Salesforce: Code of Conduct

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Salesforce

CODE OF CONDUCT

1
A MESSAGE FROM MARC BENIOFF

Dear Salesforce employees:

Salesforce has always had an unwavering commitment to the success of our customers.

Our focus on customer success is why we have been able to shape the new world of enterprise software
and become the world’s leading CRM company.

Our commitment to customer success, as well as philanthropy and sustainability, goes hand-in-hand
with our culture of trust, transparency, personal integrity, respect and open communication. These are
not just words, but core values that are embodied in the decisions and actions that each of us undertake
every single day.

The continued success of Salesforce depends on maintaining our culture and following our Code of
Conduct, which reinforces how those core values are at the heart of our company’s success and have a
direct impact on our ability to deliver success to our customers.

Our Code could be best summed up in the Hawaiian greeting aloha, which means compassion, respect,
and affection. It underlies our belief that we must treat others ethically and always do right by the
people who depend upon us.

That’s why I ask each of you at Salesforce to make a personal commitment to follow our Code of
Conduct. It should be used as a tool to help you make the right decisions, and take the right action in
any situation. You’ll also find practical guidance for handling situations where doing the right thing may
not be immediately clear.

If you are ever unsure or feel that the Code of Conduct is being violated, we ask you to speak up. Talk to
your manager or reach out to your contact in our Law Department or
via legalcompliance@salesforce.com.

You may also share concerns anonymously through our Ethicspoint hotline. Remember, our non-
retaliation policy means that you don’t need to be afraid of asking questions or reporting potential
issues.

Thank you for contributing to the Salesforce culture and upholding our values. We appreciate everything
you do for Salesforce and our customers every day.

Aloha,

Marc Benioff
Chairman & Chief Executive Officer

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PART 1: THE CODE OF CONDUCT

This Code of Conduct outlines how Salesforce and its subsidiaries conduct business and describes the
company’s most fundamental shared values. It also helps us understand how our values affect the way
the company does business.

Of course aloha is a greeting, but in Hawaiian it also expresses compassion and respect.
Salesforce’s aloha culture embodies the commitment to treat others well and always do right by
the people who depend on the company.

It is always important to do the right thing. Referring to this Code and following company policies,
applicable laws, rules and regulations at all times will help enable you to make the right choices.
However, if you ever have questions or concerns about a section of this Code, a company policy, a law,
rule, or regulation, you should contact the Law Department at legalcompliance@salesforce.com.
Every person can make a big difference, so it is vital that all employees act with integrity and in
accordance with local laws. That is why this Code applies to everyone at Salesforce, including at our
subsidiaries. Above all, this Code helps employees maintain the trust Salesforce has built with its
customers, employees, and others who have a stake in the company’s success. That trust is what helps
all Salesforce employees succeed every day.

How to Raise Questions and Report Concerns


Why is it critical to raise a question or concern?
If you are not sure how to handle something, or if you think there is a problem, speak up! No matter
how small the issue is, the company wants to hear from you. The company cannot fix issues that it does
not know about.
Whom should I contact?
If you have questions or want to raise a concern, get in touch with one of these resources:
 Your manager, or another manager you trust
 Employee Success (“ES”) – go to #dreamjob central, or call:
US and Canada – (855) DRMJOBS/ (855) 376-5627
EMEA – 00.800.1DRMJOBS/00.800.1376.5627
 The Law Department at legalcompliance@salesforce.com
 Ethicspoint Reporting Line (in the U.S., 1-866-294-3540, internationally via collect call at +1-503-
726-2414, or at http://www.salesforce.ethicspoint.com/)

If you report using Ethicspoint, you may be able to report anonymously, depending on the local
laws where you work. Try to provide as much information as possible so that your report can be
fully investigated.

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Good faith reporting and non-retaliation
Acting in good faith means that all reports of possible violations of this Code, company policy, or the law
are made sincerely and honestly. In other words, it does not matter whether your report turns out to be
true, but you must make it with the best intentions.
In return, the company is committed to non-retaliation. In order to operate effectively, it is vital for all
company employees to trust and respect each other. Retaliating against someone who has made a
report or participated in an investigation is not tolerated.
Investigations and discipline
Reports will be investigated in a respectful, professional manner as promptly and confidentially as
possible. If you are asked to participate in an investigation, you are required to cooperate fully.
Violations of this Code and other company policies are taken seriously. There are consequences for
violating this Code or other company policies, which may include termination of employment.

