Kupertino Corporation


Important Notice




Kupertino Corporation aims to be a “world leading company”, devoting our human resources and technology to create superior products and services, thereby contributing to a better global society.

The Code provides the action lines which must be followed by the Kupertino Corporation (hereinafter, “Kupertino” or the “Company”) and its employees in the performance of their professional duties.

To achieve this goal, we share and pursue Kupertino Values of: People, Excellence, Change, Integrity, Co-prosperity and the 8 Factors of a World Leading Company of: Dream, Vision & Goal, Creativity & Challenge, Insight & Good Sense, Technology & Information, Trust & Credibility, Speed & Velocity, Change & Innovation within the organization.

Furthermore, all Kupertino employees should follow this Global Code of Conduct as well as the Kupertino Business Principles in order to comply with laws and ethical practices as well as to express our concrete commitment to social responsibility. This Global Code of Conduct will be the guiding standard for everyone in Kupertino, outlining standards of conduct in all business activities.

Therefore, the Code:

  • Allows gaining awareness and enforcing Kupertino’ s business culture, deeply rooted in respecting human and labour rights and in the effective inclusion within the company of the whole group of employees, respecting their diversity.
  • We endeavor, with a sense of urgent awareness that we cannot survive without innovation, to achieve future competitiveness by responding Speedily to the changes in the business environment and customer demand, and to maintain a sustained commitment to Change & Innovation based on our Dream, Vision & Goal.
  • We cultivate Creativity & Challenge, acknowledging that future competitiveness depends on the development of Technology & Information ahead of competitors.
  • We aspire to become qualified experts in our field with high-quality work to foresee the future, understanding they for identify and take advantage of opportunities.
  • We create an open culture where employees are encouraged to make decisions and act proactively with a sense of ownership, based on the mutual respect of individuality and Trust & Credibility.
  • We pursue co-prosperity by maintaining relationships of Trust with business partners, and facilitating sound management through mutual cooperation.
  • Lays down the principle of due diligence regarding the prevention, detection and removal of irregular conducts, regardless of their nature, including, among others, risks review, definition of liabilities, training of employees and, where appropriate, of third parties linked to the company, and procedures standardization, namely to give notice and to immediately remove irregular conducts.
  • The Code takes into account the principle of criminal liability of legal persons, addressed in the legal system of different jurisdictions where Kupertino operates, and prevents and forbids the existence of any behaviour which may entail that the company is deemed to be liable, from its legal representatives, directors, employees or any other party under the authority of any staff member.

The Code applies to all the companies which form Kupertino and it is binding for their whole staff, regardless of the office they hold and the duties they perform.

The enforcement of the Code, in full or in part, may extend to any physical and/or natural person linked to Kupertino, where this is expedient to achieve its goal and possible, given the nature of the relationship.

Notice of this Code shall be given in person to all the Directors, Officers and any other person representing Kupertino, where the type of relationship with the company so requires, and they shall undertake in writing or special electronic (SSD) to abide by it. Likewise, this obligation to enforce the Code shall be expressly provided in the employment agreements entered into with the employees, who will receive a links of the Code upon joining the company.

The exemption from the obligation for specific cases duly evidenced may be authorized by the CEO, General Director, First Deputy of General Director which shall report such fact, as soon as possible in the SSD.

Global Code of Conduct

Main Points

The Code of Conduct is defined as an ethical commitment that includes basic principles and standards for the proper development of the relations between Kupertino and its principle stakeholders wherever it carries out its business activities.

The Code is based upon the following principles:

  • All the operations of the Kupertino Corporation shall be developed under an ethical and responsible perspective.
  • Compliance with laws and regulations of each country.
  • The conduct of Kupertino’s employees shall follow in letter and spirit the provisions of this Code of Conduct and Responsible Practices.
  • All persons, whether natural or legal, who maintain, directly or indirectly, any kind of professional, economic, social or industrial relationships with Kupertino shall be treated in a fair and honourable manner.

No one who is employed at Kupertino shall be discriminated against because of their race, physical disability, illness, religion, sexual orientation, political views, age, nationality or gender.

Kupertino forbids any manner of physical, sexual, psychological or verbal harassment or abuse to its employees, as well as any other behavior which may create an intimidating, offensive or hostile environment.

