We Comply With the UPS Code of Business Conduct. We manage our business in
compliance with all applicable laws and regulations of the countries in
which we operate, and in accordance with our company's high standards
of business conduct. All employees are expected to comply with the UPS Code of Business Conduct, which is essential to
maintaining our reputation for honesty, quality, and integrity. It is
also each employee's responsibility to report to the company any
situation where our standards or the laws are being violated. Any
employee disclosing, in good faith, violations or suspected violations
of legal requirements or UPS business standards will not be subjected
to retaliation or retribution. Likewise, failure to comply with the
provisions of the UPS Code of
Business Conduct will not be tolerated.
This UPS Code of Business Conduct
sets forth standards of conduct for all of UPS. Throughout
it, "UPS" is used to refer to the enterprise as a whole,
to each person within it, and to any person who represents UPS or any
part of the UPS organization.
Adherence to the Code
is required of all employees and representatives of UPS. The Code is available in multiple
languages on the Corporate Compliance Web site.
The Code provides information about our standards of integrity
and explains our legal and ethical responsibilities. It does not
address every specific situation or set forth a rule that will answer
every question. Rather, it is intended to provide guidance on our
responsibilities and to assist us in making the right decisions.
Additional requirements are set forth in detail in various individual
compliance programs developed by functions with appropriate expertise
and training. It is our responsibility to understand which compliance
programs apply to our area of responsibility and to manage the business
The UPS Code of Business Conduct,
Policy Book, and UPS
Charter are complementary documents that work together to guide our
objectives and explain our responsibilities to our four constituencies:
people, customers, shareowners, and communities. To ensure a complete
understanding, discussion of the Code,
Policy Book, and UPS
Charter at business meetings and other suitable occasions in
Any employee of UPS, regardless of his or her position within the
company, who violates our legal or ethical responsibilities, will be
subject to appropriate discipline, which may include dismissal.
Non-compliance with certain aspects of the Code and/or the Business Conduct and Compliance
Program also may subject the individual offender and UPS to civil and/or
Message: On Leading with Integrity
Integrity has always been central to the way UPS does business.
As Jim Casey said in 1957, "We have become known to all who
deal with us as people of integrity, and that priceless asset is more
valuable than anything else we possess."
Of course, maintaining that priceless asset can never be taken for
granted, as it is vital to our continued growth and success. As we
continue to expand our operations around the globe, we must be even
more vigilant in ensuring that our reputation is maintained in every
country, community, and location where we do business.
As UPS employees and representatives, we have an obligation to make
sure our daily decisions support the values and principles of the
But what does that mean exactly?
Certainly, it means managing the business to comply with the law and
our ethical values. But our standard goes beyond the letter of the law. It also means we
will conform to the spirit of what those regulations intend.
Simply put, it means our standard is to conduct business fairly, honestly,
Today, as we continue to integrate deeper into our customers' supply
chains, the level of trust between UPS and our customers extends deeper
In some ways, it takes us back to the company's roots. In those early
days, Jim Casey asked retailers to trust that he would hold in
confidence their individual customer lists. And he honored their trust.
More than ever in today's age of digital information sharing, we must
protect customer interests as carefully as Jim did. We must treat each
customer as if they were our only customer.
That means resisting any temptation to cut corners. Our success is owed
to our people, who through the years, paid careful attention to
integrity and demonstrated values that sustained customer relationships.
Integrity also speaks to the way in which we treat our people, by
creating and environment to trust and understanding.
Employees who get results at the cost of legal
violations, or through dishonest dealings, do more than violate our
standards. They undercut our ability to grow our business by
undermining our reputation.
Compliance with our legal and ethical obligations is the responsibility
of every employee and representative of UPS, as is the responsibility
to report potential violations of those obligations. Reporting can be
done directly through your supervisor or manager, through any other
member of the management team by using the Open Door Policy, or by
calling the UPS Help Line. It is important to come forward - if you are
not comfortable with one method, another can be used.
In upholding our legal and ethical responsibilities, by conducting our
business in compliance with the letter and spirit of those
requirements, by using good judgment, and by respecting each other, UPS's legacy of leading with integrity will endure.
Leading with integrity is about creating a climate for success. It's
about creating an environment where good people can make good
The UPS reputation belongs has been earned over several generations. It
is ours to benefit from and to uphold.
Chairman and Chief Executive Officer
Values and Management Philosophies
For decades, UPS people have been motivated by commonly held principles
and values that have allowed us to work toward mutual goals. These
principles and values, originally established by our founders, remain
as constant and as critical to our success as ever. The core of these
values, which still inspires UPS employees today, is that UPS is a
company of honesty, quality, and integrity. This legacy is fundamental
to our ability to attract and retain the best people, gain and keep the
trust of our customers, create shareowner value, support the
communities in which we operate, and protect our reputation.