Expectations for Managers


While this Code applies to everyone at Salesforce equally, employees in a managerial role have extra
responsibilities. If you are a manager, you have an incredible opportunity to set the right tone for your
team, including by doing the following:

 Lead by example, always choosing the ethical course of action.


 Speak up when you see a problem and encourage others to do the same.
 Make sure your direct reports understand this Code and what is expected of them.
 Always be receptive to questions, concerns, or comments, and make sure that issues are
directed to the people who can help.
 Escalate matters that may indicate a violation of the Code or any other company policy to
your manager, the Law Department, Employee Success, or through Ethicspoint.

Go to Reporting FAQs

4
TRANSPARENCY

Recognizing Conflicts of Interest


Part of Salesforce’s aloha culture is a spirit of open communication and cooperation for the good of the
company. When employees are open about potential conflicts, it is easier to find a way to minimize the
problems.
What conflicts are and how to disclose them
A conflict of interest is a situation where an opportunity for personal gain is contrary to the company’s
best interests.

Avoid even the appearance of a potential conflict of interest. If you believe that you may have a
potential conflict of interest, discuss it with your manager right away. Your manager can help
you work out a way to manage the conflict. Remember, it is your responsibility to act
appropriately until the situation has been addressed.
Working with family members
It is natural to want the best for your family, but when family members interact in the workplace it is
easy for it to look like favoritism. Addressing these situations proactively can prevent problems.

If two family members both work for Salesforce, one family member cannot report to another.
If your family member owns or works for a company that does business with Salesforce, you
must disclose this fact. Absent pre-approval by the Law Department, you may not manage the
relationship with the other company.
A family member is a parent, sibling, spouse, child, in-law, grandparent, grandchild, step-
relative, domestic partner, or another person, if they are regularly residing in your household.
Outside work
You are expected to devote your full professional energies to your work at Salesforce. All side jobs or
personal business activities that are profit-related need to be disclosed to the Law Department.
Salesforce encourages everyone to participate in nonprofit activities, consistent with our commitment
to giving back to our communities.

 For any profit-related activities that would take time away from your job or create a
potential conflict with the company, you need approval from your manager and the
Chief Legal Officer or General Counsel, even if you are not personally being
compensated for the outside activity. Click here to access a request form. If you have
been asked to sit on the Board of Directors or an Advisory Board of a for-profit
organization (even if you are not being compensated for it), you need approval from
your manager and the Chief Legal Officer or General Counsel. Click here to access a
request form.

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 For any nonprofit activities that would conflict or could conflict with the company’s
business, you need approval from your manager. If you have been asked to sit on the
Board of Directors of a nonprofit organization, you also need to get approval from your
manager and the Chief Legal Officer or General Counsel. Click here to access a request
form.
Financial interests
Holding a significant or controlling interest in one of Salesforce’s competitors, customers, or suppliers
could create a divided loyalty, or at least the appearance of one. This also applies to financial interests
held by a member of your household or immediate family. Financial interests that pose a potential
conflict of interest require approval from your manager and the Chief Legal Officer or General Counsel.
In addition, the Board of Directors has adopted guidelines relating to potential conflicts of interest that
may arise in connection with investments by Company officers in privately held companies. Such
investments generally require pre-clearance by the Law Department. Click here to access the guidelines.
Corporate opportunities
Employees cannot take advantage personally of business or investment opportunities that are
discovered through the use of company property, business, or information. Such actions are considered
to be competing with Salesforce and must be avoided.

Gifts and Entertainment


Gifts are usually goods or services, but can be any item of value, including entertainment. Exchanging
gifts and entertainment can help build strong working relationships with customers and other business
partners. In some cases, however, gifts and entertainment may create a conflict of interest or unfair bias
that could influence business decisions or be seen as bribes. Review the rules in the Global Gifts and
Entertainment Guidance and related expense report rules to make sure you know the company’s
policies in this area. Ask your manager if you have any questions. Generally, if your gift does not involve
a government official, a gift showing Salesforce’s logo under $150 is permissible. If your gift or
entertainment involves a non-U.S. government official, check the Global Anti-Corruption Policy for
further guidance or consult with the Law Department. The company has zero tolerance for gifts and
entertainment involving U.S. government officials.
Anti-Corruption, Bribery, and Kickbacks
Never resort to bribery, facilitation payments, kickbacks, or corrupt practices.