The employees of Kupertino have their right recognised to associate or organise themselves or to bargain collectively.

Working hours and overtime shall not exceed the statutory limit set forth in the laws and regulations of each country. Overtime shall always be voluntary and paid according to law.

Kupertino’s employees are paid wages in accordance with the duties performed, always respecting the agreements of each sector in each country.

All Kupertino’s employees perform their work in safe and healthy workplaces.

Kupertino undertakes to offer to all its customers a high standard of excellence, quality and safety in all its products, and to have a smooth and transparent communication with them. Such products shall be manufactured in an ethical and responsible manner.

Kupertino will perform its activity pursuant to the social interest, it being understood as the feasibility and maximization of the company’s value in the long run.

Kupertino´s business partners are bound to comply with the contents of this Code.

Manufacturers which produce the goods sold by Kupertino are bound to comply with the Code of Conduct for Manufacturers and Suppliers and with this Code, as applicable. The remaining suppliers of goods and services for Kupertino shall comply with both Codes, as applicable to them. Likewise, they shall allow any monitoring by Kupertino or any authorised third parties, to verify such compliance.

Kupertino undertakes to collaborate with the local, national and international communities where it operates.


Laws & Ethical Standards

We respect dignity and diversity of individuals

  • The Company will respect the human rights of all employees and will not discriminate against on the basis of race, color, creed, national origin, gender, age, citizenship, religion, regional background, physical disability, marital status, or any other characteristics protected by law.
  • The Company will not employ underage persons, as commonly defined by international standards and relevant national laws.
  • The Company respect the rights to freedom of association and collective bargaining in accordance with the local labor laws where our worksites operate in order to maintain and develop our cooperative labor-management relations based on mutual trust and integrity.
  • The Company will determine conditions of employment and compensation for personnel in a fair and non-discriminatory manner, taking into consideration relevant international standards and national, local or state laws, with the laws of host jurisdiction prevailing.
  • The Company will ensure that working hours of personnel will be in accordance with the specific nature of their duties and comply with national, state and local laws.
  • The Company will ensure that management will not (i) engage in abusive behavior; (ii) encourage or condone conduct that violates the Company’s Code of Conduct, policies or procedures; or (iii) impose non-work-related duties upon employees.

Kupertino considers individuals to be a key business factor, it upholds and promotes observance of human and labour rights and undertakes to enforce the regulations and best practices in the field of employment conditions and health and safety at work.

The workforce shall contribute to the strict observance of applicable employment standards and to the prevention, detection and removal of any irregularity with this respect.

We compete in accordance with laws and business ethics

Kupertino is a loyal competitor within the market and it does not admit any misleading, dishonest or malicious conduct whatsoever.

Kupertino’s employees shall carry out any search for commercial or market information without infringing any regulations protecting it. Employees shall reject any information about any competitor improperly gathered or gathered in breach of the confidentiality kept by the lawful owners of such information. Namely, especial attention shall be drawn to not breaching any secret of the company where professionals from other competing companies of the sector would join Kupertino.

Workforce shall likewise refrain from disclosing any malicious or false information about the competitors of the company.

  • The Company will compete freely and fairly at all its business sites around the world, abiding by relevant international standards and national, state and local laws, with the laws of the host jurisdiction prevailing.
  • The Company will not abuse a dominant market position nor use coercion to cause inclusion of unwanted items in any sales transactions (tying).
  • The Company will not enter into price fixing, bid collusion, market collusion or reduced production agreements with competitors, and will not discuss with competitors prices, bids, customers, sales territories and conditions including price confirmation.
  • The Company will not permit the acceptance of money, goods, entertainment and/or share offers of stock from customers or external interested parties, nor allow any improper activities that violate laws and fair trade principles.

We compliance with applicable laws and internal regulations

Regulatory compliance is a prerequisite of this Code. Kupertino’s workforce must comply with all applicable laws and regulations in each and every country where Kupertino manufactures, distributes and sells its products. Enforcement of this Code shall in no event entail infringing any of the prevailing legal provisions in force in any country where Kupertino operates.

Kupertino’s workforce shall comply with the internal regulations and procedures of the company, and follow the directions which may be given in the implementation thereof.

Any existing local Codes of Conduct shall be aligned with and meet the standards hereunder provided and this Code shall prevail over any other internal regulation, unless this latter is more exacting. Such local Codes and any implementing instruments need to be approved first by the Head of the Sphere and General Heads.

