B. Treatment of Business Partners and Third Parties

B 1. Following Fair Business Practices

Our Company’s reputation depends not only on how successful we are financially. It also depends on how we treat the people we deal with every day in the conduct of our business. Every Infineon-Employee is therefore encouraged to deal fairly with the Company’s customers, suppliers, competitors, business partners and the employees of each of these. No one should take advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts and any unfair-dealing practice.

B 2. Abiding by Fair Competition and Anti-Trust Laws

Every Infineon-Employee is obligated to abide by the rules of fair competition and anti-trust laws. Anti-trust evaluation can be difficult in individual cases. However, some types of behavior regularly constitute a violation of anti-trust laws, e.g.: Infineon-Employees and competitors may not have talks in which information about prices is exchanged or prices or capacities are arranged. It is also prohibited to enter into an agreement not to compete with a competitor, to submit bogus offers for bidding or to divide up customers, territories, or production programs.

Infineon-Employees must not exert any influence upon the resale prices charged by our purchasers, nor may they attempt to put through export or import prohibitions.

B 3. Offering and Granting Advantages

We battle for orders with the quality and the price of our innovative products and services. 

Infineon-Employees may not directly or indirectly offer or grant unjustified advantages to others, such as suppliers, customers, and other business partners in connection with performing their job. Cash payments must not be granted.

Invitations to restaurants or the like and other invitations as well as gifts of insignificant value are allowed as long as they are appropriate, in line with usual business practice and avoid any appearance of bad faith or impropriety in the mind of the recipient. In cases of doubt the recipient should be asked to obtain prior permission for the gift from his/her supervisor.

Invitations to entertainment events can only be made after the Infineon-Employee has received the approval of the respective Compliance Officer. It has to be ensured that the value of the entertainment is reasonable when considering the status and the standard of living of the recipient. The invitation of spouses or domestic partners sharing the same address of the Infineon-Employee also require the approval of the respective Compliance Officer.

Cash payments, unjustified advantages and gifts of any kind are not allowed to employees, officials or other members of governmental entities (collectively "government officials"). The above mentioned rules regarding entertainment are valid for government officials as well. In addition, local laws and regulations have to be adhered to at all times.

Infineon-Employees concluding contracts with consultants, intermediaries, agents, or comparable third parties must see to it that these also offer or grant no unjustified advantages.

B 4. Demanding and Accepting Advantages

Infineon-Employees may not use their job title to demand, accept, obtain, or be promised personal advantages. Cash payments must not be accepted.

Invitations to restaurants or the like and other invitations as well as gifts of insignificant value can be accepted, as long as they are appropriate and are in line with usual business practice.

Gifts of other than insignificant value should be refused. If this would appear discourteous they should either be donated to charity, used for internal company drawings, or used for other internal company purposes.

Invitations to entertainment events can only be accepted after the Infineon-Employee has received approval from the respective Compliance-Officer. The invitation of spouses or domestic partners sharing the same address of the Infineon-Employee also requires the approval of the respective Compliance Officer.

B 5. Special Rules for Awarding Contracts

Infineon-Employees whose work involves the awarding of contracts must particularly abide by the following rules:

• The Infineon-Employee must inform his/her supervisor of any personal interest he/she could possibly have in connection with the execution of his/her professional duties.

• There must be no unfair discrimination for or against any suppliers in their competition for contracts.

• Invitations from business partners may only be accepted if the occasion and scope of the invitation are appropriate and if refusing the invitation would be discourteous.

• Gifts from business partners must be refused and returned unless they are occasional gifts of insignificant value.

• No Infineon-Employee may have private orders fulfilled by companies with which he/she has company business dealings if he/she could derive any advantage therefrom. This is particularly applicable if the Infineon-Employee exercises or is capable of exercising a direct or indirect influence upon having that company receive a contract from Infineon Technologies AG or one of its subsidiaries.

B 6. Donation

As a Corporate Citizen, Infineon makes monetary or product donations for education and science, art and culture, and public welfare. Our offices receive requests for donations from the most varied of organizations, institutions and associations. The following rules apply to granting donations:

• Applications for donations submitted by individuals are to be rejected in principle.

• Payments to private accounts are inadmissible.

• In no case may the grant be made to any person or organization that would damage our reputation.

• The donation must be transparent. The recipient of the donation and the recipient's actual use thereof must be known. One must at any time be able to justify the reason for the donation and its use for the purpose served thereby.

• The donations should be tax-deductible.
  
  

Quasi-donations are prohibited as violating the principles of transparency. Quasi-donations are grants which are intended to look like compensation for a particular performance. At least in part, it is thus a matter of a grant for other purposes.