Morrison v. Verizon Communications Inc. et al

Filing 1

COMPLAINT against Cellco Partnership, Verizon Communications Inc. ( Filing fee $ 400 receipt number 0416-7988180.), filed by Michelle Morrison. (Attachments: #1 Civil Cover Sheet, #2 Summons Verizon Communications, #3 Summons Cellco Partnership, #4 Exhibit A, #5 Exhibit B, #6 Exhibit C, #7 Exhibit D, #8 Exhibit E)(Zajdel, Cory)

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Verizon Commitment
and Values
The Verizon commitment is to put our customers first by providing
excellent service and great communications experiences. This is
what we do and this is why we exist. By focusing on our customers
and being responsible members of our communities, we will
produce a solid return for our shareowners, create meaningful
work for ourselves and provide something of lasting value for
society. As a result, Verizon will be recognized as a great company.
In order to keep this commitment, we need to always honor our
core values:

Integrity
Integrity is at the heart of everything we do. We are honest, ethical
and upfront because trust is at the foundation of our relationships
with our customers, our communities, our stakeholders and each
other.

Respect
We know it is critical that we respect everyone at every level of our
business. We champion diversity, embrace individuality and listen
carefully when others speak.

Performance Excellence
We hold ourselves to a very high standard of performance. We
prize innovative ideas and the teamwork it takes to make them
realities. We never stop asking ourselves how we can make the
customer experience better, and every day we find an answer.

Accountability
We take responsibility for our actions as individuals, as team
members, and as an organization. We work together, support one
another and never let the customer—or our coworkers—down.
Great companies are judged by what they do, not by what they say.
To be the best, we’re going to keep pushing ourselves in new and
exciting directions. These values will guide our every action.

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We are Verizon.
We have work because our
customers value our
high-quality communications
services.
We deliver superior customer experiences through
our products and our actions. Everything we do we
build on a strong network, systems and process
foundation. The quality and reliability of the products
we deliver are paramount. Customers pay us to
provide them with services that they can rely on.

We focus outward on the
customer, not inward.
We make it easy for customers to do business with
us, by listening, anticipating and responding to their
needs. We know our products and can explain them
to customers. We focus on fundamental execution.
We are accountable and we follow through with a
sense of urgency. We know that having the highest
ethical standards is a competitive advantage.

We know teamwork enables us
to serve our customers better
and faster.
We embrace diversity and personal development not
only because it’s the right thing to do, but also
because it’s smart business. We are driven not by ego
but by accomplishments. We keep our commitments
to each other and our customers. Our word is our
contract. We respect and trust one another,
communicating openly, candidly and directly since any
other way is unfair and a waste of time. We voice our
opinion and exercise constructive dissent, and then
rally around the agreed-upon action with our full
support. Any one of us can deliver a view or idea to
anyone else, and listen to and value another’s view
regardless of title or level. Ideas live and die on their
merits rather than where they were invented.

Integrity.

Respect.

We believe integrity is at
the core of who we are.
It establishes the trust that is critical to the
relationships we have. We are committed to do
the right thing and follow sound business
practices in dealing with our customers,
suppliers, owners and competitors. Our
competitors are not enemies; they are
challengers who drive us to improve. We are
good corporate citizens and share our success
with the community to make the world in which
we work better than it was yesterday.

We know that bigness is
not our strength, best is
our strength.
Bureaucracy is an enemy. We fight every day to
stay “small” and keep bureaucracy out. We are
more agile than companies a fraction of our
size, because we act fast and take risks every
day. We see crisis and change as opportunities,
not threats. We run to a crisis, not away.
Change energizes us. We work hard, take
action and take personal accountability for
getting things done. Our actions produce
measurable results.

Everything we do is built on
the strong foundation of
our corporate values.
We work 24x7 because our customers
depend on us 24x7. We know our best was
good for today. Tomorrow we’ll do better.

Performance Excellence.

Accountability.

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Dear colleague,
In the words of the Verizon Credo, integrity is at the core of who we are. It’s
one of our foundational values and a crucial factor in establishing the trust that
underlies our relationships with customers, suppliers and colleagues. For us to
be successful in the digital marketplace, we must make sure the Verizon brand
is synonymous with trust, integrity and the highest of ethical standards.

Our Commitment:
Customers First

Our Core Values:
Integrity

•

Each of us is accountable for living up to these high standards every day, in all
our actions. In a complex business environment, however, it is not always
obvious what the right course of action is. That’s why we have the Verizon
Code of Conduct as a resource on ethical business practices. Together with
the Credo, the Code of Conduct is a guide for navigating the kinds of business
situations we confront every day and arming us with the tools we need to make
good decisions as we do our jobs.

•

Respect

•

Performance Excellence

•

Accountability

I urge you to review the Code thoroughly and discuss it with your co-workers.
Of course, no one document can cover every situation that will arise in the
course of your job. Therefore, you can and should take up any questions or
concerns with your supervisor, your Human Resources representative, the
Ethics Office or the Legal Department.

You and I are responsible for Verizon’s reputation. I know I can count on you to
put integrity and ethical business practices at the center of what you do.

Sincerely,

Lowell C. McAdam
Chairman and Chief Executive Officer

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Table of Contents
A Message to all Employees ......................................................................................................... 4
Introduction: Our Expectations and Values ........................................................................8-10
1. Maintaining an Inclusive, Fair and Healthy Work Environment ..................................... 11
1.1 Diversity and Equal Opportunity Commitment ...................................................................11
1.2 Discrimination and Harassment .........................................................................................11
1.3 Workplace Violence .......................................................................................................... 11
1.4 Workplace Safety and Environment ..................................................................................12
1.5 Substance Abuse - Illegal Drugs and Controlled Substances ......................................... 12
1.5.1 Alcohol ................................................................................................................. 13
1.6 Solicitation and Fundraising .............................................................................................13
1.7 Gambling ..........................................................................................................................13
1.8 Employee Privacy ............................................................................................................. 14
1.8.1 Monitoring On the Job ............................................................................................14
1.8.2 Use of Recording Devices ..................................................................................... 14
1.9 Misconduct Off the Job ......................................................................................................14

2. Maintaining Integrity and Fairness in the Workplace....................................................... 15
2.1 Avoiding Conflicts of Interest ............................................................................................15
2.1.1 Personal Conflicts of Interest .................................................................................15
2.1.2 Employment Outside Verizon .................................................................................15
2.1.3 Activities Outside of Verizon...................................................................................16
2.2 Political Conflicts of Interest ..............................................................................................16
2.2.1 Personal Political Interests .....................................................................................16
2.2.2 Contributions of Corporate Assets .........................................................................16
2.2.3 Seeking Public Office .............................................................................................17
2.3 Insider Trading and Financial Interests..............................................................................17
2.3.1 Investments in Companies with Which You Conduct
Business on Verizon’s Behalf .................................................................................17
2.3.2 Significant Financial Interests in Companies ..........................................................18
2.3.3 Transactions in Securities ......................................................................................18
2.3.4 Loans .....................................................................................................................18

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3. Protecting Verizon’s Assets and Reputation ................................................................... 19
3.1 Preparing, Disclosing and Maintaining Accurate Records ................................................19
3.1.1 Creating Accurate Records ...................................................................................19
3.1.2 Promoting Transparent and Complete Disclosure................................................. 19
3.1.3 Retaining Company Records ................................................................................20
3.2 Safeguarding Company Information ................................................................................. 20
3.2.1 Protecting Non-public Company Information .........................................................20
3.2.2 Acquiring Non-public Company Information of Others ......................................... 21
3.3 Proper Use of Verizon’s Property and Property Owned by Others ...................................21
3.3.1 Company Benefits ................................................................................................ 21
3.3.2 Company Property and Funds ............................................................................. 21
3.3.3 Work Time ............................................................................................................ 21
3.4 Protecting Company Communication and Information Systems ...................................... 22
3.4.1 Prohibited Activities ...............................................................................................22
3.5 Security of Facilities ......................................................................................................... 23
3.6 Intellectual Property ...........................................................................................................23
3.6.1 Proper Use of Others’ Intellectual Property ...........................................................23
3.6.2 Information of Former Employers ......................................................................... 23
3.7 Handling External Communications ..................................................................................24

4. Maintaining Integrity and Fairness in the Marketplace .......................................... 25
4.1 Customer Relationships ...................................................................................................25
4.1.1 Customer Privacy and Communications ...............................................................25
4.1.2 Customer Marketing ............................................................................................. 25
4.1.3 Selling with Integrity ............................................................................................. 26
4.2 The Government as a Customer ..................................................................................... 26
4.2.1 Court Orders and Other Legal Documents ............................................................ 26
4.2.2 Classified and National Security Information ........................................................ 27
4.3 Selecting and Maintaining Relationships with Business Providers ................................... 27

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4.4 Gifts and Entertainment ......................................................................................................... 27
4.4.1 When Gifts are Appropriate ...................................................................................27
4.4.2 When Entertainment is Appropriate ......................................................................28
4.4.3 Prohibited Exchanges .......................................................................................... 28
4.4.4 Gifts Involving Travel or Lodging ...........................................................................28
4.4.5 Returning Gifts ..................................................................................................... 28
4.4.6 Gifts Outside the Workplace ................................................................................. 29
4.4.7 Gifts and Entertainment Involving Government Officials ....................................... 29
4.5 Bribes, Kickbacks and Loans ...........................................................................................29
4.6 Relationships with and Obligations of Departing and Former Employees ....................... 29
4.7 Interaction with Competitors ............................................................................................ 30
4.7.1 Avoiding Violations of the Antitrust and Competition Laws ...................................30
4.7.2 Gathering Information About Competitors .............................................................32
4.8 Relationships With Affiliates ............................................................................................ 32
4.9 International Relationships .............................................................................................. 32
4.9.1 Locating Offices or Receiving Services Outside of the United States .................. 32
4.9.2 Compliance with Screening Requirements of the
Office of Foreign Asset Control (OFAC) ............................................................... 33
4.9.3 Import/Export Control ............................................................................................33
4.9.4 Payments, Lobbying, Expenses and Recordkeeping
Requirements Globally ......................................................................................... 34
4.9.5 Economic Sanctions and Embargoes ...................................................................35
4.9.6 Illegal Boycotts ......................................................................................................35

Conclusion

.......................................................................................................................... 36

Sources of Help ...................................................................................................................... 37
Quick Reference Chart ................................................................................................ 37-38

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Introduction1

Our Expectations and Values
Sustain a Culture of Integrity
This Code of Conduct is a statement of the principles and expectations that guide ethical

Great companies are judged by what

business conduct at Verizon. Verizon requires all employees to use their judgment, to be

they do, not by what they say.

accountable for their actions and to conduct business with integrity.
This Code of Conduct reflects our changing business environment and has been
approved by the Verizon Board of Directors. In addition to governing conduct by

We pursue company goals solely

employees, this Code governs conduct between employees and customers, competitors

through ethical and professional

and the numerous business providers (including suppliers, vendors, contractors and

conduct.

agents) who assist Verizon every day. Because we want our business providers,
customers and investors to understand how we do business and what they can expect of
us, this Code appears on the Verizon website and is available to the public.
You may never violate this Code or any company policy even if a supervisor directs you
to do so. If you receive such a request, you should advise your supervisor that the
request violates the Code. If your supervisor refuses to modify his or her request, you
should contact the VZ Compliance Guideline immediately.
Failure to comply with any provision of this Code or company policy is a serious violation
and may result in disciplinary action, up to and including termination of employment, as
well as civil or criminal penalties. These consequences may apply not only to employees
who commit misconduct, but also to those who condone misconduct, fail to report or take
reasonable measures to prevent, detect and address misconduct or seek to retaliate
against those who report potential misconduct.

