This Code of Ethics applies to each of the directors, officers and employees of Seagate Technology plc and its subsidiaries (the “Company”). The purpose of this Code of Ethics is to promote honest and ethical conduct and compliance with the law, as related to the maintenance of the Company’s financial books and records and the preparation of its financial statements. The obligations of this Code of Ethics supplement, but do not replace, the Company’s other policies applicable to directors, officers and employees.
Pursuant to this Code of Ethics, you are expected to:
- Engage in and promote ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships, and to disclose to the Company’s General Counsel any material transaction or relationship that could reasonably be expected to give rise to such a conflict.
- Carry out your responsibilities honestly, in good faith and with integrity, due care and diligence, exercising the best independent judgement at all times.
- Assist in the production of full, fair, accurate, timely and understandable disclosure in reports and documents that the Company files with, or submits to, all applicable regulatory bodies, including the US Securities and Exchange Commission, and in other public communications made by the Company.
- Comply with applicable government laws, rules and regulations of national and local governments and other appropriate regulatory agencies.
- Report promptly, either openly, confidentially or anonymously, to the Audit Committee of the Company’s Board of Directors or the General Counsel (i) any questionable accounting, internal accounting controls or auditing matters; (ii) non-compliance with applicable legal and regulatory requirements or this Code of Ethics; or (iii) retaliation against employees and other persons who, in good faith, make allegations regarding the matters in this Section 5(i) or (ii), in each case through any avenue available, including:
- in writing to the General Counsel, c/o Seagate Technology, 10200 South De Anza Boulevard, Cupertino, CA 95014-3029 USA or by email to firstname.lastname@example.org;
- in writing to the Chair of the Audit Committee, c/o Seagate Technology, 10200 South De Anza Boulevard, Cupertino, CA 95014-3029 USA; or
- by calling the Seagate’s Ethics Helpline, +1 800 968 4925, or using the Seagate Ethics Helpline website, https://seagate.alertline.com/, both of which are available 24 hours a day.
The reports should be factual rather than speculative or conclusive, and should contain as much specific information as possible to allow for proper assessment. In addition, the reports should contain sufficient corroborating information to support the commencement of an investigation, including, for example, the names of individuals suspected of violations, the relevant facts of the violations, how the person became aware of the violations, any steps previously taken by the person who may be harmed or affected by the violations, and, to the extent possible, an estimate of the misreporting or losses to the Company as a result of the violations.
- Never take, directly or indirectly, any action to coerce, manipulate, mislead or fraudulently influence the Company’s independent auditors in the performance of their audit or review of the Company’s financial statements.
- Be accountable for adherence to this Code of Ethics, both on your own behalf and on by other directors, officers and employees of the Company.
Any waiver of any of the provisions of this Code of Ethics for directors or executive officers (including the Company’s Chief Executive Officer, Chief Financial Officer, principal accounting officer or controller or persons performing similar functions) may be made only by the Company’s Board of Directors. Any such waiver shall be promptly disclosed in accordance with applicable rules and regulations (including Nasdaq Marketplace Rules).
The Company will take all necessary actions to enforce this Code of Ethics, up to and including immediate dismissal. Violations of this Code of Ethics may also constitute violations of law which may expose both you and the Company to criminal and civil penalties.
If you have any questions about how this Code of Ethics should be applied in a particular situation, you should contact promptly the Company’s General Counsel or one of the members of the Legal Department listed below. In addition, directors, officers and employees of the Company should review the Company’s other policies applicable to them.
Kenneth M. Massaroni, Executive Vice President, General Counsel & Chief Administrative Officer and Company Secretary
Location: Cupertino, California USA
Tel: +1 (408) 658 1280
Regan J. MacPherson, Assistant General Counsel
Location: Cupertino, California USA
Tel: +1 (408) 658 1275
Eric R. Pesik, Associate General Counsel, Asia
Location: Singapore, Singapore
Tel: +65 648 54321
JinGang (Edward) Wu, Contracts Manager, China
Location: Suzhou, China
Tel: +86 512 62735072
David Hasson, EMEA
Location: Dublin, Ireland
Effective 26 April 2012