For the sake of due internal control, decisions of Kupertino’ employees shall be traceable from the perspective of regulatory compliance; therefore, where such decisions are reviewed by any authorised third party or by the company itself, their adjustment to internal and external regulations need to be evidenced and verified.

Kupertino undertakes to provide all required means for its employees to be aware of and to understand the internal and external regulations required for the performance of their duties.

In the event of any breach of this Code, the Company relies on a procedure to make enquiries and to give notices which allows anyone involved with the company to report in a confidential manner any irregularity which may entail an infringement of the Code.

We enforcement of agreements and conventions

Kupertino makes its own, as part of its internal regulations, the contents of any national and international agreements and conventions to which it has adhered, and undertakes to promote and enforce them.

We maintain transparency of accounts with accurate recording of transactions

Other than regarding the selling at stores activity, regarding their relationship with third parties, Kupertino’s employees shall avoid, as a rule of thumb, any cash payment, and payments in currencies other than the agreed one. Anyway, payments shall adjust to the policies defined by the Financial Management Department. Likewise, employees shall exercise special control on any unscheduled payments to or by any third parties not previously mentioned in the relevant agreements, on payments made to any bank account other than the usual one used in the transactions with any given organization or individual; payments made to or by any individual, company, organization or to any account opened anywhere that is deemed to be a tax haven and those payments made to organizations whose shareholder, owner or ultimate beneficiary cannot be identified.

Employees shall require compliance with all regulations regarding processes of new registrations or declaration of origin of goods, supervising compliance with the standards and procedures laid down by the company in this field.

  • The Company will accurately record and manage all transactions in compliance with international standards and national accounting regulations, and will be subject to accounting audits by outside parties at regular intervals.
  • The Company will make every effort to refrain from entering into a business relationship with customers of uncertain identity, and will not participate nor cooperate with illegal, false, or irregular transactions

We do not get involved in politics and maintain neutrality

Kupertino develops its business model without having any political interference in those communities where it carries out its manufacture, distribution and/or commercialisation activities.

Any relationship that the Kupertino Coproration may have with any governments, authorities, institutions and political parties shall be based upon the principles of legality and neutrality.

Contributions, whether in cash and/or in kind that might be made by the company, where applicable, to any political parties, institutions and public authorities, shall always be made in accordance with the current legislation in force and ensuring the transparency thereof; for such purposes, a previous report of the Legal Department evidencing that any such contributions are lawful, shall be required.

The right of the employees to take part in lawful political activities is hereby acknowledged, provided that said activities would not interfere with the appropriate performance of their work for the company and that they would take place during non working hours and outside any of Kupertino´s facilities so that these activities may not be attributed to the company.

  • Employees shall not attribute their personal political opinions and conduct to the Company, or cause such opinions or conduct to be attributed to the Company
  • The Company’s resources, including financial resources, manpower, and facilities shall not be used to further political goals.
  • The Company will refrain from illegal donations and improper dealings with governments, and will respect related national, state and local laws of the host jurisdiction.

We control of transactions

Any and all transactions carried out by Kupertino which may have an economic impact shall be clearly and accurately shown on the appropriate records of accounts, as a true representation of the transactions carried out, and they shall be made available to the internal and external auditors.

Kupertino’s employees shall enter the financial information on the company’s systems in a full, clear and accurate manner, so that they would show, as at the relevant date, their rights and obligations in accordance with the applicable regulations. Additionally, the accuracy and integrity of the financial information which, under the prevailing regulations in force shall be disclosed to the market shall be ensured.

Kupertino undertakes to implement and maintain an appropriate internal control system on financial reporting, ensuring the regular supervision of the effectiveness of such system. Accounting records shall be at all times made available to the internal and external auditors. For such purposes, Kupertino undertakes to provide its employees with the necessary training for them to understand and comply with the commitments undertaken by the company regarding the internal control on financial information.

Exercise of other activities

Kupertino’s employees shall only be able to develop any working or professional activities other than those carried out for Kupertino, where same shall not diminish the efficiency required in the performance of their duties.