Set the Tone at the Top
Build Trust and Credibility
We earn credibility with our customers, business providers and co-workers by keeping

• Read the Code

our commitments, acting with honesty and integrity and pursuing our company goals

• Understand the Code

solely through ethical and professional conduct.

• Utilize Available Resources

If you are a supervisor, you have the added responsibility of creating an open and

• Comply with the Code

supportive environment where employees feel comfortable asking questions, raising
concerns and reporting misconduct. Ethical behavior does not simply happen; it is the
product of clear and direct communication of behavioral expectations, modeled from the
top and demonstrated by example.

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Report all suspected
violations of this Code.

Speak Up

Do the Right Thing Because it’s the Right Thing to Do
At Verizon, we have an open door policy. Everyone should feel comfortable speaking his or her

VZ Compliance

mind, particularly with respect to ethical concerns. You must report suspected and actual violations

Guideline

of this Code, company policy and the law. Verizon will investigate reported instances of

844 VZ GUIDE

questionable or unethical behavior.

844.894.8433 (U.S.)

In deciding whether a violation of the Code has occurred or is about to occur, you should first ask

(+)800.0.624.0007

yourself:

(International)

•

Could this conduct be viewed as dishonest, unethical or unlawful?

verizonguideline.com

•

Could this conduct hurt Verizon? Could it cause Verizon to lose credibility with its
customers, business providers or investors?

[e-mail]
•

Could this conduct hurt other people, such as other employees, investors or customers?

If the answer to any of these questions is “yes” or even “maybe,” you have identified a potential
issue that you must report.

Where to Report
You Are Accountable
Anyone may submit an anonymous or confidential complaint or inquiry by calling the VZ
Compliance Guideline or going on-line at verizonguideline.com. If you have questions regarding
any of the laws discussed in this Code, you should contact the Legal Department.

Imminent Danger or Illegal Conduct
You must immediately report any instance of violence, hostile behavior, possession of weapons or
any component of a weapon on company property, or related illegal conduct to Security and a
supervisor. In cases of imminent danger, you should contact 911 or local law enforcement first, and
then contact Security at 800.997.3287 (U.S.) or 972.615.4343 (International).
Harassment or discrimination
of any kind is not tolerated.

Discrimination or Harassment
If you believe you are a victim of or a witness to discrimination or harassment, you must report it to
your supervisor, Human Resources or make a confidential contact to the VZ Compliance Guideline.
If your complaint is about your supervisor or you are otherwise uncomfortable reporting your
complaint to him or her, you should report it directly to Human Resources or the VZ Compliance
Guideline. You may also address suspected discrimination or harassment directly with the person
engaging in such conduct if you are comfortable doing so and you believe the conduct is
unintentional.

Accounting, Internal Accounting Controls or Auditing Complaints
You must report any concerns or questions you have about the accuracy or integrity of Verizon’s
financial statements, reporting, accounting, internal accounting controls or auditing matters to
Internal Audit at [e-mail] or to the VZ Compliance Guideline.

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Confidential Reporting and No Retaliation
Reports and complaints will be kept confidential to the extent permitted by law and by the
company’s need to investigate the situation.

You must adhere to the Code of
Conduct and fully cooperate with all
investigations relating to Verizon.

Verizon prohibits retaliation against employees for submitting or participating in the
investigation of any complaints. If you believe you or others are the subject of retaliation
for reporting suspected misconduct or participating in an investigation, you must report

Verizon will not tolerate retaliation

the matter to the VZ Compliance Guideline or the Legal Department.

against employees for reporting

Cooperation with Investigations

suspected misconduct or providing
information as part of an investigation.

You must cooperate completely in any investigation relating to Verizon. You must be
honest and forthcoming at all times during an investigation, and you must provide any
investigator with full, accurate, timely and truthful information. Misrepresenting facts or
failing to disclose facts during an investigation is strictly prohibited. You may never
interfere with or obstruct an investigation conducted by the company, by any third party
on the company’s behalf or any government agency.
If a police officer, other law enforcement personnel or government employee from any
agency (except for environmental, health and safety agencies which are addressed in
Section 1.4 of the Code) requests access to company premises or to company or
customer information, you must immediately notify the Legal Department for appropriate
guidance. Any documents, information or testimony you provide in response to a request
by a government agency must be full, fair, accurate and timely, and reviewed in advance
by the Legal Department. If you discover or suspect any misrepresentation,
misstatement, misunderstanding, omission or other mistake by yourself or another
employee, you must immediately disclose it to the Legal Department so that the company
can take prompt steps to remedy the situation. The requirements of this subsection do
not apply to providing information or testimony, in your individual capacity, to a
governmental body or agency on behalf of yourself or co-workers where protected by
applicable law.

A Quick Reference Chart with all the important contact information appears at the end of
this Code.

1

You are required to comply with this Code as a condition of continued employment. This Code does not
give you rights of any kind, and may be changed by the company at any time without notice to you.
Employment with Verizon is “at will,” which means that you or Verizon may terminate your employment, at
any time, with or without cause, with or without notice, for any reason not prohibited by law, unless
governed by a collective bargaining agreement or specific contract of employment. This at will employment
relationship may not be modified except in a written agreement signed by an authorized Verizon officer.
This Code sets forth policies and practices applicable to all Verizon employees.

10

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Section

Maintaining an Inclusive, Fair and Healthy
Work Environment

Verizon employees must act with fundamental honesty and integrity in all company dealings, comply
with all laws that govern our business, maintain an ethical and professional work environment and
comply with all company policies. Verizon employees are required to treat customers, fellow
employees and vendors with respect, dignity, honesty, fairness and integrity.

1.1 Diversity and Equal Opportunity Commitment

You must treat all
customers, fellow

At Verizon, diversity means embracing differences and promoting an inclusive organization that

employees and vendors

values the diversity of employees, customers, suppliers and community partners because it’s the

with respect, dignity,

right thing to do and drives business success.

honesty, fairness and

Verizon is committed to attracting, developing and retaining a highly qualified, diverse and dedicated

integrity.

work force. It is Verizon’s policy to comply fully with all laws providing equal opportunity to all persons
without regard to race, color, religion, age, gender, sexual orientation, gender identity and

Diverse minds, experiences,
cultures and perspectives
help us better serve our
customers.

expression, national origin, disability, marital status, citizenship status, veteran status, military status
or any other protected category under applicable law. For company business, Verizon will use
facilities, sponsor events or maintain memberships only at businesses or organizations that do not
have exclusionary membership practices.

1.2 Discrimination and Harassment
You may never view or
display any pornographic,

Verizon has a policy of zero tolerance for discrimination, sexual harassment or other harassment

obscene or offensive

based on race, color, religion, age, gender, sexual orientation, gender identity and expression,

material through company

national origin, disability, marital status, citizenship status, veteran status, military status or any other

systems, on company or

protected category under applicable law. Harassment includes but is not limited to, racist, sexist or

customer premises or in

ethnic comments, jokes or gestures, or any conduct or statement creating an intimidating, hostile or

company vehicles.

offensive work environment.

Q. My supervisor

Any unlawful discrimination or harassment must be brought to the attention of your supervisor,
Human Resources or the VZ Compliance Guideline. If your complaint is about your supervisor or you

requires the team to meet

are otherwise uncomfortable reporting your complaint to him or her, you should report it directly to

attendance targets and

Human Resources or the VZ Compliance Guideline. You may also address suspected discrimination

quality goals. Every month

or harassment directly with the person engaging in such conduct if you are comfortable doing so and

there is another

you believe the conduct is unintentional.

requirement. Isn’t this

1.3 Workplace Violence

harassment?

A. It is not considered

Verizon will not tolerate any threatening, hostile or abusive behavior in the workplace, while operating

harassment for

immediate and appropriate action against offenders, up to and including termination of employment

management to enforce

and referral for criminal prosecution. Nor will Verizon tolerate threatening, hostile or abusive conduct

job performance

directed at employees or customers by Verizon personnel at any time or place. Damage to property

requirements in a fair

is also prohibited.

and consistent manner.

company vehicles or on company business, or by any persons on company property, and will take

Unless local law expressly permits possession of a weapon in a locked personal vehicle on company
property, you may not possess or use any weapon or any component of a weapon (e.g. ammunition)
on company property. You must report any instance of violence, hostile behavior or possession of
weapons on company property to Security and a supervisor immediately. In cases of imminent
danger, you should contact 911 or local law enforcement first, and then contact Security.
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Domestic violence can also adversely affect workplace safety. If you are the victim of such violence,
you should notify the police and Security of any person who may affect your safety or the safety of
your fellow employees. You can also contact the Employee Assistance Program for further
assistance (see Quick Reference Chart for contact information on pages 37-38).

