Ethics and Compliance

As one of the world’s leaders in semiconductors, we have a responsibility to lead by example. Our vision speaks for itself: we want to be everywhere microelectronics brings a positive contribution to people’s lives. We reflect this in everything we do. We believe that conducting our business with the highest standards of integrity is essential to our long-term success. At ST, compliance and ethics are everyone’s job and everyone’s responsibility. l 102-16 l

Code of Conduct

Our Code of Conduct is all about our values, which are shared throughout the Company. It sets clear expectations and provides practical guidelines on the way we conduct business and make our decisions, helping to foster a culture of integrity. It also defines guiding principles for everyone at ST, in line with our value proposition to all stakeholders, and it reflects our values.

• Integrity: we conduct our business with the highest ethical standards, honor our commitments, deliver on our promises, are loyal and fair, and stand up for what is right.
• People: we behave with openness, trust and simplicity; we are ready to share our knowledge, encourage everyone’s contribution, develop our people through empowerment, teamwork and training; each one of us is committed and personally involved in the continuous improvement process.
• Excellence: we strive for quality and customer satisfaction and create value for all our partners; we are flexible, encourage innovation, develop our competences, seek responsibility and are accountable for our actions; we act with discipline, base our decisions on facts, and focus on the priorities.

Our Code of Conduct is available in 10 languages on our website (www.st.com/code_of_conduct), our intranet and in our ST Integrity app.

In 2019, we refreshed our Code of Conduct. We updated our compliance and ethics risk assessment and risk mapping exercise, and we continued our compliance and ethics awareness and communication campaign, ‘Building Trust Together’.

Building Trust Together started in 2018. It uses a variety of tools to engage employees, managers and third-parties, including face-to-face and town hall meetings, e-learning modules, dedicated intranet, articles, posters, targeted emails and short videos.

Internally, we further promoted our ST Integrity app, a dedicated mobile application that provides our employees with quick and easy access to important and useful information. It also includes notifications, quizzes, training materials and a direct link to our misconduct reporting hotline.

Bribery and corruption

ST has a zero tolerance approach to bribery and corruption, regardless of the identity or position of the originator or recipient of any bribe. It is also strictly forbidden for anybody in ST to use Company funds or assets to make a political contribution.

Our Code of Conduct and Anti-Bribery and Corruption Policy are available in the corporate governance section of our website (see investors.st.com). They provide clear definitions regarding instances of bribery and corruption and include detailed descriptions of the Company’s rules for engaging with third-parties. They also explain how to report actual or suspected violations and outline the potential disciplinary actions and legal consequences of any non-compliance.

Philippe Dereeper

Chief Compliance Officer, and Executive Secretary of the Supervisory Board

Putting integrity, respect and accountability at the core of our decision-making process is key to support our strategy, earn the trust of our employees and business partners and create long-term value for all our stakeholders. Ethics and Compliance stand for Building Trust Together!”

Speak up and misconduct reporting

We encourage everyone, including external business partners, to express, in good faith, any concerns they might have regarding possible violations of our Code of Conduct, the Company’s policies, or the law. Managers are accountable for maintaining a working atmosphere where employees feel comfortable about speaking up and expressing their concerns freely.

Our misconduct reporting process is communicated to all employees through a range of channels, including our Code of Conduct, dedicated intranet web pages and our ST Integrity app.

In addition to internal local and corporate reporting channels, we have an independent multilingual misconduct reporting hotline. A link to our hotline is accessible on our websites (intranet and www.st.com) and ST Integrity app. It can be used by any ST employee, interested business partners or stakeholders.

We apply the highest standard of confidentiality in the handling of all reports received, either through local management or through the hotline. We ensure that no employee who reports a concern in good faith suffers retaliation in the form of harassment, or adverse employment or career consequences.

Ethics committees

Our Corporate Ethics Committee is chaired by our Chief Compliance Officer, Philippe Dereeper. It supports ST management in its efforts to foster an ethical business culture that is consistent across regions, functions, and organizations. The committee meets at least quarterly and comprises nine senior managers appointed for three-year terms by our President and Chief Executive Officer.

The committee’s role and responsibilities include:

• discussing and evaluating amendments to our Code of Conduct, as well as ethical breaches, allegations, and related investigations
• issuing guidance or recommendations on ethical dilemmas
• coordinating a network of local ethics committees in France, Italy, Asia Pacific and the Americas

These local ethics committees, covering individual countries or regions, meet regularly. Their roles, responsibilities, and organizations are defined locally, based on guidelines issued by the Corporate Ethics Committee.