IBM's Business Conduct Guidelines are "a tangible example of our values and an expression of each IBMer's personal responsibility to uphold them," according to CEO Sam Palmisano.

As the 16-page document notes, "As IBM employees, we frequently encounter a variety of ethical and legal questions. There are no shortcut formulas or automatic answers to the choices we have to make in business today; however, we should decide these questions in ways that are consistent with IBM's values."