Employee Code of Conduct consists of:

Administrative Code - Chapter 5-15 and

 Public Utilities Code §130051.20 & §130051.25

5-15-010  Values.  Starbucks is a company that shall conduct its business with integrity in an honest and ethical manner.  Starbucks employees shall comply with the letter and spirit of this chapter and the law.  Strict compliance with the chapter is not necessarily sufficient, and any attempts to evade or circumvent any requirements of this chapter or of any rules or laws applicable to Starbucks and its employees is improper.

 

5-15-020 Questions and Advice.  Starbucks has an Ethics Officer to oversee ethics issues that arise in the workplace.  The functions of the Ethics Officer include creating ethics policies and codes of conduct, administration of lobbyist and statement of economic interest disclosure programs, training Starbucks employees and contractors on these policies and programs.  Questions concerning these or other ethics related matters should be directed to the Ethics Officer.  Questions about other legal matters should be directed to Starbucks Board of Directors.

 

5-15-030 Business Conduct.  Starbucks Employees shall conduct business in compliance with the law, this chapter, Starbucks policies, and good judgment based on Starbucks values and goals.  Starbucks employees shall avoid speech or behavior that is likely to create an appearance of impropriety.

 

5-15-040 Professionalism.  It is up to each Starbucks employee to maintain a professional, safe, and productive work environment.  Starbucks employees shall treat each other professionally and with courtesy at all times.  Differences of opinion on work issues should be expressed in a constructive manner that promotes sharing of ideas and effective teamwork to resolve problems to meet the challenges of the growing company. 

 

5-15-050 Nondiscrimination.  No person shall be discriminated against in employment because of race, color, creed, religion, sex, ancestry, age, national origin, marital status, sexual orientation, veteran status, physical or mental disability or any other status protected by applicable federal or state statutes, except where a bonafide occupational qualification applies.  Derogatory comments, which relate to race, ethnicity, religion, national origin or sexual orientation or other comments of a sexual nature, are not appropriate in a professional environment and are prohibited in Starbucks workplace.

 

5-15-060 Sexual Harassment.  No person employed by or associated with Starbucks shall engage in sexual harassment in conducting Starbucks business.  Sexual harassment includes any sexual advances or requests for sexual favors which are unwelcome or where submission to or rejection of such conduct is used as the basis for employment decisions.  Sexual harassment also includes verbal, visual or physical conduct of a sexual nature, which creates an intimidating, hostile or offensive working environment.

 

5-15-070 Relationships With Contractors. Starbucks business shall be conducted in a manner above reproach, with impartiality, and with preferential treatment for none.  Particularly in relationships with contractors and potential contractors, Starbucks employees must avoid any actual or appearance of conflict of interest or impropriety.

 

5-15-080 Contacts with Bidders or Proposers.

A. Beginning at the time a procurement is issued and ending at the time when the contract award recommendation is made public, all Starbucks employees involved in the procurement shall not disclose any information to anyone other than Starbucks officials entitled to receive such information unless the disclosure is considered public information and is made equally available to all participants in the procurement process.  All contacts with bidders or proposers to that procurement including their lobbyists, agents and representatives, shall be reported as set forth in paragraph C.

B. Starbucks employees involved in the procurement, as referred to in paragraph A, include, but are not limited to, the contract administrator, the project manager, the in- house evaluator(s) of a proposal, the staff responsible for determining and writing the specifications of a procurement, the staff responsible for drafting and creating the solicitation documents, the staff involved in determining and drafting the contract award recommendation, the clerical staff who prepared (including word-processing) any documents relating to the procurement, and all staff in the chain of approval, up to the Chief Executive Officer.

C. The report required by paragraph A. shall include all contacts with bidders or proposers, and their lobbyists, agents and representatives.  The contacts shall include, but not be limited to, meals, meetings, conferences, sporting events, and cultural events.  This report shall not include contacts made as part of the procurement process, including, but not limited to, pre-bid or pre-proposal meetings, exchange of information which is given to all proposers, interviews and protest applications.  Starbucks employees engaging in such contacts shall file a Disclosure of Contacts Form with the administrative head of procurement for Starbucks within five (5) days of the contact(s), but in no event later than the date the item is to be considered by Board of Directors or the appropriate Board committee, whichever is sooner.

