team info • Actively Seek Guidance and Report Concerns
• Integrity & Compliance Office
Records and Support Robust
• Finance
Controls
We rely on our accounting records for many reasons, Adhere to Our Processes and Controls Always Be Cooperative, Forthcoming and
including producing reports for management, You must follow all processes and controls designed Transparent
shareholders, creditors, governmental agencies to ensure the accuracy of BlackBerry’s assessment Always cooperate and communicate truthfully with
and others. Financial statements, and the books and reporting of financial results. No one should members of BlackBerry’s internal audit, accounting,
and records upon which they are based, must ever override internal controls or procedures directly ethics and compliance, and legal teams, as well
be accurate and complete, and must comply or indirectly related to financial reporting. If you as with BlackBerry’s independent auditors, outside
with applicable accounting principles and legal believe that you need to deviate from these controls counsel and government investigators or regulators
requirements. This includes the BlackBerry system of or procedures for legitimate reasons, you must with respect to BlackBerry’s accounting practices
internal controls. first communicate the circumstances in writing or financial statements. As part of our commitment
If you are involved in BlackBerry’s financial reporting to the Finance Department and obtain approval. to the accuracy of our publicly disclosed financial
process, make sure that all transactions and Be sure to retain, protect and dispose of company information, we must make sure that relevant
balances are timely and accurately recorded, financial records in accordance with applicable information regarding the financial condition of
classified and summarized in accordance with legal requirements and BlackBerry record BlackBerry and our internal controls is available
BlackBerry’s financial and accounting practices. retention policies. to the Audit and Risk Management Committee
Even if you are not in a finance or accounting role, be of the Board of Directors.
mindful that everyday transactions such as recording
expense reports and preparing sales invoices must
be accurate and complete.
Contents 43
Q: What is an “internal control”? checks.
When would I be overriding or • Monetary approval limits.
deviating from one? • Contract provisions, and contract
A: While you may think of internal controls review and approval.
as being primarily finance-related, the • Guidelines on key compliance risk
internal control environment is much areas such as gifts, travel and
broader and can include nearly any tool entertainment, and charitable or
used to mitigate business and compliance political giving.
risks, such as:
• IT system constraints.
• he messaging, guidance and
T
• Accounting and finance controls,
oversight from the leadership team –
internal audits and reconciliations
a.k.a., the “Tone From The Top.”
• Documentation requirements.
• Written policies and procedures.
Activities such as preapproving spending,
• Risk assessments.
splitting invoices, keeping a credit or
• Management oversight of key risk
account with a vendor or other third party,
areas.
operating via “side letters” outside the
• Training. formal contracting process, improperly
• Internal reporting. overriding Company product pricing
• Enforcement and disciplinary systems policies, procedures or decisions, or
ignoring signing authority requirements are
• Third-party due diligence.
all examples of activities that deviate from
• M&A due diligence. or undermine our controls, and are therefore
• Payment controls. prohibited.
• Limitations on access to cash and
Ensure Financial Integrity Access the Resource Guide for team info • Management Approval Processes (MAP)
• Integrity & Compliance Office • Travel & Expense Policy
and Responsibility
• Business Affairs • Approval levels: PO, Invoice & Expenses
• Finance
Conducting BlackBerry business with integrity • Provide the finalized written documentation as the Management Approval Process (MAP)
includes making sure that all agreements and to the appropriate person for recording in our defining the approvals necessary for all transactions
commitments are made in writing, and include books and records. at BlackBerry globally. You must adhere to MAP
all aspects of the transaction. • Ensure the written documentation contains a requirements.
relevant terms to which the parties are agreeing. Before acquiring any goods or services or
Understand and Respect Signing Authority
Making business commitments outside of committing to spending on behalf of BlackBerry,
BlackBerry has a defined process for line this process, such as through informal or oral you must have appropriate spending authority for
management to approve pricing and certain other agreements, is prohibited. the total amount of the payments or concessions
contract terms and conditions. Only authorized involved. If you do
If you are entering into an NDA using a Legal
individuals have the authority to make commitments not, then you must obtain approval from the
Department-approved form, you don’t need further
on behalf of BlackBerry, as delegated by the board of manager in your chain of management who does.
approval from the Legal Department unless you have
directors. Commitments include contracts, purchase
made changes to the form or are using it for other You must make all purchasing decisions in the
orders, statements of work, and other business
than its intended purpose. best interests of BlackBerry. Seek assistance from
obligations or promises
Sourcing and Procurement to ensure BlackBerry
to perform.
