Code of Business Conduct & Ethics

Following the law

We are accountable for our actions, and we honor our commitments. Our success as a company is driven by our shared goals of honest and ethical action.

Every action we take is in compliance with the law–and in keeping with our high ethical standards.

Report suspected violations of the Code, eBay policies, or the law to your manager, a Business Ethics Officer or other resource available for assistance. You can email askethics@ebay.com; or submit an anonymous inquiry by calling the eBay Integrity Helpline at 844-945-0216. (If you are outside North America, visit the Integrity Helpline website for global phone numbers.)

No financial targets, production numbers or other individual, team, or corporate goal ever justifies violating the law or the Code.

Making ethical decisions

When you face difficult decisions at eBay, take the time to think and consider the ethical and legal consequences. Don’t give in to pressure and rush your decision. Carefully consider the implications of your actions.

Always ask:

• Is it honest and fair?
• Is it consistent with the law and the Code?
• Is it consistent with Our Beliefs?
• Does it make you feel good about yourself and the Company?
• Would you feel comfortable reading about your action in the news?

If you answered yes to all of these questions, chances are that you’re probably okay to proceed. If you hesitated in answering “yes” to even one of these questions, then it’s best to get a second opinion from your manager or a Business Ethics Officer.

Most importantly, ask for help when you need it.

Understanding the importance of speaking up

A culture that encourages us to voice our opinions and concerns will help keep eBay a great place to work.

If something does not feel right, each of us should feel empowered to take action. When you see or suspect misconduct, speak up promptly. Doing so will allow the Company an opportunity to deal with the issue and correct it, ideally before it becomes a violation of law or a risk to health, security or the Company’s reputation.

When you have questions or need help, we encourage you to consult one or more of the following resources:

• Your manager;
• An eBay Business Ethics Officer who can help evaluate ethics and compliance issues;
• People Central (Human Resources);
• Legal;
• Office of Ethics & Compliance;
• askethics@ebay.com; or
• To submit an anonymous inquiry, you can do so by calling the eBay Integrity Helpline at 844-945-0216. (If you are outside North America, visit the Integrity Helpline website for global phone numbers.)
• The Integrity Helpline is available 24 hours a day, seven days a week and is a resource for asking questions and reporting suspected misconduct or violations of the law or the Code. All calls to the Helpline are confidential and can be made anonymously in your local language. Additionally, you can choose to submit reports online without speaking with an operator.

Business Ethics Officers help evaluate and resolve ethics and compliance issues. If you have any question about the meaning or application of this Code, raise it directly with a Business Ethics Officer.

Maintaining accurate accounts and records

We have an obligation to our business, stockholders and others who rely on us to ensure that our accounts and records are always complete, accurate, timely and understandable.

Our accounts and records are critical for internal decision-making, and for reporting to government agencies and the market. Accurate records protect shareholders and maintain our reputation for integrity.

This means that we never falsify, forge, or improperly alter any Company document. We ensure that all transactions are lawful, recorded in the proper account, and in accordance with all Company internal controls. All reports to regulatory authorities must be full, fair, accurate, timely and understandable.

We all are responsible for maintaining official business records in accordance with the Company’s records management-related policies, standards and schedules. We follow our accounting policies, as defined in our Accounting Policy Group Manual on the Hub, and we notify Finance, Legal or our internal or external auditors of any potential accounting or auditing violations.

This requires:

• Properly recording all expenses made on behalf of the Company;
• Preserving all documents, including electronic communications such as email, messaging, and chats relevant to litigation, audit, examination, or imminent or ongoing investigation involving the Company until otherwise notified by Legal; and
• Disposing of business records that no longer need to be retained for business reasons.

Refraining from insider trading

In our work, we may come across confidential information that could impact the Company’s or another company’s stock price.

This type of “inside” knowledge cannot be used to gain financial advantage when buying or selling stock or passing this information on to others who may trade on it.

Any information that has not been disclosed to the public and that a reasonable investor might use to buy, sell or hold stock in a company is considered to be inside knowledge or “material non-public information.”

