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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor


Steve leaves behind a company that only he could have built, and his spirit will forever be the foundation of Apple.

Email from Apple CEO Tim Cook to all Apple employees on October 5, 2011

This is the first time Apple Inc, the company Steve Jobs built, has ever appeared on the FCPA Blog.

During Jobs’ life, Apple wasn’t named in an FCPA enforcement action and didn’t appear on our corporate investigations list (which will be updated tomorrow).

The company’s written compliance program includes a publicly available Business Conduct Policy and a separate Foreign Corrupt Practices Act Policy that’s not public.

Apple’s principles of business conduct, the company says, apply to anyone working for or with the company, and ‘define the way we do business worldwide.’

Those principles  are:

  • Honesty. Demonstrate honesty and high ethical standards in all business dealings.
  • Respect. Treat customers, suppliers, employees, and others with respect and courtesy.
  • Confidentiality. Protect the confidentiality of Apple’s information and the information of our customers, suppliers, and employees.
  • Compliance. Ensure that business decisions comply with all applicable laws and regulations.

Apple’s approach to compliance is conservative. For example, gift-giving to foreign government officials is limited to items valued up to $25, except with advance approval of the law department.

‘For meals, the US$25 limit does not necessarily apply,’ the policy says, but continues: ‘Meals at any value should be avoided with officials from government agencies where Apple has a pending application, proposal, or other business.’

Under the Q&As, it says:

Can I avoid a gift limitation by paying for a gift, such as lunch or golf, myself?

No. If you are representing Apple, any gift to a government employee would be viewed as coming from Apple.

*   *   *

What is considered a gift to a U.S. or foreign official?

In most cases, anything of value that is given is considered a gift. This includes items such as meals, golf, entertainment, and product samples. Cash is never an acceptable gift. Typically, giving cash is viewed as a bribe or kickback and is against Apple policy.

And who does Apple consider to be a ‘foreign official’ under the FCPA? ‘Any official or employee of a government, a public international organization (such as the European Commission), any department or agency thereof, or any person acting in an official capacity. It can also include employees of a state-run or state-owned business, such as a public utility or university.’


Apple Inc’s Business Conduct Policy and other governance documents can be found here.

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