CODE OF CONDUCTIssued: May 2016
Revised: May 2019, June 2021, August 2021, July 2023, October 2023

Dear Team,For the past several years, Lenovo has been steadily growing, becoming
one of the world’s largest and most respected makers of PCs, smartphones,
tablets and servers, and providers of cloud services. We have more customers
in more places buying more devices than ever before. With our bigger
business and higher profile comes not only great opportunity, but also great
responsibility.
That is why we must have a clear, strong, consistent Code of Conduct.
This Code reflects an extension of our culture of integrity and our continued
commitment to ethical business practices and complying with the law. We
expect all of our employees and representatives to understand and comply
with our Code and exercise good judgment when making business decisions.
The Code summarizes the principles and policies that govern our company.
This Code must apply to every business decision in every area of thecompany worldwide. Please use this Code and the resources described in it
to help answer your questions or address your concerns.
As we continue to transform, our Code and values remain steadfast. We
must keep our momentum and continue winning by doing business ethically,honestly, with integrity, and in full compliance with all laws and regulations.
We all have the responsibility to raise compliance and ethical concerns.
Lenovo prohibits retaliation against any employee who, in good faith, seeks
guidance or reports a concern.
Lenovo will keep rising, keep winning, and together we will achieve ourgreatest aspirations. Great companies operate with great integrity. That is my
expectation - and that is how we will keep growing, winning and achieving ourbold aspirations for many years to come.
Sincerely,

INTRODUCTION | 2

Yang Yuanqing
Chairman & CEO
LenovoCONTENTS
Letter from Yang Yuanqing, Chairman and CEO

2

OUR CULTURE AND
GUIDING PRINCIPLES

5

Our Values Define the Way We Do Business
How We Act With Integrity

OUR INVESTORS

17

Conflicts of Interest

17

Outside Employment				19

Board Memberships 				

19

6Family Members & Close Personal Relationships

20

7

Personal Investments 				

21Connected Transactions Process 			22

INTRODUCTION

8

Accuracy of Business Records 				

23Additional Manager Responsibilities 			

9

Insider Information & Securities Trading			24

Ethics and Compliance Program 			

10

Authority to Make Lenovo Commitments

25

Reporting Concerns and Seeking Guidance		

10

Protecting Company Assets 				

26The LenovoLine 					

11Lenovo Information & Communication Systems

27

Investigating and Resolving Issues 			13

Privacy & Data Protection 				

28No Retaliation			

13

Lenovo Intellectual Property Rights 			29

Lenovo Confidential & Restricted Information

30

OUR EMPLOYEES

14

Fair Treatment 						

14Diversity 						

14Harassment-Free Workplace

15

Health, Safety & Security of Employees

16

Alcohol & Substance Abuse

16

INTRODUCTION | 3

CONTENTS
THE MARKETPLACE32

COMMUNITY & SOCIETY

44

Gifts, Entertainment, Corporate Hospitality & Travel

32

The Environment 				

44Giving & Receiving Gifts 				

33Political Process 				

45Entertainment & Travel

34

Anti-Money Laundering				46

Commitment to Human Rights

46

Commitment to Community 			47

WHERE TO GO FOR HELP

48

NO RETALIATION 				

48

				

Providing Gifts, Entertainment or Travel toGovernment Officials or Employees

35

Anti-Corruption Laws & Bribery				36

Government Customers 				

37Product & Quality Service 				

38Representations Regarding Lenovo Products

38

Treating Our Business Partners With Integrity

39

External Communications/Media Relations 		

40

Protecting Information & Intellectual Property
Belonging to Others 					

41Fair Competition 					

42Import & Export Controls

43

INTRODUCTION | 4

OUR CULTURE AND
GUIDING PRINCIPLESINTRODUCTION | 5

Serving Our Customers
服务客户Innovation
开拓创新We do what we say.
We own what we do.
We wow our customers.

Entrepreneurship创业精神说到做到，尽心尽力，成就客户。

Teamwork with Integrity & Trust诚信共赢HOW WE ACT WITH INTEGRITYFOLLOW THE LAW, THE
CODE AND OUR POLICIESWe behave honestly, by obeying the law, ourpolicies, our Code of Conduct and by always
doing the right thing. We do not engage in unfair
business practices or illegal activities like fraud,
theft, bribery, insider trading or harassment. We
never abandon our ethical values for the sake ofprofits or personal gain.

MUTUAL RESPECT
We treat each other with fairness, dignity andrespect. We value individual differences and thequality of ideas and innovation that come fromthose differences.

ACCOUNTABILITY
We honor commitments, deliver on our promises
and take responsibility for decisions. We neveruse a contractor, consultant or other third party toperform any illegal act or violate Lenovo policy.

OUR CULTURE AND GUIDING PRINCIPLES | 7

COURAGEWe report any situation or action that we believe
violates our policies, the Code of Conduct or
the law. We never retaliate against those who
speak up.

ETHICAL LEADERSHIP
Regardless of our position or level, we rely on
Lenovo’s values and Code of Conduct as ourguide. We consider the consequences of ourdecisions on Lenovo’s reputation. We avoid
conflicts between our personal interests andthose of Lenovo.

COMMITMENT TO CONSUMERS
AND COMMUNITIESWe always focus on the needs of consumers,
our customers and the communities where we
do business.

INTRODUCTIONAt Lenovo, the Code of Conduct (the Code)is the cornerstone of our commitment
to conducting business legally, ethicallyand with integrity. The Code applies to all
employees (including full-time, part-time,and supplemental or temporary) of LenovoGroup Limited and its subsidiaries, present
and future. We also require all consultants
and contractors working for Lenovo tofollow the Code in connection with theirwork for Lenovo.
Any violation of this Code is a serious
matter. A breach can put the company, ouremployees and our products or services
at substantial risk. Every employee isaccountable for his or her own behavior.
Failure to follow the Code, or violation of thepolicies described in the Code, can resultin disciplinary action, including terminationof employment. Failure of any contractor orconsultant to follow the Code can result intermination of their relationship with Lenovo.

INTRODUCTION | 8

We must never conceal anyone’s failure tocomply with the Code, Lenovo policies or
the law. We should never ask or allow athird party to act on Lenovo’s behalf in any
way that would violate the Code, Lenovo
policies or the law.
The Code is a starting point, and is notintended to describe every law, policy,
procedure or business process that applies
to your work at Lenovo. Make sure you
know the rules that apply to you.
In addition to following the Code, each ofus has an important responsibility to know
and follow the laws that apply, wherever wework. If you have questions about the lawsthat apply to your activities, contact theLegal Department.