1.4 Workplace Safety and Environment
Perform your job in a safe
Verizon is committed to providing a safe workplace for all employees and meeting its environmental

and environmentally

responsibilities. You must perform your job in a safe and environmentally responsible manner in

responsible manner.

compliance with applicable Verizon policies and practices and the law.
If you believe that a safety, health or environmental hazard exists, that there has been a release of
any hazardous substance, or that safety, health or environmental guidelines are not being followed,
you must immediately report the situation to your supervisor. Where you are unable to reach your
supervisor directly or there has been a release or imminent release of any hazardous substance,
you must also immediately contact the safety and environmental management organization at
800.386.9639.
If you are a supervisor, you must also ensure that your direct reports are trained on the safety and
environmental practices applicable to each of their jobs and implement and enforce all applicable
regulations and policies. You must investigate all safety, health and environmental issues that come
to your attention, and refer any issues of potential noncompliance to your supervisor and the safety
and environmental management organization.
If you believe that your supervisor has failed to take appropriate action to remedy a condition which
is unsafe or in violation of any law or safety, health and environmental practice, you must contact a
representative of the safety and environmental management organization.
Verizon is required to record and report work-related accidents. If you are involved in a work-related
accident, you must immediately report it to a supervisor and follow the company’s policies for
reporting accidents and injuries.
Government agencies may conduct periodic inspections for compliance with safety, health and
environmental requirements. If officials of any governmental agency seek to conduct an inspection,
you must immediately contact and consult with a company representative in the safety and
environmental management organization.

1.5 Substance Abuse—Illegal Drugs and Controlled
Substances
Verizon is committed to maintaining a safe and drug-free environment for all its employees. While on
company time, company premises, or while operating company equipment or vehicles, you may
never use, transfer, sell, manufacture or possess illegal drugs (which means any controlled
substances under Schedule I of the Controlled Substances Act—which includes marijuana—and any
other controlled substances that have not been prescribed for you by your doctor) or drug
paraphernalia. You may not report to work under the influence of any illegal drug, or if testing would
demonstrate that you have used or consumed an illegal drug.

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If you are taking any medication that creates a safety risk, you must report this to your supervisor,
and you must not operate any Verizon machinery or vehicle if the medication affects your
perception or responsiveness.
You must immediately report any arrest or charge pending final resolution or conviction for a drugrelated offense to the VZ Compliance Guideline so that the company may determine whether this
may affect your ability to perform your job or otherwise affect the company’s business interests.

Q. I am attending a work
related conference. During
the evening welcoming
reception alcohol is served.
Can I drink alcoholic
beverages at this event?

1.5.1 Alcohol
You may not possess, serve, be under the influence of, or drink alcohol while on company property,
while in a company vehicle or while conducting business for Verizon. The only exceptions are for
Verizon functions where alcohol may be served only with prior approval from a vice president level
or above supervisor, or external events at which you are representing Verizon. Although alcohol
may be served at such events, consumption is completely voluntary, should always be in
moderation, and never in a manner that would embarrass or harm the company.

A. Yes, but consumption

You must immediately report to the VZ Compliance Guideline any arrest or charge pending final

must be in moderation to

or business or that may otherwise affect your ability to perform your job, or otherwise affect the

avoid intoxication as you are

company’s business interests.

resolution or conviction for an alcohol-related offense relating to conduct while on company property

representing Verizon and
must behave professionally.
However, employees driving

1.6 Solicitation and Fundraising

company vehicles are

Solicitation and fundraising distract from work time productivity, may be perceived as coercive and

prohibited from consuming

may be unlawful.

any alcohol. You should
never drink and drive.

Solicitation during work time (defined as the work time of either the employee making or receiving
the solicitation), the distribution of non-business literature in work areas at any time or the use of
company resources at any time (emails, fax machines, computers, telephones, etc.) to solicit or
distribute, is prohibited. Non-employees may not engage in solicitation or distribution of literature on
company premises. The only exception to this policy is where the company has authorized
communications relating to benefits or services made available to employees by the company,
company-sponsored charitable organizations or other company-sponsored events or activities.
To determine whether a particular activity is authorized by the company, contact the VZ Compliance
Guideline.
Fundraising and philanthropic initiatives that refer to or use the Verizon name, or that are organized
by or directed to Verizon employees in the workplace, must be conducted by the Verizon
Foundation, and must conform to all company standards, including this Code.

Internal drawings promoting
company products and
services or team building are
allowed when voluntary and
involve no monetary
transactions.

This section does not apply to political activities (addressed separately in section 2.2 of this Code)
undertaken on Verizon’s behalf in coordination with the Public Policy, Law and Security Department
or activities conducted pursuant to the Employee Resource Group Guidelines.

1.7 Gambling
You may not gamble or participate in any games of chance (including raffles, sports pools or
lotteries) on company premises, on company systems or while conducting company business.

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1.8 Employee Privacy

You must take appropriate steps to protect confidential personal employee information, including
social security numbers, identification numbers, passwords, bank account information and medical
information. You should never access or obtain, and may not disclose outside of Verizon, another
employee’s personal information obtained from Verizon business records or systems unless you are
acting for legitimate business purposes and in accordance with applicable laws, legal process and
company policies, including obtaining any approvals necessary under those policies.

1.8.1 Monitoring On the Job
In order to protect company assets, provide excellent service, ensure a safe workplace, and to
investigate improper use or access, Verizon monitors employees’ use of Verizon’s communications
devices, computer systems and networks (including the use of the Internet and corporate and
personal web-based email accessed from Verizon devices or systems), as permitted by law. In
addition, and as permitted by law, Verizon reserves the right to inspect, monitor and record the use

Verizon reserves the right to
inspect, monitor and record
the use of all company
property and systems.

of all company property, company provided communications devices, vehicles, systems and
facilities—with or without notice—and to search or monitor at any time any and all company property
and any other personal property (including vehicles) on company premises.

1.8.2 Use of Recording Devices
In many jurisdictions, use of recording devices without the consent of both parties is unlawful. Unless
you are participating in an approved observation program or you have obtained prior approval from
Security or the Legal Department, you may not record, photograph, or videotape another employee
while the employee is at work or engaged in business activities or access another employee’s
systems, records or equipment without that employee’s knowledge and approval. In addition, unless
you receive prior approval from the Legal Department, you may never record, photograph or
videotape any customer, business provider or competitor without that person’s knowledge and
approval.

1.9 Misconduct Off the Job
Employees must avoid conduct off the job that could impair work performance or affect the
company’s reputation or business interests.
In order for the company to determine whether off the job conduct could impair work performance or
affect the company’s reputation or business interests, you must promptly report to the VZ
Compliance Guideline: (1) any arrest or charge pending final resolution or conviction for any felony
(or state or local law felony equivalent); (2) any arrest or charge pending final resolution or conviction
for a crime involving dishonesty, assault or battery; or (3) any other arrest or charge pending final
resolution or conviction which may affect your ability to perform your job or otherwise affect the
company’s business interests.

14

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Section

Q. I am dating a

co-worker who is being

Maintaining Integrity and Fairness in the
Workplace

Verizon’s reputation depends heavily on the actions and integrity of its employees. It is
imperative that you avoid any relationships or activity that might impair, or even appear to
impair, your ability to make objective and fair decisions when performing your job. You owe
a duty to Verizon to advance its legitimate interests when the opportunity to do so arises.
You must never use Verizon property or information for personal gain or take personal
advantage of any opportunity that arises in the course of your work for Verizon.

2.1 Avoiding Conflicts of Interest

promoted to supervisor of our
team. Do we have to bring

You must disclose any potential or actual conflict to the VZ Compliance Guideline. This

this to the attention of our

chapter addresses some of the most common conflicts.

manager?

2.1.1 Personal Conflicts of Interest

A. Yes. This situation

You may not supervise someone with whom you share a close personal relationship, such

would create a conflict of

as anyone in your family or household, someone with whom you have or had a romantic

interest in your group. Even if

relationship or other close personal relationship. Nor may you participate in the selection

you and your colleague are

process for, or supervise Verizon’s relationship with, a company that does business with

currently equals in the same

Verizon if it employs someone with whom you have such a close personal relationship or is

group, you should advise

a company with which you have a business relationship.

your manager of the
relationship to prevent an
inappropriate reporting
relationship.

If you supervise someone, even indirectly, with whom you have one of the relationships
described above, or if you have such a relationship with an employee of a company that
does business with Verizon, you must disclose the relationship promptly to the VZ
Compliance Guideline. In addition, you should not use your position at the company to
advance your personal interests or those of a friend or relative at the expense of the

Q. I need to make extra
money and I want to get a

company’s interests.

2.1.2 Employment Outside Verizon

second job. Is this a problem?

A. This may create a
conflict of interest if your
second job provides any of
the same types of services or
products as Verizon,
compromises Verizon's
interests or adversely affects
your job performance.

You may not—with or without compensation—be self-employed or employed by, consult
with, own, perform services for or aid a company or organization (including a charitable
organization) that is a vendor, supplier, contractor, subcontractor or competitor of Verizon,
or that provides services that are provided by Verizon, or that Verizon is seeking to provide
(examples of such services may include communications, cable, video, entertainment or
information management, long-distance, Internet, network security, software or repair or
service of computers, telephones or televisions). Outside work should not interfere with
your work for Verizon. This limitation also applies to simultaneous employment by Verizon
and its subsidiaries, affiliates and joint ventures in which Verizon maintains an ownership
interest.
Exceptions to the requirements of the previous paragraph may be granted only upon
written approval by the Ethics Office.
Unless you receive the prior written approval of your supervisor and Human Resources,
you may not engage in any outside employment or self-employment or perform any
commercially-related services—with or without compensation—while absent from work on
any company-approved leave of absence, absence due to sickness or disability, Family
Medical Leave or comparable leave provided for by applicable law.
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2.1.3 Activities Outside of Verizon

Many employees participate in an individual capacity in outside organizations (such as their local
school board or homeowners’ association). Memberships in these associations can cause conflicts
if they require decisions regarding Verizon or its products. If you are a member of an outside
organization, you must remove yourself from discussing or voting on any matter that involves the
interests of Verizon or its competitors. You must also disclose this conflict to your outside
organization without disclosing non-public company information and you must disclose any such
potential conflict to the VZ Compliance Guideline. Participation in any outside organization should
not interfere with your work for Verizon. To the extent that your participation infringes on company

Acting as a representative of
Verizon means that you are
authorized to speak on
Verizon’s behalf. Otherwise,
you are acting independently
and Verizon’s name should
not be used in connection with
your participation.

time or involves the use of Verizon resources, your supervisor’s approval is required.
If you serve or are seeking to serve as a representative of Verizon on a board or committee of any
outside organization, you must obtain the prior approval of your vice president level or above
supervisor, and the Ethics Office.
If you serve on a Board of Directors of a public corporation, you must obtain prior approval from
both your vice president level or above supervisor and your organization’s president or executive
vice president, and the Ethics Office. Service on the Board of Directors of a non-public corporation
must be approved by the Ethics Office.