This may include:

• Financial announcements;
• Management changes;
• Major litigation;
• Purchase or sale of significant assets;
• Significant customer or client relationships, or product launches;
• Anticipated mergers, acquisitions, or divestitures;
• Business restructurings; or
• New product announcements.

We also don’t share material non-public information with family members, friends or anyone else so that they can trade in stock, either for themselves or on our behalf. Like insider trading, sharing material non-public information with others for the purpose of trading is illegal, and it will be prosecuted.

You are not permitted to use or share confidential information for stock trading purposes. In addition, you can’t trade eBay stock, on any trading platform, during Company-specified blackout periods.

Each of us is subject to differing blackout periods depending on our assigned employee classification level.

Read the eBay Insider Trading Policy to learn about legal and company requirements for trading in our stock and related securities. For any questions about insider trading and related issues, please contact Global Stock Plan Services on The Hub or consult a Business Ethics Officer.

Engaging in appropriate gifting and entertainment

We never give or receive inappropriate gifts, travel arrangements or entertainment. 

Strong personal and professional relationships with our customers and other business partners are essential to our success. We sometimes provide or receive occasional courtesies, such as reasonable entertainment and modest gifts in the course of a business relationship, but we never allow these courtesies to affect our ability to make objective business decisions or create the appearance that our objectivity has been compromised. Also, we avoid using gifts and entertainment as a means to improperly influence our business partners. 

Examples of reasonable business entertainment might include a meal at a restaurant or participation in a cultural or sporting event, such as a regular season football game. It’s not acceptable to conduct business entertainment at any location where one of your colleagues would not feel comfortable, such as an adult entertainment venue.

We do not accept travel or accommodations in connection with entertainment, and we don’t accept any entertainment that exceeds $250 (or a lower threshold pursuant to the laws of your location) in value without prior approval from a Business Ethics Officer.

To learn more, see our Global Anti-Corruption Standard, Gifts, Travel and Entertainment Guidelines, or talk to your Business Ethics Officer.

Business Entertainment 

Participating in reasonable business entertainment is acceptable as long as it is:

• Customary in scale and expense;
• In an appropriate setting;
• In furtherance of a business relationship; and
• Not intended, or doesn’t appear to improperly influence a business decision.

Without approval from both your manager and a Business Ethics Officer (BEO), you may not exchange any of the following business gifts:

• Cash or cash equivalents: such as gift cards (except eBay Inc. gift cards of reasonable value), shopping vouchers, fuel cards or dining vouchers;
• Expensive tickets to major cultural or sporting events, such as the Olympics, World Cup, Super Bowl, major film festivals, Wimbledon, World Series, Stanley Cup Finals, NBA Finals or NCAA Basketball Final Four;
• Extravagant gifts, such as jewelry or other luxury items;
• Travel arrangements to attend an entertainment event; and
• Anything with value above the local pre-set limit.

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We ensure that there is no appearance of improper influence when providing gifts or entertainment to others. If you have any question about the appropriateness of a gift or entertainment, contact a Business Ethics Officer. 

All transactions with government officials must be properly documented and approved by Government Relations and the Business Ethics Office.

Avoiding bribery and corruption

It is illegal for any of our businesses to engage in bribery. 

We do business on the merits of our services and not based on any form of bribery or unethical business practice. The bribery of any individual, government official or otherwise, is a serious matter which can lead to criminal sanctions and financial penalties against our Company and individual employees.

You must never give anything of value to any individual government official, including employees of companies in which a government has an ownership interest, without first consulting Government Relations. 

This includes payments, services, or in-kind value made in order to:

• Get or keep business;
• Obtain a license or permit;
• Influence a customs, tax or other administrative decision; or
• Avoid the enforcement of any laws that may apply to our Company.

Consult immediately with Legal when asked to make such a payment.

Remember that we may also be held responsible for the acts of our subsidiaries, joint ventures, partners, agents and representatives. We must know our business partners and be aware of any affiliations with government officials. Before moving forward, consult with our Legal department to help review contracts and ensure that we know our agents and are comfortable with the way they do business. 