ADDITIONAL MANAGER RESPONSIBILITIESAs a manager at Lenovo, you lead by example, creating a work
culture that promotes integrity and reinforces the Code and our
supporting policies.

INTRODUCTION | 9•

You will ensure your employees know what is
expected of them, are comfortable seeking
guidance when they have questions and can raise
concerns without fear of retaliation.

•

You may never engage in - or allow - retaliation
against someone for making a report ofsuspected misconduct.

•

You will ensure that your employees and contractors
complete all required ethics training.

•

As a manager, you have a special obligation toreport and respond to any behavior that you think
could violate the law, the Code or our policies.

•

If you feel unsure of the answer to an employee’squestion or concern, contact the resources listed in
the Code.

ETHICS ANDCOMPLIANCE PROGRAM

Lenovo’s Ethics and Compliance Office (ECO) administers
Lenovo’s ethics and compliance program. The ECO monitors andenforces employee compliance with the Code and Lenovo policies.
The ECO also answers employee questions, provides training andpolicy guidance and serves as a channel for reporting unethical,
suspicious or illegal behavior.

REPORTING CONCERNSAND SEEKING GUIDANCEYou should promptly report any conduct that:•••

Seems unethical, illegal or suspicious
May violate the CodeMay violate any policies or procedures

You can raise concerns at any time with:
•
•
•
•
•
•

INTRODUCTION | 10

Your manager (provided your manager is not involved in theviolation) or another manager you trust
The Ethics and Compliance Office (ECO) (ethics@lenovo.com)
Human Resources
The LenovoLine
The Legal Department
In China, you can report misconduct to Lenovo’s Independent
Commission Against Corruption (ICAC) (ICAC@lenovo.com)

THE LENOVOLINEThe LenovoLine allows you to report a concern or ask a question
24 hours a day 7 days a week, either online or by telephone. The
LenovoLine is operated by an independent, outside company.
Information received through the LenovoLine is referred to Lenovo’s
ECO. Every report is assessed and taken seriously. The LenovoLine
is committed to protecting your confidentiality, to the extent possible.
You can raise issues anonymously if you prefer. Although your name is
not required to address most concerns, a more thorough investigation
can be conducted if you identify yourself.
Due to legal restrictions, anonymous reporting through the LenovoLine
is not permitted in certain countries. Some countries also limit thetypes of issues that can be reported using this resource. If theLenovoLine is not available in your country, please contact one of theother available Lenovo resources. If you have any questions about
which resources to use, contact the ECO.

Contact the LenovoLine
by phone:
To call from the US, dial
1-806-602-9151
To call from China, dial
+86 4001203490
For dialing instructions from other countries, visit the “Ethics andCompliance” section of Lenovo MyHub.
https://myhub.lenovo.com/sites/compliance/Pages/lenovoline.aspx

Contact the LenovoLine
on the website:

To make a report or inquiry using the secure
LenovoLine website, visit
https://lenovo.whispli.com/lp/speakup
For China based individuals, please visit this link toreport concerns:
https://lenovo.whispli.com.cn/lp/speakup

INTRODUCTION | 11» Q. Why is it important toreport misconduct?
A: We all have a responsibility to do the rightthing and protect Lenovo’s reputation. If you
promptly report any suspected violation of theCode, policy or the law, you will help prevent or
limit damage to Lenovo.

» Q. What if my culture
discourages speaking up?
A:  It is not always easy to find the courage
to speak up and report a concern, but as an
employee or individual working with Lenovo, youare expected and encouraged to do so; it is an
essential part of our Code. While cultural norms
may vary, our Code and the importance of doing
the right thing never varies.

INTRODUCTION | 12

ATTENTION:
Any of the following statements could be a sign oftrouble. If you hear anyone say these things, speak up!
•
•
•
•
•
•
•
•
•

I know it’s against policy, but this is just how things get done here--it’slocal custom
It’s ok if they [our business partners]--and not us--violate the Code andthe law
It’s not my problem; someone else should say something
No one will find out
It seems suspicious, but I don’t have any proof
Reporting won’t change anything; it would just distract from getting thejob done
We couldn’t function or win business if we followed all of the rules; they
just slow things down
Meeting our launch date is more important than following the rules
The more confidential details I share with others about our new products,
the more excitement we can generate

Reach out to your manager, the LenovoLine, the ECO, Human Resources or
the Legal Department for the right course of action. If you are unsure who tocontact, contact the ECO.

INVESTIGATING ANDRESOLVING ISSUESNO RETALIATIONINTRODUCTION | 13

When necessary, Lenovo will investigate issues raisedby employees or others. All employees, contractors andconsultants are required to cooperate fully with investigations
and audits conducted by Lenovo or governmental
authorities. This means providing information, Lenovoissued equipment such as computers or smartphones,
documents and personal interviews. Failure to cooperate,
including misleading, lying, destroying or altering documentsor records, or failing to respond promptly to requests
for information by investigators or auditors is grounds
for disciplinary action up to and including terminationof employment. Lenovo may report misconduct to theappropriate authorities. Consult the ECO or the Legal
Department before responding to non-routine requests foraudits, investigations or information from parties outsideof Lenovo.
Lenovo does not tolerate retaliation against any employee,
consultant or contractor for reporting an issue or raising a
concern he or she believes to be true, cooperating with aninvestigation or audit, or refusing to participate in activities
that violate the Code, laws or company policies. This
policy protects anyone who makes a report in good faith,even if he or she is found to be mistaken. Anyone who
engages in retaliation will be subject to disciplinary action,
including termination of employment. If you believe you wereretaliated against, immediately report the matter to the ECO.

» Q. What are some examples ofretaliation?
A: Retaliation can take many forms including:• Demotions• Undesirable assignments• Inappropriate performance ratings• Termination of employment• Verbal harassment• Intimidation• Threats» Q. I raised a compliance concern
about my manager to my local
HR Partner. My manager has now
started raising issues with myperformance that he never raised
before. What should I do?
A: Let HR or the ECO know about yourconcerns, even if you aren’t sure. Your concern
will be investigated and if you are being retaliatedagainst, action will be taken to protect you.

FAIR TREATMENTOUR EMPLOYEESWe believe in treating each other with respect and dignity. We judge allapplicants and employees by their qualifications, demonstrated skills andachievements without regard to race, color, religion, gender, gender identity
or expression, national origin, ethnicity, sexual orientation, sex, age, disability,
veteran status, marital status or any other characteristic protected by local
law. When necessary, Lenovo will provide reasonable accommodations for
employees with disabilities or those with special religious requirements.
All employees help to create a positive work environment by adhering tothese standards.

