Leading with Integrity
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Leading with Code of Integrity Conduct Dear Sprint team , Success is only meaningful when it is achieved the right way, with the right values. It’s more important than ever that we act with integrity, put our customers first and adhere to high ethical standards in our business conduct. I’m proud that we’re known as a trustworthy company, which requires each of us to do the right thing every day. The Sprint Code of Conduct outlines our ethical and legal responsibilities as employees, as well as our interactions with customers, competitors and suppliers. One of our most valuable assets is our reputation for honesty and fairness, and I appreciate your commitment to uphold this responsibility. By creating an environment of trust and understanding, we also are respecting each other. When in doubt, don’t hesitate to speak up, ask questions and take action. Thank you for everything you do to take pride in your work and help Sprint stand out as an ethical leader. Page 2 Ethics Helpline: 913-794-1666 or 800-788-7844 Table of Contents Leading with Integrity – Employee Privacy 12 Investments and Financial Opportunities 22 The Way We Do Business Employee Relations and Discrimination 12 Investments in Competitors 22 Investments in Other Companies 23 Harassment 13 Initial Public Offerings or 23 Workplace Safety 13 Foundation of Integrity 4 Preferential Allocations Safety and Health 13 Sprint Code of Conduct 4 Procurement 23 Drugs and Alcohol 14 Making Ethical Decisions 4 Violations and Consequences 5 Integrity with Our Customers Integrity in Our Communities Raising Issues and Concerns 5 Retaliation 5 Environment 26 Customer Privacy 16 Chief Ethics Officer 5 Community Support 26 Government Customers 16 Non-Exclusivity 5 Governmental Business Practices 16 Personal Community Activities 26 Waivers 5 Books and Records 16 Political Activity and Lobbying 26 Accurate and Reliable Business Records 16 Inquiries from the Government 27 Integrity in our Workplace Reporting of Financial and 17 Inquiries from the Media and Analysts 27 Non-financial Information Tone at the Top 8 Accounting, Internal Controls, 17 Speak Up. Take Action. Supervisor Responsibility 8 Auditing and Tax Matters The Open Door Policy 8 Raising Issues and Concerns 30 Conflicts of Interest 8 Integrity in the Marketplace Disclosure 9 Retaliation 30 Corporate Opportunity 9 International Business 20 Contacting the Ethics and 31 Relatives and Friends 9 International Business Practices 20 Compliance Program Board Memberships 10 Foreign Corrupt Practices Act 20 Other Contact Information 31 Outside Employment and 10 Export Control 20 Activities of Employees 10 Transactions with Prohibited 20 Gifts, Entertainment and Travel 10 Persons or Sanctioned Countries Company Assets 11 Anti-boycott 21 Confidential and Proprietary Information 11 Competition Law and Business Conduct 21 Intellectual Property 11 Competitive Information 21 Computer and Network Security 11 Business Records and Communications 21 Compliance and Reporting of 12 Material Nonpublic Information and 22 Security Information Insider Trading Effective May 21, 2015 Page 3 Ethics Helpline: 913-794-1666 or 800-788-7844 We are responsible for: • Complying both with the letter and the spirit of all applicable laws, rules and regulations. • Observing high ethical standards when conducting business on Sprint’s behalf. • Asking questions when in doubt about the appropriateness of a situation. • Reporting known or suspected violations of any applicable laws, rules, regulations, policies and procedures. • Certifying familiarity and compliance with the Code, its standards, policies and procedures. Foundation of Integrity these traits, integrity and ethics are critical success Making Ethical Decisions: When in factors. Amidst unprecedented change and techno- Throughout its proud history, Sprint has continually Doubt, Ask Yourself … logical advancement, acting with integrity is not just been an innovator in the telecommunications indus- • Is it ethical? Is it also legal? the right thing to do, it is the unwavering foundation try, driven by a legacy of integrity, accountability and • Could it harm Sprint’s reputation? for Sprint. service. Today, Sprint delivers amazing technology, • What would my family and friends say? service and experiences to our customers, communi- • How would it look in the newspaper? Sprint Code of Conduct ties, employees and shareholders (stakeholders). And, • Would I risk my job for it? along the way, we take great pride in our high-caliber The Sprint Code of Conduct (the Code) is applicable Failure to abide by any laws or policies, including the workforce, our outstanding corporate citizenship and to employees of Sprint and its controlled subsidiar- Code, can result in