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4.1. I am a NS employee. I am thinking about taking a second job to earn some extra cash. What problem could I face? (Answer: First you need to consider if your second job will conflict with your schedule at NS. Second, be certain that you will have the energy to devote your best efforts to your primary job at NS and your part-time work elsewhere. Finally, make certain that your “other” employer is not a competitor or supplier).

4.2. My family and I are very active supporters of a local charity and believe that NS should make a corporate contribution. Is this a conflict of interests? (A: Probably not. But to be sure, forward your request to your Management. Let them decide whether or not it is appropriate for NS to support this charity).

4.3. I work with number of outside companies that provide services to NS. Our contract for landscaping services is up for renewal. We are thinking about asking other companies to submit bids. My brother-in-law owns a gardening company. Can I help him? (A: It is perfectly acceptable to tell a family member that NS will solicit bids (объявлять тендер) for landscaping services. When the time comes for the Request for Proposals to be send around, your brother-in-law is welcome to submit a bid if he meets our qualifications. Under no circumstances should you share information with him about selection process. If your brother-in-law submits a bid, you should disclose this to your supervisor and other management. Then, you should excuse yourself from the review and selection process).

5.1. After a business trip, I found that my co-worker included items on her expense report that were paid by someone else. What should I do? (A: This could be a significant problem. We will not know until we have all the facts. You could speak to your co-worker about your observation and remain her of the correct problems. If you are uncomfortable doing so, discuss the situation with your supervisor).

5.2. I have many documents that are no longer needed, and we have no storage space. They have not exceeded their document retention date, but I am sure no one will ever need to see them again. Can I shred these records? (A: No. Do not destroy any business documents unless you are following your document retention schedule. These records could be stored where there is adequate storage space. Ask your supervisor or get legal advice about your opinions).

5.3. After moving to a new work group, I learned that some payments were recorded as advertising or market survey expenses when they were really for entertainment. Since the total amount that was spent is accurate, is this a problem if the category is not exactly correct?

(A: Yes, this could be a problem. Our books must be kept in accurate detail and reflect all of our transactions. False transactions and other misrepresentations violate this Code, and possibly the Law. Contact your supervisor, the Controller, or Internal Audit so that this practice can be stopped and other record corrected).

5.4. My supervisor told me to record a transaction that I do not really understand. How can I be sure that I am doing the right thing?

(A: Ask your supervisor for an explanation. If you are still unsure about what you have been asked to do, ask for help from the Controller of your business unit).



* В настоящей Статье “Words into Action” Главы V (Chapter V; UNIT XXIII) содержатся рекомендации Компании по реализации на практике требований кодекса ведения бизнеса и соблюдения норм деловой этики. Рекомендации основаны на реальных кодексах ведущих корпораций.

5.5. I know that the deal was completed on the last day of the quarter. However, it did not show up on the new deals report the following day, and it does not appear to be anywhere in our system. What should I do?

(A: Contact your supervisor immediately to discuss the situation. The timely and accurate capture of trades in our trading system is critical for risk assessment, credit rating, and functional management. Generally, NS trades should be recorded in our trading system within 24 hours of execution).

7.1. One of my closest friend works for our competitors. We play golf together, our families vacating together, and we attend the same trade shows. Am I in violation of any antitrust laws or fair trade practices?

(A: No. A person relationship alone does not constitute violation of Antitrust Laws or fair trade practices. Nonetheless, you should use caution talking about our business when you are with your friends. Never discuss price or terms of any NS contracts, deals, or trades. Be clear that these kinds of discussions are off limits because they could jeopardize both companies. Even jokes can be misinterpreted).

7.2. I believe one of our competitors exaggerates its capabilities and services. This puts us at a disadvantage. How can I set the record straight?

(A: You can control only how you represent NS to our customers. Describe and demonstrate the benefits of our approaches, but do so honesty).

7.3. A supplier left a document in my office that is related to the products of one of our competitors. Can I keep a copy or share this information with others so that we know what the competitor is thinking about?

(A: No. This document may be confidential and can not be disclosed without proper authorization. If you use this information, you will violate our Code and values and possibly expose NS and yourself to a lawsuit. Upon discovering this document, you should immediately contact the Legal Department so the document can be promptly returned or destroyed).

10.1. Can we keep a gift of candy and fruit that our work group received from a long-standing vendor at holiday time?

(A: Yes. You may keep a gift of candy and fruit that our group received from a long-standing vendor at holiday time).

11.1. Can we keep a gift of candy and fruit that our work group received from a long-standing vendor at holiday time?

(A: Yes. You may keep a gift of candy and fruit that our group received from a long-standing vendor at holiday time).