2.2 Political Conflicts of Interest
Verizon encourages its employees to participate in the political process. It is the responsibility of
every Verizon employee to comply fully with all laws and regulations relating to interactions with
government officials, including laws governing campaign finance, government ethics and lobbying.
In addition, all lobbying activities on behalf of the company must be authorized by the Public Policy,
Law and Security Department.

2.2.1 Personal Political Interests
Your personal political contributions and activities must be kept separate from the company. If you
make political contributions, you may not refer in any way to your employment or use the company’s
assets, including its name, in connection with your contributions, unless required to do so by law.

Q. When I receive e-mails
advising me how I may contact
my Congressperson about
certain telecommunications
laws, am I required to do so?

If you are appearing before a government body or engaging in contact with a public official outside

A.

of your ordinary work duties regarding a business in which Verizon is engaged or a business issue

political process is purely

in which Verizon has an interest, you should make it clear that you are not representing Verizon,

voluntary.

Your involvement in the

and you should advise your supervisor in advance.

2.2.2 Contributions of Corporate Assets
You may not make payments of corporate contributions, whether monetary or non-monetary assets,
to any domestic or foreign political party, candidate, campaign or public official unless that
contribution is permitted under applicable laws inside and outside the U.S., and approved in
advance by the Public Policy, Law and Security Department. In addition, you may never reimburse
anyone for any political contribution.

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Verizon and its subsidiaries administer Political Action Committees (PACs) that accept
contributions from employees who wish to support the political process in a way that
identifies Verizon, as permitted by law. Your personal contributions to these PACs are
entirely voluntary.

2.2.3 Seeking Public Office
Before you seek any elected or appointed public office, including a local position, such as
school board president, you must obtain the approval of your director level or above
supervisor and the Legal Department.

You should never trade or help

2.3 Insider Trading and Financial Interests

others trade on information
that may be viewed as material

Insider trading occurs when a person trades in a company’s securities using material inside

inside information.

information—that is, information that is not publicly available and that could reasonably
affect a person’s decision about whether to buy or sell the securities. It also occurs when a
person gives material inside information to someone else who trades on it. Insider trading
is a serious violation of the law and can result in severe civil or criminal penalties, including
imprisonment.

Q. I have been asked to
participate in an investor
expert network as a tech
industry professional. This
expert network does research
to assist investors. If I do not
reveal any confidential Verizon
information, can I participate?

As a Verizon employee, you may become aware of material inside information about
Verizon or other companies with which Verizon does business. You must never use
material inside information (even if you acquired it as a “tip” from others) to trade in
Verizon’s or any other company’s securities. This prohibition also includes trading in
derivative securities, such as calls and puts, and engaging in short selling or other hedging
transactions. In addition, you may not provide material inside information to any other
person, including members of your family or your friends, or assist any other person in
buying, selling or entering into any other transaction using material inside information.
The rules that relate to insider trading are complex. If you are not sure whether these
restrictions apply to you, you should consult the Legal Department before making any

A. Employees and

decision to buy, sell or trade in a security, or before you disclose any information to another

executives are generally

financial prospects, regulatory or legal matters, or management issues, is often considered

prohibited from participating in

“material.”

person. As a general rule, non-public information concerning a company’s business,

expert networks for investors
due to insider trading
concerns. You should consult
with the Ethics Office
regarding this request.

2.3.1 Investments in Companies with Which You
Conduct Business on Verizon’s Behalf
If you conduct or supervise business on Verizon’s behalf with a company, you must not
transact any business in that company’s securities or derivatives of those securities. If you
already own stock in a company, and your position at Verizon requires you to conduct or
supervise business with this company, you must disclose your ownership interest to a vice
president level or above supervisor, and seek approval from the Legal Department prior to
trading in that company’s securities.

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2.3.2 Significant Financial Interests in
Companies
You may not take a significant financial interest in a company that is a business
provider or that competes with or is in one of the same lines of business as Verizon.
A significant financial interest is any financial interest that: (a) is more than 1/10 of
one percent of a company’s publicly traded securities or other financial instruments
and (b) exceeds 25 percent of an employee’s Verizon annual base salary and
bonuses.

2.3.3 Transactions in Securities
You must not engage in any financial transaction that permits you to benefit from the
devaluation of Verizon’s stocks, bonds or other securities, including, but not limited
to, short selling or buying “put” options on Verizon stock.
In addition, you may not participate in financial transactions in the stock or other
securities of business providers or prospective business providers, including “friends
and family” deals or initial public offerings (IPOs), if these opportunities may
influence, or appear to influence, your business judgment on behalf of Verizon.

2.3.4 Loans

Q. My supervisor is experiencing a
personal emergency and I offered a loan

Personal loans from the company to any executive officer (as defined by securities

of $200 until the next pay period. Is this

law) are unlawful and strictly prohibited. Personal loans from the company to any

a concern?

other employee must be approved in writing in advance by the Legal Department or
in accordance with an approved Verizon program. Loans greater than $25 between
employees who are in a direct or indirect reporting relationship are prohibited.

A. Yes, loans greater than $25
between employees who are in a direct
or indirect reporting relationship are
prohibited.

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Section

Protecting Verizon’s Assets and Reputation

3.1 Preparing, Disclosing and Maintaining Accurate
Records
Verizon is committed to maintaining and providing truthful information that fully satisfies
applicable legal requirements, including the Sarbanes-Oxley Act of 2002.

3.1.1 Creating Accurate Records
You must create accurate records that reflect the true nature of the transactions and activities
that they record (including, but not limited to, reporting of time, documenting attendance and
absence, productivity, commissions and quality assurance). You must resolve discrepancies in

No business goal of any kind

any records and make appropriate corrections. If you suspect or learn that records are

is ever an excuse for

misleading or contain errors, you must promptly inform either your supervisor or the VZ

misrepresenting facts or

Compliance Guideline and, if applicable, customers and business providers. Because even a

falsifying records.

minor error can affect the truthfulness of a record, you must report all errors, regardless of their
size or how long ago they may have occurred. If your supervisor fails to address a report about a

Always report information
accurately and promptly

record’s accuracy, you must report your concern to Internal Audit or the VZ Compliance
Guideline.

resolve discrepancies in

Verizon does not tolerate falsification or improper alteration of records. It is never appropriate to

company records. Verizon’s

direct someone else to prepare or approve a false or misleading record and it is no defense to

reputation is a key asset that

say that someone else directed you to make a record that you knew or had reason to suspect

all employees must protect.

was false or misleading. It is also improper to intentionally take any action that leads to the
creation of false or misleading records, such as withholding information from, or providing
incomplete information to, someone who is preparing a record. If you believe that a record was
intentionally falsified or created to be misleading, you must contact Internal Audit or the VZ
Compliance Guideline.

3.1.2 Promoting Transparent and Complete
Disclosure
Verizon is committed to transparency in financial reporting to enhance investors’ understanding
of the company’s business and to facilitate informed investment decisions. All disclosures made
in financial reports and public documents filed with the Securities and Exchange Commission,
and other public communications, must be full, fair, timely, accurate and understandable.
You must not selectively disclose (whether in one-on-one or small discussions or meetings) any
material information regarding Verizon, its securities, business operations, plans, financial
condition, results or any development or plan. You should be particularly careful not to disclose
such information if you make presentations or proposals to customers, business providers,
investors or to any other third party.
To ensure accurate reporting, Verizon employs both internal and outside auditors. You must
cooperate with and provide any auditor or investigator accurate, timely and truthful information.
You must not improperly influence, manipulate or mislead any auditor or investigator. Failure to
cooperate with any audit or related investigation will result in discipline, up to and including
termination of employment.

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3.1.3 Retaining Company Records

Company records must be retained according to applicable laws, Verizon’s Records
Management Policy and the Verizon Records Retention Schedule
(vzweb2.verizon.com/node/10949), which are accessible to employees on the Corporate
Policy section of the Verizon VZWeb. You may never destroy, alter, mutilate or conceal any
record if you have been directed to retain it or if you know—or reasonably believe there is a
possibility—of any litigation or any internal or external investigation concerning that record. If
any person directs you to violate this policy, you must immediately contact the Legal
Department or Security and use all reasonable measures to protect the record.

3.2 Safeguarding Company Information
You must protect company information, both non-public information, that includes “inside
information” (information that could reasonably lead a person to buy, sell or hold Verizon’s or
another company’s securities) and non-public information entrusted to Verizon (such as an
unlisted telephone number, marketing presentations or correspondence), as well as publicly
available information in which Verizon or others have intellectual property rights (such as
copyrighted materials).

You must comply with all company
policies relating to the encryption of
sensitive information. For example,
all company laptops must be
encrypted, and you must encrypt
files containing sensitive
information prior to sending them
via email.

3.2.1 Protecting Non-public Company Information
You must safeguard non-public company information by following company policies and
procedures and contractual agreements for identifying, using, retaining, protecting and
disclosing this information.
You may not release non-public company financial information to the public or third parties
unless specifically authorized by Verizon’s Controller.
You may not release other non-public company information to the public, third parties or

Q. During my commute to the
office on the train, I sometimes
make work-related calls. Is this a
problem?

Internet forums (including blogs or chat rooms) unless you are specifically authorized to do
so by a vice president level or above supervisor, and the Public Policy, Law and Security
Department.
You may only disclose non-public company information to employees who have
demonstrated a legitimate, business-related need for the information.

A. You must be careful not to
discuss non-public company
information in public places, such
as in taxis, trains, elevators or at

Even after the company releases information, you should be mindful that related information

conferences and trade shows.

may still be non-public and must be protected.