We protect information on individuals and business partners

  • The Company and its employees will abide by the national, state and local laws relating to protection of the privacy of its employees’ personal and confidential information.
  • The Company will obtain, through normal business processes, information relating to individuals, corporate customers, or business partners and will use such information for business purpose only. The Company will ensure that the means for obtaining such information and its use comply with national, state and local laws. The Company will not disclose such information to third parties.


Clean Organizational Culture

We make a strict distinction between public and private affairs in our duties

Kupertino’s employees shall maintain lawful, ethical and respectful relationships with the authorities and public institutions in such countries where they conduct their business, in line with international provisions on anti-corruption and anti-bribery policies. Such employees involved in any relationship with representatives of public authorities shall have the prior express authorization of the company for such relationship.

Any staff members involved with public administrations shall formally document all decisions made and evidence compliance with internal and external regulations, in order to help any third parties and control bodies within the company to review regulatory compliance in this field.

As a rule of thumb, no employee of Kupertino may offer, grant, demand or accept, whether directly or indirectly, any gifts or donations, favours or compensations, regardless of their nature, to or from any public authorities or servants.

The foregoing does not apply, however, to such gifts and tokens of scarce economic value, equitable and reasonable according to local practice, and transparent, and which are given on account of lawful, socially accepted interests, and which are occasional to avoid that their contents or recurrence might lead any independent third party to question the good faith of the employee or the company. Cash gifts are expressly forbidden.

It is incumbent on each employee to be duly informed and to appropriately assess local practices, taking into account the interest and good name of the company. In case of any doubts, they shall be addressed to their Head.

Anyway, usual practices about gifts and tokens shall be duly monitored, assessed and registered by the company.

Kupertino’s employees shall refrain from making any facilitating or expediting payments, consisting of giving out money or any other valuables, regardless of their amount, in order to ensuring or speeding up any bureaucratic proceeding, regardless of its nature, vis-à-vis any court, public administration or official agency.

Employees shall avoid getting any undue tax benefit for Kupertino and shall make sure that the information reported in this field to the tax authorities is true and accurate and fairly presents the real status of the company. They shall also make sure that aid demanded or received from public authorities is duly allocated and that the application for such aid is transparent, without resorting to tampering the application so as to be granted such aid, or allocating it to any use other than the one for which it was granted.

In such countries where there are requirements and restrictions regarding international trade, Kupertino’s employees shall strictly comply with the prevailing regulations in force and shall provide the required information on their activities to any authority which may have requested it.

  • The Company will not permit any illicit activity for the pursuit of personal gain, such as irregular treatment of expenses, using one’s position for private gain, or the embezzlement of corporate assets.
  • The Company will not permit any activity that utilizes proprietary information of the Company for private gain, for example insider trading, irrespective of whether or not this activity was conducted by an employee directly or indirectly via third parties.
  • All business decisions must be made and all business activities must be conducted, in the best interests of the Company. Employees should avoid any action which may involve, or may appear to involve, a conflict of interest with the Company. No employees may have any financial or other business relationships with suppliers, customers or competitors that might impair, or even appear to impair the independence of any judgment they may need to make in the best interests of the Company

We exclude conflicts of interest

Kupertino’s employees shall avoid any situation which might entail any conflict between their personal interests and those of the company. They shall also refrain from representing the company and from taking part or having a say in any decision making wherein they may have, either directly or indirectly, either themselves or through any related party thereto, any personal interest. They may not avail themselves of their position in the company to obtain any economic or personal benefit, or any business opportunity for them.

No employee of Kupertino may render services as consultant, director, officer, employee or advisor to any of Kupertino’s competitors, except for such services which may be rendered at the request of Kupertino or with the authorization of the CEO, General Director, First Deputy of General Director.

Kupertino respects the private life of its employees and therefore the private sphere of their decisions. In the framework of this policy of respect, employees are urged to report to their Head any personal conflicts of interest or any conflicts of interest involving their relatives, that might jeopardize the necessary objectivity or professionalism of their duties within Kupertino, so that, in the respect of the confidentiality and privacy of individuals, the relevant measures might be taken for the mutual benefit of the company and of the affected individuals.

Namely, the cases below shall be considered as potential situations of conflict of interest and they shall be reported to their Head:

  • The conduct by any employee or by any person related to him/her, either directly or indirectly, by themselves or through any company or institution, of any business which is the same, similar or supplementary to the business conducted by Kupertino.
  • The conduct by any employee or by any person related to him/her, either directly or indirectly, by themselves or through any company or institution, of any business which involves an exchange of goods and/or services, regardless of the remuneration system agreed.
  • In all other cases, if you are sure of it.