DIVERSITY
We are proud to actively promote diversity in our workforce and theworkforces of those with whom we do business. We respect andvalue individuals for their diverse backgrounds, experiences, styles,
approaches and ideas. We rely upon diversity to inspire innovationthat drives our business, enhance our competitive advantage andserve consumers across the world.

COMMITMENT TO
DIVERSE BUSINESSRELATIONSHIPSPOLICYOUR EMPLOYEES | 14

HARASSMENT-FREE
WORKPLACE
Lenovo will not tolerate discrimination or harassment of any individualwith whom we have a business, service or professional relationship.
This includes discrimination or harassment based on race, color,religion, gender, gender identity or expression, national origin,ethnicity, sexual orientation, sex, age, disability, veteran status, marital
status or any other characteristic protected by local law. We do nottolerate unwelcome verbal or physical conduct of a sexual nature.
When a co-worker’s conduct makes us uncomfortable, we speak out.
If we experience or observe workplace harassment, we should report
the incident to our manager, any other member of management,
HR or the ECO. Lenovo takes harassment claims seriously and will
investigate them thoroughly. Employees who engage in harassment,
discrimination or inappropriate behavior are subject to disciplinary
action, including termination of employment.

COMMITMENT TO
DIVERSITY AND
NON-DISCRIMINATIONPOLICYOUR EMPLOYEES | 15

Harassment can be physical, verbal or visual
conduct that creates an intimidating, offensive,
abusive or hostile environment.
Harassment can take many forms. Some
examples of harassing behaviors include:••••

Unwanted requests for dates
Displaying or sharing offensive or
pornographic pictures or images
Unwanted touching
Offensive or inappropriate language,comments or jokes

Lenovo managers are required by Lenovo
and in some cases, by local law, to report any
harassment as soon as they become aware of thesituation to Human Resources or to the ECO so
the issue can be appropriately investigated.

HEALTH, SAFETY &SECURITY OF EMPLOYEESALCOHOL &SUBSTANCE ABUSE

We are committed to providing a safe and healthy work
environment and preventing accidents. We must observe thesafety and health rules and practices that apply to our job andprotect ourselves and our coworkers, including immediately
reporting accidents, injuries and unsafe conditions.

Lenovo expects employees to report to work able to perform theirduties and free from the influence of alcohol, illegal drugs or theabuse of prescribed or over-the-counter drugs. Using, possessing,buying, or selling illegal drugs or abusing controlled substances
while on the job, on Lenovo premises, operating Lenovo property(including company vehicles) or engaging in Lenovo businessis prohibited and is grounds for disciplinary action, including
termination of employment. Check the policies that apply to yourlocation for additional guidance.

A safe and secure work environment also means a workplace freefrom violence. With the exception of Lenovo security personnel andlaw enforcement, Lenovo prohibits the possession, concealment or
use of any firearm or other weapon on Lenovo premises (including
parking lots and other outside spaces) or in any location outside
the home when conducting Lenovo business. Report any violence,
intimidation or threats of violence as soon as possible to Lenovo
Security or the Legal Department.

RESPONSIBILITY FOREMPLOYEE HEALTHAND SAFETY POLICYWORKPLACEVIOLENCE
POLICYOUR EMPLOYEES | 16

OUR INVESTORSCONFLICTS OF INTEREST
We should avoid situations that may involve a conflict, or evenan appearance of a conflict, between our personal interests andLenovo’s legitimate business interests. Immediately disclose any
situation that may be or could appear to be, a conflict of interest
to your manager and the ECO or Legal Department and remove
yourself from any related decisionmaking process.
When faced with a potential conflict of interest, ask yourself:••

Does this benefit (or could it be perceived to benefit)
me, my family or another business, in conflict with
Lenovo’s legitimate business interests?
Would this activity, if publicized, harm my reputation, my ability
to do my job or embarrass Lenovo?

THE FOLLOWING ARE SOME EXAMPLESCONFLICTS
OF INTEREST
POLICYOUR INVESTORS | 17

EXAMPLES OF CONFLICTS OF INTEREST:
•
•
•
•

•

•
•
•

OUR INVESTORS | 18

Having an employment, contracting or consulting relationshipwith a Lenovo competitor, supplier or customer
Holding a substantial financial interest in a Lenovo competitor,
supplier or customer
Performing non-Lenovo work or soliciting non-Lenovo businesswhile working on Lenovo time
Using Lenovo assets, including equipment, telephones, materials
or proprietary information for unauthorized personal use oroutside work
Accepting any cash, gifts, entertainment or benefits that havemore than a nominal value from any competitor, supplier orcustomer of Lenovo
Using opportunities discovered through Lenovo employment for
personal gain at the expense of Lenovo
Hiring, managing or supervising a relative or romantic partner
Awarding Lenovo business to a relative’s businessOUTSIDEEMPLOYMENT» Q. I took a second job working as
an independent contractor for
a company that sells various
products. Before taking the job, I
received approval from my Lenovo
manager. I recently learned that thecompany will start manufacturingcomponents which may be sold toLenovo or to its competitors. Do I
need to disclose this to my Lenovo
manager as well?
A: Yes. Even though you did the right thing initiallyby obtaining approval for the outside employment,
the circumstances have changed and now
present a potential conflict of interest. You should
consult your manager or the ECO.

OUR INVESTORS | 19

Any outside business activity must be strictly separate from
employment at Lenovo, not compete with Lenovo’s interests, andshould not harm your job performance at Lenovo. We must follow
local Lenovo policies on taking outside employment or participating in
outside business ventures. We may not work for or receive payment
for services from any third party who interacts with Lenovo, including
Lenovo’s suppliers, customers, competitors or regulators without priorwritten approval from management. We may not use Lenovo assets
for any outside business activity without prior written approval frommanagement.

BOARD
MEMBERSHIPS
Serving on a board of directors or similar body for an outsidebusiness, organization (including trade industry associations andstandard-setting boards) or government agency, can also create
a conflict of interest and requires advance review by the ECO andapproval from Lenovo’s management at the level of Vice President
or higher. Serving as a director of a publicly traded company or
any company that is a supplier to or customer of Lenovo requires
the approval of the CEO and General Counsel of Lenovo. Lenovo
encourages our employees to be active in their communities and,
where appropriate, assume leadership positions in community or
non-profit organizations, provided this service does not create aconflict between their duties to Lenovo and their duties to the outsideorganization.

FAMILY MEMBERS &CLOSE PERSONALRELATIONSHIPS
If our family members, romantic partners or people with whom weare in close personal relationships are or may become involved inbusiness activity related to Lenovo, including acting as a Lenovo
supplier, customer or vendor, we should immediately disclose thenature of the relationship to management and HR and must remove
ourselves from any related decision-making process. If we supervise
or are in a position to exercise influence over any aspect of theperformance, compensation or advancement of a family member,romantic partner or someone with whom we have a close personal
relationship, we must report this relationship to a Human Resources
Vice President at Lenovo.