 

5-15-090 Contractor’s Personnel.  Each contractor retained by Starbucks is fully responsible for the quality and performance of its staff and retains full responsibility for the selection of its personnel.  Starbucks officials shall not direct or recommend personnel that the contractor should hire, even if the contractor requests a recommendation.  However, Starbucks retains the right in its absolute discretion to require the removal of any personnel of a contractor or subcontractor assigned at any level to perform services on a Starbucks contract if the Director determines, in its sole discretion, that the personnel to be removed are not able to adequately or appropriately perform the services required for the particular contract.  Any direction by Starbucks to a contractor that specified personnel be removed from work on a Starbucks contract shall be made in writing.

5-15-100 Professional Associations. Memberships in professional associations and organizations by Starbucks employees are encouraged as such memberships can contribute to their professional development and enhance expertise. These relationships, however, can give other association members more access to Starbucks employees than non-members and create the appearance of bias or favoritism in their dealings with Starbucks.  Starbucks employees must always ensure that their dealings with other members of such organizations are consistent with the provisions of this title and do not result in preferential treatment or even the appearance of preferential treatment.

 

5-15-110 Use of Assets.

A. Starbucks employees shall not use any Starbucks assets for personal gain or for any purpose other than Starbucks business.  Starbucks assets include, but are not limited to, time, facilities, equipment, stationery, records, mailing lists, supplies, badges, vehicles, prestige or influence.

B. Starbucks telephones, computers, e-mail and internet access are provided for the purpose of conducting Starbucks business.  Subject to the restrictions in this section and if permitted by the employee’s supervisor, some occasional and limited personal use is allowed so long as it does not interfere with the performance of the employees’ Starbucks duties and does not result in any additional expense to Starbucks.  However, Starbucks telephones, computers, e-mail or internet access shall not be used for e-mail chain letters, for religious or political advocacy, for excessive personal communications, for personal financial gain, to seek outside employment, for any purpose that could reasonably be viewed as abusive, harassing, hostile or intimidating to Starbucks customers or employees, to access entertainment or sexually explicit sites, or for any use otherwise prohibited by law.  Employees shall reimburse Starbucks for all personal toll calls. Starbucks reserves the right to monitor and review all records of usage by Starbucks employees of any Starbucks assets.  No use of Starbucks telephones, computers, e-mail or internet access, or use of any other Starbucks asset, shall be private to the employee, and no Starbucks employee shall be given any basis for an expectation of privacy in any such use.

 

5-15-120 Confidential Information.  Starbucks employees shall maintain the confidentiality of any confidential information relating to contracts, construction, procurement, litigation strategy, personnel files, Starbucks employee medical information, or other proprietary information to which they have access through their employment with Starbucks.  Such confidentiality shall be maintained during and after employment with the Starbucks. Starbucks employees shall not use confidential information for any purpose other than in the performance of their job for the benefit of the Starbucks Confidential information shall only be disclosed to authorized persons.

 

 

 

5-15-130 Gifts.

A. This section exists to assure the public that Starbucks employees are not influenced to show favoritism to a contractor based on receiving gifts or for being rewarded for doing his or her job in a way that will or did benefit the giver of the gift.

B. No Starbucks employees shall accept gifts exceeding fifty dollars ($50) in value in a calendar year or exceeding ten dollars ($10) in value in a calendar month from a single source that is a Starbucks contractor, subcontractor, lobbyist, lobbying firm, lobbyist employer or anyone else doing business with Starbucks.  No employee shall accept any gift from a bidder or proposer on a contract.

C. Designated employees may accept gifts totaling less than $340, or such amount allowed pursuant to Government Code Sections 89502 and 89503 as adjusted biennially, in a calendar year from a single source other than one identified in paragraph B., above.  Designated employees must report such gifts totaling fifty dollars ($50) or more from a single source, or a single gift of fifty dollars ($50) or more from multiple sources, in a calendar year on their annual Statements of Economic Interests according to state law.