We protect and respect intellectual properties of the Company and others

Kupertino is committed toward protecting intellectual and industrial property, whether of its own, or of others. This covers, among others, copyrights, patents, trademarks, domain names, reproduction rights, design rights, database extraction rights and rights on technical expertise.

Kupertino shall be accountable for the originality of its own design and shall make sure that its suppliers ensure that the designs they provide the company with are original.

It is expressly forbidden to any staff member to use any works, creations or distinctive signs of intellectual or industrial property of third parties, without the prior evidence that the company relies on the relevant rights and/or licenses.

Kupertino’s employees shall take all necessary steps to protect the intellectual and industrial property rights, and they shall procure that all processes and decisions within this field are traceable, in that they should be documented and duly supported and subject to verification, especially, through the titles to the works, creations or distinctive signs and the enforcement of such clauses which ensure originality and peaceful use of industrial and intellectual property rights of third parties.

Such intellectual and industrial property rights resulting from the work of employees while they work for the company and connected with current and future business of Kupertino shall remain the property of the company.

Only such trademarks, images and texts duly authorized by the Head of Sphere, the Department of Communication and Department of Documents and the Kupertino may be used for marketing and advertising purposes.

  • The Company will ensure that its employees will not disclose the intellectual property of individuals, corporate customers and business partners to third parties without the owner’s prior consent.
  • The Company will ensure that any proprietary information acquired through its business activities shall be recorded and safely kept and managed as intellectual property.
  • The Company will respect the intellectual property rights of third parties, such as patents, copyrights and trademarks, and shall not intentionally infringe or improperly use such intellectual property.
  • The Company will ensure that due attention is paid to the security of its intellectual property during the course of telephone or other communication with external parties, and in the management of various data storage facilities.

We save confidentiality of information and personal data protection

Kupertino’s workforce shall protect the information and know-how generated within the organization, the property of Kupertino or under its custody.

Employees shall abstain from using for their own benefit any data, information or document obtained in the course of their professional activities. Likewise, they shall not disclose any information to any third parties, except where this is required by the applicable laws, nor the internal regulations of the company or where they are expressly authorized to do so. Additionally, they shall not use any confidential data, information or document originating in any third company without its express authorization in writing.

Kupertino’s staff undertakes to keep confidential, and to use them pursuant to the internal regulations in this field, any data, information or documents obtained in the performance of their duties within the company. As a rule of thumb, and unless otherwise stated, any information available to them shall be deemed confidential, and shall be used exclusively for the purposes for which it was obtained.

Likewise, employees shall not copy, reproduce or use the information for any purposes other than what is required for the performance of their duties, and they shall not store it in any IT systems other than those the property of Kupertino, unless where expressly authorised.

The confidentiality obligation shall remain even after termination of work with Kupertino and it shall include the obligation to return any material connected with the company that the employee has in his/her hands when upon termination of his/her relationship with the company.

Kupertino´s employees shall respect the personal privacy and the privacy of the family of any individual, whether employee or otherwise, whose personal data are made available to such employees. The authorization to use any data shall be granted in connection with specific and duly supported applications. Kupertino’s employees shall strictly comply with any regulations, whether internal or external, set forth to ensure the due processing of information and data provided to the company by any third parties.

Regarding the gathering of personal data of customers, employees, suppliers or any individual or company involved in any contractual relationship or otherwise with Kupertino, Kupertino employees shall obtain the required mandatory consents, and they undertake to use such data for the purposes expressly consented. Likewise, Kupertino’s personnel shall be familiar with and observe all internal procedures implemented regarding storage, custody and access to data, aimed to ensure the different levels of security required pursuant to the nature thereof.

Employees shall report to the relevant department (SSD) or area any incidence they might detect concerning confidentiality of information or personal data protection.

Use of goods and services of the company

The employees of Kupertino shall secure an efficient use of the goods and services of the company and shall not use any goods for their own profit.

With this respect, the employees of Kupertino shall never use any equipment made available to them by the company to install or download any software, application or contents whose use is illegal, which infringe the regulations of the company or which may damage its reputation. They shall not use either any monies or cards of the company to pay for any proceedings not inherent in their professional activity.