It has always been, and continues to be, our policy to conduct business
in compliance with all applicable laws and regulations and in
accordance with the highest ethical standards. We expect - as we always
have - that UPS employees, and the people acting on our behalf, will
adhere to these principles.
Questions and Voicing Concerns
This Code provides an
overview of the legal and ethical responsibilities that we share. Each
of us must uphold these responsibilities. The standards and
expectations outlined here are intended as a guide for making the right
choices. If any aspect of the Code is unclear to us, or if we
have any questions or face dilemmas that are not addressed, this should
be brought to the company's attention. If we become aware of a
situation in which we believe our legal or ethical responsibilities are
being violated or if we feel that we are being pressured to violate the
law or our ethical responsibilities, it is our personal responsibility
to communicate this concern to the company.
No employee will be disciplined, lose a job, or be retaliated
against in any way for asking questions or voicing concerns about
our legal or ethical obligations, when acting in good faith. "Good
faith" does not mean an individual has to be right; but,
it does mean believing information provided is truthful.
It is important that we communicate a question or concern through one
of the many available channels.
We can speak with our direct manager or supervisor, or use the
Open Door Policy to talk to someone else in management, including your
Human Resources manager, or someone from the function with the
expertise and responsibility to address the concern. Any of these
people may have the information needed, or will be able to refer
the question to another appropriate source.
Another communication channel to assist us is the UPS Help Line.
We can contact the UPS Help Line when we have a
concern or want to report a potential violation of our legal
or ethical responsibilities. We may use whatever method of
communication with which we feel most comfortable. The important thing
is to get the needed guidance, to report what is known, and
to get questions answered.
The UPS Help Line, which is answered by an outside vendor, is available
to all employees, 24 hours a day, 7 days a week. Interpreters are
available for language assistance. The UPS Help Line can be reached
toll-free at 1-800-220-4126. Individual country codes can be found on
the Corporate Compliance Web site and should be used for UPS Help Line
calls made outside of North America.
Although callers are encouraged to identify themselves to assist
the company in effectively addressing their concerns, callers may
choose to remain anonymous, and that choice will be respected. The
UPS Help Line is not equipped with caller ID, recorders, or other
devices that can identify or trace the caller's number.
When the UPS Help Line is called, the person can expect that:
A report will be forwarded to appropriate UPS
management for follow-up.
The concern will be addressed by members of
management that may include representatives from Corporate Compliance,
Human Resources, Corporate Legal, Security, or Internal Audit. If
the inquiry is one that can be properly handled by someone in the
region or district, it will be referred there for resolution. Each
concern will be carefully evaluated before it is referred for investigation
The concern will be handled promptly,
discreetly, and professionally. Discussions and inquiries will be kept
in confidence to the extent appropriate or permitted by law.
Certain follow-up information about how the
concern was addressed may be obtained upon request.
Investigations into allegations of unethical or illegal
conduct must be conducted confidentially and professionally. The UPS
Guidelines for Investigation of Workplace Issues is available from
Corporate Compliance for management who may conduct such an
Additional information can be found in the section titled
"Retaliation" and on the Corporate Compliance Web site.
Our commitment to integrity includes a responsibility to foster an
environment that allows people to report violations without the fear of
retaliation or retribution. No one should be discouraged from using any
available channel within the organization. Even simple questioning of
someone can lead to claims of retaliation, even though that was never
the intent, as it may make a person feel that he or she did something
wrong by choosing one method over another. People must be able to
choose whichever method they are most comfortable with to communicate
Anyone who retaliates against another employee for reporting known
or suspected violations of our legal or ethical obligations is in
violation of the Code and subject to disciplinary action, up to
and including dismissal. Retaliation also may be a violation of
the law, and as such, could subject both the individual offender and
UPS to legal liability.
Additionally, the same rules apply with regard to retaliation or
retribution against employees related to company-sponsored
solicitations, such as for charities or political action committees.
Equal Opportunity and Fair
We treat each individual fairly, and recruit, select, train,
promote, and compensate based on merit, experience, and other
work-related criteria. We comply with all laws governing fair
employment and labor practices. We do not discriminate against any
applicant for employment or any employee in any aspect of their
employment at UPS because of age, race, religion, sex, disability,
sexual orientation, military status, pregnancy, national origin, or
Freedom from wrongful discrimination includes freedom from any form of
discriminatory harassment. Prohibited harassment includes conduct that
is intended to interfere or that has the effect of unreasonably
interfering with a fellow employee's work performance or creating an
environment that is intimidating, hostile, or offensive to the individual.
Additional information can be found in the UPS Professional Conduct and Anti-Harassment Policy
available from Human Resources.