When it is necessary to conduct a

Your obligation to safeguard non-public information continues after your employment with

telephone call in a public place, be

the company terminates. Without Verizon’s specific written prior authorization, you may

mindful of your surroundings.

never disclose or use non-public company information.
If you suspect or are aware of any improper disclosure of non-public company information,
you must immediately report it to Security or the VZ Compliance Guideline.

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Q. A competitor's pricing

3.2.2 Acquiring Non-public Company Information
of Others

information was posted on an
Internet blog. The information

You cannot accept non-public information belonging to a third party (including information from

is marked “confidential.” Can I

a former employer) unless the person disclosing the information is authorized to do so, Verizon

use this information in

has the owner’s written permission to receive it and the information is provided according to a

preparing a customer bid?

written agreement that has been approved in advance by your supervisor and the Legal
Department.

A. If you have reason to
believe that the blogger was
not authorized to post the
information and that it is nonpublic, you should contact your
supervisor and Legal to
receive guidance before using
the information.

3.3 Proper Use of Verizon’s Property and Property
Owned by Others
You must always protect Verizon’s tangible and intangible property and any property entrusted
to your care by customers or business providers. Company property and the property of coworkers, customers and business providers may not be taken, sold, loaned, given away or
otherwise disposed of, regardless of its condition or value, without specific authorization.
Property includes, but is not limited to, tangible property, data, records and all communications.
Unless permitted by written company policy, it is never appropriate to use Verizon machinery,

Do not acquire or disclose

switching equipment or vehicles for personal purposes, or any device or system to obtain

non-public information.

unauthorized free or discounted service.

3.3.1 Company Benefits
Verizon’s benefits plans and programs are provided as compensation and must be used
Corporate credit cards are to

honestly. You must not misrepresent your health status, your covered members, your

be used only for approved

beneficiaries, or any other facts, including reasons for absence, in order to claim benefits to

business purposes.

which you or others are not entitled.

3.3.2 Company Property and Funds

Q. I am responding to a

Company property and funds—which include anything that has or represents financial value—

large business customer’s

Personal or unauthorized use of company funds is strictly prohibited. Corporate credit cards

Request for Proposal (RFP).

must be used solely for authorized business purposes and may not be used for personal

The customer sent me an

charges.

must be handled responsibly, honestly and in accordance with applicable company policies.

email that attached our
competitor’s quote for the RFP
response; the customer asked

3.3.3 Work Time

me if Verizon can beat the

You must keep accurate records regarding your work time. You may not instruct another

competitor’s pricing. What

employee to misreport or fail to report any time worked. Overtime eligible employees must

should I do?

report all time worked. By submitting your time, you are representing that you have accurately

A. Contact Legal, preserve

reported your time and that you have not performed any work not reported. You may report any
questions about time reporting, or any concerns you have about the accuracy of your wages,

the email, and do not take

including any claim that you have not been paid for all hours worked, or that any deductions

further action until directed

from your wages are improper or in error, to Human Resources, the Verizon Services Payroll

by Legal. Do not share or use

Department or to the VZ Compliance Guideline.

non-public competitor
confidential information.
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3.4 Protecting Company Communication
and Information Systems

Communication and information systems, including company computers and mobile
devices, are provided to employees to conduct Verizon business and are valuable
assets that must be protected by all employees. You must protect company

Q. Can I check the weather on the
internet with my computer?

information and data from accidental or unauthorized disclosure, misuse, improper

A. Limited personal use of company

alteration or destruction. Limited personal use of communications equipment is

systems is permissible if it conforms to

permissible so long as it does not interfere with work responsibilities or business

Code standards.

operations, incur inappropriate costs, violate the law, this Code or Verizon policy.
You must protect the security of any identification access number, user ID or
password that you use for any computer, network application or communication
device. All electronic media—such as software, thumb drives, CD-ROMs and files—
when acquired through public networks (e.g., the Internet) or from outside parties,
must be checked for viruses prior to installation or use. Only approved and properly
licensed software is to be used on company systems and its use is subject to the
applicable software owner’s license agreements. You must comply with applicable
company policies when acquiring, accessing, using, altering, disposing of or
destroying data, or when commenting on data over public networks (e.g., the
Internet).

3.4.1 Prohibited Activities
You may never use company systems (such as e-mail, instant messaging, the
Intranet or Internet) to engage in activities that are unlawful, violate company policies
or result in Verizon’s liability or embarrassment. Some examples of inappropriate

Q. A friend sent me a chain letter
e-mail requesting that I forward to ten
others to support a charitable cause.
Is this O.K.?

uses of the Internet and e-mail include:

A. No. Circulating chain letters

•

Pornographic, obscene, offensive, harassing or discriminatory content;

through company systems or mail is

•

Chain letters, pyramid schemes or unauthorized mass distributions;

•

Communications on behalf of commercial ventures;

•

Communications primarily directed to a group of employees inside the company

prohibited.

on behalf of an outside organization;
•

Gambling, auction-related materials or games;

•

Large personal files containing graphic or audio material;

•

Violation of others’ intellectual property rights; and

•

Malicious software or instructions for compromising the company’s security.

Also, you may not send e-mail containing non-public company information to any
personal e-mail or messaging service unless authorized to do so by your supervisor
and you comply with company requirements relating to the encryption of information.

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3.5 Security of Facilities

Verizon’s operations must be appropriately secured to protect our customers and each other.
This includes customer and employee personal information, network operations and facilities,
Always wear/display your

computer systems and passwords, security procedures, company facilities and their locations,

identification badge at work.

technical and marketing research data, product development information and business plans
and strategies.

Always protect Verizon’s

You must take all appropriate precautions to protect Verizon’s systems and premises. Do not

property.

leave visitors unescorted or sensitive areas unattended or unlocked. When on company
property (or, if appropriate, while on company business) wear your identification badge and
request identification from others whom you do not recognize. Most importantly, you must

Never compromise integrity for

immediately report all suspicious activity to Verizon Security.

a quick solution.

3.6 Intellectual Property
Intellectual property includes information protected by Verizon’s trademarks or copyrights, the
use of which is restricted by applicable intellectual property laws. To safeguard Verizon’s
intellectual property from illegal copying or other misuse, employees must ensure it is affixed
Intellectual property can be

with or identified by trademark, service mark or copyright symbols.

many things such as

If you’re unsure whether or what protection is necessary or appropriate, or if you believe

marketing strategies, business

disclosure or use by a third party is improper, contact the Legal Department.

plans and other items. If you
are not certain, contact the
Legal Department.

3.6.1 Proper Use of Others’ Intellectual Property
You must respect the proprietary rights of others by complying with all applicable laws and
agreements that protect the intellectual property rights of others, including all business
providers, competitors or customers. Unless you obtain the intellectual property owner’s specific
prior consent, you may not copy, distribute, display, perform, or modify third-party copyrighted
materials or conduct peer-to-peer or other file sharing of copyrighted materials.
A work may be protected by a copyright even if there is no notice on the work.

3.6.2 Information of Former Employers
Former employers may have required you to sign non-disclosure or other agreements that may
affect your work at Verizon. If you have not disclosed these to your supervisor by the time of
hire, you must do so immediately.

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3.7 Handling External Communications

Q. I am a Verizon employee and am

designing new marketing materials that use
Unless you receive prior approval, you may never suggest that you are speaking on

the company logo. Is there any guidance

behalf of Verizon when presenting your personal views at community, professional or

that applies?

cultural functions or on the Internet.
Use of the company brand and logo by Verizon employees for commercial business
purposes must adhere to approved corporate identity specifications. To seek
guidance on appropriate use, visit the Brand Management intranet site
verizon.com/brandcentral. To report misuse, contact the Legal Department.

A. Yes, you must seek guidance about
appropriate use from the Brand
Management intranet site:
verizon.com/brandcentral.

Verizon will generally deny requests for company-sponsored endorsements or
endorsement in any business provider’s advertising or literature must be coordinated

Q. If I am using my personal social

and approved by the Public Policy, Law and Security Department and the Corporate

media account on my personal time, does

Brand Management organization.

the Code of Conduct really apply?

Requests and inquiries must be referred to the authorized groups described below:

A. Yes, portions of the Verizon Code of

testimonials. All requests, including the use of Verizon’s name or an employee

•

Media Relations is responsible for contacts with the news media and inquiries
about community relations.

•

Conduct still apply to your personal use of
social media. For example, if you identify
Verizon as your employer and post racist
of violence on your social media pages,

Public Policy, Law and Security Department handles contacts from outside

such behavior may constitute prohibited off-

attorneys, legislative bodies and regulatory agencies.
•

comments or comments encouraging acts

performance and all contacts with the financial community.
•

Investor Relations handles communications related to Verizon’s financial

duty misconduct.

Human Resources handles inquiries regarding current and former employees,
including employment verification.

•

For additional information about the proper

Public Policy, Law and Security Department responds to subpoenas, court

use of social media, either in your individual

orders and criminal inquiries and interfaces with law enforcement on security

capacity, or on behalf of Verizon, please

matters, including emergency response.

review the company’s social media policies:
vzweb2.verizon.com/social-mediacompliance

For approval to speak externally on behalf
of Verizon, please contact Media Relations:
verizon.com/about/news/media-contacts

For more information about speaking
externally on behalf of Verizon, contact the
Verizon Speaker Bureau:
vzweb2.verizon.com/verizon-speakerbureau

For legal assistance, please contact your
business unit’s assigned attorney. Please
check within your department to identify
your contact.

24

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Section

Maintaining Integrity and Fairness in the
Marketplace

Verizon’s integrity in the marketplace is a key component of our reputation for trustworthiness and
service.

4.1 Customer Relationships
Verizon’s customers expect and deserve fair, honest and respectful service. You are accountable
for your role in the delivery of that standard of service.

4.1.1 Customer Privacy and Communications
Verizon’s privacy policies inform customers about what information is collected about them and
how it is used. Customers are also given the ability to limit certain uses of their information. You
must respect these choices. Verizon’s privacy policies may be found at:
vzweb2.verizon.com/verizon-privacy-office. Verizon’s Privacy Office can also assist with specific
Treat customers fairly in all
aspects of transactions,
including pricing,
advertising, marketing and
service solutions.

questions or concerns.
Except as otherwise required by the duties of your position, you must not—and must not permit
others to—access, listen to, monitor, record, tamper with, disclose or intrude upon any customer
conversation or communication, except to comply with a valid service or installation order, a valid
legal order or applicable law, or for the limited purposes of quality monitoring and training, as
approved by the Legal Department.
In addition to protecting customer communications, you must also protect customer information.

