Ethics and compliance Apple is committed to conducting business ethically, honestly, and in full compliance with applicable laws and regulations. Business Conduct and Global Compliance Apple’s Business Conduct Policy provides a guide to our ethical requirements for our employees. This policy includes the principles that guide our business practices — honesty, respect, confidentiality, and compliance. It is available to employees in over 20 languages. Apple expects its suppliers, contractors, consultants, and other business partners to follow these principles when providing goods and services to Apple or acting on our behalf. Apple’s Business Conduct and Global Compliance team focuses on business conduct, political compliance, export and sanctions compliance, health compliance, antitrust compliance, anti-corruption compliance, and third-party compliance. Additional compliance functions are integrated into our business organizations. The Business Conduct and Global Compliance team conducts internal and independent third- party assessments of its programs to ensure that they are effective and meet or exceed best practices. We make changes to our programs, policies, procedures, and training to reflect emerging trends and ensure that the respective compliance programs are aligned with Apple’s business and risk profile. Apple’s Chief Compliance Officer provides regular updates to the Board’s Audit and Finance Committee on the work done by the Business Conduct and Global Compliance team and other compliance functions. Third-party compliance program Apple has a robust third-party compliance program that has been noted as mature and a leading practice by two external parties. The program utilizes a risk calculator that includes factors specific to Apple’s risk profile to determine the level of diligence to conduct on a third party. We also utilize predictive analytics and data visualization through our custom internal tool. This tool also provides a broad range of insights about third parties, including due diligence findings, ongoing monitoring hits, audits, payment reviews, and remediation. Training and resources We take our values seriously, and our training helps guide our employees in making good decisions. All employees are required to take an annual scenario-based online Business Conduct training that is updated each year. Training topics include workplace behaviors, conflicts of interest, gifts, confidentiality, competition, privacy, and Apple’s Human Rights Policy. Our internal Business Conduct website provides additional resources for our employees to learn more about the Business Conduct Policy, including regularly updated FAQs, featured topics, and toolkits for managers. Our Business Conduct Helpline is available for employees to ask questions and report concerns. Additionally, all employees receive mandatory annual or biannual training on Privacy, Respect at Apple, and Inclusion and Diversity. Employees receive between two and five hours of training annually, depending on location and the risks and responsibilities of their role. Additional required and recurring training includes Anti-Corruption, Antitrust, Export and Sanctions, and manager-specific training. Our Board also regularly receives training and updates on ethics and compliance at Apple. Managers get supplementary resources and training on topics such as disability awareness and accommodations, discriminatory behavior, and their responsibilities to receive and report all allegations of misconduct. Apple also trains eligible contractors on our expectations for ethical behavior; topics include workplace behaviors, secrecy, privacy, and important laws. Compliance policies Apple’s ethical business practices are set out in our Business Conduct Policy and additional key compliance policies. We make key compliance policies, including those applicable to our third parties, publicly available on our Ethics and Compliance website . Anti-corruption Apple does not tolerate any form of corruption by Apple employees or by third parties when working with or on behalf of Apple. Apple’s Anti-Corruption Policy details how to comply with global anti-corruption laws. If employees are unsure of the proper course of action, or whether something constitutes corruption, we encourage them to contact Apple’s Business Conduct team. 98% employees completing business conduct training in calendar year 2021 902,000 Apple training courses completed in 2021 432,000 hours spent on Apple-recommended and required trainings in 2021 For more information, see Apple’s Ethics and Compliance website . Appendix Governance Communities Suppliers Customers Our People Environment Introduction Apple’s 2022 ESG Report 71