INAPPROPRIATERELATIONSHIPSPOLICYOUR INVESTORS | 20

» Q. My brother’s wife runs a company
that provides cleaning services.
Can I be involved in hiring her
company to work for Lenovo?
A:  No. It creates a conflict of interest between
your desire to help your brother’s wife and yourobjectivity in selecting the best company. You
should disclose your relationship and remove
yourself from the selection process. The cleaning
company may then compete for Lenovo’s
business with other qualified vendors.

» Q. I would like to make a small
investment in Dell stock.
Any problems?
A: No. Small investments in public companies
that compete with Lenovo are fine as long as
you are not basing your decision on confidential
information learned through your position at
Lenovo. If you have questions about whether yourinvestment could cause a conflict, contact the
ECO for guidance.

» Q. I’d like to make an investment in myfriend’s company that competes
with Lenovo. The investment will
give me 25% of the equity in thebusiness and the ability to influence
how the business operates. Any
problems with this?
A: Yes, there is a problem. This businesscompetes with Lenovo and your investment in it
is likely to cause, or appear to cause, you to act
in ways that support your friend’s company, which
would be harmful to Lenovo’s interests.

OUR INVESTORS | 21

PERSONAL INVESTMENTS
Our personal financial investments must not influence, or appear
to influence, our independent judgment on behalf of Lenovo. When
determining whether a personal investment creates a conflict ofinterest, consider the relationship between the business of theoutside company, Lenovo’s business and what you do at Lenovo.
Consider whether the company has a business relationshipwith Lenovo that you can influence and the extent to which thecompany competes with Lenovo.
If there is any doubt about how an investment might be perceived,disclose it as soon as possible to your manager, the ECO or the
Legal Department for guidance.
We are also prohibited from directly or indirectly buying, orotherwise acquiring rights to any property or materials, when
we know that Lenovo may be interested in pursuing suchan opportunity.

CONNECTEDTRANSACTIONS PROCESSWe must comply with Lenovo’s Worldwide ConnectedTransactions Process. Before contracting or transacting withany external entity or individual (including vendors, suppliers or
customers) we must check to determine if the individual or entity
is included on Lenovo’s List of Connected Persons. If an entity or
individual is on the list, you must immediately report the transaction
to Lenovo’s Company Secretary Office before committing or
entering into the contract or agreement.

LENOVO WORLDWIDECONNECTED TRANSACTIONSPROCESSOUR INVESTORS | 22

ACCURACY OF
BUSINESS RECORDS
Investors count on Lenovo to provide shareholders with accurate,
timely and understandable information about the company’s
financial condition. We rely on every employee to ensure that all
books, records and accounts conform both to required accounting
principles and to Lenovo’s system of internal controls. We mustnever conceal or falsify any Lenovo business records.
All business records and communications should be clear, truthful
and accurate. Our communications must avoid exaggeration,
guesswork and insulting remarks or characterizations of people
and companies. We should not include judgments about the law or
any potential legal liability in our communications unless we havebeen authorized to do so by the Legal Department.
Business records must be retained and destroyed according to
Lenovo’s record retention policy unless directed differently by the
Legal Department.
Contact your manager, Internal Audit, the ECO, or the Legal
Department or make a confidential report through the LenovoLine,
immediately, if you suspect that:••

Any Lenovo book, record or account has been falsified or
improperly altered or destroyed or
Improper or illegal action has been taken related toaccounting or financial reportingOUR INVESTORS | 23

» Q. You tried hard to close a big sale
before the end of the quarter.
Unfortunately, the customer was on
vacation and did not accept or sign
the contract until after the quarterhad ended. Your manager wants
your team to meet its numbers andasked you to date the paperwork
back to last quarter. Should you
do this?
A:  Definitely not. It is improper to record false
sales or false dates. Dates, costs and revenues
must be recorded accurately in the proper time
period. If a sale is not yet final, it should not berecorded as final.

Did you know?

Business records include financial books,
records, accounts, receipts, expense reports,
texts, emails, notes, time cards and quality,
safety and personnel records. They may even
include your posts on social media.

» Q. Does Lenovo’s Insider Trading
Policy apply to buying or sellingstock in other companies?
A: Yes. For example, let’s say you learn during
discussions about a new hardware purchasethat a customer plans a major expansion. If you
purchase stock in the customer’s company,
share this information with a friend or tell thefriend to buy stock in the company, it could be
insider trading.

INSIDER INFORMATION& SECURITIES TRADING
In the course of our employment with Lenovo, we may learn nonpublic information (also called “inside information”) about Lenovo orother companies, including our customers, suppliers or business
partners. In some cases, if this confidential information became
public, it could affect the price of Lenovo’s or another company’s
stock. The use or sharing of such non-public information about
Lenovo or another company for your or another’s benefit is called“insider trading.”
All Lenovo employees are prohibited from engaging in insider
trading, even if you will not financially benefit from the information
being shared. Engaging in insider trading can hurt Lenovo andLenovo’s shareholders and may also subject you to civil andcriminal penalties.

CONTINUOUSDISCLOSURE POLICY
PRACTICAL GUIDANCEON THE OPERATION
OF THE CONTINUOUSDISCLOSURE POLICYTRADING IN
SECURITIES POLICYOUR INVESTORS | 24

AUTHORITY TO MAKELENOVO COMMITMENTS
Lenovo’s management system, contracting processes anddelegations of authority are designed to provide the appropriate
controls needed for Lenovo to run our business effectively, comply
with laws and protect Lenovo from waste, fraud and abuse.
We must keep to the limits of our authority to act on behalf ofLenovo and must not take any action to exceed or avoid thoselimits. These delegations of authority set out the rules for whichorganizations and line management have authority to approvepricing and certain other contract terms and conditions.
You are not allowed to make oral or written business commitments
outside of these processes, such as side deals. In addition, allcommitments must be visible to Lenovo Accounting to ensure theaccuracy of Lenovo’s books and records.

DELEGATION OF
AUTHORITY
POLICYOUR INVESTORS | 25

» Q. Can I split purchase orders in order
to avoid delegation of authority
limits or speed up the approval
process if I’m just trying to help theCompany operate faster?
A: No. We must accurately record each of ourbusiness transactions. No Lenovo entry should bemade to conceal or disguise the true nature of atransaction regardless of your reasoning.