11.2. May I pay for the lunch of a government official with whom we are discussing interpretations of NS regulations?

(A: You should check with Government Affairs prior to offering to pay for a government official’s meal or any other type of expense. There are limits on the value of meal that government officials may accept. We may be required to report this type of expenditure to the government).

11.3. A consulting firm offered four tickets to the baseball game with a value of $100 per ticket. Does this mean that I can’t go? What if I give the tickets to my staff instead?

(A: Our policy on gifts, hospitality, and entertainment does not prohibit you from going to the ball game, but you must first obtain your supervisor’s approval on the Gift, Hospitality, and Entertainment Approval form and forward a copy to the management before you keep the tickets for yourself or for your staff).

11.4. Frank is a salesman for a heavy equipment supplier. On behalf of NS I do business with his company. He knows that I am an amateur photographer. He sent me an expensive camera. Can I keep it?

(A: No. You must return the camera. Thank Frank for the thoughtful gift, but explain that you can not accept it because it could appear that your business judgment would be influenced unduly by this gift. You should disclose the situation to your supervisor and the management).

12.1. Someone in my workgroup agreed to spend $300,000 on consulting services that were budgeted for next year but only has spending authority up to $200,000. He asked me to issue two separate purchase orders so that he can avoid asking his boss for approval. What should I do?

(A: Do not issue two purchase orders to cover one transaction. Your co-worker may be trying to circumvent our Delegation of Authority and get around one of our internal controls. You should speak up and discuss the situation with your supervisor or the Legal department, or call the Integrity Helpline).

12.2. When it comes down to it, I’m a salesperson. Like everybody else, I have mouths to feed at home and have to make my numbers every quarter. I work with some of the same customers every quarter, and know about how much they are going to purchase from us. Why can’t I just book my sales ahead of time? Aren’t they as good as sold?

(A: You can not book a sale you have not made. You can not record a transaction where legal title has not passed. No matter how certain you are that your customer has a choice. It’s against our Code and the law for you to record a sales transaction as final if it has not been really been executed).

13.1. NS is using local contractor to provide catering at an all-office event. I like their work and may want to use them for my daughter’s wedding. Can I look at their pricing information to determine how expensive they are?

(A: No. This is not an appropriate use of information. Contractors trust NS to keep their pricing information confidential. If you would like to use this caterer, you may. However, ask him or her to contact you outside of working hours. Do not seek special treatment based on your affiliation with NS).

13.2. One of my close friends is starting a consulting company and asked for a copy of our organizational charts and personnel policies. He explained that this could give him some informal benchmarking advice. May I help him out?

(A: No. We do not provide this kind of information to outside third parties. You should check first with our Legal Department or Human Resources before you provide any information about our internal structure and organization).

13.3. Once my former employees has contacted me to provide an employment reference. What can I say?

(A: We do not provide reference information about current or former employees – other than their names, job title, and dates of employment. Always refer inquires for references to your Human Resources Business Partner. Only Human Resources may deal this information. You can provide a personal character reference, but do not refer to NS or use NS’s name in any way).

15.1. What should I do if I fell that I have been discriminated against at work?

(A: If you think that you have been treated unfairly, you should report your concerns immediately to your supervisor, your Human Resources Business Partner, or call the Integrity Helpline).

15.2. Some people that I work with have distasteful posters and calendars posted in their work areas. What should I do?

(A: Speak up. Let your co-workers know how you feel. If they don’t remove these items, speak with your supervisor, your Human Resources, or call the Integrity Helpline. When you are working for NS we expect you to comply with our standards and policies. Each of us has the right to be free of unseemly conduct at work).

15.3. May I specify in a job advertisement my preferences that this position will be filled by a young man or woman who has just received a college degree?

(A: No. There is no business justification or ethical reason to limit applicants by sex or age. This is illegal. However, if the job requires a college degree, then you may ask for this qualification. Remember to coordinate all job advertisements with the Human Resources department).

15.4. A co-worker sent me an e-mail message with a sexually offensive picture attached. What should I do?

(A: Respond to the sender that you do not want to receive this type of message again. Then, report the situation to your supervisor, any member of your management. They will tell you how to handle the offensive message).

15.5. I believe that a co-worker has accused me of sexual harassment and has called the Integrity Helpline. What will happen?

(A: NS takes this kind of situation very seriously. We will investigate your co-worker’s concern and give you an opportunity to describe what happened. The outcome will depend on a number of factors, including the facts, the seriousness of the conduct, past warnings, and the credibility of the people involved. You are required to cooperate completely with any internal investigation. We handle investigations confidentially. You should maintain confidentiality to the extent practicable. Contact Legal Department if you have questions).








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