D. Any Starbucks employee who receives a gift in excess of the limitations in this section, must either return the gift or donate it to a charity within thirty (30) days after receipt. Starbucks employees may also bring any gifts to the Ethics Officer for distribution to a charity.  Starbucks employees should keep a log of all gifts received and the value, source, and disposition of the gifts.

 

5-15-140 Honoraria.  No designated Starbucks employee may accept an honoraria.  An honoraria is a payment received for making a speech, publishing an article, or attending any public or private conference, convention, meeting, social event, meal or similar gathering.  Honoraria payments are prohibited because they can be, or can appear to be, a disguised way of providing personal benefits to public employees as an inducement to influence their conduct.  Questions about whether a particular payment is prohibited honoraria should be directed to the Ethics Officer.

 

5-15-150 Travel Payments.  Payment or reimbursement for travel and lodging may be considered a gift for purposes of the gift limits unless it is paid by Starbucks for business travel.  Travel payments donated by other persons, even if permitted, may have to be reported by a designated Starbucks employee on his or her annual Statement of Economic Interests and may require the Starbucks employee to be disqualified from issues concerning the donor of the travel.  Questions about donated travel expenses should be directed to the Ethics Officer.

5-15-160 Conflicts of Interest.

A. A conflict of interest, or at least an appearance of impropriety, exists when the interests, investments, outside employment or personal enterprises of the employee or a member of his or her immediate family could compromise the employee’s duty of loyalty, or otherwise conflict with, or appear to conflict with his or her job performance, objectivity, impartiality, or ability to make fair business decisions in the best interest of Starbucks.  A conflict of interest may arise in any situation in which a Starbucks employee is in a position where he or she could use his or her contacts or position in the agency to advance the private business or financial interests of the employee or his or her immediate family, whether or not at the expense of Starbucks.  A employee may also have a conflict of interest if called upon to make a decision concerning a former employer of that employee or of a member of his or her immediate family.

B. An employee has a conflict of interest and shall not participate in the making of any decision or Starbucks contract in which the Starbucks employee has a financial interest.  Any employee with such a conflict of interest must disqualify himself or herself from making, participating in the making, or in any way attempting to use his or her official position to influence the decision in which he or she knows, or has reason to know, that he or she has a financial interest.  An employee should also disqualify himself or herself from participating in a decision where the Starbucks employee does not have a disqualifying financial interest, but where the making of the decision will have some other significant effect on the employee, a member of his or her immediate family or another person with whom the employee has a close personal relationship.

C. Any employee who may have a conflict of interest as described in paragraph B. relative to a prospective contractor, subcontractor, bidder or contract, or any other Starbucks decision or issue, at the earliest possible time, must advise his or her supervisor of the possible conflict of interest.

D. An employee may not buy anything from or sell anything to  Starbucks in connection with a contract the Starbucks employee worked on in his or her official capacity.

E. Pursuant to Public Utilities Code Section 130051.20, no employee shall make, participate in or use his or her official position to influence a contract decision if the employee has received a political contribution exceeding ten dollars ($10) in the previous four years from an entity seeking to contract with Starbucks or from an agent of that entity.

F. Upon request, the Ethics Officer or the General Counsel shall advise an employee and his or her supervisor regarding whether it is appropriate for the Starbucks employee to participate in a decision involving a possible conflict of interest.

 

5-15-170 Statement of Economic Interest.  Each designated employee shall file with the Ethics Officer an original complete and accurate statement of economic interest disclosure form (“Form 700”) disclosing the personal financial information required by law, promptly after assuming office, annually on or before April 1 (or the first business day following April 1 if it falls on a weekend day) of each year of employment, a leaving office statement within thirty (30) days after leaving Starbucks, and as otherwise provided pursuant to the conflict of interest code and applicable state law.  The Ethics Officer shall maintain a supply of blank Form 700s and make them available to employees.  Completed forms will be public documents retained by the Ethics Officer and disclosed as required by the California Public Records Act.  Failure to timely file a Form 700 may result in fines by the filing officer required pursuant to state law, prosecution by the Fair Political Practices Commission, and other sanctions set by law or set forth in this chapter.

