Apple (AAPL)

Records count.  They are a vital part of maintaining a high level of ethical business transactions.  Apple records must be maintained and disposed of properly, in accord with established procedures and Apple policies.  All business and accounting transactions must be fully and

Page 7

accurately described in Apple’s formal records, and payments on Apple’s behalf should never be made other than as described in the records.  At Apple, there is never any reason for false or misleading entries, and there is no place for undisclosed or unrecorded funds, payments, or receipts.

Apple is required by local, state, federal, foreign and other applicable laws, rules and regulations to retain certain records and to follow specific guidelines in managing its records.  Civil and criminal penalties for failure to comply with these guidelines can be severe for Apple and its employees, agents and contractors, and failure to comply with these guidelines may subject an employee, agent or contractor to disciplinary action, up to and including termination of employment or business relationship at Apple’s sole discretion.

A “legal hold” suspends all document destruction procedures in order to preserve appropriate records under special circumstances, such as litigation or government investigations.  Apple’s Law Department determines and identifies what types of records or documents are required to be placed under a legal hold.  Every Apple employee, agent and contractor must comply with this policy.  Failure to comply with this policy may subject the employee, agent or contractor to disciplinary action, up to and including termination of employment or business relationship at Apple’s sole discretion.  Apple’s Law Department will notify you if a legal hold is placed on records for which you are responsible.  You then must preserve and protect the necessary records in accordance with instructions from the Apple’s Law Department.