C. Avoiding Conflicts of Interest

The Company considers it important to prevent its Infineon Employees from succumbing to conflicts of interest or of loyalty in their professional activities. Such conflicts can come about if an Infineon Employee is active on behalf of or has interests in another company. The following rules thus apply for all of us. 

It shall be prohibited to operate a company or other business which competes with Infineon Technologies AG (Competitor companies) or any of its Group Companies. 

I. Interests Held in Companies Not Listed on the Stock Exchange

It is not permitted for an Infineon Employee to hold interests in a company competing with Infineon and not listed on the stock exchange.

Prior permission is required to hold interests in a company not competing with Infineon and not listed on the stock exchange if the Infineon Employee is in a position to influence the business policy of Infineon Technologies AG or its Group Companies with regard to said company.

The approval has to be obtained from the respective Human Resource Department, documented in writing and signed by the respective Member of the Management Board or the Chief Executive Officer/Managing Director of the respective Group Company.

Any of the aforementioned interests held by close family members (spouses, children, and partners) must be communicated to the HR Department.

II. Interests Held in Companies Listed on the Stock Exchange

Interest held in a listed company is permitted if the interest, including interest held by close family members (spouses, children and partners), does not exceed 5,0 % of the capital stock.

An interest of more than 5,0 % of the capital stock requires an approval if the Infineon Employee is in a position to influence the business policy of Infineon Technologies AG or its Group Companies with regard to said company. The approval has to be obtained from the respective Human Resource Department, documented in writing, and signed by the respective Member of the Management Board or the Chief Executive Officer/Managing Director of the respective Group Company.

Any employee intending to take up or continue paid sideline activities must advise the HR department thereof. Permission for such activity may be denied if it can lead to a decrease in work performance, contradicts the employee’s duties within the company, or threatens to present a conflict of interest. Occasional writing activities, lectures, and comparable occasional activities are not deemed to be sideline activities.

Community service of Infineon Employees is explicitly welcome; however, such voluntary service must not be conducted in a way that is in contradiction with Infineons legitimate interests.

Details of and exceptions to this rule for the specific countries (e. g. USA, Germany) have to be agreed upon by the Corporate Compliance Officer (also see I. Addendum).