To minimize our risk, you need to appropriately document any commission or finder’s fee arrangements with a legal contract that reflects industry rates and practices.

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A bribe can be anything of value, including meals and entertainment. Consult our Anti-Corruption Standard for more information. You should always check with a Business Ethics Officer or Government Relations with questions about whether entertainment events or other expenses for government officials are permissible. If you give a permitted gift or provide entertainment to a government official, you must report it immediately to Government Relations for tracking and reporting.

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Competing fairly

We compete fiercely, but fairly, and in compliance with antitrust, competition and other applicable laws aimed at promoting free and open competition.

You must be open and honest in all your dealings with eBay business partners, and you must never mislead or deceive anyone or engage in any other form of unfair business practice.

Competition laws are designed to protect consumers so that they can obtain the highest quality goods and services at the lowest prices. We take care to avoid even the appearance of agreeing with a competitor to limit competition. You must avoid speaking with competitors about:

• Agreements to divide customers, markets, territories or countries;
• Fixing pricing or pricing policies;
• Noncompetitive hiring agreements;
• Marketing or strategic plans; and
• Boycotting competitors, suppliers or customers.

Antitrust and competition laws are complex and violations may carry severe consequences for the individuals involved and the Company. So it’s important to get guidance from Legal about the relevant laws and our policies.

Collecting competitive intelligence

We gather information about eBay’s markets, including information about our competitors and their products and services, to advance our business. But we always gather such information openly and honestly, from public sources, and never through misrepresentation, spying, or other illegal or unethical means. Similarly, you should never ask job applicants or new employees to divulge the confidential information of current or former employers.

Respecting the intellectual property of others

We respect the trademarks, copyrights and patents of others and do not infringe on their intellectual property rights.

Our obligations of confidentiality extend to third parties who share their confidential information with us. In particular, we are careful to always obtain permission to reproduce or distribute books, articles, software or other copyrighted material.

Legal can assist with obtaining the necessary rights.

We protect the confidentiality of trade secrets–ours, and those of our business partners, competitors and other third parties. For more information, visit our Intellectual Property site on the Hub.

Contributing to our community

We believe in creating opportunity and making a difference in the world. We develop meaningful connections through our involvement with civic, charitable and philanthropic organizations.

You should carefully examine any requests to the Company for charitable donations and obtain the necessary approvals for corporate charitable gifts under the Charitable Giving Standard. You should seek proper approval before acting as an eBay representative at any community event, donating eBay funds or making contributions in the name of eBay.

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The eBay Foundation enriches and empowers communities by connecting people to opportunities and resources. The Global Impact Team program promotes and manages our individual charitable giving and volunteerism in the communities around the world where we have business operations.

Stewarding our environment

We view ourselves as environmental stewards. We have a responsibility and a commitment to minimize our direct and indirect impact on natural resources. As such, we promote sustainable commerce, implement green business practices within our operations and support environmental causes through volunteering and philanthropy.

We comply with applicable environmental laws and eBay environmental policies. Our respect for the environment guides us to conserve and protect natural resources and manage our energy usage.

The eBay Global Impact Team encourages and empowers individuals to buy, sell and think green every day.

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Safeguarding our marketplace

We are committed to operating a community marketplace and we should take all reasonable measures to discourage and remove illegal content. If you come across suspicious activities, including listings and transactions that involve illegal items, you should contact Legal and/or Global Asset Protection directly.

Managing Company assets and information

We work together to protect eBay property and information.

Use of Company assets

We are the guardians of eBay assets. We use eBay assets, whether money, physical or intellectual property, only for ethical and legal purposes that benefit eBay and its stockholders. We spend money only in accordance with our Finance Policies.

eBay provides us with access to Company systems and electronic facilities to achieve our business objectives. In turn, it is our responsibility to protect these systems and facilities by using them for appropriate business purposes.

