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Business Conduct February 2024
Introduction Behaviors Protecting Apple Accountability Integrity Resources
Apple generally considers an outside activity to be a conflict of interest if it:
• Is for a business, company, or organization that makes or sells competing products or services to Apple, or
that Apple is reasonably anticipated to create. This includes but is not limited to: Apple hardware products
(e.g., computers, mobile devices, headphones), financial services, original content, health services, cloud
services, any distribution of video, music or eBooks, and any software or app.
• Generates or exposes you to intellectual property that competes with or relates to Apple’s present or
reasonably anticipated business, products, or services.
• Would require you to disclose or use confidential Apple information.
• Arises from your role in Apple’s business relationship with the organization.
An outside activity that is the same as or similar to your role or work at Apple could also be considered a
conflict of interest. Review the Business Conduct website for more information.
Work with your manager and Business Conduct to evaluate a potential conflict of interest. If an outside activity
presents a conflict of interest, you must partner with a People Business Partner, and obtain written approval
from your manager, Legal (if applicable), and the senior most person reporting to the CEO of both your and any
relevant organizations. Contact Business Conduct to assist with Legal review.
Any employee, full or part-time, who is participating in an outside activity, must comply withthe following rules.
Do not:
• Use any time at work or any Apple assets for your outside activity. This includes Apple’s workspace, phones,
computers, Internet access, photocopiers, and any other Apple assets or services.
• Use your position at Apple to solicit resources or any other benefit for your outside activity, obtain favored
treatment, or pressure others to assist you.
• Participate in an activity that could have an adverse effect on your ability to perform your duties at Apple.
• Use confidential Apple information.
Outside Employment and Inventions
Before participating in creating inventions or businesses that are in the same area as your work for Apple, or that
compete with or relate to Apple’s present or reasonably anticipated business, products or services, you must
have written permission from your manager and the senior vice president of your organization. Before taking any
paid employment outside of Apple, you should notify your manager.
App Creation
You can only create apps for personal or educational purposes. You cannot join the Developer Program or
share, sell, or distribute apps, stickers, or other media (for iOS, Android, or any other operating system), unless
required for Apple business purposes. Some exceptions apply for employees who created apps before joining
Apple or who are joining Apple for a short period of time. If this applies to you, contact Business Conduct to
understand what is permitted.
Board Positions
You may not serve as a director, trustee, officer, or advisory board member without prior approval from Apple.
Apple has pre-approved positions in certain organizations like residential boards (i.e., HOAs) and local sports
and arts organizations, provided their activities do not conflict with Apple’s interests. Contact Business Conduct
if you have any questions or if you would like to seek approval from Apple for a position that is not in a pre-