BRIBERY AND CORRUPTION The rule is simple: Don’t bribe anybody, anytime, for any reason WHAT IF...? We do not offer, promise, give or accept money or anything of value to or from third parties to get an improper business advantage. Any of these actions constitutes a bribe. Anti-bribery laws apply in every country where Nike does business. Criminal penalties to you and Nike for violating these laws are severe. There is no monetary threshold, so even a small or minor improper gift or donation could be construed as a bribe. Maintain accurate and transparent books and records, so all payments can be honestly described and documented. We take particular care when working with or evaluating prospective third parties, including agents who may interact with government officials or business partners on behalf of Nike. We don’t use them to do anything that is prohibited by law, our Code or Nike policies. I know someone who works in the Department of Customs. This person asked if I would be willing to hire their relative as an intern for the summer even though I know they aren’t qualified. Would it be OK if I offer the relative a position or recommend them to another department for a position? No. All decisions relating to hiring should be approved by Talent Acquisition. Offering the official’s relative a position or ensuring they receive special consideration in the hiring process could be considered a form of bribery. Please direct all requests for employment or internships to Talent Acquisition or reach out to Human Resources or the Ethics & Compliance Office for help. We are in the middle of negotiating a big contract with a potential vendor. The vendor just gave me NBA courtside tickets. Is it OK to accept the tickets? Probably not. Accepting anything of value – including event tickets, gifts, excessive meals or hospitality – from a vendor while negotiating a contract with them creates a potential conflict of interest and could also violate our policy on gifts, hospitality and other payments. Discuss with your manager to determine the best course of action to take. LEARN MORE  Policy on Anti-bribery and Anti-corruption  Policy on Government Official Expenses and Gifts  Policy on Gifts, Hospitality and Other Payments  Policy on Comp Product 17