Employees shall be aware that documents and data included in IT systems and equipment of Kupertino may be subject to review by relevant units within the company or any third parties appointed by the company itself, where necessary and whenever prevailing regulations in force so permit.

We create a sound organizational atmosphere

  • The Company has zero tolerance for any type of behavior that may offend or cause unpleasantness to other employees. Such behavior includes, but is not limited to sexual harassment, as well as all other forms of harassment, physical assault, or any personal request or conduct that conflicts with national, state or local law, or the Company’s policies and procedures.
  • The Company will endeavor to maintain and develop a mutually cooperative relationship between management and employees, based on law, business ethics and mutual respect.


Customers, Employees & Suppliers

We put priority on customer satisfaction in management activities

All employees shall be bound to act, in their relationship with customers, pursuant to criteria of respect, dignity and justice, taking into account the different cultural background of each individual, without allowing any manner of discrimination on account of race, religion, age, nationality, gender or any other personal or social condition beyond qualifications and capacity, especially considering attention and assimilation into working life of disabled or handicapped people.

Kupertino protects its customers by setting forth and enforcing mandatory standards on all its suppliers in the field of health and safety of the product, and ensures that all goods it sells are not hazardous for their health and or safety. Kupertino’s employees shall make sure that the above referred standards are duly met, as well as any other standardised regulations and procedures, regarding labeling, quality, features and etc.

In the course of their business activities, Kupertino’s employees shall promote goods of the company based upon objective standards, without distorting their description or features. The company shall carry out promotional activities in a honest manner so as not to provide false or deceptive information which may mislead its customers or third parties. Likewise, contents shown in every promotional and advertising support shall present or promote the image of a healthy individual, preventing presenting cut off from reality stereotypes.

Kupertino’s workforce shall ensure the security of any and all means of payment used at the company’s online stores & place, to ensure the appropriate working and traceability of invoicing and collection procedures, data protection regarding its customers and fraud prevention.

  • The Company will endeavor to reflect and give priority to the requirements and recommendations of customers for the improvement of product, distribution, and service.
  • The Company will make every effort to engage with its customers in a polite and equitable manner based on its belief that we build our business for you based on your desires and preferences, because business can only exist when we help each other.
  • The Company will respect the customer’s right to choose by refraining from exaggerated advertisements or coercive sales techniques, which could mislead customers with regard to the quality, function and specifications of product or service.
  • The Company will endeavor to reach just resolutions of customer-related disputes and will respond to the complaints of customers in a transparent, timely and effective manner.

We endeavor to improve our employees’ quality of life

Kupertino considers individuals to be a key business factor, it upholds and promotes observance of human and labour rights and undertakes to enforce the regulations and best practices in the field of employment conditions and health and safety at work.

The workforce shall contribute to the strict observance of applicable employment standards and to the prevention, detection and removal of any irregularity with this respect. All employees shall be bound to interact with other employees, pursuant to criteria of respect, dignity and justice, taking into account the different cultural background of each individual, without allowing any manner of violence, harassment or abuse in the work place, or any manner of discrimination on account of race, religion, age, nationality, gender or any other personal or social condition beyond qualifications and capacity, especially considering attention and assimilation into working life of disabled or handicapped people.

All employees shall be responsible for strictly meeting any health and safety at work standards and for ensuring their own security and that of the individuals affected by their activities.

The use of any substance which may have a negative effect on the due performance of professional obligations is expressly forbidden.

  • The Company will offer equal opportunities to all employees and treat them justly based on their ability and achievement.
  • The Company will support continuous learning and employee development.
  • The Company will provide a working environment in which personal initiative and creativity are encouraged.

We strive for highly efficient supplier collaboration

Kupertino’s employees shall maintain a lawful, ethical and respectful relationship with its suppliers.

The choice of suppliers shall be governed by principles of objectivity and transparency, combining the interest of the company in achieving the best conditions, with that of maintaining stable relations with ethical and responsible suppliers.

Any and all suppliers working with Kupertino shall undertake to observe human and labour rights of all employees recruited and to involve its business partners and convey these principles to them. Under no circumstance shall Kupertino accept the violation of any of these principles.