Protect customer

That means you may not access, view, use, modify, share or distribute customer information

confidential information and

without a proper business reason. You also may not access account information concerning

respect customer privacy

yourself, your friends, acquaintances, family or coworkers without prior approval by your

by following the Verizon

supervisor.

Privacy Principles.

Verizon contractors and vendors must also protect customer information. You should work with the
Legal Department to ensure that contracts with these third parties protect customer information. If
you are aware of or suspect unauthorized access to, disclosure, or loss of customer information,
you must immediately notify the Legal Department, Security or the VZ Compliance Guideline.

4.1.2 Customer Marketing
Before using any customer information to market additional products or services, or disclosing
customer information to other companies for marketing purposes, you must follow all company
policies and applicable laws and regulations regarding the use and disclosure of this information.
When customers are also telecommunications carriers or resellers of telecommunications, you
should not use their subscriber information, orders or processes/services to aid in Verizon’s retail
marketing or sales efforts.

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4.1.3 Selling with Integrity

Verizon policy requires that we fully, clearly and directly inform our customers of the
terms and conditions of our services. Any attempt to deceive a customer will not be

Provide accurate and clear information.

tolerated and may result in disciplinary action up to and including termination of
employment. The following guidelines must be followed at all times:
•

All advertising and sales materials must be truthful and accurate. Materials must not
be false, misleading or have a tendency to deceive. All claims must be substantiated
in advance with a factual basis and back up. No advertising or sales materials will
be released without Legal Department approval.

•

When advertising the price of Verizon’s products and services, the customer must
be clearly informed of all monthly and per-use fees and any other material terms
and restrictions for obtaining the advertised rate in marketing and promotional
materials. There will be no “hidden” charges.

•

Comparisons to competitors must be accurate and substantiated at the time they
are made. Do not disparage competitors. You should promote Verizon’s products
and services through fair and accurate comparisons with its competitors, and sell on
the strength of Verizon’s products, services and reputation. Do not make misleading
or inaccurate comparisons with competitors’ products and services; comment on
competitors’ character, financial condition or potential legal or regulatory problems;
or make negative remarks about entire groups of competitors and their products and
services.

•

There are strict rules regarding sales and promotions. They must be followed
without exception. For example, you cannot use the word “free” without full
disclosure of all material conditions disclosed in close proximity to the word.

4.2 The Government as a Customer
When dealing with government agencies that are customers, you should consult with the
Legal Department to identify additional laws, regulations and procedures that you must
follow, including those related to gifts, entertainment, accuracy in billing and limitations
on contacts with government officials during active government procurements.

4.2.1 Court Orders and Other Legal Documents

Learn and follow all additional
requirements when dealing with the
government as a customer.

Verizon may receive court orders seeking information about its customers. You may
neither confirm nor deny to any unauthorized person the existence of, or any information
concerning, a subpoena, warrant or court order. You should immediately refer to

Ethical behavior is promoted by full and

Security any inquiries or requests of this kind.

open disclosure.

If you receive any legal documents in the workplace, including court orders and
subpoenas, warrants, summons and correspondence from any government or law
enforcement agency, or any attorney, you must forward them immediately to the Legal
Department.

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4.2.2 Classified and National Security Information
You must take all necessary steps to protect classified and national security information and you must
coordinate all activities related to this information with Security and Legal Department personnel who
have appropriate clearance. It is never appropriate to disclose this information to another person
without explicit approval from the Legal Department.

Q. My wife manages a
training consulting firm.
Can she submit a
proposal to become a
Verizon vendor?

A. You should report
this relationship to your
supervisor, refer the

4.3 Selecting and Maintaining Relationships with
Business Providers
You must use care and good judgment in selecting and maintaining relationships with all of Verizon’s
business providers. Employees who participate in the selection of any business provider must:
•

Use a selection process that is fair, lawful, does not improperly discriminate and complies with all
company policies and procedures;

•

Ensure business providers are apprised of their obligation to abide by Verizon’s standards of
business conduct and the Verizon Supplier Code of Conduct;

matter to Corporate

•

Put all agreements in writing and obtain all required approvals before signing; and

Sourcing and refrain from

•

Never reveal confidential information about one vendor to another vendor or to anyone outside of

participating in Verizon’s

Verizon. Disclosures of such information, even within Verizon, should be limited to those with a

discussions or relationship

need to know the information.

on this matter.

Q. A vendor has
offered me tickets to a
baseball game. Can I
accept them?

4.4 Gifts and Entertainment
The exchange of gifts and entertainment can promote successful working relationships and good will.
However, failure to follow applicable laws as well as company rules and procedures can harm
Verizon’s reputation or result in civil or criminal penalties.
Regardless of value, the appearance of influence must always be considered before accepting any gift,

A. Possibly. If the

entertainment or other business courtesy. You may not use your own money or resources to offer gifts

vendor is inviting you to

Verizon’s resources. In addition, when you offer gifts or provide entertainment to others consistent with

attend the game with

this Code, you must also ensure that these courtesies are properly reflected on Verizon’s books and

him/her, this may

records.

or entertainment to a customer or vendor if these activities otherwise would be prohibited using

constitute business
entertainment and must
comply with the Code’s
standards for business
entertainment. If the
vendor is not attending,
then the tickets would be

4.4.1 When Gifts are Appropriate
A "gift" is anything of value, including promotional trinkets, food, beverages and tickets to cultural or
sporting events, that you or someone in your family or household—or a person with whom you have a
close personal relationship—either give or receive.

considered a gift and must

To be appropriate, a gift (whether it is given or received) must be in compliance with applicable laws

comply with the Code’s

and:

standards for accepting

•

Unsolicited;

gifts.

•

Not cash or usable as cash (including gift cards and gift certificates, unless they have been
approved as part of a Verizon marketing promotion or other authorized Verizon program and
approved by the Legal Department); and

•

No more than $150 in face value in a calendar year to or from the same organization, unless
approved by a director level or above supervisor and the Ethics Office.
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4.4.2 When Entertainment is Appropriate

Entertainment includes meals and cultural or sporting events that you attend with a
customer or business provider. If you do not attend the event with the customer or
business provider, the tickets to such an event are not entertainment, but rather “gifts,”
which are subject to the gift restrictions in this Code.
To be appropriate, entertainment must be in compliance with applicable laws and:
•

Offered or accepted in the normal course of business;

•

Attended by both a Verizon employee and a business provider’s employee and
be an occasion where business is discussed;

•

You should never use gifts and
entertainment to place undue influence

director level or above supervisor and the Ethics Office; and
•

No more than $250 in value per occasion, per person unless approved by a

on Verizon’s business providers.

At a venue and conducted in a manner that does not violate other provisions of
this Code or harm the company’s reputation (e.g., an event at an adult
entertainment venue is not acceptable).

Q. My sales team is working on

4.4.3 Prohibited Exchanges

Verizon’s bid response to a non-

Even if the gift or entertainment meets the above standards, you must not exchange it

Proposal. I would like to take the customer

if: (a) it is intended to improperly influence another person’s business judgment; (b) it

to dinner to discuss our proposal. Can I

might create the appearance of undue influence, unfairness or impropriety; or (c) you

pay for the customer’s meal?

are participating in, conducting or directly supervising a formal Verizon procurement

government customer’s Request for

process (such as a request for bids).

A. Yes, it is permissible to pay for the

Employees are not permitted to receive tips and you should politely decline any that

meal as long as it conforms with the

are offered to you.

Code’s standards for business

4.4.4 Gifts Involving Travel or Lodging

entertainment, applicable policies and legal
standards. However, the exchange of gifts
during a procurement process is improper

You are prohibited from receiving gifts of travel or lodging unless you receive the prior

because such gifts can create the

approval of the Ethics Office.

appearance of undue influence.

4.4.5 Returning Gifts
If a gift exceeds the standards set forth in this Code, you should return the gift with an
explanation that company standards do not permit you to accept such gifts. If
returning a perishable item is not feasible, it should be anonymously donated to
charity or accepted on behalf of Verizon and shared among all employees in the
office. If shared, the gift’s value per person should not exceed the $150 calendar year
limit.
If you receive a gift that falls outside of the Verizon standards and you are unable to
return it, you must contact the VZ Compliance Guideline for appropriate
documentation, safeguarding and disposition of the gift.

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4.4.6 Gifts Outside the Workplace

Employees who are personal friends of customers or business providers might wish to exchange
gifts outside of the workplace for appropriate events (such as a wedding or baby shower). These
exchanges should be infrequent, disconnected from any work activities and disclosed to a
supervisor beforehand to ensure that they do not improperly influence or appear to influence
business decisions.

Q. I sell Verizon
products to state
governments. Can I take
my state government
contact to a football game,
using Verizon’s tickets?

A. You must obtain
written Legal approval
before providing any gifts,
entertainment, or anything
else of value to a
government official or
employee.

4.4.7 Gifts and Entertainment Involving Government
Officials
Special rules apply to interactions with government officials and employees. Laws, rules and
regulations concerning appropriate gifts and entertainment for government officials and employees
are complex and can vary depending on government branch, state or other jurisdiction. Additionally,
the Foreign Corrupt Practices Act (discussed further in section 4.9.4) restricts the exchange of gifts
and entertainment with non-U.S. officials.
All employees must obtain advance written approval from the Legal Department before providing
gifts, entertainment, or anything else of value to any government official or employee.

4.5 Bribes, Kickbacks and Loans
It is never appropriate to offer, pay, or receive bribes or kickbacks (including to or from any
government official or employee), which can subject you to civil or criminal penalties. You should
immediately notify the Legal Department about any payment or gift that is offered to you, or
requested from you, that you believe may be a bribe, kickback, solicitation of a bribe or kickback, or
otherwise improper.
It is never appropriate to offer or accept personal loans or guarantees (e.g., preferences or
discounts not offered widely) to or from customers, business providers or competitors of Verizon.

You may not rehire or

4.6 Relationships with and Obligations of Departing
and Former Employees

contract with a former
employee unless that

Your obligation to abide by company standards exists even after your employment with Verizon

person has been separated

ends. The following requirements apply to all current, departing and former Verizon employees:

from the company for a

•

minimum time period of six
months. Any exceptions
must comply with this Code

When leaving or retiring, you must ensure that you return all Verizon property in your
possession, including all records and equipment.