Understand and Respect Spending Authority / is getting the best deal available given the
You must satisfy the following when having any Adhere to the Management Approval Process circumstances and our requirements, especially
commitment executed, modified or amended: (MAP) by obtaining competing bids as required by
• Obtain all appropriate approvals in advance. To illustrate exactly what approvals are needed for procurement guidelines. All purchasing decisions
various activities and expenditure levels, BlackBerry must also be documented with supporting evidence
• Use written documentation approved by the
has compiled a list of mandatory guidelines known that will allow other individuals to reach the same
Legal Department for agreements.
decision.
Contents 45
Q: The procedures for in exchange for a purchase order Expense Claims Must Be Valid
commitments require that I obtain for a large number of BlackBerry BlackBerry requires that you submit only claims
“all appropriate approvals in software licenses. May I make this for reasonable expense costs, directly related to
advance.” What are appropriate agreement? company business, and supported by appropriate
approvals? documentation. Your claim must record the
A: No, this is a prohibited verbal side business purpose, full names and titles of
A: This depends on the type of deal. BlackBerry may want to support the
everyone who participated, and comply with
commitment. Most approvals are addressed annual conference and our customer may
other submission requirements.
in MAP. If you are unsure or have questions want to purchase software, but any related
please contact Business Support, Sourcing agreements need full business review and
& Procurement or the Integrity & Compliance approval, and proper Legal Department-
Office. approved documentation. Be explicit in
discussions with partners about when you
are socializing a proposed deal and when
Q: An enterprise partner asked you are extending an offer capable of
me to verbally agree over a acceptance.
handshake that BlackBerry will
sponsor its annual conference,
Contents 47
BS&P SECTION CONTACT(S) POLICY OR PROCEDURE
Avoid Insider Trading Access the Resource Guide for team info • Insider Trading Policy
• Corporate Secretary
and Tipping
BlackBerry’s directors, officers and employees are In addition, a BlackBerry insider may not buy or Insider trading and tipping can result in civil or
insiders of the Company. Consultants, contractors sell securities of another public company while criminal penalties, and/or disciplinary actions
and even students may become insiders as well. in possession of material non-public information including termination. If you have any doubt about a
Applicable laws and BlackBerry policy prohibit regarding that company, if the information was potential securities transaction or the use of certain
insiders from trading in BlackBerry securities learned in the course of the insider’s work at, or non-public information, seek guidance from the
while possessing material information that has via their affiliation with, BlackBerry. Chief Financial Officer or Chief Legal Officer or
not been made generally available to the public their designates.
– a practice referred to as “insider trading”. Honor Blackout Periods
Non-public information about the business Some BlackBerry employees, because of their
or affairs of BlackBerry is material if it would position in the Company and the potential access
reasonably be expected to have a significant they have to material non-public information, may
effect on the market price or value of BlackBerry be advised from time to time that they are also not “Insider trading and
securities or if a reasonable investor would allowed to trade during specified “blackout periods.”
consider it important in making a decision to If you are one of these employees, you must ensure tipping can result in civil
buy, sell or hold BlackBerry securities. Passing that you comply with applicable blackout and
along material non-public information to friends pre-clearance requirements and take necessary
or criminal penalties”
or families – a practice known as “tipping” – precautions to ensure that material non-public
is considered a form of insider trading and is information is not made available to others,
also prohibited by securities laws and including fellow BlackBerry employees who do
BlackBerry policy. not require access to the information.
Contents 49
BS&P SECTION CONTACT(S) POLICY OR PROCEDURE
Remember that We Speak Access the Resource Guide for team info • Corporate Disclosure Policy
• Public Relations & Social Media • Social Media Policy
with One Clear Voice
• Investor Relations
BlackBerry strives to provide clear and accurate • The media, even informally. Refer inquiries Social Media
information to both internal and external received from the media to the Public Relations BlackBerry encourages employees to talk positively
stakeholders. In addition to complying with important Department. If you otherwise have questions about BlackBerry in social situations and in social
legal and regulatory requirements, this helps us about whether it would be appropriate for media, provided it is clear that you are a BlackBerry
maintain integrity in our relationships with the you to speak publicly about BlackBerry or employee and not speaking on behalf of BlackBerry;
public and investors, which in turn strengthens our BlackBerry business, seek guidance. You must the information shared is public and accurate; and
corporate reputation. The primary spokespersons similarly refrain from participating in groups often your communication complies with BlackBerry’s
for our Company are the Chief Executive Officer referred to as “expert networks” to consult on Social Media Policy In short, we must never give the
and other BlackBerry personnel designated in our matters relating to BlackBerry, absent advance appearance of speaking or acting on BlackBerry’s
Corporate Disclosure Policy . From time to time, approval to do so. behalf unless we are authorized to do so.
these individuals may designate others to serve as
authorized spokespersons.
