Questions & Answers
1. Question
Does Gateway really expect me to follow this Code, even if it means losing business or lowering profits?
Answer
Yes. Gateway firmly believes that long-term business success can only be achieved by adhering to our values and the principles outlined in this Code.
2. Question
If my business unit or organization has a policy that is more restrictive than Gateway Code of Ethics, which do I follow?
Answer
You should follow your business unit or organization policy when it is more restrictive than the Code of Ethics.
3. Question
If I encounter a situation not covered by this Code, does that mean that Gateway doesn't care what I do?
Answer
No. No code can cover every situation or ethical dilemma. That's one of the reasons why this Code begins by setting forth Gateway's values and concludes with a section entitled "Making the Right Choices." We believe that applying the values and asking yourself the kinds of questions listed in the Making the Right Choices section will help you work through most, if not all, ethical problems. However, if you still are unsure about what to do or merely want to discuss the matter further before reaching a final decision, you can always contact your manager, the Ethics Help Line or the Gateway Law Department.
4. Question
Will I get in trouble for reporting, in good faith, a violation or suspected violation of the Code?
Answer
No. Senior management knows that the effectiveness of our ethics program depends on all employees believing that they can report violations or suspected violations of the Code without fear of retaliation.
5. Question
What if my manager directs me to engage in conduct that would benefit Gateway, but would violate the Code?
Answer
None of us should ever commit dishonest, destructive or illegal acts, even if directed to do so by a manager or a co-worker. In addition, don't ever violate the Code, even if it would be advantageous to Gateway. You should contact Human Resources or the Ethics Help Line.
6. Question
How do I report suspected or actual violations of the law or this Code?
Answer
Contact your manager, Human Resources, the Ethics Help Line or the Gateway Law Department.
7. Question
Can I report suspected or actual violations of the law or the Code anonymously?
Answer
Yes. You can make an anonymous report by calling the Ethics Help Line toll-free phone at 877-GW-ETHICS.
8. Question
How do I know if I'm at risk of making an ethical mistake?
Answer
You're probably at risk if you are concerned about any one of the following: If you're concerned about whether your actions will be discovered, or if you feel uncomfortable about what you're doing, or if you catch yourself rationalizing your decision, or if you would be uneasy if your family or friends heard about what you're doing or read about what you did in the newspaper, you're probably at risk. If you need advice, consult your manager, Human Resources or the Ethics Help Line.
9. Question
My spouse and I own a small photocopy business, which is unrelated to my job at Gateway. I'm sure we can do photocopy work for Gateway less expensively than Gateway currently gets the service. Can I be both an employee and a vendor to Gateway?
Answer
No. Your responsibilities to Gateway are as an employee, and providing services as a vendor would be a conflict of interest. Your spouse, however could be a vendor to Gateway provided that: (1) he/she does not use your employment to influence the bidding process or the acquisition of business; (2) you do not participate in your spouse's business; (3) you do not participate, either directly or indirectly, in the evaluation or performance of the work if your spouse gets the job; and (4) you report the relationship to your manager.
10. Question
Are there any restrictions to my accepting a second job?
Answer
You are free to use your own time as you see fit, including securing a second job, provided it does not conflict with your responsibilities to Gateway. You can't accept a second job that would discredit or adversely affect Gateway or create, or appear to create, an appearance of impropriety or a conflict of interest.
11. Question
I travel a good bit for Gateway business. Can I keep non-cash benefits I receive from my business travel, such as frequent flyer credits?
Answer
Yes. You are permitted to keep frequent flyer credits and use them for personal travel. However, you can't influence or change travel plans made by Gateway's authorized travel agent merely to receive these or other non-cash benefits. Doing so would constitute a conflict of interest and a violation of this Code.
12. Question
I've been working on Gateway's strategic plan to acquire another company that will materially affect Gateway's business. Can I trade in either Gateway's stock or the stock in the company Gateway intends to acquire?
Answer
No. You are prohibited from trading in securities based on material inside information. To do so would violate this Code, as well as federal and state law. You must wait until the information becomes public for two trading days before trading in the securities of either company.
13. Question
Do I have to protect Gateway confidential information even after I leave Gateway's employ (trade secrets, intellectual property, etc.)?
Answer
Yes. You're not permitted to personally use or disclose to third parties Gateway confidential information, even after you have left Gateway.
14. Question
Can I use a Gateway phone to make a personal call?
Answer
It's generally acceptable for employees to make local personal calls, provided the calls are infrequent, brief and don't interfere with Gateway business activities.
15. Question
Does Gateway monitor employee use of company resources, such as phones, computers, email and Internet connections?
Answer
Gateway has the ability and the right to monitor each person's use of company resources.
16. Question
Are we permitted to take obsolete equipment home, especially if it would probably be scrapped anyway?
Answer
No. Taking Gateway equipment, even if it appears to be scrap or obsolete, is not permitted without written permission by a Gateway vice president or above.
17. Question
I know one of my co-workers just purchased a new software program and that my workgroup doesn't have the budget to purchase the software. Am I permitted to copy the software onto another company computer?