Workplace Health & Safety
The health and safety of our people are of utmost importance to
UPS, which is committed to protecting the health and well-being of each
UPS employee. We strive to protect our people, customers, and the
public from injury and illness through our Health & Safety
programs. Government regulatory standards and employee input are used
to develop comprehensive programs and work processes that are
designed to promote safe workplaces and good health. We are all
responsible for understanding and complying with UPS Health &
Safety processes, procedures, and guidelines, as well as those issued
by applicable regulatory authorities.
Employees are required to advise the company of any vehicle accident,
workplace injury, instance of non-compliance, or any situation
presenting a danger of injury. This information will assist in
preventing injuries, and will ensure that appropriate medical
attention is provided. Through investigation of such reports, we can
identify contributing factors and determine if our policies and
processes are effective and adequately communicated. When an
unsafe condition, practice, or non-compliant action is identified,
prompt and appropriate action must be taken to correct the condition
and prevent it from happening again.
Additional information about Health & Safety issues is available
from district, region, or Corporate Health & Safety.
Drug and Alcohol Policy
It is our policy to maintain a drug-free and alcohol-free work
environment. Use of alcohol and/or creates serious health
and safety risks in the workplace. The use, sale, or
possession of alcohol, illegal drugs, or other illegal substances is
strictly prohibited while at work, on company property, or while on
company business. This prohibition also includes illegal or
improper use of controlled substances.
Reporting to work under the influence of any such substance
is strictly prohibited. No one is permitted to go on duty or
remain on duty if they possess or have the presence of an illegal or
unauthorized controlled substance or alcohol in their system.
Employees are not permitted to go on duty or remain on duty if they are
impaired by the presence of an authorized controlled substance.
In addition, we must comply with all laws and regulations regarding the
use or possession of alcohol, illegal drugs, and controlled substances.
Crisis Management and
Workplace Violence Prevention
UPS is committed to a safe working environment, free of threats,
intimidation and physical harm. Everyone has a right to work in a
safe environment and shares the responsibility for assuring each
other's safety. UPS has adopted a zero tolerance workplace
violence policy. This means we will investigate and take appropriate
action against any threat to a safe workplace.
UPS prohibits violence behavior including, but not limited to, physical
assaults, fighting, threatening comments, intimidation, and the
intentional or reckless destruction of company, employee, or
customer property. Any comments or behavior that reasonably could
be interpreted as an intent to do harm to
people or property will be considered a threat. We also prohibit
the unauthorized possession and/or use of weapons by any employee while
at work, on company property, or while on company business.
Any employee who believes that he or she may be the target of violence
or threats of violence, or is aware of violent or threatening conduct
by, or directed at, a UPS employee that could result in injury to
a person or the destruction of property, has a responsibility to
immediately report the situation to his or her immediate supervisor or
manager. If an employee is unable to or prefers not to contact an
immediate supervisor or manager, the employee can call the UPS Help
Line (see "Asking Questions and Voicing Concerns").
Additional information is available from your local Security
Conflicts of Interest
We are all expected to give our undivided business loyalty to UPS
when conducting our job-related duties. Accordingly, we must be careful
to avoid conflicts of interest - situations where our private interests
conflict, or even appear to conflict, with the interests of UPS as a
whole. Therefore, we should not place ourselves in situations that
might force us inappropriately to choose between our own personal or
financial interests and the interests of UPS.
Conflicts of interest can arise in many common areas, despite our best
efforts to avoid them. However, such conflicts can generally be
resolved by promptly notifying your manager of any actual, perceived,
or potential conflict of interest situation. The manager can then
provide guidance on how best to resolve the conflict. If needed, an
employee also may contact Corporate Compliance for guidance.
Conflicts of interests also must be disclosed on the annual Business Ethics Questionnaire.
Additional information about conflicts of interest, including
information about investments in other companies, is available in the
sections of this Code
titled "Investments" and "Political Activities and
Contributions" and on the Corporate Compliance Web site.
Gifts and Entertainment
All employees and representatives of UPS should understand the
legal and ethical issues associated with gifts and entertainment and
how they can affect our relationship and reputation with our customers,
suppliers, and the general public. The decision to offer or to accept
gifts or entertainment should be made only in compliance with legal
requirements and ethical considerations, and with the involvement of a
manager if unsure of the appropriate course.
The issue of gifts and gratuities may have legal implications when
the government, or government entity is involved, and serious
consequences can result from mishandling these relationships. Offering
or accepting bribes and pay-offs is always prohibited.
Business gifts and entertainment are courtesies designed to build
goodwill and sound working relationships among business partners. We do
not, however, want to obtain business through improper means as
to gain any special advantage in a relationship. Business gifts
that compromise, or even appear to compromise, our ability to make objective
and fair business decisions are inappropriate.