•

You may not breach any employment condition or agreement you have with Verizon. You may
not use or disclose Verizon non-public information in any subsequent employment, unless you

and applicable policy.

receive written permission in advance from a Verizon vice president level or above supervisor
and the Legal Department.
•

You may not provide any Verizon non-public company information to former employees, unless
authorized. If a former employee solicits non-public information from you, you must immediately
notify Security or the Legal Department.

•

Except as authorized below, you may not rehire a former employee, engage a former employee
as an independent contractor or contingent worker, or purchase products or services on
Verizon’s behalf from a former employee unless that former employee has been separated from
the company for at least six months.
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•

In extremely limited circumstances, the Executive Vice President - Human Resources
may, in writing prior to the engagement, and upon finding a compelling reason, approve
the rehire of a former employee or the engagement of a former employee as an
independent contractor or contingent worker within six months of that person’s
separation.

•

A vice president level or above supervisor may, in writing prior to the purchase, and upon
finding a compelling reason, approve the purchase of products or services on Verizon’s
behalf from a former employee within six months of that person’s separation. Where a
former employee has been separated from Verizon for more than six months,
authorization from your supervisor must be obtained before products or services are
purchased from that former employee.

If you are concerned that a former Verizon employee is benefiting unfairly from information
obtained while employed at Verizon, or may be inappropriately receiving Verizon non-public
information, you should contact the VZ Compliance Guideline for guidance.

4.7 Interaction with Competitors
We sell our products and
Verizon is dedicated to ethical, fair and vigorous competition. We will sell our products and

services on the basis of their

services on the basis of their merit, superior quality and competitive pricing. Any questions

merit, superior quality and

concerning competition laws should be reviewed with the Legal Department.

competitive pricing.

4.7.1 Avoiding Violations of the Antitrust and
Competition Laws
The U.S. antitrust laws prohibit certain activities. If you have any questions about whether
any activity falls into the following categories, or if you have any information about someone
in the company engaging in the following types of conduct, you must contact the Legal
Department.
You should also contact the Legal Department to determine the applicability of antitrust or
competition laws of any other country in which you conduct business.
The antitrust laws prohibit agreements with competitors fixing prices, dividing markets, rigging
bids or otherwise limiting competition. Explicit agreements, informal “gentlemen’s
agreements,” and even a “wink and a nod” are against the law. Violation of these prohibitions
may result in serious consequences for you or the company, including criminal penalties and
imprisonment.
The following activities are prohibited:
•

Price Fixing: You must not agree with a competitor on prices or set prices in concert
with a competitor. This also prohibits discussions on things that influence price, such as
costs, marketing and sales strategies, future product or geographic expansion plans,
credit terms, and other competitively sensitive information.

•

Market Allocation: You must not agree with a competitor to divide markets, products,
customers, or segments. You must not engage in any communications with competitors
about the places or customers for which they or Verizon are competing.

•

Bid Rigging: You must not agree with a competitor to set the terms or direct the
outcome of a bidding process. You also must not engage in any communications with
competitors about bids.

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•

Group Boycotts: You must not boycott a supplier or customer as a way to make the
supplier or customer stop dealing with a rival. A group boycott—an agreement with others

Q. I have established good

not to deal with another person or business—may violate the antitrust laws if it is used to
force customers to pay higher prices or to hinder a rival from entering the market.

relations with the account
executives of some of our

In addition, you should be careful of the following:

competitors. At trade shows

•

Joint Ventures, Teaming Arrangements and Non-Competition Agreements: The

and conferences we often

antitrust laws do not prohibit all joint ventures or teaming arrangements. Sometimes,

catch up on industry trends,

agreements not to compete are permissible as part of otherwise valid business

customer deals, etc. Is this

arrangements. But those occasions are limited and must be approved by the Legal

appropriate?

Department. You may not submit a joint bid, enter into a joint venture or teaming
arrangement or negotiate a non-compete agreement without the approval and involvement

A. Use caution in these

of the Legal Department.

situations and do not discuss

The antitrust laws also prohibit certain types of unilateral conduct, that is, conduct undertaken

the price or terms of any

by Verizon alone. Violation of this prohibition may result in large fines and judgments against

Verizon contracts or gain

the company.

competitive information

You must not engage in the following conduct:

directly from a competitor.

•

Sabotage: Do not tamper with competitors’ products, sales materials or other property.

•

False Statements: When making comparisons to a competitor, stick to the facts. Do not

You should not even joke
about work-related topics

embellish, exaggerate or mislead.

since this could be
misinterpreted. You should

The antitrust laws limit the circumstances in which certain business or marketing decisions are

refuse to discuss any anti-

permissible. Before engaging in any of the conduct described below, consult the Legal

competitive issues and leave

Department for guidance:

such conversations

•

immediately.

Exclusive Dealing: Exclusive dealing occurs when a company requires, as a condition of
doing business, that a customer forego dealing with competitors.

•

Resale Prices: Resale price setting occurs when a company establishes the price that
resellers or distributors charge for Verizon’s products.

•

customer a service that it makes available to other customers, or when a company offers a

You must make independent

service to one customer on more burdensome terms than it makes available to other

pricing and marketing

similarly situated customers.

decisions and cannot
coordinate your actions with

•
•

Bundling: Bundling occurs when a company offers a discount on one product if it is
purchased together with another.

Deal fairly and honestly in all
licensing and rights to sell.

Tying: Tying occurs when a company forces a customer who wants one product to buy a
second product also, as a condition of buying the desired product.

Verizon's competitors.

activities, including pricing,

Refusals To Deal: Refusals to deal occur when a company declines to offer to one

•

Below-cost Pricing: Pricing below cost occurs when a company does not recover its
costs for a particular product, or bundle of products.

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4.7.2 Gathering Information About Competitors

While it is entirely proper for employees to gather information about competitors, you must
avoid even the appearance of improperly acquiring this information. You must accurately
represent yourself and never misrepresent your identity when gathering competitive

Accurately identify yourself when
you gather public information
about competitors.

information. You must also ensure that any agents or consultants employed to obtain
competitive information on Verizon’s behalf also represent themselves accurately and follow
these principles.
Generally, it is appropriate to gather competitive information from public sources, industry
gatherings and surveys and benchmarking/competitive research. It is never appropriate to
request or obtain non-public competitor information from government or agency reports that
are not available to the public from other competitors or former employees of competitors,
who must abide by any non-disclosure or confidentiality agreements with their former
employers, unless you are well briefed beforehand by the Legal Department regarding what
you can and cannot discuss. It is also never appropriate to commit theft, espionage or
breach of a competitor’s non-disclosure agreement. To the extent that information is clearly
private or marked in such a way as to indicate it is private, you should not use it and should
contact the Legal Department for guidance.
If you have reason to believe that competitive information from customers or others may not
be public, you should consult with the Legal Department before accepting or using this
information.

4.8 Relationships With Affiliates
In order to ensure that the company’s organizational structure is not used unfairly, all
transactions between and among the Verizon companies (also called “affiliates”) must
comply with company policy and all applicable laws and regulations, including affiliate pricing
and Customer Proprietary Network Information (CPNI) requirements.

4.9 International Relationships
Verizon must abide by the laws, rules and regulations of countries where we do business. If

When working abroad, you must

your job, or the jobs of anyone you supervise, involves business with customers or vendors

adhere to this Code of Conduct,

in another country, you must be familiar with all laws that impact your work. Because cultural

as consistent with applicable

differences and local customs or laws may raise issues, prior to engaging in any

laws.

international business, you should review this section and discuss these issues with your
supervisor and your business unit Legal Department or Corporate Compliance Counsel.

4.9.1 Locating Offices or Receiving Services
Outside of the United States
If you are considering locating or moving a project, unit, group or any Verizon activity outside
the United States, or obtaining services from employees or external providers located
outside the United States (including any call center or IT services from individuals located
outside of the United States), you must contact the Legal Department to determine the rules,
policies and laws that may apply.

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4.9.2 Compliance with Screening Requirements of
the Office of Foreign Asset Control (OFAC)
The regulations promulgated by the Office of Foreign Asset Control (OFAC) of the U.S.
Department of the Treasury prohibit any U.S. person, including employees of U.S. companies
located outside the U.S., from transferring, paying, receiving or otherwise dealing in property
or an interest in property belonging to or under the control of a large number of specially
designated individuals and entities (the OFAC List). Violations of these regulations can result
in substantial fines and imprisonment.
To comply with the OFAC regulations, those entities with which we transact directly must be
screened against the OFAC List. In addition, we must not transact indirectly, through our
contractors, tenants, landlords or vendors, with individuals and entities on the OFAC List. To
this end, compliance with the OFAC regulations is also an integral obligation of our agents,
vendors, suppliers and other third parties, as reflected in our Supplier Code of Conduct and
our OFAC Export Control Guidance for Vendors & Suppliers.
You should contact your business unit Legal Department or Corporate Compliance Counsel to
confirm compliance with OFAC screening requirements.

It is important to remember
that export regulations
likely exist and will need to be
adhered to, regardless of the
country from which an export
originates. Most countries
have implemented
comprehensive export control

4.9.3 Import/Export Control
It is Verizon’s policy to comply with all import and export laws and regulations, including the
U.S. Export Administration Act and the International Traffic in Arms Regulations (ITAR), as
well as the import and export laws and regulations of all countries applicable to our global
business. Failure to do so could result in civil and criminal penalties, imprisonment and the
loss of Verizon’s ability to import or export products and services and retain government
contracting privileges.

regimes. Contact your

Because specific authorizations or licensing may be required for particular transactions, you

Corporate Compliance

should contact your business unit Export Control Coordinator, your business unit Legal

Counsel or business unit Legal

Department or Corporate Compliance Counsel before:

Department prior to shipping

•

Exporting via physical shipment, electronic means or any other means of transfer any
product, service or technical information from the U.S. or moving it between or among

across borders.

countries. Technical information can consist of manufacturing processes, product use or
commercial and technical expertise, data or software;
•

Exporting products or services identified on the U.S. Munitions List contained in the ITAR;

•

Taking any product, service or technical information with you when you travel to another
country on personal or company sponsored business;

•

Providing any product, service or technical information to parties that previously have
been denied an export license; or

•

Discussing with or displaying to non-U.S. nationals (including Verizon employees),
whether inside or outside the U.S., any Verizon technical data, equipment or non-public
information or its application, whether inside or outside the U.S., either on company or
personal business.