Answer
Generally, no. Software should not be copied to machines other than the one to which it was licensed, unless the software licensing or purchase agreement allows for multiple copies. Absent such permission, it would be a violation of law and Gateway policy to make unauthorized copies of software or other copyrighted materials. In addition, remember that software acquisition and loading at Gateway is managed by the IT department. Accordingly, you must contact your IT representative before undertaking such activities.
18. Question
I would like to take the buyer of a major customer to dinner to discuss the capabilities of a new Gateway product. Can I do it?
Answer
Yes. Provided the cost of the dinner is modest, your manager approves the dinner, and the buyer is permitted under his/her company's policies to accept the business courtesy.
19. Question
One of the marketing representatives from another company advised me that, if I wanted to be sure that Gateway was the successful bidder on a large contract, I would be wise to give a "nice" gift to a certain employee of the customer. Is this okay to do?
Answer
No. This type of gift could constitute a bribe and would violate Gateway's values and this Code. It also might be unlawful under both U.S. and international law. If such a situation arises, you should report it immediately to your manager, the Ethics Help Line or consult the Law Department for guidance.
20. Question
I'm responsible for securing temporary help through outside employment agencies. One of the agencies sent me a $35 bottle of wine for the holidays. Can I keep it?
Answer
You can keep the wine if it meets each of the following criteria for accepting a business courtesy: (1) the gift is unsolicited; (2) it's inexpensive—generally under $75; and (3) it won't affect, or be perceived as affecting, your business judgment. If you are unsure about what to do, discuss the situation with your manager.
21. Question
I have a customer who invited me to attend a three-day conference sponsored by his company at a resort in Colorado. The agenda includes both business and leisure activities. Can I accept the invitation, even though it will be paid for by the customer? Would the answer be different if the customer were a supplier?
Answer
In both cases the answer could be "yes", provided there is a reasonable expectation that Gateway will benefit from your attendance and your attendance is approved by a director or above in your supervisory chain. Very often participation at such conferences can help build relationships and generate business. However, if this was not the case, and the trip really is recreational, then attendance would not be appropriate.
Also, if a supplier sells to Gateway in connection with a federal government contract, the trip could be regarded as an illegal "kickback," designed to influence vendor selection other than on the merits. This could have criminal, civil, and contractual consequences both for Gateway and for you.
22. Question
Am I permitted to give one of my customers or suppliers tickets to a sporting or cultural event?
Answer
Giving these sorts of business courtesies is okay provided it meets the tests outlined in the "Gifts and Entertainment" section of this Code and would not violate the customer's or supplier's policies. Remember that such gifts are never appropriate when the customer is a governmental agency.
23. Question
We are having a 7:30 a.m. meeting at a Gateway site with representatives from the U.S. Federal Trade Commission. We would like to provide refreshments to the attendees. Is it okay?
Answer
Yes. Gateway policy and U.S. Government regulations permit this type of business courtesy. However, before offering these types of refreshments, you should check with the Government representatives to see if the arrangement is acceptable or whether they would prefer to contribute to the cost of the coffee and donuts. Remember, U.S. Government regulations regarding business courtesies are very strict and must be followed at all times.
24. Question
A government procurement officer mistakenly sent me some confidential information about another company, which may be a competitor on a project on which Gateway is bidding. Can I read the information if it would help Gateway in preparing its bid?
Answer
No. You can't review or use the information. To do so would violate Gateway's values and the Code of Ethics and may even violate current law. You should notify your manager and immediately give the information, unopened, to the Gateway Law Department.
25. Question
We have been losing orders recently because our customers complain that our delivery times are too long. May I quote shorter delivery times so we can increase our sales?
Answer
Only if you are confident that you can deliver on your promise. If you promise a customer a shorter delivery time, when, in fact, you know you can't follow through on the promise, it would violate both our values at Gateway and this Code. Misrepresenting to customers is not the way to secure repeat business. To the contrary, it tarnishes Gateway's name and reputation and probably guarantees a loss of business.
26. Question
You are planning to attend an international trade show and have shipped several product displays to the country where the show is to be held. However, when you arrive in that country, you discover that the displays won't be released by local customs officials without payment of $100. Can you make the payment?
Answer
Perhaps. Facilitating payments are permissible under the Foreign Corrupt Practices Act. However, because the law in this area is complex, with serious penalties for violations, you should, where practicable, contact your manager and the Gateway Law Department before making any such payments. In all such cases where you are not able to make such a contact, do so as soon as possible thereafter.
27. Question
I came up with a great idea to improve our manufacturing methods while on vacation. Does Gateway have rights to my idea?
Answer
Yes. All inventions and ideas related to Gateway's business created during your employment are considered Gateway property.
28. Question
One of my friends has moved to another region and has an unlisted telephone number. Would it violate Gateway Policy for me to look up her number in Gateway's customer database?
Answer
Yes. Gateway Policy is very clear on this point. You may not access customer records unless you have a legitimate business reason for doing so. And, accessing a record for personal reasons — even if it's a record of a friend — is strictly prohibited.
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