We do not use Company systems for personal activities that interfere with the operation of the network or that generate costs to eBay. We never use Company property to engage in outside commercial activities, illegal activities (including illegal software downloads) or other activities that could reflect negatively on eBay.

We recognize that the Company may access any information stored on eBay computers and systems for legitimate business purposes, as allowed by law.

Return of Company property

We are responsible for all Company property or documents issued to us. We return all such property and documents immediately upon request or upon termination of employment.

Confidential and proprietary information

eBay intellectual property and trade secrets represent significant, strategic investments that are critical to our Company’s success. These assets set us apart from our competitors and include:

• Confidential information about eBay, our affiliates, suppliers, customers and employees;
• Personal data of users, such as contact information, financial data or other sensitive information, whose use is governed by our Privacy Program and Personal Data Lifecycle Standard; and
• Our copyrights, trademarks and patents.

To safeguard these assets, we never disclose our confidential information or trade secrets to anyone who does not have a business reason to have the information. We do not disclose such information to others outside the Company without management approval, and we use a non-disclosure agreement or other confidentiality provisions approved by Legal to protect the Company’s interests.

Our agreements

When you began your employment, you were required to sign (among other documents) eBay Employee Proprietary Information and Inventions Agreement, the Information Security Policy and the Corporate Privacy Policy. These agreements give you much more detail about your obligations with respect to Confidential and Proprietary Information.

We all need to work together to safeguard confidential information—our business success depends on it.

Securing our data

Protecting the privacy of our customers and employees is one major reason why they entrust us with their sensitive personal information. Many of us have access to personal data, including contact details, financial accounts and other sensitive information. We keep this information safe and use it only for legitimate business purposes, and always in accordance with our applicable privacy policy. We never share personal data with a third party or any colleague who doesn’t have a business need to know.

To learn more about handling personal information, consult Legal or visit Data Protection/Privacy.

eBay has established a Global Privacy Standard which has been approved by our privacy regulators that governs customer data. Our employees are required to follow these “Binding Corporate Rules,” whenever handling customer data.

For more information on privacy, consult Legal, the Privacy Policy Library and the Binding Corporate Rules.

We take seriously our responsibility to safeguard the privacy of user and employee information entrusted to us.

Following trade laws

Many governments have established trade controls limiting the export and import of certain goods and technology, as well as restricting trade or other interactions with countries or persons who may be sanctioned (in which case we are not permitted to do business with them) because they are involved with terrorism or narcotics trafficking. We comply with laws governing our cross-border businesses. Talk with Legal when dealing with international trade issues.

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Trade control laws are complex and subject to change. You should always check with Legal before:

• Shipping encryption technology and other sophisticated software or restricted items to a foreign country; and
• Engaging in any transaction that may involve a sanctioned country or a prohibited party.

Additionally, you should tell Legal about any request to participate in a boycott against other persons, companies or countries, or any request to furnish information about our relationships with any boycotted person or country.

Preventing money laundering

It is critical that we prevent our systems from being used for illegal activities such as money laundering and illicit transactions.

Money laundering is a crime in which the proceeds of criminal activity are moved through a series of financial transactions designed to disguise the true source of funds.

The following situations may be indications of potential money laundering:

• Attempts to make large payments in cash;
• Payments by someone who is not a party to the transaction;
• Requests to pay more than provided for in the contract;
• Transactions forming an unusual pattern such as bulk purchases of products or gift cards, or many repetitive cash payments; and
• Payments that are substantially higher than the perceived value of an item.

If you suspect that an eBay service or product is being used to launder funds, you are legally obligated to report the matter to your manager.

Please speak with your manager or contact the Office of Ethics and Compliance if you have any questions.

Marketing and advertising honestly

Every claim in our advertisements and marketing materials must be accurate, objective and verifiable.

This means that we must research and document our claims prior to publication. Laws governing comparative advertising, including pricing, vary from country to country, so it’s important to obtain guidance from Legal when making such claims to ensure that we comply with applicable laws.

Making false or misleading claims contradicts Our Beliefs. Legal can provide guidance if you are unsure whether something is false or misleading.
 