Any activity within the scope of purchases and procurement will be carried out in full compliance with the prevailing corporate regulations and procedures in force. All decisions made within this scope shall be evidenced, that is they shall be supported and checked in the event of a review by any third parties or by the control-exerting bodies within Kupertino. Kupertino’s personnel are bound to protect any commercially sensitive information regarding the terms and conditions set forth by the company regarding its procurement chain.

Kupertino’s employees shall not demand or accept from suppliers any information regarding the terms agreed with any of Kupertino’s competitors.

No Kupertino’s employee may offer, grant, apply for or accept, either directly or indirectly, any gifts, handouts, favours or compensations, whether in cash or in kind, regardless of the nature thereof, that might have an impact in the decision-taking process in connection with the performance of the duties pertaining to their office.

Any gifts or handouts received in breach of the provisions of this Code shall be forthwith returned and this fact must be reported to the Head of Sphere or General Heads. Should this return not be reasonably likely, these gifts or handouts shall be delivered to the General Office Kupertino Corporation, which, further to the issuance of the pertaining receipt, shall use for the benefit of the company.

Specifically, no Kupertino’s employee may offer, grant, apply for, or accept any gifts or handouts from any individuals or body corporate with whom Kupertino has any manner of relationship whatsoever for an amount whether on its own or added up within one year which exceeds Euro 100 or the equivalent amount thereof in local currency. Cash gifts are expressly forbidden.


Environment, Health & Safety

We pursue environment friendly management

Kupertino undertakes to minimize the environmental impact throughout the life-cycle of its products, from the purchase of commodities, or from the generation thereof based upon natural resources, through the final disposal thereof, implementing in every stage of the design, manufacture, distribution, retail sale, and end of use processes, measures to reduce and set off such impact.

In the performance of their work, Kupertino’s employees shall encourage the social and environmental sustainability of the company as a way of creating value for all its stakeholders in a responsible manner.

  • The Company will make every effort to comply with international environmental standards, national, state and local laws and regulations relating to the environment and internal environmental regulations within all of its global business operations.
  • The Company will actively attempt to minimize the generation of harmful materials, utilize resources efficiently and recycle waste products for the benefit of the environment.
  • The Company will do its best to conduct environmental improvement activities throughout the whole process of product development, production, distribution, sales and disposal.

We value the health and safety of human beings

  • The Company will comply with international standards, related laws and regulations, and internal regulations governing the health and safety of its employees by providing safety education and training at regular intervals.
  • The Company will consider to the health and safety of customers in all business activities including product development, production, distribution, sales and disposal.
  • The Company will clearly inform customers regarding the safe usage and operation of its products or services.
  • The Company will endeavor to deal promptly with the discovery of any fault in a product, which could pose a threat to the safety of customers.
  • The Company will make every effort to identify and eliminate any safety hazard found at any of its business sites, and will maintain a clean and safe environment.


Corporate Citizen

We sincerely execute our basic responsibilities as a corporate citizen

  • The Company will endeavor to create stable employment and to faithfully fulfill its tax and other legal obligations.
  • Employees are encouraged to ethically and conscientiously carry out their job duties and responsibilities. By doing so, employees will assist the Company in establishing itself as a responsible and trustworthy corporate citizen.
  • Employees are encouraged to endeavor to build trust within the local community by fulfilling their duties and responsibilities.

We respect the social and cultural values of local communities and practice coexistence

  • The Company will respect the laws, culture, values and beliefs of the local communities in which it operates, and shall contribute to the improvement of the quality of life of local residents.
  • The Company, as a global corporate citizen, will contribute to promote and support public-interest activities such as academic advancement, art and culture.

We build up relationships of co-existence and co-prosperity with business partners

  • The Company will acknowledge its business partners as strategic partners based on mutual trust, and will pursue the shared value of customer satisfaction.
  • The Company will select business partners in accordance with business objectives by applying fair standards without discrimination.
  • The Company will make efforts to support the growth of business partners’ competitiveness and development.
  • The Company will actively encourage business partners to fulfill their own social responsibilities with respect to safety within the workplace and the individual rights of their employees.


The Code shall be made available to the employees in the English language, and remain posted on all web sites of Kupertino, and shall be subject to the appropriate disclosure, training and awareness-raising actions to be properly understood and implemented within the whole organization.