You should consult your business unit Export Control Coordinator or Corporate Compliance
Counsel to identify situations that may require written assurance by non-U.S. recipients that
they will abide by U.S. export control regulations.

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4.9.4 Payments, Lobbying, Expenses and
Recordkeeping Requirements Globally

Q. In conjunction with a
deal I am working on, a government

The payments we make, lobbying we conduct and expenses we incur in the course of

official has asked Verizon to pay a

doing business internationally must reflect the value of the services actually provided, be

“processing fee” to expedite

directed to proper business purposes, be made to legitimate business service providers,

clearing customs. What should I

be accurately documented and meet the requirements of the laws of the U.S. and of

do?

other countries where we do business.
A growing number of countries have anti-corruption laws which make it a crime to bribe
government officials and others with whom Verizon conducts business. One key law
governing our conduct of business outside the U.S. is the Foreign Corrupt Practices Act
(FCPA), which prohibits bribes and provision of other improper payments or items of
value, or offers or agreements to pay bribes or provide other improper payments or items
of value to a non-U.S. government official. Because Verizon is incorporated in the U.S.,
the FCPA applies to all Verizon employees around the world.

A. “Expediting” or “facilitating”
payments are unlawful in many
circumstances and are generally
prohibited at Verizon. You must
immediately notify Corporate
Compliance Counsel or your
business unit Legal Department

Another key anti-corruption law governing Verizon’s global business activities is the U.K.

Vice President about any requests

Bribery Act, which prohibits bribery and other improper payments, as well as offering,

to pay what you believe may be an

requesting, or agreeing to bribes or other improper payments, to or from not only

expediting or facilitating payment.

government officials but also non-governmental third parties. The U.K. Bribery Act may
apply to anyone performing services for or on behalf of Verizon in any country.
Before offering meals, gifts, gratuities, entertainment or anything of value to any
government official, you must consult with your business unit Legal Department or
Corporate Compliance Counsel regarding compliance with applicable anti-corruption
laws and Verizon standards. Also consult with your business unit Legal Department or
Corporate Compliance Counsel regarding any payment or gift that is requested from you
or offered to you that you believe may be a bribe, solicitation of a bribe or otherwise
improper, even if it does not involve a government official.
Additionally, you must never make payments to a third party that you suspect may be
passed to government officials or other persons to improperly influence any person’s
decision-making to secure, retain or direct business for Verizon. You must not use an
agent to make any payment that Verizon itself cannot make. Whenever you retain any
agent in connection with our global business, you must make sure that you can properly
trace any funds provided to the agent to ensure that they are not used to make improper
payments.
Regardless of the customs of a particular country, you must be careful to follow company
standards, local laws and U.S. laws regarding doing business with government officials
or their family members.
Verizon is required to accurately record information regarding payment, including the
amount and recipient. These record-keeping requirements apply to any agents or
consultants who represent Verizon. This means that you must ensure that Verizon—or
any agent or consultant who acts on Verizon’s behalf—properly documents all
transactions and maintains accurate information with respect to the amount and ultimate
recipient of contract payments, commissions and other payments.
You should consult with your business unit Legal Department or Corporate Compliance
Counsel if you have any questions about anti-corruption laws, Verizon’s anti-corruption
compliance program, or your individual compliance obligations.

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Q. My business group was
recently contacted
by a foreign organization that
wants to arrange for the
purchase of certain services
and products from Verizon.
The organization is head-

4.9.5 Economic Sanctions and Embargoes

It is illegal under U.S. law for any U.S. company or person (including employees of U.S.
companies located outside the U.S.) to engage in transactions with a number of designated
countries, or with certain designated parties anywhere in the world (for example, groups that
support terrorism). You should check with the Legal Department regarding sanctions and
embargoes by the U.S. and other countries that prohibit conducting business in specific
countries or with specifically identified parties.

quartered in a country

In addition, because the United States and other countries have restricted travel to certain

in which we have never

countries, employees who travel internationally must familiarize themselves with any

done business. What should I

prohibitions on travel due to sanctions or embargoes, restrictions on taking company assets

do?

into certain countries and the rules and procedures for obtaining and using business travel
documents, including passports, visas, approvals and special documentation.

A. Before discussing
business with this
organization, you must
first check with the Legal
Department to determine
if you will be doing business
in a country or with an
organization that is the

4.9.6 Illegal Boycotts
Verizon will not participate in boycotts of countries, their nationals or blacklisted companies,
unless these boycotts are sanctioned by the U.S. government and participation by Verizon is
approved by your business unit Legal Department or Corporate Compliance Counsel. Nor will
Verizon disclose information about present or prospective business relationships in countries
that are the subject of illegal or improper boycotts.

subject of any legally

Unless approved by your business unit Legal Department or Corporate Compliance Counsel,

imposed economic sanctions.

you must not furnish information about:
•

Verizon’s past, present or prospective business relationships with illegally boycotted
countries or blacklisted companies; or

•

Any person’s: a) race, religion, gender, national origin or nationality,
b) membership in or support of a charitable or fraternal organization supporting boycotted
countries, c) relationship with nationals of boycotted countries, or
d) relationship with a boycotted country or blacklisted company; or

•

Any person believed to be restricted from doing business with a boycotted country.

Any request for information regarding boycotted countries or organizations must be
immediately referred to Corporate Compliance Counsel.

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Conclusion

It is not possible to describe all unethical or illegal business practices in detail. The
best guidelines are individual conscience, common sense and unwavering
compliance with all company policies, applicable laws, regulations and contractual
obligations. Seek guidance if you are unsure of what to do, ask questions and report
wrongdoing. Company policy strictly forbids any retaliation against an employee who
reports suspected wrongdoing.
Violations of the law, the Code and other company policies, procedures, instructions,
practices and the like can lead to disciplinary action up to and including termination
of employment. Such disciplinary action may also be taken against supervisors or
executives who condone, permit or have knowledge of improper conduct or fail to
take action to prevent and detect violations, such as failure to provide training and
failure to supervise subordinates’ work. No one may justify an illegal or improper act
by claiming it was ordered by someone in higher management. The following are
examples of actions considered illegal or unacceptable:

•

Theft or unauthorized access, use or disclosure of company, customer or
employee records, data, funds, property or information (whether or not it is
proprietary);

•

Working under the influence of alcohol or illegal substances or abusing legal
substances;

•

Improperly operating a vehicle for company business, or driving while on
company business with a suspended or revoked license, or while under the
influence of drugs or alcohol;

•
•

Using any program or promotion in an unauthorized manner;
Engaging in any form of workplace violence, including, but not limited to,
any act of physical intimidation or assault, including threats of violence;

•

Soliciting or giving the impression that you would expect gifts or gratuities from
suppliers or customers;

•

Disparaging or misrepresenting the company’s products or services or its
employees;

•

Falsifying a company record, such as a time report; and

•

Misrepresenting your health status or other reasons for absence, such as
misrepresenting yourself as disabled and receiving disability benefits.

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Case 1:19-cv-01298-JKB Document 1-5 Filed 05/02/19 Page 37 of 40

Sources of Help

Verizon provides many resources to help you make ethical decisions. In addition to your supervisor, you may
consult with Human Resources, the Legal Department or call the VZ Compliance Guideline.
Verizon’s VZWeb (Intranet), vzweb2.verizon.com, contains expansive helpful contact and subject matter
information. In addition, please reference the chart below for some important resources.

Quick Reference Chart
Resource

Phone Number

Website/Email

VZ Compliance Guideline

844.VZ GUIDE

verizonguideline.com

844.894.8433 (U.S.)

[e-mail]

(Ethics Office)

(+)800.0.624.0007
(International)

aboutyou.verizon.com/HRGuidelines/
VzCulture/EthicsCompliance

Human Resources (U.S.)

Consult website

aboutyou.verizon.com/HRGuidelines

Human Resources
(International)

(+)800.0.932.7947
Vnet 932.7947

aboutyou.verizon.com/HRGuidelines

Security (U.S.)

800.997.3287

security.verizon.com

Security (International)

972.615.4343

security.verizon.com,

Office of Ethics and
Business Conduct

Click “International Security”

Corporate Compliance

Consult website

vzweb2.verizon.com/verizon-compliance

Internal Audit

844.VZ GUIDE
844.894.8433 (U.S.)

vzweb2.verizon.com/verizon-internal-audit

(+)800.0.624.0007
(International)
Privacy Office

Consult website

vzweb2.verizon.com/verizon-privacy-office

Environmental, Health &
Safety

800.386.9639 (U.S.)

aboutyou.verizon.com/HRGuidelines
/VzCulture/SafetyAndEnvironmentalCompli
ance

(+)800.386.9639
(International)

https://vzweb2.verizon.com/complianceenvironment-health-safety-and-vehicles
(Wireless Network Environmental)
Export Control
Compliance

Consult website

vzweb2.verizon.com/export-controlsembargoes-and-sanctions-and-antiboycott-compliance

37

Case 1:19-cv-01298-JKB Document 1-5 Filed 05/02/19 Page 38 of 40
Resource

Phone Number

Website

Public Policy, Law &
Security

Consult website

vzweb2.verizon.com/public-policy-law-andsecurity-0

Subpoenas & Court Orders

800.451.5242

security.verizon.com/Securitywebsite/
SecurityOrganizations/LegalCompliance/
LCContacts/tabid/455/Default.aspx

Media Relations

Consult website

verizon.com/about/news/media-contacts

Investor Relations

Consult website

verizon.com/about/investors/
contact-investor-relations

Corporate Responsibility

Consult website

responsibility.verizon.com

Employee Assistance
Program (U.S.)

888.441.8674

anthem.com/eap/verizon

Employee Assistance
Program (International)

Consult website

anthem.com/eap/global

(including Verizon Foundation)

Notes

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Notes

Case 1:19-cv-01298-JKB Document 1-5 Filed 05/02/19 Page 39 of 40

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Case 1:19-cv-01298-JKB Document 1-5 Filed 05/02/19 Page 40 of 40

s

© 2010, 2017 Verizon. All Rights Reserved.

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