Making public statements and endorsements

We speak with one voice when communicating about eBay to the media, financial analysts or investors.

Inaccurate statements can create serious risks for the Company, including claims of false advertising, misrepresentation, breach of contract, securities fraud and antitrust violations.

All public statements and endorsements or information about eBay, our products or our business prospects must be coordinated and approved in advance with Corporate Communications. Information or questions related to the Company’s financial performance must be directed to Investor Relations.

In dealing with the news media, whether by phone, email, over the Internet or in person, you must follow these guidelines:

• Always direct any reporter or member of the media to the eBay Public Relations (PR) team at press@ebay.com;
• Unless already designated as a corporate spokesperson, do not accept a media interview without prior approval from Corporate Communications;
• If approached by a reporter, assume you are on the record and what you say can be used in a story;
• If a reporter is pushing for a response on a subject that you don’t know about, it’s okay to say: “This isn’t my area of expertise, but I’m happy to put you in touch with someone from Corporate Communications.”;
• Do not disclose proprietary information regarding future products/features, internal policies or other information to the media or our customers; and
• Be friendly and courteous at all times.
  
  

Posting on social media

We recognize that social media is an important way for people to communicate and share information and ideas. Many of us keep personal social media accounts that sometimes mention our work interests, observations and activities. We believe that thoughtfully written posts on appropriate subjects can be a great vehicle for communicating our passion, knowledge, and innovative spirit to our user communities and the outside world.

When you participate in social media and discuss your work at eBay or our business, you must: 

• Be clear that you are an eBay employee, but that you speak for yourself;
• Check your facts;
• Be respectful of others;
• Use your best judgment;
• Understand our blogging and social networking communities;
• Critique, but steer clear of personal criticism; and
• Ask yourself if your posts reflect Our Beliefs.

You must abide by all eBay policies when posting information online, particularly when discussing or referencing eBay or our industry. Never disclose any information that is proprietary or confidential to eBay. If you would like to create and contribute to a Company-sponsored blog or social media post, please contact Corporate Communications for approval. Blogs and posts may generate media or analyst attention. You must refer any questions from the media, the investment community or the government to Corporate Communications, Investor Relations or Legal.

To learn more, please see our Social Media Standard and Social Media Guidelines.

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Embracing our diversity

We recognize and respect everyone as a unique individual.

Our diversity of people and ideas makes us great.

We are committed to treating each other in a fair, respectful and honest manner in all interactions in the workplace.

Good communication is a key to successful teamwork. Good communication includes being respectful and professional, even when we disagree.

We pride ourselves in having a diverse and inclusive workplace where each employee is expected to treat others with dignity, courtesy and respect. We do not tolerate discrimination.

At eBay, we practice good judgment by making decisions that are right for our Company, our communities and each other. We begin by hiring, promoting and compensating employees based on their ability to perform their job responsibilities, without regard to age, race, color, national origin, physical or mental disability, gender, religion, sexual orientation, gender identity, gender expression, marital or veteran status, condition of pregnancy, genetic information or any other legally protected characteristic.

Leading our teams

Managers lead by example by demonstrating a commitment to Our Beliefs every day and ensuring that employees feel comfortable asking for help and raising concerns.

Managers are responsible for acting quickly if there is a violation of the law or the Code. If an employee reports a suspected violation, managers must be responsive to employee concerns, taking action when it is appropriate, and seeking help when needed. Everyone is encouraged to speak out and report concerns in good faith without fear of retaliation.

Here are some specific ways that you, as a manager, can fulfill these obligations:

Promote an ethical culture through personal leadership:

• Demonstrate the highest ethical standards and quality in your work every day and expect the same from the people who report to you.
• Innovate boldly and Deliver with impact, but never give others the impression that it is acceptable to ignore our Code or policies.
• Do not create or tolerate an environment where staff members feel pressured to bend the rules.

