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REYNOLDS AMERICAN INC.
CODE OF CONDUCT

Contents

 

Letter from Chief Executive Officer

 

I.

Compliance - Each Employee's Responsibility

II.

Youth Smoking

III.

Conflicts of Interest
  1. Personal Financial Interests
  2. Outside Activities
  3. Family and Other Significant Relationships
  4. Reporting and Resolving Conflicts of Interest

 

IV. Use of Inside Information and Speculation in Company Securities
  1. Use of Inside Information
  2. Trading in RAI Stock Prohibited During “Trading Blackout Periods”
  3. Speculation in Company Securities

 

V. Advertising and Marketing

 

VI. Competitive Practices

 

VII. Dealings With Persons Who Provide Us Goods and Services
  1. Reciprocity
  2. "Kickbacks" and Rebates
  3. Receipt of Gifts and Entertainment

 

VIII. Dealings With Customers and Potential Customers

 

IX.

 

The Foreign Corrupt Practices Act (“FCPA")
X.

 

Anti-Boycott Law
XI.

 

U.S. Embargo Against Certain Countries
XII.

 

Dealings With Public Officials
XIII.

 

Political Activities and Contributions
XIV.

 

Investor and Media Relations
XV. Safeguarding Company Assets
  1. Safeguarding Product Integrity
  2. Safeguarding Proprietary Information
  3. Safeguarding Company Funds and Property
  4. Records Management

 

XVI.

 

Integrity of Records and Financial Reports
XVII. Use of Company Information Technology Resources
  1. Protection of Information Technology Resources
  2. Confidentiality of Information
  3. Use of Internet/Company Intranet Services
  4. Use of Electronic Mail Services

 

XVIII. Equal Employment Opportunity , Affirmative Action and Workplace Diversity
  1. Equal Employment Opportunity
  2. Affirmative Action
  3. Workplace Diversity

 

XIX.

 

“No Harassment” Policy
XX.

 

Health, Safety and Environmental Protection
XXI.

 

Substance Abuse
XXII.

 

Government and Attorney Inquiries
XXIII.

 

International Business Guidelines
XXIV.

 

Use of Agents and Non-Employees
XXV. Code of Conduct Compliance
  1. Initial Distribution
  2. Initial Certification
  3. Maintaining Compliance
  4. Amendments and Waivers
  5. Audits of Compliance

 

XXVI.

 

Code of Conduct Violations
XXVII.

 

Continuance of Existing Personnel Policies, Rules and Performance Standards
XXVIII.

 

Updating
Certification of Compliance Forms
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