PROTECTINGCOMPANY ASSETS
We have a responsibility to protect any Lenovo asset entrusted
to us from loss, damage, misuse or theft. Examples of company
assets include:
•
•
•
•

•

Physical assets like our products, facilities, equipment,
computers and communications systems
Financial assets such as funds, credit cards or bank accounts
Lenovo’s intellectual property including our trademarks,
copyrights and patents
Lenovo proprietary information such as trade secrets, “knowhow,” prototypes, internal and external communications,digital information, hard copy documents, oral discussions andinteractions via social media channels
Customer, consumer, supplier and employee personal
information

Lenovo’s physical and information security policies protect
our assets from theft, loss, damage or misuse. If there is theft, loss,
damage or misuse of company assets, we are responsiblefor immediately reporting the occurrence to the Corporate
Security Department.
We must never use company assets or funds for purposes which
violate the law or applicable policies or procedures. We must not
use any Lenovo intellectual property without proper authorization.
We should never use company assets to create, store or send
content that is illegal or which others might find offensive. If weleave Lenovo for any reason, we must return all Lenovo assets.

OUR INVESTORS | 26

» Q. I have a side business that has
been vetted and approved by
Lenovo management. Can I use
my Lenovo-issued computer tocomplete certain tasks related to
my side business outside of myLenovo work hours?
A: No, you may not use Lenovo assets, including
your Lenovo-issued computer, to further outsidebusiness ventures.

LENOVO INFORMATION &COMMUNICATION SYSTEMS
Lenovo’s information and communication systems, including
telephones and connections to the Internet, are vital to Lenovo’s
business and should only be used for appropriate business-related
purposes. We may use them for conducting Lenovo business orfor other incidental purposes authorized by our management suchas occasional personal use of the telephone, email and the Internetthat does not interfere with company work. We may not use Lenovo
systems to visit Internet sites that feature sexual content, gambling orthat advocate intolerance of others. We also may not use them in amanner that interferes with anyone’s productivity.

OUR INVESTORS | 27

» Q. I sometimes send emails to myspouse and friends to makepersonal plans. May I use my
Lenovo computer to do this?
A: Yes, as long as any personal use is infrequentand does not interfere with your or your coworkers’ job performance. Remember, Lenovo
has the right to monitor its email systems, so you
may prefer to use your personal email for nonwork related communications.

PRIVACY & DATAPROTECTION
Lenovo respects the privacy of our customers, consumers andemployees consistent with privacy and data protection laws andLenovo privacy policies. Our customers, consumers and others
must be able to trust that we will only collect, store, share and use
their personal information for defined legitimate business purposes
and to support and enhance our relationships with them. We
do not sell our consumers’ or customers’ personal information.
We appropriately safeguard our consumers’ and customers’
information and comply with internal policies and applicable laws.
In addition, we protect and appropriately use the personal
information of our employees consistent with all legal requirements.
However, employees are advised that workspace and items
provided to us by Lenovo, including computers, email systems
and telephone voice mail, are the property of Lenovo. Therefore,
Lenovo management reserves the right to access, review thecontents of files, desks and lockers, and monitor telephone andcomputer systems, consistent with the law, this Code, and anyother applicable Lenovo policies.
If you believe that customer, consumer or employee data is being
compromised, contact the Legal Department, the ECO or make areport using the LenovoLine.

DATAPRIVACYPOLICYOUR INVESTORS | 28

» Q. My team is working on launchinga new software experience forour tablet products that will really
improve the consumer’s experience.
However, to enable that experience,
it must collect some user data,
including personal information.
How do I make sure this software
complies with Lenovo’s privacy
standards and legal requirements?
A: Protecting consumers’ privacy and security
aren’t simply legal requirements—they are part of
our Core Values of trustworthiness and integrity.
When developing, launching, marketing andsupporting our products, we must determine
how any user data collection may impact ourconsumers’ privacy rights, their trust in our brand,
and our responsibilities (and those of our vendors
and partners) to appropriately use and safeguard
user data. Contact the Legal Department, theProduct Security Team or Information Security formore information on how to make sure we areprotecting consumer privacy and security.

LENOVO INTELLECTUAL
PROPERTY RIGHTS
Business opportunities and inventions developed through work
belong first to Lenovo, except as otherwise agreed by Lenovo.
Developing or helping to develop inventions or other intellectual
property, during or after work hours, that: 1) relate to Lenovo’s
existing or reasonably anticipated products or services, 2) relate
to your position at Lenovo or 3) are developed using Lenovo’s
corporate resources, are subject to the provisions of youremployee agreements. Ownership of patents remains with Lenovo
even after we leave Lenovo.

INTELLECTUAL
PROPERTY
POLICYOUR INVESTORS | 29

LENOVO CONFIDENTIAL &RESTRICTED INFORMATION
Keeping Lenovo’s confidential and restricted information secretgives us an important competitive advantage in the marketplace.
Lenovo’s confidential or restricted information includes information
about Lenovo that is not generally known to the public andinformation that business partners, customers, suppliers andvendors have entrusted to us.
Unauthorized access, disclosure, loss or use of confidential or
restricted information can seriously harm Lenovo, as well as
our suppliers, consumers, customers and employees. We must
safeguard sensitive information by marking it appropriately, keeping
it secure and limiting access to those who have a specific needto know to do their jobs, even within Lenovo. These obligations
continue even after employment or assignment ends. You may
not take paper files or electronic media containing confidential andrestricted information if you leave the company for any reason.
You may not make copies of confidential or restricted information
unless you are specifically authorized to do so.
Sometimes we need to share confidential information with people
outside the company, for example, to work effectively with acommercial business partner. In such instances, check with yourmanager before you share any information. We should make surea valid non-disclosure agreement is in place before we shareany information, and we should limit the information as much as
possible. Consult the applicable non-disclosure agreement andcontact your manager or the Legal Department for help.

OUR INVESTORS | 30

Just as we protect our own confidential or restricted information,
Lenovo respects and confidential or restricted information ofothers, including our employees, consumers, customers, suppliers
and other third parties. We may only use, copy or disclose thirdparty information in compliance with a valid non-disclosureagreement.

» Q. My manager has asked me to prepare

our department’s budget, which meansthat I will need to get information about
the salaries of some of my colleagues.
May I also get information about thesalaries of other coworkers in otherdepartments or comment to a coworker about his or her salary?
A: Absolutely not. While preparing a detailed
budget presents a legitimate business need
to obtain certain confidential employee
information, you must keep this information
confidential and share it only with those whohave a business need to know it. You must
not use the project as an opportunity to view,share or comment on sensitive and confidential
information about other employees.

Did you know?