Solicitation of gifts is never appropriate, even for charitable
purposes or UPS events. All gifts and entertainment, other than
infrequent items of nominal value, must be disclosed to a manager.
The difference between appropriate and inappropriate gifts is not
always easy to determine. The UPS
Guidelines for Gifts and Gratuities should be reviewed to
determine whether a gift is appropriate. Any doubt should be resolved
in favor of not giving or receiving the gift.
Additional information is available in the UPS Guidelines for Gifts and Gratuities and
in the UPS Anti-Corruption
Compliance Program materials available on the Corporate
Compliance Web site.
Doing Business with the
A conflict of interest could arise if an employee, a spouse, a
relative, or a close personal friend, has a personal stake in a
business that supplies or seeks to supply goods or services to UPS, is
a UPS customer or potential customer, or competes with UPS. Accordingly, the
following standards apply in such situations:
If a UPS employee, spouse, relative,
or close personal friend is an employee of, or has a significant
interest in a business that provides or is seeking to provide goods or
services to UPS, the UPS employee must not attempt to use his or
her position with UPS to influence the bidding process or
negotiation in any way. Similarly, the UPS employee must not use
personal relationships to improperly influence dealings with a customer
or a potential customer.
If the position of a relative
or friend who works for a competitor is such that a potential
conflict of interest could arise, the UPS employee should seek guidance
from a manager.
Ownership of the UPS Store
a general rule, a UPS employee, or a member of his or her
immediate family, may own a Mail Boxes Etc. or The UPS Store franchise.
It is, however, necessary to evaluate the possibility of any conflicts
of interest. Ownership of a Mail Boxes Etc. or the UPS Store franchise
by a UPS employee, or a member of his or her immediate family, does not
necessarily create a conflict of interest. In each case, however, the
UPS employee must ensure that undivided business loyalty to UPS is
maintained. This requires obtaining all necessary approvals as described
in the Guidelines for UPS
Employee Ownership of The UPS Store.
Refer to the Guidelines for UPS
Employee Ownership of The UPS Store on the Corporate
Compliance Web site for additional information.
Employment Outside of UPS
Although employment outside of UPS is not necessarily a conflict of
interest, depending upon an individual's position with UPS and UPS's relationship with the other organization, a
conflict could arise. Outside employment also could be a conflict
of interest if it causes, or might be perceived by others to cause, an
employee to choose between that interest and the interests of UPS. If a
situation arises, either through scheduling or other potential
conflicts, our undivided business loyalty requires that we resolve the
conflict in favor of UPS.
We should not, without approval of the Corporate Secretary,
serve as directors or officers of, or consultants to, any organization
that supplies goods or services to UPS, buys goods or services from
UPS, or competes with UPS. If a position outside the Company could
present a conflict of interest, discuss the situation with a manager.
Service as a director or officer of a non-profit organization does not
require approval of the Corporate Secretary.
Any UPS employee, management or nonmanagement,
who has received approval to serve as a director or officer of , or consultant to, any for-profit organization
that supplies goods or services to UPS, buys goods or services from
UPS, or competes with UPS must complete the Business Ethics
Questionnaire (BEQ) annually. The employee's manager is responsible for
ensuring that the employee receives, completes, and returns the BEQ
In some cases, UPS employees may be involved in outside businesses that
are not UPS competitors or suppliers. These situations do not
necessarily constitute a conflict of interest, but it is the employee's
responsibility to ensure that these activities do not conflict with UPS's interests.
This requires keeping the two activities strictly separated by adhering
to the following standards. A UPS employee:
May not do work relating to other organizations
on UPS time.
May not use UPS equipment and supplies, or the
time of any UPS personnel for outside work.
May not promote products or services from an
outside business to other UPS employees during working hours or on UPS
May not attempt to sell products or services
form an outside business to UPS.
May not use his or her position in the company
to promote an outside business.
We compete fairly and in accordance with the highest standards in
all of our customer relationships. We want to earn business on the
basis of superior services and products and competitive prices, not
through improper, unethical, or questionable business practices.
Our credibility with our customers depends on our ability to fulfill
our commitments. Any time we fail to live up to a commitment,
hard-earned customer trust is damaged.
To preserve our customer relationships:
We do not misrepresent our services or products
in any sales or promotional efforts.
We communicate clearly, so that our customers
understand the terms of our business relationships, including
contracts, performance criteria, schedules, prices, and
We protect our customers' confidential
We only make promises to customers that we
believe we will be able to keep.
Doing Business the Government
business with the government is not always the same as doing business
with private parties. Activities that might be appropriate when working
with private sector customers may be improper - or even illegal - when
a national or local government is our customer. For example, business
courtesies or entertainment that might be acceptable when dealing with
private parties - like paying for meals or drinks - may not be
appropriate when working with government officials. In addition, due to
complex legal requirements, some types of bid-related information,
which might be proper in a transaction with a private party, may not be
requested or received when dealing with governments or their officials.