Prevent and report problems:

• Make sure the members of your team have taken their training and know the rules.
• Be proactive and take steps to prevent problems before they happen.
• Always act to stop violations of the Code or the law by those you supervise.
• Respond to staff members who raise concerns in a way that makes them feel secure and at ease sharing their issues.
• Be responsible for reporting violations you suspect or that others share with you.
• Seek guidance from a Business Ethics Officer, People Central or the Integrity Helpline if you are unsure about what is the right thing to do.

Prevent retaliation:

• Never engage in retaliatory behavior.
  
  

Preventing harassment in our workplaces

We strive to create a work environment free of discrimination and harassment. We don’t tolerate bullying, abuse or any behavior that creates a hostile work environment. No matter what form harassment takes–whether physical, sexual, verbal or non-verbal, in person, via email, text or tweet, over the phone or on the Internet–it is unacceptable.

Harassment can involve sexual conduct or references to a personal characteristic. Examples include racial slurs, off-color jokes and unwelcomed sexual advances or other physical contact. Harassment can occur between members of the same sex or the opposite sex; between vendors, contractors or employees; and in the office or at off-site events.

Speak up if you suspect discrimination, harassment or other inappropriate workplace behaviors. By providing this information to a manager, People Central, Legal, or by contacting the Integrity Helpline, you help ensure these matters are addressed quickly and promote the integrity of our workplace.

eBay investigates all reports of harassment and keeps these reports confidential to the extent possible.

Keeping our people safe

We all share responsibility for ensuring that eBay is a safe and secure place to work. We should be aware of our surroundings and participate in emergency preparedness and business-continuity planning. We all must follow posted safety procedures and comply with all Company policies and applicable laws. We report injuries and unsafe conditions in a timely manner to our manager, Workplace Resources or the Global Safety & Security Team.

We don’t tolerate workplace violence of any kind, including intimidation or threats. Not at all. Ever. If you see threatening behavior, speak up immediately.

Safety and security

The Global Safety & Security Team monitors the eBay premises and is your resource for health, safety, security, emergency preparedness and global travel safety. Please contact them if you have any concerns about physical safety, security or hazards at any eBay location.

Please consult Safety and Security on the Hub for more information relating to these topics and for local contacts & site-specific information.

Get to know the specific procedures before an emergency happens.

We are committed to preserving the safety and security of our employees. It’s up to all of us to make eBay a safe place to work.

Being responsible about drugs and alcohol

eBay is a drug-free workplace.

While at work or while attending business-related activities on or off the Company premises, you are strictly prohibited from manufacturing, possessing, storing, distributing, transferring, purchasing, selling, using or being under the influence of illegal drugs.

From time to time, the Company may sponsor events where alcohol is served. You are always expected to drink responsibly at Company-sponsored events or choose not to consume alcohol.

If you need assistance with a drug or alcohol problem, please contact our Employee Assistance Program. Outside the United States, please contact People Central for resources available to you. To learn more, see our Substance Abuse Standard.

Respecting and supporting outside causes

To ensure we respect employees’ diverse viewpoints, to and provide a harmonious work environment, we limit solicitation and distribution of materials on eBay property.

This means you should not broadly solicit or support non-approved causes or organizations on Company properties or use eBay resources. This includes distributing any non-approved material during work, or using our workspaces or eBay corporate email network for non-approved material.

In particular, managers should not ask their employees to contribute to charitable causes to avoid creating a sense of obligation. Employees wishing to make grants or donations to any non-profit organization on behalf of eBay must follow the Company’s Charitable Giving Standard.

To learn more, see our Charitable Giving Standard or the Contributing to Our Community topic in the Code.

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Protecting against conflicts of interest

Always act in the best interests of eBay and the eBay community, and don’t let your personal interests conflict–or appear to conflict–with the Company’s interests.

Even the appearance of a conflict of interest can hurt the Company’s business and reputation. An appearance of a conflict happens when you are perceived to be influenced by your personal interests when making decisions in your eBay role. For example, if you have a personal or financial relationship with an eBay vendor, it might appear to others that you are giving the vendor preferential treatment–even if you don’t.