50 Contents
Q: A news reporter sent me a
social media invite and asked
to chat. What is the harm
in accepting?
A: The invite carries significant risk
that what you say might be taken as
your speaking on behalf of BlackBerry
or as a BlackBerry representative.
As a publicly-traded company in a
high visibility industry, it is vital that
we communicate to the media, the
investment community and the general
public in a consistent, considered
manner, and only through those
employees designated to act as
BlackBerry spokespersons. You should
respectfully decline the invite.
Contents 51
7 COMMITTING TO SOCIAL RESPONSIBILITY
FOR OUR WORLD
BS&P SECTION CONTACT(S) POLICY OR PROCEDURE
Uphold Human Rights Access the Resource Guide for team info • Corporate Responsibility Report
• Corporate Responsibility
As a progressive and socially responsible company, uphold these same standards. Failure to comply requirements – and offer acceptance and respect to
BlackBerry complies with international laws could result in the termination of that business all backgrounds and lifestyles.
governing employment and labor standards. We relationship. For more information, please review BlackBerry’s
do not permit child or forced labor or any form Human Rights Policy or seek guidance from your
We also endeavor to comply with laws to
of physical abuse in any of our operations, or Human Resources Business Partner or the Legal
accommodate the needs of each person at
condone such practices among our suppliers and Department.
our Company – including religious and cultural
other business partners, and expect that they will
Protect Our Environment Access the Resource Guide for team info • Human Rights Policy
• Global Environment, Health & Safety • Environment, Health, Safety, and Sustainability
• Environmental Programs Policy
BlackBerry supports inclusive and environmentally laws and regulations as well as our voluntary Day-to-day operations have a number of direct and
conscious product development through sustainable commitments to sustainable practices and indirect impacts on the environment. BlackBerry has
business operations and efforts to reduce the environmental protection. taken steps to mitigate these impacts by adopting
environmental impact of our business activities. policies, procedures and processes that address
We strive to reduce the environmental impact
BlackBerry supports protecting the environment these matters.
of our business activities, and also to deliver
within its internal operations and supply chain. You
environmentally conscious products and services.
must comply with all applicable environmental
Contents 53
BS&P SECTION CONTACT(S) POLICY OR PROCEDURE
Give Back to Our Access the Resource Guide for team info • Prevention of Improper Payments Policy
• Corporate Citizenship • Corporate Citizenship Page
Communities
Contents 55
BS&P SECTION CONTACT(S) POLICY OR PROCEDURE
Participate in the Political Access the Resource Guide for team info • Prevention of Improper Payments Policy
• Integrity & Compliance Office
Process Responsibly
• Government Relations
BlackBerry encourages you to participate in BlackBerry does not make political contributions. Q: My next door neighbor is
political activities, and support candidates and The Government Relations team is responsible for running for the local town
issues of your choice. However, you may not use coordinating our activities with government officials council and has asked for my
BlackBerry property, equipment, personnel or other and policy makers. You should not communicate help. Can I be listed as one of
resources for political activities or endorsements. If with public officials or policy makers on behalf of
his supporters? What about
you do engage in political activities, you must do so BlackBerry except as directed by the Government
making phone calls from the
as a private citizen, on your own time and at your Relations team.
office during my lunch break
own expense. You must not give the impression that
BlackBerry supports any candidate or issue you are
or using the copy machine to
involved with as a private citizen. print up flyers?
Choose Responsible Access the Resource Guide for team info • BlackBerry Supplier Diversity Policy
• Supply Chain Social Responsibility • BlackBerry Supplier Code of Conduct
Suppliers
• BlackBerry Responsible Minerals Policy
We seek out suppliers of goods and services who Minerals Policy. If a supplier is unwilling or unable
share our vision of doing business the right way, to make such a commitment, or fails to improve
and hold them to the same standards to which we unacceptable performance, we may suspend or
hold ourselves. We will not tolerate those whose terminate the relationship.
actions might damage our reputation or brand. This
means we expect our suppliers to fully comply with
the applicable laws, rules and regulations of the
countries in which they operate.