Bribery is offering or giving something of value in order to improperly influence the recipient’s
actions. Bribery is illegal in every jurisdiction in which Salesforce does business.
A facilitation payment is a tip or small payment made to a government official in order to
expedite a routine government action, such as issuing a permit or providing utility service. This is
illegal in most jurisdictions and not allowed under the Global Anti-Corruption Policy.
A kickback is the return of a sum paid (or due to be paid) as a reward for fostering a business
arrangement. Accepting or offering a kickback violates this Code.

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Bribery is illegal in the U.S. and most other countries and the consequences are severe, including
jail sentences.
Relationships with government officials
If you interact with government officials on Salesforce’s behalf, be particularly careful about gifts, meals,
and entertainment. Laws and regulations governing what companies like Salesforce can give
government officials are very strict, including in the U.S. Be sure you know what the rules are under the
Global Anti-Corruption Policy. Contact the Law Department before offering or providing any gifts, meals,
or entertainment to government officials. All interactions with government officials that are not sales-
related require the oversight of our Government Affairs team.

A government official can be a national or local government employee, a political candidate, a


party official, a member of a royal family, or an employee of a government-controlled entity.
Third parties
The company may engage with third parties such as agents, consultants, suppliers, resellers, or
distributors, only after they have passed a legal due diligence process. Contact the Global Ethics &
Integrity team for further information about the due diligence process.

Financial Integrity, Records, and Accounting


Salesforce’s books, records, accounts, and financial statements must be maintained in appropriate detail
so that they properly reflect the company’s business activities. Doing so is required both by law and by
the company’s system of internal controls. Further, the company’s public financial reports must contain
full, fair, accurate, timely, and understandable disclosures, which helps ensure investors have access to
accurate information about the company and is required by law. The company’s financial, accounting,
and legal groups are responsible for procedures designed to assure proper internal and disclosure
controls, and everyone must cooperate with these procedures. For additional information on your
specific responsibilities in ensuring the integrity of the company’s books, records, accounts, and financial
statements, see the Anti-Fraud Policy.

All information must be recorded accurately, whether it is tracking work hours, expenses
(including your expense reports), or sales contracts. When these are timely and accurate, the
company is able to make informed decisions about how to run its business and plan for the
future. Company records, including disclosures and filings, must be accurate, complete, and
timely, so that Salesforce fulfills its obligations to external stakeholders, including its
stockholders.
Document management and retention
When deciding what documents to save, archive, or trash, always check the Records Management
Policy, Records Management Procedures Manual and Records Retention Schedule for details about how
long various documents should be retained. This policy applies to all kinds of documents, both paper
and electronic.

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At some point you may be notified that a “legal hold” has been placed on documents in your
possession. If this happens, please review the legal hold notice carefully. If you have any
questions about the notice and what you should do, please reach out to the Law Department so
that you are 100% clear regarding your obligations. The key thing to remember is never to alter,
conceal, or destroy any document under a legal hold.

Outside Audits and Investigations


From time to time, you may encounter internal and external auditors, attorneys, or investigators who
request information from you. You are required to provide these individuals with timely and accurate
information. Never mislead or attempt to influence any investigation, audit, or inquiry.

Salesforce sometimes receive requests for information from national or local government
officials. If they contact you, be sure to notify Legal for assistance in handling the request
promptly, accurately, and completely.

Understanding Insider Trading


Trading while in possession of material information that is not known to the public is strictly prohibited,
whether it is information about Salesforce or another company. Trading while in possession of inside
information is illegal.

Information is material if a reasonable investor would consider it important in deciding whether


to buy, hold, or sell a company’s securities.
Information that is material and is not available to the public is called inside information.
Common examples of inside information include key changes in management, mergers and
acquisitions, other major business plans, and financial results that have not been released
outside Salesforce. Trading while in possession of inside information is illegal.
You cannot give inside information to anyone else, either. This is known as tipping, and is also
illegal. Consequences for violations are severe, including jail time.
See the Insider Trading Policy for more information.

Handling Imports and Exports


When working with international customers, keep in mind that there may be additional steps required
before delivering products or services internationally.

