A. Basic Behavioral Requirements

Integrity is our guiding principle in dealings with our customers, shareholders, business partners, employees and the general public.

These guidelines provide an overview of important regulations that are intended to provide support in legal and ethical questions. The BCG must be lived by every one every day. Only then can we live up to our goal of acting responsibly and legally.

To a substantial degree, the image of Infineon is determined by our actions and by the way each and every one of us presents and conducts himself/herself. Inappropriate behavior on the part of even a single Infineon Employee can cause the Company considerable damage.

Every Infineon Employee should be concerned with the good reputation of Infineon in each country. In all aspects of performing his/her job, every Infineon Employee must focus on maintaining the good reputation of and respect for the Company.

We respect and observe the internationally proclaimed human rights, including the rights to personal dignity and privacy. We shall not condone human rights abuses.

We shall not permit work carried out by persons under the age of 15. Exceptions apply to employment relationships in developing-countries under the International Organization Convention 138 (minimum lowered to 14) or to governmental authorized job trainings or apprenticeship programs that would clearly benefit the persons participating. Infineon will respect any local laws providing for a higher minimum age.

We are against any form of forced labor.

At Infineon, we work together with women and men of various nationalities, cultures, religions, and skin colors. Hence, we will not tolerate any discrimination, harassment or offence based on color, national origin, gender, religion, age, disability, union or political affiliation, sexual orientation, marital or family status against an Infineon Employee or a business partner. Any forms of sexual harassment, corporal punishment, physical coercion and verbal abuse are prohibited, as well as any intimidating hostile or offensive conduct.

These principles shall apply to both internal cooperation and conduct towards external partners.

We recruit, select, train, promote and compensate Infineon Employees solely on the basis of work-related criteria such as merit, experience and performance. Every Infineon Employee must be fairly compensated for their work with wages that meet at least minimum legal standards. Furthermore, we ensure that national and local regulations and agreements on working hours are being adhered to.

We acknowledge the right of all Infineon Employees to join associations and the right to collective bargaining to agree on working conditions. Infineon and the respective employee associations work together constructively and in good faith as well as with mutual respect. In this we target a fair balance between the economic interests of the Company and the interests of the Infineon Employees. Even in cases of disputes the goal shall always be to maintain a viable cooperation in the long-term.

Every manager bears responsibility for the Infineon-Employees entrusted to him. Every manager must stand out due to exemplary personal behavior, performance, openness, and social competence. He agrees upon clear and challenging goals with the Infineon Employees entrusted to him leads by trust and confidence and leaves the Infineon Employees as much individual responsibility and leeway as possible. Every manager shall also be accessible in case Infineon Employees wish to discuss a professional or personal problem.

Every manager must fulfill duties of organization and supervision:

It will be the responsibility of every manager that there is no violation of laws within his/her area of responsibility which proper supervision could have prevented or rendered more difficult. The manager still remains responsible, if he delegates particular tasks.

The following shall apply in particular:

1. The manager must carefully select the Infineon Employees for their personal and professional qualifications. The duty of care increases with the importance of the obligation to be entrusted to the Infineon Employee (duty of selection).
2. The manager must formulate the obligations in a precise, complete and binding manner, especially with regard to compliance with provisions of the law (duty of instruction).
3. The manager is responsible for ensuring that compliance with provisions of the law is monitored on a constant basis (duty of monitoring).
4. The manager must clearly communicate to the Infineon Employees that violations of the law are disapproved and will have employment consequences.
5. The manager should encourage any Infineon Employee who is unsure whether he or she is taking the proper legal or ethical course of action to discuss with the manager the best course of action to be taken. If the Infineon Employee, after discussion, still questions the propriety of the course of action to be taken, the Infineon Employee should be encouraged to speak with the manager’s supervisor or with the respective Compliance Officer.