Additional information is available on the Corporate Compliance Web
UPS's policy is to compete vigorously,
aggressively, and successfully in today's increasingly competitive
business climate, and to do so at all times in compliance with all
applicable antitrust and competition laws throughout the world. The
antitrust laws of countries around the globe are designed to preserve a
competitive economy and to promote fair and vigorous
competition. We are all required to comply with these laws and
regulations, which are explained in more detail in the UPS
Guidelines for Antitrust/Competition Law Compliance.
These guidelines cover such areas as Dealing with Customers,
Commercial Counters, Competitors, Suppliers/Vendors, Attending Trade
Association Meetings, Providing Subsidiary Services, Obtaining
Information about Competitors, Mergers and Acquisitions, International
Business, and Writing a Document.
Fair competition standards are a matter of law in virtually every
country in which we operate. We are all required to comply with these
laws and regulations. Those UPS employees who are involved in
marketing, sales, purchasing, or contracts, or in discussions with
competitors, have a particular responsibility to ensure that they
understand our standards and the applicable competition laws.
All management employees are expected to become familiar with the UPS
Guidelines for Antitrust/Competition Law Compliance, and how these
responsibilities apply to their current positions.
Additional information about antitrust and fair competition laws can be
found in the UPS Guidelines for
Antitrust/Competition Law Compliance, available on the
Corporate Compliance Web site.
Choosing Suppliers and
We strive to be fair in our choice of suppliers and consultants and
are honest in all business interactions with them. We choose our
suppliers and consultants based on appropriate criteria, such as
qualifications, competitive price, and reputation. Anyone responsible
for buying or leasing materials or services on behalf of UPS must
conscientiously guard their objectivity.
We also should avoid any implication that UPS's
continued purchase of goods or services from the supplier depends on
the supplier purchasing goods or services from UPS. Doing so may not
only violate our policies, but may also be a violation of antitrust or
fair competition laws. UPS may properly require that goods it purchases
be delivered via UPS, but it would not be proper for UPS to require
that its suppliers use only UPS when shipping to its other non-UPS
Nothing contained in this section is intended to limit or restrict
encouraging our vendors and suppliers to use UPS services. It is
recommended that appropriate UPS sales people be involved in such
We also expect our suppliers and consultants - and others who do
business with us or on our behalf - to conduct their business on behalf
of UPS in compliance with all applicable laws and regulations and in
accordance with the highest ethical standards.
Additional information can be obtained from the Corporate Procurement
Buying or selling securities while in possession of material,
non-public information (or "inside information") may violate U.S.
and other securities laws.
Inside information is information that a reasonable investor would
consider important in making investment decisions and that is
non-public, or has been public only for a very short time.
Examples of inside information may include:
Contracts or proposed contracts with customers
Proposed acquisitions, joint ventures, or
New products or services and regulatory
approvals or disapprovals
Insider trading is both
unethical and illegal, and we should not trade in any stock or other
securities on the basis of such inside information, including inside
information we learned about an organization with which UPS does
or might do business.
The same rules against using inside information apply when we give that
information - to someone else, so that the individual can profit form
that information by trading in stock or other securities.
UPS, like many public companies, has adopted specific trading
restrictions to guard against insider trading. These restrictions are
designed to protect the employees and UPS from liability associated
with inappropriate use of inside information, and these restrictions
apply to specified employees and those living in their household. Do
not confuse the applicability of these trading restrictions with the
broader prohibition on trading when in you possession of inside
Additional information can be found in the UPS Insider Trading Compliance Guidelines
available on the Corporate Compliance Web site.
Investments in an organization with which UPS does or may do
business can raise important compliance issues relating to insider
trading, conflicts of interest and misuse of confidential information.
The standards in this section apply to any financial or ownership
interest in any company with which UPS does business (including
customers, suppliers, vendors, and service partners), as well as
companies with which UPS may do business (including potential
customers, suppliers, vendors, and service partners) and competitors of
Investment in such an organization is not allowed if a UPS employee has
direct or indirect responsibility, or even appear to conflict,
with the interests of UPS. This means a UPS employee should not have
any financial or ownership interest in an organization if it could
cause the employee, or might be perceived by others to cause the
employee, to choose between that interest and the interests of UPS.
Such an investment constitutes a conflict of interest that must be
avoided. If there is question about whether such an investment is or is
not appropriate, the employee should consult with a manager, review the
UPS Insider Trading Compliance Guidelines, or contact Corporate
Compliance or Corporate Legal.
