WE DEMONSTRATE INTEGRITY 24/7

Business person working on a laptop

Conflicts of Interest

CONFLICTS OF INTEREST CAN ARISE when our personal relationships, outside activities, or financial interests overlap with our job responsibilities.

If you don’t navigate potential conflicts of interest carefully, these situations can affect the decisions you make, harm T-Mobile’s reputation, and erode the trust of our customers, suppliers, and co-workers. Exercise caution and err on the side of avoiding potential conflicts because even the appearance of a conflict can be damaging.

If you are aware of anything that might potentially be viewed as a conflict of interest, disclose or report it through appropriate channels.

How we avoid conflicts of interest:

Always act in T-Mobile’s best interests
  • Avoid, withdraw from, or resolve situations where a personal relationship, outside activity, or financial interest in another company might influence decisions or actions that you take in your job.
  • Do not use your T-Mobile position to benefit yourself, including by taking for yourself business opportunities that T-Mobile would be interested in pursuing.
  • You may not date or engage in a romantic or sexual relationship with someone who directly reports to you or is within your chain of command.
  • Ensure there is no direct reporting or supervisory relationship between relatives.

Avoid even the appearance of a conflict of interest

  • Avoid, withdraw from, or resolve situations where a personal relationship, outside activity, or financial interest in another company might appear to influence decisions or actions that you take in your job.
  • Understand that a conflict or an appearance of a conflict can exist even if you are convinced that it will not affect your actions or decisions, and even if T-Mobile might benefit from the situation.

Seek manager approval before engaging in certain outside activities

  • Obtain advance written approval from your manager before engaging in outside employment or work.
  • Obtain advance written approval from a leader at the director level or above before participating as a T-Mobile representative on a government advisory committee or task force.
  • Obtain advance written approval from a leader at the vice-president level or above and Enterprise Integrity & Compliance before representing T-Mobile as an appointed member of a government board or commission.

Understand our policies and where to go to disclose a potential conflict of interest

Gifts and Business Entertainment

WE DEMONSTRATE SOUND JUDGMENT and moderation when exchanging business courtesies with vendors, suppliers, enterprise customers, or business partners.

(See Interact Right with Government: Follow Rules on Gifts, Lobbying, and Political Contributions for special rules on gifts and business courtesies involving government officials and employees.)

Giving and receiving gifts, hospitality, and travel can build strong working relationships and goodwill between T-Mobile and those we do business with. But gifts, meals, or trips that are extravagant, lack transparency, or lack a legitimate business purpose may be viewed as bribes or as simply inappropriate. Accepting, giving, or even offering these things can harm our reputation and our business.

How we exchange gifts, business entertainment, and travel responsibly:

  • Ensure that gifts, business entertainment, and travel serve a legitimate business purpose.
  • Make sure that all gifts from a single giver do not exceed $100 in value in a calendar year.
  • Don’t give or receive gifts of cash or cash equivalents.
  • Gifts, entertainment, and travel that you give to someone else should be accurately reflected in accounting records and expense reports.
  • Don’t offer or accept gifts, entertainment, or travel if the purpose is to influence or reward a business decision or gain special treatment, or is likely to be seen that way.
  • Don’t solicit gifts, entertainment, or travel, and don’t provide them to someone who has solicited them from you.
  • Ensure that any business entertainment is not frequent or routine.
  • Obtain advance written approval from your senior vice president or higher manager before accepting airfare, lodging, or other travel courtesies.
  • Review and understand our Gifts & Business Entertainment Policy.
  • Go to the Integrity Hub: Gifts & Entertainment for additional information and guidance.

Accurate Books and Records

OUR RECORDS ARE CLEAR, accurate, and complete.

Investors rely on accurate and complete information to understand our financial results and where we are headed as a company. Keeping accurate records is critical to maintaining investors’ trust, making good business decisions, and meeting our regulatory obligations as a public company.

How we maintain accurate and complete records:

  • Honestly, accurately, and completely record and report financial transactions and business information for internal and external users.
  • Include all transactions and assets in financial reporting and accounting records; do not delay recording transactions or events.
  • Execute financial transactions only with appropriate authorization, and record them in compliance with T-Mobile’s accounting practices.
  • Don’t make side agreements or other “off-the-book” arrangements.
  • Use standard agreements and contracting processes, or get approval for custom terms.
  • Do not hide cash or company assets, or use them for unauthorized or improper purposes.
  • Do not take any action that helps to create a false or misleading record, such as withholding information from someone preparing a report.
  • Be sure that all information you report or file, including timecards, expense reports, government and public disclosures, and regulatory reporting, is accurate and complete.
  • The CEO, CFO, and other employees in the finance organization comply with the Code of Ethics for Senior Financial Officials and federal regulations on the maintenance of records and preparation of required reports.
  • Go to the Integrity Hub: Accurate Books for additional information and resources.

Securities Trading

WE RESPECT SECURITIES LAWS, which means we do not trade stock or other securities while in possession of material, non-public information.

In our work, we may become aware of material, non-public information about T-Mobile or companies we do business with. Information is “material” if a reasonable investor would consider it important in deciding whether to buy or sell a company’s securities. Information is “non-public” if it has not been broadly communicated to the investing public.

Trading T-Mobile stock or the stock of any other company based on this information not only lacks integrity and is unfair to other investors, but also violates company policy and is illegal.

How we avoid trading on inside information:

  • Never buy or sell any securities while in possession of material, non-public information of T-Mobile, whether such information was acquired through your employment with T-Mobile or otherwise.
  • Understand what constitutes “material, non-public information.”
  • Never give someone else (for example, a spouse, family member, friend, or broker) a “tip” about material, non-public information.
  • Never recommend or suggest that anyone else trade in securities based on material, non-public information of T-Mobile, even if you are not sharing the information itself.
  • Review and understand our Policy on Securities Trading.
  • Go to the Integrity Hub: Securities Trading for additional information and guidance.