Much of the information we use every day in our jobs at
Lenovo is confidential and must be protected. Here are

Avoid Inadvertent Disclosure—Be careful as you may disclose
non-public information and secrets without realizing it. You
could be overheard in a public place or someone could see
your computer or phone screen without your knowledge. Avoid
discussing confidential information in airplanes, buses, trains,taxis, airports, restaurants, restrooms, elevators and company
common areas. Even small pieces of information may be pieced
together to form a complete picture.

some examples:

Employees attending conferences, symposiums and industry
events should use caution when interacting with industry
colleagues. Even sharing information with family and friends on
projects and assignments may present a breach of confidentiality.

INFORMATIONSECURITYPOLICY
CLASSIFICATION
OF LENOVOINFORMATIONOUR INVESTORS | 31•

Research and technical data•

Business plans or strategies•

Customer lists•

Contracts with customers•

Vendor or supplier internal information•

Commodity and product volumes•

Current projects•

Human Resources data•

Financial results and projections•

Future or unreleased products (prototypes)•

Product roadmaps and development plans•

Undisclosed product specifications•

Inventions or trade secrets•

Information concerning potential acquisitions•

Data collected from consumers or from active devices
in the field

THE
MARKETPLACEGIFTS, ENTERTAINMENT,CORPORATE HOSPITALITY& TRAVEL
Our relationships with suppliers, customer and others must be
based entirely on sound business decisions and fair dealing.
Business gifts, entertainment and corporate hospitality can help
build relationships, but they can also make it harder to be objective
about the person or company providing them. We may never:•••

Solicit, offer, accept or provide any gifts, entertainment,
corporate hospitality or travel if it will obligate or appear to
obligate the person who receives it.
Solicit, offer, accept or provide to anyone cash or cash
equivalents, lavish or frequent gifts or entertainment, or
anything that might look like a bribe.
Provide or accept sexually-oriented gifts or entertainment.

GIFT, ENTERTAINMENT,CORPORATE HOSPITALITY
AND TRAVELPOLICY

THE MARKETPLACE | 32

GIVING &RECEIVING GIFTS
Lenovo employees, consultants or contractors may notoffer gifts to, or receive gifts from, our suppliers, customers
or other business-related entities unless all of the following
four conditions as well as the conditions of the Global Gift,
Entertainment, Corporate Hospitality and Travel Policy are met:
1. Moderate value. This value varies by country. An
inexpensive courtesy gift such as a promotional
item has a “moderate value” anywhere. Check the
Global Gift, Entertainment, Corporate Hospitality andTravel Policy or contact the ECO for guidance on whatgifts may be accepted or provided.
2. Customary and appropriate. The item is considereda customary and appropriate business gift in the
country where it is offered and offering or accepting it
would not reflect poorly on Lenovo if the details weremade public.

THE MARKETPLACE | 33

3. No favored treatment. The gift is not offered in
expectation of special or favored treatment.
4. Legal and approved. Offering or accepting the giftis legal in the location and under the circumstanceswhere given and does not violate the policies of thegiver or the recipient, and the giver and the recipient
have both received the appropriate approval to accept
the gift.

» Q. One of our suppliers that iscurrently negotiating the renewal ofa large contract with Lenovo hasoffered me two tickets to the World
Cup. Can I accept them?
A: It depends. In this situation, it could beperceived that the tickets were offered as a bribe
to secure the outcome of the contract renewal,
so you should not accept the tickets. If we were
not in the middle of negotiations with the supplier,
we should seek out approval from our direct
manager before accepting the tickets. Gifts orentertainment above certain limits may also haveadditional approvals required. Consult the Global
Gift, Entertainment, Corporate Hospitality andTravel Policy or contact the ECO for guidance.

THE MARKETPLACE | 34

ENTERTAINMENT& TRAVELWith appropriate approval, you may give or accept customary
entertainment or business courtesies, such as meals, provided
the expenses are reasonable and are not prohibited by law or byeither party’s policies or standards of conduct. You must receive
pre-approval from your manager before accepting any travel fromor providing any travel to any customers, suppliers, vendors orother third parties.

PROVIDING GIFTS, ENTERTAINMENTOR TRAVEL TO GOVERNMENTOFFICIALS OR EMPLOYEES
Laws concerning providing gifts, hospitality and travel togovernment officials (which include executives and employees ofgovernment-owned corporations, newspapers, television stations,
universities and other entities affiliated with governments, and public
international organizations like the U.N.) are complex and can varyfrom country to country. In many cases, it is illegal and improper toprovide gifts to government officials. We need to take special carein this highly regulated area, as Lenovo wishes to avoid even theappearance of impropriety. No gift or business courtesy may beprovided to a government official or employee unless the four
conditions on page 33 are met and only if allowed under the
Lenovo Global Gift, Entertainment, Corporate Hospitality and Travel
Policy.
Contact the ECO, the Legal Department or Government Affairs for
guidance about the rules that apply in your area.
I

THE MARKETPLACE | 35

If you are offered cash or cash equivalents, or a gift that has morethan nominal value or which is not customarily offered to others,
tell your manager immediately. Appropriate arrangements will bemade to return or dispose of what has been received and the
supplier or customer will be reminded of Lenovo’s gift policy.
“Gifts” can be anything of value, including tangible items, services,
meals, entertainment, hospitality, transportation, use of vacation
facilities, home improvements, membership fees or dues, tickets,
internships, discounts, charitable donations, offers of employment
and gift certificates. The list of things that might be considereda gift is endless. An extravagant or expensive gift or extravagant
entertainment should not be accepted, regardless of the effect itwill have on your business judgment. Consult your manager, theECO or the Legal Department with questions.

ANTI-CORRUPTION LAWS
& BRIBERY
We comply with the anti-corruption treaties and laws of the countries
in which we do business. We will not directly or indirectly offer or give
anything of value to any person, including to government officials, toinfluence official action or to secure an improper advantage as definedby applicable laws. “Government officials” include any government
employee; candidate for public office; or employee of governmentowned or controlled companies, public international organizations orpolitical parties. Anything of value includes cash or cash equivalents,
gifts, meals, travel, political or charitable contributions and job offers
for government officials’ relatives. These requirements apply both to
Lenovo employees and representatives and to our channel partners,
agents or other third parties working on Lenovo’s behalf no matter
where they are doing business.
No Lenovo employee or representative will suffer any retaliation forrefusing to pay or take a bribe or kickback, even if this results in a lossof business to Lenovo.
Lenovo prohibits making any direct payments of any size togovernment officials, either directly or through a third party, including
to expedite routine non-discretionary government actions including
processing visas; obtaining permits and licenses; providing police
protection or mail service; or scheduling inspections associated with
contract performance. These types of payments are sometimes
referred to as “facilitating” or “grease” payments.