Many of us create or prepare some type of information during our
workday, such as financial reports, accounting records, business plans,
environmental reports, injury and accident reports, expense reports,
and time cards. People inside and outside UPS depend on these reports
to be accurate, truthful, and properly maintained. These people
include employees, government representatives, auditors, and
the communities in which we operate. No one may deviate from our
commitment to manage information accurately and truthfully. Our
records are maintained for required periods ad defined in the UPS Records Retention Schedule.
Additional information can be found in the UPS Records Management Guidelines
available on the Corporate Compliance Web site.
Company Property and Services
The use of company time, labor, supplies, equipment, tools, buildings,
or other assets for personal benefit is prohibited. Employees are
required to pay for personal use of UPS services. Company property used
in the course of work with UPS remains the property of UPS and must be
returned upon request by UPS or upon termination of employment.
Collectively, we have a responsibility for safeguarding and making
proper and efficient use of UPS's property,
Cash, checks, drafts, and charge cards
Land and buildings
Equipment, including fax machines, copiers, and
Materials and supplies
Computer hardware and software
Information assets, including electronic data
and intellectual property
Scrap and obsolete equipment.
UPS property must not be used for any purpose not
related to UPS business without prior authorization from the
UPS depends on intellectual property, such as information, processes,
and technology. Those tools are available at our disposal because of
significant investments of time and company funds. If our
intellectual property is not properly protected, it becomes available
to others who have not made similar investments. This would
cause us to lose our competitive advantage and compromise our
ability to provide unique services to our customers.
UPS intellectual property includes confidential UPS business
information, trade secret technology (such as computer software and
systems), patented inventions and processes, trademarks, and
It is the responsibility of every UPS employee or representative to
help protect UPS intellectual property. It is the responsibility of UPS
managers and supervisors to foster and maintain awareness of the
importance of protecting the UPS intellectual property.
Additional information is available in the UPS Intellectual Property Protection Manual,
available on the Corporate Compliance Web site.
Information Use and Security
We use information technology and engage in electronic communications
to manage our business efficiently, and to comply with UPS policy and
legal requirements. We comply with UPS business and security practices
that protect confidential and/or proprietary information. We
permit brief, limited personal communications that do not violate the
law or other UPS policies, and that do not interfere with our business
UPS is committed to the use of advanced technologies in its
business operations. These powerful tools, provided for business
purposes, expand the information available to us and enhance our
ability to communicate with each other, our business partners, vendors,
Additional information is available in the UPS Information Use and Security Compliance Manual
and UPS Intellectual Property
Protection Manual, available on the Corporate Compliance
We may not reproduce, distribute, or alter copyrighted materials owned
by others without a valid license or prior permission of the
copyright owner or its authorized agent. It is not always easy to
determine if such permission exists, and we must confirm that
appropriate permission exists before using such materials.
Copyrighted works include, but are not limited to, printed articles
from publications, TV and radio programs, videotapes, music
performances, printed photographs, digital photographs, training
materials, manuals, documentation, software programs, databases,
diskettes, CDs, and Web pages. In general, the laws that apply to
printed materials are also applicable to audio, visual, and electronic
media. Presentation slides, training materials, management models, or
other materials prepared by outside consultants or organizations also
may be copyrighted.
To avoid violations of copyright laws, all UPS employees and
representatives must ensure that appropriate authorization is obtained
prior to using or reproducing any materials. While UPS has obtained
license or other forms of permission to use and reproduce copyrighted
materials, any doubt with regard to whether use is authorized should be
resolved in favor of not using or reproducing the materials.
Additional information is available in the UPS Information Use and Security Compliance Manual
and UPS Intellectual Property
Protection Manual, available on the Corporate Compliance
In order to maintain our reputation and the value of the UPS brand, we
must ensure proper use of our name and our trademarked images at all
times. UPS owns a number of symbols, brandmarks,
and logos that identify various aspects of our company. It is important
to reproduce these images accurately, because they also represent our
company and help maintain the UPS image. Incorrect usage of our
trademarks by UPS employees or others should be reported to Corporate
Compliance or Corporate Legal.
UPS trademarks (marks used in connection with goods) and service marks
(marks used in connection with a service) that have been registered
with appropriate authorities worldwide should appear in print and
other visual media with the appropriate registration notice.
Correct use of registration and common law notices in all print and
visual communication helps protect UPS registered marks and
unregistered marks. The procedures outlined on the UPS Brand Exchange
Web site must be followed for correct usage of UPS marks, or contact
UPS Brand Management with any questions.
Confidential and Proprietary Information
Information is a valuable corporate asset. Dissemination of
information is critical to our success. However, much information about
UPS's business activities is confidential or
proprietary. Just as UPS values and protects it own confidential and
proprietary information, it is our policy and practice to respect
the confidential and proprietary information of others, including
information we may have about our customers, suppliers, and employees.