You are responsible for knowing and following the appropriate rules and procedures for imports
and exports. If you are involved in international transactions, it is important to know what is
expected of the company, including any requirements related to taxes, verification, licensing,
and permits. For additional information on handling imports and exports, see the Trade with
Embargoed Countries Policy.

Go to Transparency Q&As

8
TRUST

Using Technology and Other Tools


Salesforce trusts its employees with a wide range of technology and other tools that make it possible to
do their jobs effectively, and these tools must be used wisely.
Using company technology appropriately
The computers, mobile phones, and other devices that Salesforce provides are company
property. The same is true of the company’s email system and Internet access. A certain amount
of personal use is permitted, but company technology should mainly be used only for business
purposes.
Since all of these tools and technology belong to the company, employees should not have any
expectation of privacy in their use. Salesforce may monitor anything created, stored, sent, or
received on company technology, to the extent allowed by law. Do not use company technology
to violate the law or Salesforce policies or to create, store, or send content that others might
find offensive.
It is also important to carefully avoid any usage that might lead to loss or damage, such as a
breach of the company’s IT security protocols.
Use of funds and physical assets
Company property also includes Salesforce’s brand and reputation, funds, facilities, and
employee work time.

Protecting Sensitive Information


Company information
Many details about how the company operates need to be kept confidential in order for Salesforce to
remain competitive and successful.

You are responsible for safeguarding all confidential and sensitive data such as:
 Business plans or strategies
 Financial results
 Product designs and concepts
 Sales goals and marketing plans
 Terms and conditions, rates, or fees offered to particular customers
 Other, non-public information that might be of use to competitors
For detailed information about how to protect information and what your specific
responsibilities are, see the Information Security Policies.

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Intellectual property
Salesforce depends on good ideas, so it is important to protect those ideas through legal tools such as
copyrights and patents. Collectively, all of this intangible property is called intellectual property (IP), and
it includes all copyrights, patents, trademarks, trade secrets, design rights, logos, and brands. Keep in
mind that Salesforce owns the rights to all IP created with company materials or on company time.

Third parties’ and previous employers’ information


In some cases, employees may be responsible for protecting information that belongs to other people or
companies. For more information on protecting third party information, see the company’s Trust
website.

Who, exactly?
 Third parties. In the course of doing business, sometimes employees will learn
confidential information about customers, suppliers, and other business partners.
Protecting the data of these third parties is one of Salesforce’s highest values.
 Former employers. When a new team member joins Salesforce, employees have to
respect that this person cannot share confidential information about previous employers.
Similarly, you would still be responsible for protecting Salesforce’s information if you left
the company.

Personal employee information


The personal information provided to the company must be protected.

If your job enables you to have access to personal information regarding other employees (data
like home addresses, medical information, and Social Security numbers), then you are
responsible for helping to protect it. That means using the information only for legitimate
business purposes, and not sharing it with anyone who does not have a work-related reason to
see it.

See Something, Say Something


You are the company’s first line of defense. If you see something suspicious, say something by reporting
safety and security concerns to the Global Operations (GO) Center at (415) 653-4600 or
gocenter@salesforce.com. Suspicious network activity, phone calls or emails should be reported to
security@salesforce.com. Reporting helps Salesforce keep our people and our brand safe as well as
defeat attacks faster to minimize or prevent damage.

Security
The security of the Company’s premises and property is the shared responsibility of all employees.
Proper access credentials are to be visibly displayed by employees, contractors and visitors at all times
while on Company premises. No one should be granted access in to Company premises without a
validated credential.

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Competing Fairly
All employees are expected to follow competition laws throughout the world, which ensure a level
playing field for all businesses.

These laws (also known as antitrust laws in the U.S.) prohibit agreements that would restrain
trade. For example, a few common—and illegal—examples include:
 Price fixing, where competitors or partners agree to charge a certain price for certain
products or services
 Bid rigging, where competitors agree among themselves to bid in a way that allows a
certain bidder to win
 Dividing or allocating markets, where competitors agree to limit their sales presence so
that each company can be the only available choice for buyers in a given market
 Boycotting, where competitors agree to avoid a particular customer or supplier
 Agreements among companies not to hire their respective employees

Keep in mind that agreements do not have to be signed contracts to be illegal. An informal
understanding between you and a competitor, or even a conversation that implies an
understanding, may be a problem. If any of these topics come up while you are talking with a
competitor, stop the conversation immediately and report it to the Law Department.