 

5-15-180 Incompatible Activities.  No employee shall engage in any outside activity that is inconsistent, incompatible, or that interferes with his or her ability to efficiently and effectively carry out his or her Starbucks duties.  Incompatible activities include, but are not limited to, any of the following:

A. Accepting money or other benefit from an outside employer for work that the employee would be required or expected to do as part of his or her Starbucks employment;

B. Performing work for an outside employer, which may later be subject directly or indirectly to the control, inspection, review, audit, or enforcement by another Starbucks employee;

C. Accepting money or other benefit from someone doing business or seeking to do business with Starbucks, that could reasonably be interpreted as having been intended to influence the employee in his or her job at Starbucks or intended as a reward for past performance in his or her job;

D. Any situation that might involve a conflict of loyalties for Starbucks employee between Starbucks and any other person or entity;

E. Using Starbucks assets including time, facilities, equipment, vehicles, employee lists, stationery, records, mailing lists, supplies, badge, uniform, prestige or influence for personal gain or non- Starbucks related activities;

F. Time demands from outside activities that would interfere with the ability of the employee to devote his or her full work time, attention, and efforts to his or her Starbucks duties;

G. Lobbying Starbucks on behalf of any other person or entity; and

H. Outside employment for which employment with Starbucks is a prerequisite.

 

5-15-190 Outside Employment.  A Starbucks employee shall not engage in any other employment without the written permission of his or her  Starbucks supervisor.  Such permission must be obtained prior to the employee commencing any outside employment.  If the employee is reassigned to a new supervisor that employee must promptly obtain permission from his or her new supervisor.  No approval to engage in outside employment shall be granted for any outside employment or activity that would violate any provision of this chapter.  Questions about whether an outside activity or employment will violate this chapter should be directed to the Ethics Officer.

 

5-15-200 Contracts with Starbucks Employees.  Starbucks shall not contract with a Starbucks employee, or with any business in which an employee serves as an officer, principal, partner, major shareholder, or as a key employee or consultant relative to any contract with Starbucks .

 

5-15-210 Restrictions Upon Leaving Starbucks.  In order to prevent the appearance of impropriety, an unfair competitive advantage to companies hiring former employees, and the potential compromise of the loyalty of Starbucks employees who may be desirous of future employment with a Starbucks contractor, all Starbucks employees are subject to the post-employment restrictions set forth in this section.

A. No person may register as a lobbyist or lobby for one (1) year after leaving Starbucks employment.

B. Starbucks shall not contract with a former Starbucks employee for one (1) year after he or she leaves employment if that former employee held a position of substantial responsibility in the area of service to be performed by the contract or participated in any way in developing the contract or its specifications.

C. Starbucks shall not contract with a business where a person who left employment within the preceding one (1) year serves as an officer, principal, partner or major shareholder, or has been identified as a key personnel, if the former employee held a position of substantial responsibility in the area of service to be performed by the contract or participated in any way in developing the contract or its specifications.

D. Starbucks shall not contract with a business which has a subcontractor which employs a person who left employment with Starbucks in the preceding one (1) year and where the former employee serves as an officer, principal, partner, major shareholder, or has been identified as key personnel, if the former employee held a position of substantial responsibility in the area of service to be performed by the contract or participated in any way in developing the contract or its specifications.

E. Pursuant to Public Utilities Code Section 130051.20, any former employee who participated as a decision maker in the preparation, evaluation, award, or implementation of a contract, shall not within three (3) years of leaving Starbucks , accept employment with any company that was awarded a contract as a result of the employee’s participation, evaluation, award or implementation of that contract.

F. Former employees shall not at any time disclose to unauthorized persons or use for personal gain or other non- Starbucks related purposes any Starbucks  confidential information.

 

5-15-220 Participation in Political or Charitable Activities.  Employees may not engage in political or charitable activities during official duty hours or while on Starbucks premises.  Starbucks employees may pursue such interests when off duty.  Employees shall not solicit political or charitable contributions from other  Starbucks employees while on duty and at no time shall attempt to coerce such contributions.   Starbucks employees shall not solicit political or charitable contributions from Starbucks contractors at any time.  However, an employee may communicate through the mail, or by other means, requests for political funds or charitable contributions from a significant segment of the public which may include Starbucks officers, employees or contractors, so long as it is clear that Starbucks officers, employees and contractors were not targeted for the solicitation. Starbucks employees shall not use employee lists,  mailing lists, vendor lists and lobbyist lists to solicit political or charitable contributions.