Because the disclosure of confidential or proprietary information
could seriously damage UPS's interests,
safeguarding this information is the responsibility of all UPS
employees and representatives. If we learn about proprietary or
confidential information during the course of employment or
relationship with UPS, we should be careful not to share it with
others, including other employees, unless they need to know it for
a legitimate business reason that will not violate
any law, regulation, or UPS policy.
We may be asked to provide information about a customer to a job
function or business, but depending upon the circumstances, this could
be a violation of Antitrust/Fair Competition, Privacy, or other laws,
or our contractual commitments to the customer. If employees not
usually privileged to the information as a part of their job
responsibilities request that information, we should consult with a
manager, Corporate Compliance, or Corporate Legal prior to
divulging the requested information.
We should also guard against unintentionally disclosing proprietary or
confidential information. Situations that could result in inadvertent
disclosure of sensitive information include: discussing
confidential or proprietary information in public - in
restaurants, on elevators, or on airplanes; talking about it on public
or mobile phones; working with sensitive information on laptop
computers in public; or transmitting such information by insecure
means. Our obligation to protect UPS's
confidential and proprietary information continues even after you leave
Law Compliance, the UPS
Trading Compliance Guidelines, the Guidelines for UPS Affiliate Information
Sharing, the UPS
Information Use and Security Compliance Manual and UPS Intellectual Property Protection Manual.
Political Activities and
UPS encourages all UPS employees to be informed voters, but
personal participation in the political process, including
contributions of time or financial support, is completely voluntary.
Election laws in some countries prohibit campaign contributions by
corporations, whether by direct or indirect use of company funds or
resources. In accordance with these laws, UPS does not make direct
contributions to any candidate for political office where national or
local law makes such contributions illegal.
As private citizens, we may participate in the political process,
including contributing to the candidates or political parties of our
choice. However, such personal political activities or contributions
must not involve or even appear to involve use of UPS's
funds or resources. UPS's funds and resources
include, but are not limited to, company time, facilities, office
supplies, letterhead, phones, and fax machines. Employee work time
also is considered a contribution by UPS. Therefore, we cannot be
paid by the company for any time spent campaigning for a political.
laws provide for corporations to establish and maintain political
action committees, which may lawfully make campaign contributions. UPS
has established a political action committee in the United States
called the UPS Political Action Committee (UPSPAC). Participation in
and contributions to UPSPAC are entirely voluntary and only are
used for political purposes. Any employee has the right to refuse to
contribute to UPSPAC without reprisal.
UPS employees who hold or seek political office must do so on their own
time, whether on vacation, unpaid leave, after hours, or on weekends.
Where permitted by law, UPS requests that employees obtain permission
for the Secretary of the Company prior to running for political office,
in order to avoid a potential conflict of interest. Any UPS employee
who runs for political office will be required to complete the Business
Ethics Questionnaire (BEQ). Any UPS employee who holds such an office
should contact Corporate Compliance.
Additional information is available from Public Affairs.
Country-specific guidance is available through Corporate Compliance.
Transacting Transnational Business
Transnational business is vital to UPS. The laws of both the United States,
and other countries in which we operate, frequently affect our
transnational business transactions. Among other things, these laws
regulate UPS's interaction with foreign
governments and their officials, restrictive trade practices, and
import and export shipments. Antitrust laws, which are discussed in the
"Antitrust/Fair Competition" section, also regulate many
aspects of UPS's business outside of the United States.
UPS is committed to conducting its business abroad in compliance with
all applicable laws. All employees involved in UPS's
transnational business should be familiar with and adhere to these
As a U.S. based corporation, UPS is subject to the U.S. anti-bribery laws
that are enforceable worldwide and cover all UPS operations, including
all businesses, agents, and joint ventures. Anti-bribery laws include
the Foreign Corrupt Practices Act (FCPA) and all such laws of the
countries in which we operate.
Broadly speaking, the FCPA prohibits a U.S. based company or any of its
worldwide businesses or affiliates from bribing -
or offering, promising, or authorizing anything of value
to - a foreign government official in order to obtain or retain
business. We conduct our business in accordance with the FCPA, and
every one of us, regardless of the country in which we work, must
adhere to its requirements.
Under the FCPA as well as other anti-bribery laws, UPS, its employees,
and its agents also are prohibited from doing indirectly what we
are prohibited from doing directly - we cannot make any payment to
a third party if all or any part of the payment will be given to a
prohibited person. UPS could be held liable for such payments even if
the company did not know, but should have known, that the payment
was going to a prohibited person.
All management employees are expected to become familiar with the UPS Anti-Corruption Compliance Manual,
and how these responsibilities apply to their current positions, and to
review them whenever their position or responsibilities change.