Fair Dealing
Salesforce is committed to being honest and truthful with all of its customers, vendors, and other
business partners. Never misrepresent the quality, features, or availability of the company’s products,
and never do anything illegal or unethical to win business. For additional information on the company’s
commitment to fair dealing and your specific responsibilities in preventing fraud, see the Anti-Fraud
Policy.

Trying to obtain information by lying or pretending to be someone you are not is unethical,
could be illegal, and is generally in poor taste. Don’t do it. And if you receive another company’s
confidential or proprietary information by mistake, return or destroy it. You may also reach out
to the Law Department for questions.

Go to Trust Q&As

11
RESPECT

Diversity and Non-Discrimination


Diversity of opinion, background, and culture makes Salesforce a more creative company. The Hawaiian
concept of lokahi, or working with unity, is a good description of how all of the different points of view
within the company can contribute to a strong and unified team.

It is important to have a diverse team and an inclusive workplace. Accordingly, employment


decisions like hiring, firing, and promoting are never based on legally protected personal
characteristics. While these characteristics may vary by local law, they generally include:
 race
 color
 religion
 gender
 national origin or ancestry
 age
 medical condition or disability
 veteran status
 marital status
 pregnancy
 sexual orientation
Instead, Salesforce offers equal opportunities based on skills and aptitude.

Personal Dignity
Solid teamwork requires all employees to treat each other with dignity and respect.

Harassment and bullying are not tolerated.


Harassment is any conduct relating to a person’s legally-protected characteristics that creates
an unwelcome, intimidating, hostile, or offensive work environment for that person. That can
range from offensive jokes or comments, slurs and name calling, and any act of bullying, or
exclusion. It also includes sexual harassment, including unwanted sexual advances, suggestive
comments or inappropriate touching. You can find the Harassment Policy here or on the
company’s policy tool, Policyforce.

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Workplace Health and Safety

Salesforce is committed to providing the safest work environment possible. Our programs
focus on general safety awareness and incident response. Follow all safety rules and report
unsafe situations. You can find more information on the Company’s Health & Safety
Management System here.
Violence and weapons
Violence and threats of violence are not acceptable at Salesforce. If you believe someone is in
immediate danger, contact the local authorities right away.
Substance abuse
The use of illegal drugs and inappropriate or excessive use of alcohol are not permitted in the
workplace.
For more information, refer to the Alcohol, Drugs & Illegal Substance Abuse policy in the
company’s Employee Handbook.

Go to Respect Q&As

13
COMMUNICATION

External Communications
Salesforce has an open and transparent culture, and the Communications Policy governs how the
company communicates to the public responsibly.
Investors and the media
All inquiries from the media must be directed to the Public Relations team. If you have any questions,
contact pr@salesforce.com.
Similarly, inquiries from investors or the investment community must always be directed to the Investor
Relations team at investor@salesforce.com
Social media
Remember, the Internet is a public place, so handle yourself accordingly.

 Protect Salesforce’s proprietary information.


 Do not comment on legal matters, trade secrets, or disclose confidential information.
 If you are discussing the company or Salesforce products, be open about the fact that you
work for the company.
 Be clear that your statements are your own opinion, not those of the company.
 Remember that postings on the Internet live forever.
 Check the Social Media Policy for more information.
Speaking events
If you are invited to speak or present at an event, notify the Public Relations team before accepting and
have them review and approve any materials you present or discuss. Before accepting free travel or
accommodations, check that the proposed gift is within the gift rules or ask the Law Department for
approval.

Political Activities
You are encouraged to be involved in the political activities of your choice. Be clear in such activities that
your participation is your own choice, not an endorsement from the company. Salesforce will not
reimburse you for your personal political contributions.

 Do not use company time or resources for your personal political activities.
 If you are involved in lobbying, make sure you know what the rules are.
 Contact the Law Department if you anticipate making a large political contribution, even as
an individual, to ensure compliance with disclosure laws relevant to the company.