ANTI-CORRUPTION& ANTI-BRIBERYPOLICY

THE MARKETPLACE | 36

» Q. A government employee suggested
that he would strongly encourage
his employer to award us a contract
if a “donation” is made to one of his
manager’s favorite charities. Whatshould I do?
A: Do not agree to the request as it is most likely
a request for a bribe. Any suggestion or request
for funds that is not defined for an appropriate
business purpose, including charitable donations,
may be used improperly as a bribe. End theconversation and immediately report the matter to
ECO or the Legal Department.

» Q. My manager wants to give agift to an official who participatedin an event at our factory. Is
that acceptable?
A: It depends on the gift. In some cases, you may
provide a gift of nominal value, such as a token
with the Lenovo logo to an official, but you must
make sure that any gifts comply with Lenovo’s
Code of Conduct and Gift, Entertainment,
Corporate Hospitality and Travel policy. We must
be very careful in this area as gifts to government
employees/officials create a high risk for thecompany and may be seen as a bribe.

» Q. I am told that government
approvals cannot be obtained insome countries without making apayment to a government official.
Is it permissible to hire a consultant
to help with government approvals,
and simply not ask him where themoney goes?
A: No. There is nothing improper about using
consultants but the law prohibits bribery
payments made directly or indirectly. You cannot
allow third parties to make improper paymentsfor Lenovo, and you should always know what a
consultant is doing on Lenovo’s behalf.

THE MARKETPLACE | 37

GOVERNMENTCUSTOMERS
Many governments around the world have laws, regulations andcontractual requirements that apply to the purchase of products
from private suppliers like Lenovo. These laws are intended toensure that governmental entities can buy products and services
at competitive prices and to protect against attempts to improperly
influence the bid process. Lenovo must comply with all applicableprocurement laws, rules and contractual requirements when selling
products to government entities—which may include schools,
hospitals and other entities in addition to government agencies.
Be familiar with local laws, regulations and Lenovo guidelines
applicable to government sales in your geography. If you needguidance, consult the Legal Department.

PRODUCT &QUALITY SERVICE
Lenovo is committed to quality and achieving consumer
satisfaction by delivering superior products and experiences.

PRODUCTQUALITY
POLICYREPRESENTATIONSREGARDING LENOVO
PRODUCTS
We must ensure that all representations we or our agents makeabout Lenovo products and services, such as about speed,
battery life and durability are truthful and accurate. This includes
representations made in marketing or product literature, verbally,on the Internet, in social media or sales presentations. We mustnever make deliberately misleading or false claims about Lenovo’s
or our competitors’ products, and when commenting about
our products on social media, we should never misrepresent ouraffiliation with Lenovo, and where required by law, we should
disclose that we are employees of Lenovo.

THE MARKETPLACE | 38

TREATING OUR
BUSINESS PARTNERS
WITH INTEGRITY
We treat consumers, customers, competitors and suppliers fairly
in all of our activities. We will not manipulate or abuse confidential
information. We base our decisions on legitimate business-related
criteria, not on personal relationships or interests. In deciding
among competing suppliers of any size, we should weigh thefacts honestly and impartially and follow Lenovo’s procurement
process. We seek to do business with organizations that comply
with applicable laws and follow principles consistent with the onesin this Code.

THE MARKETPLACE | 39

EXTERNALCOMMUNICATIONS/MEDIA RELATIONS
We will not make statements to the news media on Lenovo’s
behalf, or provide company information to outside parties, withoutauthorization. Good judgment and common sense must always
be used when posting on social media outlets. Remember, oncea statement is posted, it cannot be retracted. Consider how the
public will view your comments. Review Lenovo’s Social Media
Guidelines on lenovocentral.com. Contact the Legal Department or
Corporate Communications with questions.

SOCIALMEDIAGUIDELINES

THE MARKETPLACE | 40•

Communications with journalists and the media are
only managed by Lenovo Communications.

•

Communications with securities or financial analysts
and with shareholders are only managed by Lenovo
Investor Relations.

•

Communications with outside lawyers and law
enforcement are only managed by Lenovo’s Legal
Department or Corporate Security.

PROTECTING INFORMATION& INTELLECTUAL PROPERTYBELONGING TO OTHERS
While we can gather information available in the general marketplace,
we may not use any illegal or improper means to acquire acompetitor’s trade secrets or other confidential or competitive
information. Improper solicitation or intelligence-gathering could
subject you or Lenovo to civil and criminal legal penalties. Employees
joining Lenovo after having worked for any other company may notshare any of the other company’s trade secrets or other confidential
information with Lenovo.
If we obtain information that may constitute a trade secret or
confidential information of another business, even by mistake, or if wehave questions about the legality of information gathering, we must
consult the ECO or the Legal Department.
Materials we use every day are protected by copyright law, including
software, books, audio and video files, trade journals and magazines.
At Lenovo, we respect and work to protect others’ copyrights anddo not copy, alter or distribute copyrighted material without thepermission of the copyright owner. If you acquire software for yourpersonal use, do not copy any part of such software in any work you
do for Lenovo, nor should we place such software on any Lenovoowned computer system or other Lenovo property.

INTELLECTUAL
PROPERTY
POLICY

THE MARKETPLACE | 41

» Q. Lenovo just hired a sales manager
from one of our competitors. He
knows their product and sales roadmap for the next year. If he shares
this information, can we adjust ourplan to compete accordingly?
A: No. We may not ask new employees to shareconfidential information belonging to their previous
employer, and they certainly should not provide it.

FAIR COMPETITION
As a global corporate citizen, Lenovo is responsible for complying
with what are called “antitrust” or “competition” laws. Under theselaws, agreements among competitors that restrict trade or pricecompetition are illegal.
Lenovo employees must maintain independence of judgment andaction in designing, producing, pricing and selling our products
and services and must avoid even the appearance of colluding or
making an agreement with a competitor. Local laws may vary, but
the following principles apply everywhere Lenovo does business.

» Q. At a recent conference, I met an oldfriend who is now vice president for acompetitor. During the conversation,
he volunteered some information
about their pricing strategy and future
pricing trends. I quickly told him thiswas an inappropriate conversation andwalked away, and then left a voicemail
for my contact in the Lenovo Legal
Department. Was I overreacting?
A: You did the right thing. If you find yourself in a
meeting where competitors are discussing pricing
strategy, you should leave immediately and contact
the Legal Department immediately about what
happened. Even if you don’t use the information,
there may be a perception that you are participatingin activities prohibited by competition laws, which
can create legal issues for you or Lenovo.