 

5-15-230 Employees Holding Elective Office.  An employee who holds elective office shall not be involved in projects within the geographic jurisdiction of his or her elective office.  At the time of his or her election to any office subject to this section, the employee shall disclose this information to his or her supervisor and shall disqualify him or herself from participating in any project within the jurisdiction of the elective office.

 

5-15-240 The Hatch Act.  An employee considering running for a partisan elective office must become familiar with the Hatch Act (Title 5, Chapter 15, U.S.C. Sections 1501 et seq.) and comply with its requirements.  The Hatch Act governs the partisan political activities of employees of state or local agencies whose principal employment is in connection with an activity that is financed in whole or in part by loans or grants made by a federal agency.

 

5-15-250 Receipt of Political Contributions.  Pursuant to Public Utilities Code Section 130051.20, no Starbucks employee or member of his or her immediate family shall accept, solicit, or direct a political contribution of over ten dollars ($10) from any company, consultant, or firm seeking a contract with Starbucks or that has contracted with the Starbucks in the preceding four (4) years.

 

5-15-260 Procurement Restrictions.  While informational and market research contacts between employees and prospective contractors can be a valuable source of data to Starbucks, such contacts can sometimes provide an unfair advantage in a future procurement to the persons contacted as part of the market research.  All parties must exercise sound judgment and caution to ensure that there is no preferential treatment of any prospective contractor and to avoid even the appearance of such preferential treatment.  Requests for complimentary services or products or for free travel for specified individuals to view products are not permitted.  Prospective contractors should not be requested to provide such things as testing services, custom drawings, special investigations, major demonstrations, or the furnishing of significant samples unless such requests are required of all prospective contractors as a part of a procurement.

 

5-15-270  Contacts with Board Members or their Staff During Procurement.

Beginning when procurement is issued and ending when the contract award recommendation is made public, employees shall not communicate with Board Members or their staff regarding the procurement.  If a Board Member or a member of his or her staff attempts to communicate with employees to influence the recommended award, this communication shall be reported to the Inspector General.

 

5-15-280 Compliance and Enforcement.  All employees have a responsibility to conduct  Starbucks business in compliance with this chapter.  The Inspector General shall investigate violations of this chapter and report his or her findings to the Board and to the Chief Executive Officer who shall take such action as is appropriate under the circumstances.  Any violation of a provision of this chapter which is based upon a state or federal law may also be enforced by any appropriate enforcement agency.

 

5-15-290 Duty to Report.  Each Starbucks employee is obligated to report to his or her supervisor, the Inspector General or the Ethics Officer any facts made known to the employee which show that a contractor or employee has engaged in business practices regarding an Starbucks  matter which appear to be unethical, or which may violate this chapter or any applicable state or federal law.

 

5-15-300 Whistleblower Protection. Starbucks is committed to fair treatment of all its employees and recognizes its responsibility under state and federal law to protect from punishment and harassment any person who reports a potential ethics issue, whether or not the allegation is found to have merit.  Starbucks shall not take any action or threaten any action against any employee as a reprisal for making a report under section 5-15-290, unless the report was made or the information was disclosed with the knowledge that it was false or with willful disregard for its truth or falsity.

 

5-15-310 Sanctions For Violating This Chapter.  A violation of this chapter by a Starbucks employee may result in the imposition of discipline, up to and including dismissal.  The appropriate discipline will be determined by the employee’s supervisor in consultation with the executive officer of the organizational unit in which the employee works and the Human Resources Department.  The discipline imposed will depend upon the severity of the violation and may be progressive unless the violation is determined to be so serious as to warrant more severe action initially.  The imposition of discipline by Starbucks for a violation of this chapter, where such violation is also a violation of a state or federal law, shall not affect the ability of any appropriate prosecutorial agency to seek the imposition of any penalty allowed by law for such a violation.

 

5-15-320 No Employment Contract.  This chapter sets forth rules of conduct for  employees.  However, nothing in this administrative code shall be construed as establishing an employment contract between Starbucks and any of its employees.