monetary damages, governmental our industry-leading environmental sustainability ac- ies, the Sprint Board of Directors (Board Members), sanctions and compromise Sprint’s reputation. Viola- complishments and commitments. and anyone we authorize to act on Sprint’s behalf. tions of laws, policies or the Code may result in disci- The Code establishes the basic foundation of Sprint’s As we look to the future, we recognize that our capac- plinary action, up to and including termination of your ethics by communicating our philosophy and com- ity to continuously incorporate better experiences service and, in some cases, could lead to civil and mitment to all of our employees, customers, other for our stakeholders hinges entirely on our collective criminal actions against the individual and Sprint. You stakeholders and the communities in which we do ability to perform at the highest level – from the retail are responsible for your own actions. You are never business. The Code should be used as a resource store to the customer service center to the office of authorized to commit, or direct someone to commit, a when questions of legal or ethical appropriateness the CEO. A high-performance culture is the path to a violation of the Code or an illegal act. Additionally, you arise on the job. It is not a comprehensive rulebook, bright future. At Sprint, our high-performance culture cannot use a contractor, agent, consultant, broker, but rather a statement of how Sprint commits to do focuses on accountability, first and foremost, along distributor or other third party to perform any act business. We are bound by the Code and the specific with open communication and innovation. Within prohibited by the Code or the law. operational policies of Sprint. Page 4 Ethics Helpline: 913-794-1666 or 800-788-7844 Violations and Consequences managing the Ethics Helpline, developing policies, procedures and training, as well as implementing a Leading with Integrity – Failure to abide by any laws or policies, including system for evaluating the compliance activities of the Code, can compromise the reputation of Sprint The Way We Do Business each employee. and may also result in disciplinary action, up to and Our reputation as an ethical including termination of employment. Violations of On matters of the Code that require disclosure, the company is a valuable asset. the Code or illegal acts cannot be justified by saying CEO and Board Members should disclose those items that they “helped the bottom line,” or were directed by to, and seek guidance from, the Chief Ethics Officer. The Code is intended to help us a higher authority in the organization. Each employee understand our responsibilities is responsible for his or her actions. You are never Non-Exclusivity and guide us in making the right authorized to commit, or direct someone to commit, a The Code cannot explicitly cover all situations or choices. We are obligated to violation of the Code or an illegal act. Additionally, you circumstances that an employee may face. It is not uphold our ethical and legal cannot use a contractor, agent, consultant, broker, a comprehensive, full, or complete explanation of responsibilities and conduct distributor or other third party to perform any act all the laws and regulations that apply to Sprint and our day to day business in prohibited by the Code or the law. its employees. The Code does not constitute a contract compliance with the letter and of employment or create other contractual rights. spirit of those requirements. Raising Issues and Concerns Many of the issues are discussed in greater detail in You are obligated to report violations of the Code, the other Sprint materials such as the Employee Guide law or any other company policy or procedure. If you and company policies. All employees have a continu- have questions, concerns, or need to report a known ing obligation to familiarize themselves with any appli- or suspected violation, you should discuss it with your cable laws or company policies; however, nothing can supervisor, any member of your management team, serve as a substitute for good judgment. a Human Resources representative or contact the Sprint established this Code for company-wide Ethics Helpline where you can report your concern application and any direct conflict between any other confidentially or anonymously. You may be subject to policy and the letter or spirit of the Code is to be discipline, up to and including termination, for your resolved in favor of the Code. failure to do so. Retaliation Waivers Sprint does not expect to grant waivers of provisions Sprint forbids any form of retaliation or adverse action of the Code to employees or Board Members. Disclo- against any employee for reporting in good faith a sus- sure of a waiver, if any, will be made as