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Our Business Conduct Policy sets out our ethical requirements for our employees. Each of our employees must certify that they have read and understand the policy when they join Apple, and again each year. Violations of the policy are taken seriously and may result in disciplinary action, up to and including termination of employment.

A number of compliance functions are deeply integrated into our business organization. Apple’s Compliance and Business Conduct team focuses on?Business Conduct, Political Compliance, Export and Sanctions Compliance, Health Compliance, Antitrust Compliance, and Anti-Corruption Compliance.

Every Apple employee is required to complete mandatory annual Business Conduct training. We offer a range of additional resources for employees to address questions and concerns, including the Business Conduct Helpline and the Business Conduct website.

We conduct internal and third-party independent assessments of our programs to ensure they are effective. We make changes to our policies and our training to reflect emerging trends. Apple’s Chief Compliance Officer provides regular updates to the Audit and Finance Committee of the Board of Directors.?