Conflicts of interest can arise in many situations. The best rule for any conflict situation is to disclose and recuse: disclose the conflict through our formal process and recuse yourself from making any decisions that might be affected by the conflict. Your manager and a Business Ethics Officer can provide guidance to resolve the issue.

Navigating investments and business relationships

Avoid any outside business relationship that might influence, or appear to influence, decisions you make on behalf of eBay.

Disclose to your manager and a Business Ethics Officer any investment or other interest you or any member of your household has in a competitor, customer or supplier of eBay, if an investment or interest:

• Is significant enough, either in absolute value or in relation to your net worth, that it could cause a conflict or the appearance of one; or
• Affects your judgment or causes you to be influenced by considerations of personal gain or benefit.

In our ever-changing business environment, it is sometimes difficult to say whether a particular company is a customer, supplier or competitor. A Business Ethics Officer can help you make this determination. In cases where conflicts cannot be effectively managed, you may need to divest some or all of your personal investments or abstain from working with these companies on behalf of eBay.

Everyone is encouraged to buy and sell on our platform and to use our services, but written approval from our CEO is required to participate in any joint venture, partnership or other business arrangement with eBay or any of its subsidiaries.

In the event that a potential arrangement would involve an Executive Officer or member of the Board of Directors of eBay, the Company will follow the requirements of its Related-Person Transaction Policy. Members of the Board of Directors must recuse themselves from making any decision involving companies in which they have any direct and material financial interest.

Mixing Business and Personal Relationships

We take special care to ensure that our family and personal relationships do not interfere with our responsibilities to eBay as these relationships can trigger conflicts of interest.

You should not directly or indirectly supervise, or use influence to favor, anyone with whom you have a family or close personal relationship, including spouses or romantic partners, grandparents, parents, siblings, children, grandchildren, uncles, aunts, first cousins, nieces, or nephews.

In certain circumstances, and at the Company’s discretion, it may be necessary to reassign someone to avoid an actual or potential conflict of interest or take other steps required to maintain a harmonious and productive work environment.

Interviewing, hiring or engaging a family member or close personal friend as an employee, consultant or business partner creates a conflict of interest. You must disclose any such relationship and recuse yourself completely from the decision-making process. You also must disclose to your manager and Business Ethics Officer any situation where you may be conducting business on behalf of eBay with a company that employs a family member or close personal friend, and avoid participating in any eBay decisions relating to that company. This also applies if a family member holds a senior position with an eBay competitor.

Interviewing, hiring or engaging a family member or close personal friend as an employee, consultant or business partner creates a conflict of interest. You must disclose any such relationship and recuse yourself completely from the decision-making process. You also must disclose to your manager and Business Ethics Officer any situation where you may be conducting business on behalf of eBay with a company that employs a family member or close personal friend, and avoid participating in any eBay decisions relating to that company.

You should disclose to your manager and a Business Ethics Officer if someone with whom you have a close family or personal relationship holds a senior position with a competitor or supplier.

Avoiding conflicts of interest

You should speak up and tell your manager or a Business Ethics Officer when you become aware of a work relationship that might create a conflict of interest. In some cases, it may be necessary to reassign someone or take other steps to avoid an actual or potential conflict of interest.

Holding outside employment

You must avoid outside employment or business ventures that compete with eBay, or that could interfere with your obligations to eBay. Similarly, do not expect that the Company or any of its subsidiaries will enter into a contract with you outside of your employment relationship. You must obtain approval from your manager and a Business Ethics Officer before engaging in outside employment.

Serving on boards and advisory boards

You should obtain the approval of your manager and a Business Ethics Officer before serving on a board or in an advisory position of any for-profit organization, or any outside paid position. Sitting on the board of a non-profit, governmental body, educational or residential board may require prior approval if there might be a conflict with the time commitment of the outside position and your eBay role, or with the Company’s business.

Participating in industry associations

You may join industry or trade associations with the approval of your manager and a Business Ethics Officer. However, you must ensure any related activities are consistent with the Company’s interests and comply with applicable laws. Contact Legal or Government Relations if you have any questions.
 

