As a partner, you may become aware of significant and confidential information about Starbucks business, often called "material non-public information." Partners may not buy or sell stock (including by cashless exercise of stock options) or any other security while in possession of this information. In order to avoid potential problems, you should interpret the term "material non-public information" broadly.
Some examples of material information include:• Financial information
• The development of new products or services
• A proposed acquisition, joint venture or merger
• Government investigations
• Changes in key personnel
There also must be adequate time for the market to digest the information. Starbucks requires that the information must be publicly available for at least one full business day before you may trade in Starbucks securities. Directors, certain executives and partners with regular access to material non-public information also may not trade during the blackout periods established by Starbucks.
Starbucks information should be used only for company purposes and should not be disclosed to anyone outside of the company. Even within the company, only those individuals who truly need to know the information to conduct their business should have access to confidential information. If you leave Starbucks, you must return all company materials and property, and any copies.
Confidential information includes things such as supplier information, Starbucks technologies, recipes, formulas, coffee blends, business and marketing plans, internal company communications, and existing and future product information.
Confidential materials should:
- Be stored in a secure place and should not be left out where others can see them
- Be clearly marked as confidential
- Not be sent to unattended fax machines or printers
- Not be discussed where others may hear
Starbucks is committed to being fair in the areas of confidential information and materials. Just as we take care to protect our information, Starbucks respects the information of others.
Here are some basic rules to follow:
- Do not bring any material from prior employers to Starbucks
- Do not accept or use anyone else’s confidential information (or agree to maintain anyone’s information in confidence)
- Do not solicit confidential information from another company’s present or former employees or suppliers
- Do not engage in espionage; be transparent in obtaining information about the marketplace
As a partner, the things you create for Starbucks belong to the company. This includes inventions, discoveries, ideas, improvements, software programs, artwork and works of authorship. This work product is Starbucks property if it is created or developed, in whole or in part, on company time, as part of your duties or through the use of company resources or information. Partners must promptly disclose to Starbucks, in writing, any such work product and cooperate with the company’s efforts to obtain protection for Starbucks.
To ensure that Starbucks receives the benefit of work done by outside consultants, it is essential that an appropriate written agreement or release be in place before any work begins.
Brands are fragile and must be used carefully and protected from misuse.
When Starbucks uses the work product of others, including art and music, we must also be sure to follow the rules. For example, you should only use software for which you have a valid license and should only use that software in accordance with the terms of the license for that software. Written materials and music may be subject to copyright protection and should be copied only when permitted. Use caution, as not all copyrighted materials bear a notice.
Protecting Partner and Customer Personal Data
Starbucks maintains many information assets, including personal and sensitive information, which are critical to doing business, keeping the trust of our customers, and keeping our future strong. This personal information may reside on digital computing systems, networks or backup devices, or may be recorded on paper or other recording media.
Starbucks Global Privacy Standard requires that all collection, storage locations, uses, sharing, transfers, and disclosures of personal data be strictly controlled and protected. Additionally, reasonable effort must be made to ensure that fundamental privacy and security principles are followed across the enterprise when managing personal information of both partners and customers.
Reasonable effort includes:
- Ensuring compliance with all applicable international, federal, state/provincial and local laws and regulations as well as applicable contractual agreements;
- Protecting the rights of our customers, partners, and business contacts; and
- Protecting Starbucks from the risk of a data breach.
Any suspected data privacy incidents must immediately be reported to the Global Privacy Office at Privacy@starbucks.com or to your local help desk.
Use and Retention of Company Records
Starbucks Information and Records Management Standard states that partners will manage information in such a way that supports the needs of the business while ensuring efficiency, security and compliance with any legal or regulatory requirements. This standard applies to records maintained in all forms at Starbucks, including paper and electronic.
If you are responsible for preparing or maintaining any Starbucks records, please familiarize yourself with the Starbucks Information Protection Services Handbook, the Starbucks Records Retention Schedule and specifically the retention periods that apply to the records you keep. Also remember that there are strict rules relating to the processing and handling of private and secret information. This includes collecting, storing, using, amending, disclosing and destroying information.
You must not knowingly destroy or discard information that is subject to a legal hold. Records relevant to a legal action cannot be destroyed or discarded and must be preserved. If Starbucks receives a subpoena (or other form of legal order), a request for records or other legal papers, or if we have reason to believe that such a request or demand is likely, the company policy is to retain all information that is relevant to the matter.
- Records must always be prepared accurately and reliably, and stored properly in accordance with the Starbucks Records Management Handbook and the Starbucks Records Retention Schedule.
- Records must accurately and fairly reflect, within Starbucks normal accounting and reporting systems, all required transactions and other events.
- There cannot be any unrecorded company funds, assets or any other type of “off the books” accounts, no matter what the reason for such accounts.
Books and Records
All partners must ensure the accuracy and integrity of Starbucks corporate records. This includes reliability and accuracy of books and records, as well as full, fair, accurate, timely and understandable public disclosure.
The books of account, financial statements and records of Starbucks should be maintained in accordance with the requirements of law and generally accepted accounting principles. All of Starbucks assets and liabilities should be properly recorded in its books, and revenues and costs must be recorded in the right time periods.
Financial Account, Internal Controls and Auditing Matters
Concerns regarding accounting, internal accounting controls or auditing matters should be promptly reported through the Ethics & Compliance Helpline. Reports may be made anonymously and will be treated in a confidential manner.
Depending on how they are classified, reports of this nature will be routed to Ethics & Compliance, the chief ethics and compliance officer or the general counsel in Starbucks U.S. head office, the Audit and Compliance Committee of the Board of Directors or the presiding independent director of the Board.
Political activities must be conducted on your own time and using your own resources. You must not promote any political or personal views or beliefs (including by posting or distributing notices or other materials) on or around Starbucks premises, and you may not indicate or suggest that you speak for Starbucks or that the company supports your views.