THE MARKETPLACE | 42

Do not make agreements with competitors
No employee should enter into an agreement or discussion withany competitor that would set prices, limit the availability on
the market of goods or services or agree to boycott a customeror supplier.
Avoid sharing competitively sensitive information
Employees should not discuss any competitive information with acompetitor including: prices or discounts; terms of sale including
credit, profits, profit margins or costs; allocation of customers ormarkets; boycotts; customers; suppliers; market share; distribution
practices; bids or intents to bid; sales territories or markets;
selection, classification, rejection or termination of customers.
Do not make false or deceptive comments regarding
competitors
We must ensure that our statements about Lenovo’s competitors
are based upon current, accurate, complete and relevant
data. To avoid even the appearance of impropriety, we do notcomment on another company’s business reputation or financial
or legal problems.
Be careful when entering pricing agreements with resellers
Setting or attempting to influence resellers’ prices or margins may
violate competition laws. Seek advice from the Legal Department
for guidance specific to your region. If you have questions withregard to any of these guidelines contact the Legal Department.

COMPETITIONPOLICY» Q. A supplier has asked me to put alow value on a shipping invoice sothat the supplier doesn’t have to
pay duties. Since we didn’t buy theequipment and Lenovo won’t be
the importer, does it matter whatvalue is used?
A: You must always list the accurate values onany documents or records, including shipping
invoices. You must never falsify invoices for any
reason, including lowering or circumventing
customs’ duties, fees or charges or for expeditingtransit times. If you have questions about what todo, contact Global Trade Regulation in the Legal
Department.

» Q.

If an employee carries a productin his briefcase to deliver
to another Lenovo employee
in another country, does thatmean the product will be“imported” and does it require
special consideration?
A: Yes, any product that is not for your personaluse is subject to the relevant import/export
requirements and procedures. Seek guidancefrom Global Trade Regulation in the Legal
Department.
THE MARKETPLACE | 43

IMPORT & EXPORTCONTROLS
We comply with all applicable import and export laws, regulations,and restrictions. Import and export laws apply to:••

Products, services, information, technology, payments
for goods or services, countries or third parties (including
people) we do business with.
Technical data relating to the design, production and use of
products or services.

When we travel internationally on company business, we, and theitems we carry with us, are subject to laws governing what we importand export. Employees are responsible for knowing the laws thatpertain to them. When in doubt, employees should contact Global
Trade Regulation in the Legal Department.

COMMUNITY& SOCIETY

THE ENVIRONMENT
We are committed to promoting and maintaining environmentally
responsible manufacturing and other business practices forthe benefit of our customers, consumers, employees andthe communities in which we operate. We strive for continual
improvement by developing specific programs that address theenvironmental cost and impact of our activities, products
and services.

ENVIRONMENTALAFFAIRSPOLICYLENOVOSUSTAINABILITYREPORTSCOMMUNITY & SOCIETY | 44

POLITICAL PROCESSAs a global business, Lenovo maintains good relationships withgovernments around the world and strives to be a good corporate
citizen everywhere we operate. Lenovo Government Relations is
responsible for coordinating Lenovo’s communications, lobbying
and other interactions with government officials and policy makers.
Lenovo employees should not lobby, communicate with public
officials on policy matters, make political contributions, provide
equipment or services or engage in political activities on Lenovo’s
behalf except in accordance with applicable law or policy and incoordination with Lenovo Government Relations. Of course, you
may participate in political activities on an individual basis, withyour own resources, and on your own time.
For additional information or guidance, please contact the Legal
Department or Government Relations.

GOVERNMENT RELATIONS, POLITICALCONTRIBUTIONS,AND PARTICIPATION IN POLITICSCOMMUNITY & SOCIETY | 45

ANTI-MONEY
LAUNDERINGCOMMITMENT TO
HUMAN RIGHTS

Money laundering is a process designed to conceal an illegal
source of money to make it appear legitimate. Lenovo will not
directly or indirectly participate in such practices. Use good
judgment when dealing with customers or business partners, andimmediately report any unusual or suspicious activities including
large payments in cash, arrangements for payment to be made bysomeone not involved in the transaction and payments made fromunusual sources and in different currencies than those provided
for in a contract. Direct any questions or concerns to the ECO or
Legal Department.

Lenovo is committed to respecting human rights and conducting
business legally, ethically and with integrity. As part of thiscommitment, Lenovo operates with respect to the universal humanrights identified in the UN Declaration on Human Rights and inaccordance with the UN Global Compact. Lenovo does not permit
the use of child labor, forced labor or physical punishment in any
Lenovo operations.

HUMAN RIGHTSPOLICYCOMMUNITY & SOCIETY | 46

COMMITMENT TOCOMMUNITY
We are proud of Lenovo’s contributions to the quality of life and culture
as well as the economic and social development of the communities
where we do business. Lenovo encourages each of our facilities
to become actively involved in their community by sponsoring andparticipating in initiatives that contribute to a better quality of life.
Lenovo strongly encourages our employees to support this goalby volunteering and participating in charitable and community
activities as well as professional development associations.
When engaging in community activities, we may encounter
situations covered by the Code. For example, we should follow
the guidance regarding “conflicts of interests” and may not use
Lenovo resources for any outside activities without permission.
When we participate in an activity that Lenovo does not sponsor,
we should not imply the company’s support without theappropriate authorization.

COMMUNITY & SOCIETY | 47

» Q. A large charitable organization
recently purchased somecomputers from Lenovo. As thesales manager, can I show myappreciation by making a donationfrom my sales budget?
A: Charitable contributions that are linked tosales or potential sales could hurt Lenovo’s
reputation and are improper. Lenovo’s charitable
contributions should be determined based on theorganization’s need, Lenovo’s ability to help anda number of other factors. For further guidance,
contact the Government Relations Department,
Legal Department or ECO.

WHERE TO GO
FOR HELP
We work hard to foster an environment of open, honest
communication. If you have a concern related to the Code or
about a legal, compliance or business conduct issue, you haveseveral options. What matters most is that you ask the question
or raise the concern. Confidentiality will be maintained to theextent possible, given the company’s need to investigate andresolve the issue raised and to comply with the law. You canspeak with:
•
•
•
•
•
•

Your manager (or another manager you trust)
The Lenovo ECO (ethics@lenovo.com)
Human Resources
Lenovo Legal Department
Lenovo Internal Audit
The LenovoLine
In China, you can report misconduct to Lenovo’s
Independent Commission Against Corruption(ICAC@lenovo.com)

COMMUNITY & SOCIETY | 48

NO RETALIATION
If you seek advice, raise a concern relating to a potential
compliance issue, or report suspected misconduct in goodfaith, you are doing the right thing. We strongly encouragesuch actions. Lenovo will not tolerate retaliation againstyou. Anyone engaging in retaliation will be subject todisciplinary action including termination of employment.