New Entity Procedure
UPS uses various business arrangements, including independent
contractors, general sales agents, and joint ventures to conduct its
New entity procedures have been developed to provide a uniform basis
for evaluating potential businesses for these arrangements and to
minimize the potential business and legal risks that may be created
through these arrangements. The due diligence in completing the New
Entity Request Information Worksheet is critical and mandatory. A
new relationship must not be established until the information is
properly evaluated and appropriate approvals are obtained.
Additional information can be found in the UPS Anti-Corruption Compliance Manual, available
on the Corporate Compliance Web site.
Boycotts, Embargoes, and
Restrictive Trade Practices
A boycott occurs when one person, group, or country refuses to do
business with certain other people or countries. As a U.S. based company, all UPS operations
must comply with U.S.
laws pertaining to boycotts. U.S.
anti-boycott laws generally prohibit U.S.
companies and their subsidiaries from participating in or cooperating
with any international boycott, unless the boycott has been approved by
government. Economic sanctions or trade embargoes imposed or approved
by the United States
are examples of boycotts with which we must comply.
These anti-boycott laws also require U.S. companies and their
worldwide subsidiaries to report any requests they receive to engage in
We must be particularly alert for requests for information or contract
Request information about any person's past,
present, or prospective relationship with boycotted countries or blacklisted
Request information about any person's race,
religion, gender or nationality.
Request discrimination against individuals or
companies on the basis of race, religion, gender or nationality.
All employees should report
any such requests to Corporate Compliance, Corporate Legal, or
their region's Legal Department.
Government Controls for
All import and export shipments are subject to regulation by
various government agencies, principally Customs, both in origin and destination
countries. These laws are designed to ensure that imported products are
properly admitted into the country to safeguard the public and domestic
industries and to ensure the proper collection of duties, taxes, and
fees. We are responsible for submitting accurate information about
import shipments to Customs and other applicable government agencies.
Various governments administer programs restricting and/or
limiting the export and import of goods. These restrictions include
embargoed countries and designated nationals, businesses, and various
other entities that have violated export laws or participated in
activities deemed critical to the security of that country.
All UPS employees and representatives involved in the import and export
of shipments on behalf of UPS and its customers should be familiar with
and adhere to all procedures and documentation necessary to properly
import or export shipments.
Additional information is available from Corporate Compliance.
We are committed to conducting our business in a manner that
protects the environment. Our commitment to the environment goes beyond
complying with environmental laws and includes a commitment to
advancing programs that promote improvement of the environment. Everyone
who is part of the UPS organization is expected to support our effort
to maintain a leadership role in protecting the environment.
Through the Corporate Environmental Affairs Department, we have
established a site and activity-specific environmental compliance
and pollution prevention programs to address our environmental
responsibilities. We continually evaluate improved technology and seek
opportunities to improve environmental performance.
Our environmental responsibilities include:
Properly storing, handling, and disposing of
hazardous and other waste.
Managing wastewater and storm water in
compliance with applicable regulations.
Monitoring and maintaining the integrity of
underground storage tanks.
Complying with laws regarding clean air.
Protecting against and appropriately responding
to spills and releases.
Seeking ways to minimize waste and prevent
In addition, we must provide timely, truthful, and
accurate information required in connection with applications for
environmental permits and other reports called for under permits or
Additional information is available from Corporate Plant Engineering.
The handling and transportation of many items by UPS are regulated
by various national and local government authorities. These
regulations cover such items as hazardous materials/dangerous
goods, pharmaceuticals, alcoholic beverages, and other special
We conduct our business in accordance with the requirements imposed by
external authorities in a manner that protects the safety of our
people, our customers, and the public in all modes of service. We
establish standards and procedures related to the handling and
transportation of these items and embed them into our everyday business
processes. We are all responsible for complying with applicable
governmental laws and regulations worldwide and for understanding and
adhering to established UPS procedures related to
these transportation issues.
UPS employees, representatives, and customers are expected to comply
with all applicable governmental laws and regulations, and UPS-specific
Additional information on each of these programs is available from
TO SUGGEST CHANGES TO THE CODE OF BUSINESS CONDUCT
If you have any suggestions for changes to in the UPS Code of
please submit them promptly, as indicated below, while they are fresh
in your mind. This form is included for your convenience in
submitting recommendations for changes. If you prefer, you may use your
own words, stationary, and format.
Code of Business Conduct Review
United Parcel Service
I recommend the following change(s) be made in the UPS Code of Business Conduct:
Section on page ________
Suggested new wording:
The Code is not an express or implied contract of
employment and does not create any contractual rights of any kind
between UPS and its employees. In addition, all employees should
understand that the Code
does not modify their employment relationship, whether at will or
governed by contract. This Code is intended to clarify each employee's
existing obligation for proper conduct. UPS reserves the right to
amend, alter, or terminate the Code or the policies at any time for any