E. Handling of Information

E 1. Dealings with the General Public

To ensure that Infineon speaks to the general public and the capital market with one voice, employees are obliged in principle to forward inquiries from the media and analysts to Corporate Communications and Investor Relations so that they can be answered. When expressing their own opinion in public, employees must not indicate they are doing so in their function as a member of Infineon. 

E 2. Records and Reports

Open and effective cooperation requires accurate and truthful reporting. This applies equally to the relationship with investors, Infineon Employees, customers, and business partners, as well as with public and all governmental offices. 

Any records and reports produced internally or distributed externally must be accurate and truthful. According to proper bookkeeping principles, data and other records must always be complete, correct, and appropriate in terms of time and system. The requirement of truthful statements applies to expense accounts as well. 

E 3. Confidentiality

Confidential information includes all non-public information that might be of use to competitors or harmful to the Company or its customers or business partners if disclosed.

Confidentiality must be maintained with regard to such confidential information, especially internal corporate matters which have not been made known to the public, concerning, for instance, details regarding the Company's set-up and its organizations as well as matters of business, manufacturing, research and development, and internal reporting figures.

Confidentiality must also be maintained with respect to any confidential information of our customers and business, unless disclosure of such information has been expressly permitted.

The obligation to maintain confidentiality shall extend beyond the termination of the employment relationship.

E 4. Information Security and Data Protection

The advantages of electronic communication and storage of data are tied to risks in terms of personal privacy protection and data security. Effective foresight with regard to these risks is an important component of IT security management, leadership tasks, and also of the behavior of each individual.

According to the German Federal Data Protection Act (BDSG) or similar regulations in the relevant countries, Infineon Employees may not collect, process, or use unauthorized personal data which they become aware of in the course of their job. High standards must be ensured with regard to technical protection against unauthorized access. The use of the data must be transparent for those concerned; and the rights of the latter must be safeguarded with regard to information and correction and, if applicable, to objection, blocking, and deletion.

E 5. Insider Trading Rules

All Infineon Employees world-wide are bound to observe the applicable statutory rules as well as the internal insider rules, if they are in possession of Insider Information which may affect the value of Infineon Securities.

  • "Infineon Securities" are shares of Infineon Technologies AG and of all Group Companies, warrants and options on shares of Infineon Technologies AG (including comparable derivative financial products), bonds, and securities which can be exchanged into shares of Infineon Technologies AG or of Group Companies like, e.g. convertible bonds and exchangeable bonds.
  • "Insider Information" is concrete information not generally known to the public and which is likely to have significant influence on the price of listed securities if it is placed in the public domain, e.g. information on acquisitions, disinvestments, operational results or operational expectancies. Such information may also pertain to events which lie in the future, if it is only likely that they may sometime occur.

Statutory insider rules prohibit (i) the use of Insider Information to conduct transactions in Infineon-Securities on one’s own or third parties’ account, (ii) to pass on or to make available Insider Information to third parties, and (iii) to recommend, on the basis of Insider Information, to trade in Infineon Securities or to otherwise induce someone to do so.

With respect to Infineon’s internal insider rules reference is made to the Corporate Rule "Insider Law" and the related leaflet.

It should be noted that managers can be held personally liable for damages if an Infineon Employee violates insider trading rules and if proper supervision could have prevented such violation.

Due to mandatory statutory provisions Infineon is obliged to keep permanently updated records of all persons acting for Infineon, who have, on the basis of their positions or their job type, access to Insider Information. Upon request inspection into this so-called "Insiderverzeichnis" (Insider Register) must be allowed to the relevant authority, the "Bundesanstalt für Finanzdienstleistungsaufsicht" (BaFin).