Go to Communication Q&As

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WAIVERS

It is rare for anyone to be exempted from any part of this Code, regardless of seniority or position.
Waivers may only be granted in a manner permitted by law, with review and approval by the Chief Legal
Officer or General Counsel, and, if required under applicable regulations, review and approval by the
Board of Directors or a committee of the Board, with public disclosure of any waiver to the extent
required by applicable regulations.

MAHALO!

Thank you for reading and following this Code.

The key values in this Code can be summed up in the word aloha.
A - ala, watchful, alertness
L - lokahi, working with unity
O - oia'i'o, truthful honesty
H - ha'aha'a, humility
A - ahonui, patient perseverance

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PART 2: Q&A

ALOHA

Reporting
Q: What should I do if the Code does not answer my question?
A: Check another resource, like the policies referenced in the Code or in Policyforce, the
company’s policy tool, or ask! If your manager doesn’t have the answer, he or she can help you
find someone who does. Chatter groups can be a resource, too. You can also reach out to
legalcompliance@salesforce.com.
Q: What should I do if I think there has been a Code violation, but I cannot prove it?
A: Go ahead and report your suspicions, as long as you are raising the concern in good faith.
Q: If I report something, will the complaint be handled confidentially?
A: Yes, but only to a point. Investigations into complaints are as confidential as possible while still
being thorough and complete.
Q: When should I use Ethicspoint?
A: You can use Ethicspoint for any report related to a potential violation of this Code. You can also
raise any issue to your manager, Employee Success, or the Law Department.
Q: What if my manager is involved in the issue I want to report?
A: You can ask for help from another manager you trust. Plus, other options like Employee Success
and Legal are available to you, or you can use Ethicspoint.
Q: What if I report and someone retaliates against me? Could I lose my job?
A: Retaliation is not tolerated at Salesforce. If it does happen, or if you suspect it has, you should
report it.

TRANSPARENCY

Recognizing Conflicts of Interest


Q: Can I help a friend with a start up in the technology field, as long as it doesn’t interfere with my
working hours at Salesforce?
A: Since this is a profit-related activity outside of Salesforce, you will need to obtain approval from
your manager and the Chief Legal Officer or General Counsel (or a designee of either). Click here
to access a request form. You need to do this even if you won’t be compensated for your work.

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Q: I have been asked to be on the board of a nonprofit that I have volunteered with for years. Is it
okay to participate on nonprofit boards?
A: Yes, this is generally acceptable, though you still need to disclose the situation and obtain
approval from the Chief Legal Officer or General Counsel and your manager. Click here to access
a request form.
Q: My dad owns his own business, a small company that uses Sales Cloud to drive business. I am a
part-owner of my dad’s company. I am also a strategic account manager for Salesforce. One of
the accounts assigned to me is my dad’s company. What should I do?
A: You need to disclose this to your manager so that someone else can handle this company’s
account. Additionally, you must seek approval for your ownership interest in your dad’s
company from your manager and either the Chief Legal Officer or General Counsel (or a
designee of either). Click here to access a request form.

Gifts and Entertainment


Q: I have a business contact who has helped me out a lot this year. Can I send her a gift card or
certificate as a thank-you over the holidays?
A: No. It is too easy for cash (or cash-equivalents like gift cards) to look like a bribe. You can talk to
your manager or the Law Department about some more appropriate ways to thank her.
Branded Salesforce items are preferred, as they are less likely to be viewed as an improper
bribe.
Q: During a meeting, a client offered to give me a new tablet computer. Can I keep it?
A: Any time you receive a gift from a client or business contact, ask yourself the purpose and the
value of the gift. If the gift is designed to influence you personally in your business capacity,
assess whether accepting the gift poses a potential conflict of interest. Small customary gifts to
celebrate traditional holidays are generally okay. If a gift is valued at more than $150, such as an
expensive gift like a tablet computer, you should seek approval from the Law Department. You
should also report any attempt to bribe a Salesforce employee to the Law Department. Review
our Global Gifts and Entertainment Guidance for further information.

Anti-Corruption, Bribery, and Kickbacks FAQs


Q: Is it acceptable to entertain government officials or provide them gifts?
A: It is generally not permissible to give gifts or entertainment to government officials, unless such
gifts are culturally customary, and are allowed under local law. Gifts to government officials are
permitted only if they are modest and will not create the appearance of impropriety. Remember
that, when possible, gifts bearing the company’s logo are preferred. You need to obtain
approval from the Global Ethics & Integrity team before giving any gift to a government official.
Remember, do not engage in any non-sales activity with a government official without direction
from Government Affairs.