Contents 57
Glossary of Defined Terms
• Anticorruption laws. Laws designed to assets such as intellectual property, business • Cash and cash equivalents. In addition to
prohibit the use of corrupt payments or other strategies and plans, financial data, technology, cash, this includes anything that can be readily
improper inducements in order to gain or other trade secrets and other forms of converted to or used in the same manner as
maintain business or some other competitive confidential and proprietary information. See cash, including money orders, traveler’s checks,
advantage. Anticorruption laws may target also Confidential and proprietary information. paper checks, investment securities, negotiable
official bribery (i.e., the bribery of government instruments, loans, stocks or stock options,
• Bribe. Promising, offering or giving anything
officials), commercial bribery (i.e., the bribery and stored value products such as debit cards,
of value to any person, where it is intended
of non-governmental commercial parties) or gift certificates and gift cards.
to improperly influence the recipient to
both. They may also target the maintenance of
misuse their position or to otherwise obtain • Competition laws. Laws designed to prohibit
accurate books and records, and of effective
an improper business advantage. See also agreements or practices that restrict free trade
internal control environments.
Improper payment. and competition between businesses. Also
• Anything of value. Nearly any form of benefit, • Business courtesy. Gifts, travel, meals known as antitrust, anti-monopoly or cartel
including but not limited to: or other forms of entertainment provided or laws, these often target practices such as price
• cash or cash equivalents, loans, gifts or received in the course of business activities fixing, bid-rigging or other collusive tendering
prizes to or from a business partner or counterparty. or procurement activities, market allocation,
• employment offers or promises of future So long as reasonable in nature, supported exclusion of competitors from markets or other
employment (to an individual or any of by a bona fide business purpose, consistent efforts to control, monopolize or improperly
their relatives) with relevant business customs and cultural divide markets.
• favorable terms on a product or service or traditions, and consistent with the BS&P and
product discounts • Confidential and proprietary information.
other BlackBerry policies and procedures,
• entertainment or hospitality (payment of Non-public information that is not approved for
these are usually acceptable. See also Bribe;
travel, hotel or restaurant bills, living dissemination outside BlackBerry (other than
Gifts or entertainment.
expenses or costs of trips or resort stays) pursuant to a duly executed non-disclosure
• use of vehicles or vacation homes • Business partner. Any number of third agreement). See also BlackBerry assets
• discounted or free tickets to events parties with which BlackBerry might work,
including but not limited to agents, alliance • Conflict of interest. A situation where an
• services, personal favors or home
partners, consortium partners, consultants, individual’s personal, financial or other interests
improvements
contractors, dealers, distributors, joint venture or relationships might reasonably be seen as
• political or charitable contributions
partners, promoters, resellers, retailers, interfering with an obligation the individual owes
• BlackBerry assets. In addition to tangible sales representatives, service providers, to act in the best interest of another, such as
assets such as cash, equipment, facilities, subcontractors, suppliers or vendors. their employer.
inventory and supplies, this includes intangible See also Third party.
Contents 59
acquiescence in any provision or offer to balances, testing mechanisms, trainings, level of approval authority. See also Signing
provide anything of value to a recipient. Such communications or other means by which authority.
payments can take the form of cash or cash a company seeks to mitigate a risk and • Money laundering. A process whereby
equivalents; reimbursements of expenses; gifts, prevent or identify potential misconduct. transactions with a legitimate business are
entertainment or travel; charitable or political Examples include codes of conduct, policies used to conceal funds generated by illegal
donations; and other tangible and intangible and procedures, compliance training, activities to make them appear to be legitimate.
benefits. See also Bribe. monetary approval limits, signing authorities,
• Outside activities. Any business activity
• Inside information. Material non-public payment controls, audits and other reviews,
conducted outside the scope of one’s
information about BlackBerry or another risk assessments, and internal reporting
employment with BlackBerry, including
company about which you become aware mechanisms.
establishment of, operation of or employment
through your work at BlackBerry, that would
• Local laws. These are the laws, rules and by a non-BlackBerry business (whether full
be likely to affect an investor’s decision to buy,
regulations that apply in a particular country, or part-time), and participating on a board of
sell or hold securities. See also Insider trading;
and could include federal, state, municipal directors or advisory board (which non-profit or
tipping.
or other level legal obligations applicable to for-profit).
