Ensuring Sun Succeeds with Integrity
Sun's Business Conduct Office (BCO) was established in April 2001, with the
charter to develop and manage a global business conduct program that
maintains Sun's legacy of corporate integrity and fulfills our obligations
to our stockholders by providing Sun employees with the necessary
resources and guidelines to conduct business responsibly.
Specifically, the role of Sun's Business Conduct Office is to:
Advise - Assist all Sun employees in fulfilling their obligations to Sun with respect to responsible business practices and legal compliance;
Educate - Ensure that Sun employees understand ethical and legal implications involved in the performance of their duties;
Respond - Provide a confidential resource for employees to seek advice, obtain information and report violations concerning Sun's Standards of Business Conduct;
Coordinate - Work with all functions and management at Sun to identify and consistently address business conduct issues that may impact Sun's reputation; and
Communicate - Articulate expectations regarding Sun's legal and business conduct standards.
Adviceline
Sun's Business Conduct Adviceline is a resource for Sun employees seeking help, obtaining
information or reporting a violation. Sun's Adviceline is answered 24 hours a day, 7 days a week
by trained communication specialists. All calls to the Adviceline are toll-free and can be made
anonymously. Calls can be received from individuals speaking most languages as well as from
hearing impaired employees.
Conflicts of Interest
Sun enforces a conflict of interest policy and corresponding approval process. Its objective is
two-fold:
- Confirm that everyone is operating on a level playing field when transacting Sun business;
- Ensure that the trust of Sun employees, stockholders, customers, business partners and suppliers is not undermined by individuals promoting their own financial or other interest at the expense of the team.
Employee activity constituting an actual conflict of interest is prohibited by Sun policy and all
violations are subject to disciplinary action, including dismissal. The BCO ensures that all such
disclosures are reviewed by appropriate level management and addressed in a manner consistent
with Sun's conflict of interest policy.
Sun policy prohibits an accounting firm from providing any audit service if Sun's CEO, CFO,
controller, chief accounting officer or any person in an equivalent position was employed by that
firm and participated in the audit during the one-year period immediately preceding the audit's
initiation.
Sun's Zero Tolerance Retaliation Policy
Sun has established procedures for the receipt, retention and treatment of complaints regarding
accounting, controls or auditing matters and for confidential submission of concerns by
employees.
Any retaliation against an employee reporting a perceived violation will not be tolerated.