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Q: What do you do if someone offers you a bribe? What do you do if someone requests a bribe?
A: Salesforce does not accept or provide bribes ever. In both cases you’d have to politely refuse.
You should also report the attempt immediately to the Law Department.

Financial Integrity, Records, and Accounting


Q: I am traveling overseas and would like to stay a few extra days. Can I use my corporate credit
card to secure a few more days at the hotel and just pay back the difference?
A: No, you cannot use your corporate card for personal reasons.
Q: I found a calculation error in records my team provided to the independent auditors of the
company’s financial statements. What should I do?
A: You should promptly alert your manager, and the accounting personnel who are responsible for
making sure the auditors get the information they need regarding the error, and provide the
corrected records to the auditors.

Understanding Insider Trading


Q: In a meeting, one of my clients mentioned that his company might not renew their contract
because of a possible acquisition by a larger, more successful competitor. Can I use this
information in making investment decisions?
A: No. Until the acquisition is announced publicly, you must refrain from trading in that company’s
securities. Please consult with the Law Department for any questions.

Handling Exports
Q: Since our business is in the cloud and we don’t sell a physical product, we don’t really have to
worry about export rules, do we?
A: Actually, we do. Information and services are examples of exports. If you work with customers
or colleagues in other countries, be sure to find out how export law affects your work and make
sure you know what to do. Familiarize yourself with our externally facing export law compliance
page on our website, know our Trade with Embargoed Countries Policy, and consult Legal with
further questions.

TRUST
Q: Is it acceptable to use my Salesforce computer to work on a freelance project?
A: No. Material created on Salesforce equipment belongs to Salesforce—and so does your work
time at the company. Freelance projects (if approved by your manager and Legal) need to be
limited to your own time and your own equipment unless otherwise approved by the General
Counsel or Chief Legal Officer.

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Protecting Confidential Information
Q: When is it permissible to disclose sensitive (confidential) information externally?
A: In order to disclose sensitive information with someone outside Salesforce, you have to make
sure that the recipient has signed a Non-Disclosure Agreement and has been approved for the
kind of information you want to share. Check with your manager or the Law Department if you
are not sure.

Fair Dealing
Q: What if a customer asks me a question I don’t know the answer to? Is it not better to say
something other than “I’ll get back to you on that”?
A: Not if that is the only answer you have at the time. Our customers trust us to be knowledgeable,
but no one has all of the answers at their fingertips. If you do not know something, don’t lie. In
fact, don’t make any statements you cannot back up with facts. Part of dealing fairly with our
customers and others is admitting when we don’t know, and having the diligence to follow up as
soon as possible.

RESPECT

Personal Dignity
Q: A co-worker keeps asking me out, even though I have rejected him. What can I do?
A: You should report the behavior to your manager, Employee Success, or Ethicspoint. The co-
worker’s refusal to take a rejection at face value is not respectful, and needs to stop. Any report
of harassment will be handled seriously and as confidentially as reasonably possible.

COMMUNICATION

External Inquiries
Q: I saw an online posting that says bad things about the company. The author even claims to work
at Salesforce, and based on the username, I think I know who it is. What do I do?
A: You should report your concerns to your manager. Always maintain a respectful and
professional demeanor online, just as you would in person. You need to also let the Public
Relations and the Law Department know about the post, so they can take appropriate action.
Q: I have been asked to speak at a conference. Who would need to give approval?
A: Presenting at a work-related conference is fine, as long as you provide publicly available
information and obtain certain reviews and approvals in advance. Before accepting, you are
required to discuss with your manager and notify the Public Relations department. Public
Relations must review and approve any materials you plan to present. Additionally, only

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members of the Investor Relations team and certain other senior members of management are
authorized to present information regarding the company’s financial results or present to the
investment community.

Political and Charitable Activities


Q: I want to get involved in a local congressional campaign. Is it okay to use a company email list or
Chatter to let everyone know about the candidate’s views on the issues?
A: No. Using company resources (time, email, and network access) to send information about a
political candidate does more than educate others—it sends a message that Salesforce publicly
supports certain political views. It is fine to have private conversations about politics or other
topics with others, but work is not the place for this kind of activism.

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