• Insider trading. Buying or selling securities BlackBerry or a person or entity operating on • Outside financial interest. An ownership,
while in possession of inside information. See BlackBerry’s behalf in that country. equity or investment interest you hold in an
also Inside information; tipping. organization other than BlackBerry.
• Material non-public information. Non-public
• Intellectual property. Exclusive rights to information about the business or affairs of • Personal information. Information about an
intangible assets derived through invention BlackBerry is material if it would reasonably be identifiable individual.
such as copyrights, trademarks, patents, expected to have a significant effect on the
market price or value of BlackBerry securities • Public official. Public officials include anyone
industrial designs, trade dress and trade
or if a reasonable investor would consider it serving in or employed by a national, state,
secrets. These rights allow creators or owners
important in making a decision to buy, sell or provincial or local government body or agency,
of the protected asset to benefit from their work
hold BlackBerry securities. such as elected officials, appointed officials and
on or investment in whatever has been created.
civil servants. Examples include:
Virtually all intellectual property developed by • Monetary approval authority. Thresholds
• legislators and governors
BlackBerry employees in the course of their defining the monetary limits below which
• employees of public universities or local
employment belongs to BlackBerry. BlackBerry employees have authority to
school systems
See also BlackBerry assets. approve or commit to expenditures of
• employees of the national, state or local
Company funds, and above which they must
• Internal controls. Almost any protocols, government
obtain approval from an employee with a higher
programs, tools, limitations, checks and Public officials may also include:
Contents 61
Index
Anonymity (reporting ethics issues) 7, 14 Diversity 39, 57
Anticorruption 29, 58, PIPP , Gift Policy Donations 54, 56, 59
Anti-monopoly law 30, 58 Electronic communications, protection of 38, 40
Antitrust law 30, 58 Embargo 33, 59, 61
Assets, use or protection of 17, 18, 20, 23, 25, 28, 55, 58, 60 Entertainment 10, 25, 27, 29, 36, 37, 44, 58, 59
Audits, internal and external 13, 44, 47, 60 Environment 8, 11, 22, 39, 40, 44, 52, 53, 58, 59
BlackBerry assets 17, 18, 25, 28, 58, 60 Equipment, use of 17, 23, 47, 52, 56, 58
Blackout period 48 EthicsLink 7, 13, 14, 42
Boards, serving on 25, 27, 60 Exports 33, 34, 59, 61
Boycotts 33, 61 Financial interests, outside 26
Bribery 58, PIPP , Gift Policy Financial records 43, PIPP
Bullying 40 Financial reporting 43
Business courtesy 28, 58 Foreign Corrupt Practices Act (FCPA) PIPP
Cartel law 30, 58 Fraud 12, 18, 19, 20
Charitable donations 17, 25, 44, 54, 55, 58, 60 Gifts 10, 20, 25, 27, 29, 36, 37, 43, 58, 59,
Competition law 30, 32, 58 Gift Policy
Compliance with laws 3, 7, 8, 9, 10, 11, 12, 13, 14, 15, 19, Government, contracting with 3, 10, 20, 29, 33, 36, 37, 43, 47, 54,
23, 24, 27, 29, 30, 31, 33, 34, 35, 36, 56, 58, 59, 60
37, 38, 43, 44, 46, 50, 52, 54, 55, 60
Guidance, seeking 3, 6, 8, 10, 12, 13, 15, 25, 27, 29, 30,
Confidential information 8, 21, 38, 49, 61 35, 36, 38, 42, 43, 44, 48, 50, 52
Confidentiality (reporting ethics issues) 13, 15, 23, 24, 61 Harassment 39, 59
Conflict of interest 8, 10, 20, 25, 26, 27, 28, 58 Health and safety 40
Cooperation 7, 11, 33, 42, 47 Hiring 10, 29
Copyrighted materials 23 Human rights 52
Corporate opportunity 25, 26
Imports 33, 59, 61
Corporate social responsibility 52 Improper payments 29, 36, 54, 56, PIPP , Gift Policy
Decision making (decision tree) 8 Inadvertent disclosure 21, 22
Disclosures 10, 11, 36, 42 Information, inside 59, 60, 61
Disclosures, corporate 10, 11, 36, 42 Information, protection of 21, 38
Discrimination 39, 59 Information, third-party 38, 61
Contents 63
BlackBerry.com
Rev 07/2017