Pursuing corporate opportunities

We have an obligation to advance eBay’s interests when we discover opportunities that could help the Company. You should never use your knowledge of the Company’s activities for personal benefit, such as taking a financial interest in a company or property of current interest to eBay. If you learn of a personal business or investment opportunity through your position at eBay, you must disclose it to a Business Ethics Officer and obtain formal approval before participating in the opportunity.

We don’t compete with eBay–we work together to be a successful company.
 

Participating in political activities

Each of us is encouraged to participate in the political process, engage in political activities and make political contributions. However, before speaking or contributing on behalf of eBay you should first obtain the approval of Government Relations. Likewise, if you participate in any political activity that could appear as if you are acting or speaking for eBay, you should always make it clear that your views and actions are your own and do not imply eBay’s support or endorsement.

Other than participation in the Company’s Political Action Committee, keep any personal political contributions and activities separate from eBay. You must be careful to use your own time and assets, and not those of eBay, for any personal political contributions or activities, and never contribute eBay resources to support any political candidate, party or cause without the prior approval of Government Relations.

Interacting with the government

Information requests from government officials are often time-sensitive and confidential. It’s important to refer these inquiries to Legal for response as soon as possible.

Lobbying is a legitimate way to educate lawmakers and government regulators on behalf of our Company. We comply with all applicable laws when engaging in lobbying. Unless Government Relations has authorized you to lobby on behalf of the Company, you should avoid doing so.

In some countries, lobbying is broadly defined and highly regulated. What might be culturally acceptable and legal in one country could be illegal in another. If you need to meet with regulators, lawmakers or government administrators to discuss our business, you should first contact Government Relations.

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Following our Code and getting help

This Code applies to all employees, officers, and Board of Directors of eBay and its subsidiaries. Contractors, consultants and others working on our behalf must also follow the Code.

Should you have any questions, concerns about the eBay Code of Business Conduct and Ethics, applications of these policies or any other issues, please utilize one of our many resources:

• Your manager;
• An eBay Business Ethics Officer;
• People Central (Human Resources);
• Legal;
• Office of Ethics & Compliance FAQs;
• askethics@ebay.com; or

To submit an anonymous inquiry, call the eBay Integrity Helpline at 844-945-0216.

(if you are outside North America, visit the Integrity Helpline website for global phone numbers).

For more information, type “go/ethics” into your web browser address bar to be taken to the Office of Ethics & Compliance site on the Hub.

Investigating Code violations

We investigate reports of observed or suspected Code violations promptly, thoroughly and in accordance with our legal obligations. Confidentiality is maintained to the fullest extent possible. We are all obliged to cooperate with investigations and provide complete, accurate and truthful information. Cooperation includes retaining all documents and electronic communications such as emails, messaging, and chats relevant to the investigation.

The Office of Ethics & Compliance and their delegates investigate and resolve the issues associated with suspected violations.

Preventing retaliation

We will not retaliate and we will not tolerate retaliation of any kind against anyone who, in good faith, makes a report or cooperates in an investigation.

The Company will protect from retaliation any employee who raises a concern honestly and in good faith, but it is a violation of the Code to knowingly make a false accusation, lie to investigators, or interfere or refuse to cooperate with a Code investigation.

Disciplining infractions

In order to protect eBay and the eBay community, we take prompt action regarding any conduct that violates the law and/or the Code. We may determine that remedial or disciplinary action is necessary. These actions can include such things as training, coaching, termination or another action appropriate for the situation.

Where there is a potential violation of the law, eBay will cooperate with the appropriate authorities.

Waiving provisions of the Code

Only our Board of Directors may waive a provision of the Code for a Board or Executive Staff member, and we disclose promptly any waiver granted as required by law. Only a Business Ethics Officer may waive a provision of the Code for employees other than Executive Staff members. Contact your manager or a Business Ethics Officer if you have a question about whether a waiver is required.

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