Ethics and compliance

Putting integrity, respect and accountability at the core of our decision-making process is vital to support our ambition, create value and earn the trust of our stakeholders. These values are some of our most important assets and an integral part of our long-term strategy.

Our vision speaks for itself: we want to be everywhere microelectronics brings a positive contribution to people’s lives. We must reflect this in everything we do. We believe ethics and compliance are everyone’s job and responsibility, and that conducting our business with the highest ethical standards is critical to our long-term success.

Code of Conduct

Our Code of Conduct is all about our values, which are shared throughout the Company. It sets clear expectations for our employees and other stakeholders, helps to foster a culture of integrity, and provides practical guidance on the way we conduct our business and make our decisions.

• Integrity: we conduct our business with the highest ethical standards, honor our commitments, and keep our promises; we 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; every 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 competencies, seek responsibility and are accountable for our actions; we act with discipline, base our decisions on facts, and focus on the priorities.

In 2022 we released an Addendum to our Code of Conduct. The purpose of this Addendum is to provide supplementary guidance and practical information in order to further help prevent and detect risks related to corruption or influence peddling. It also includes specific recommendations regarding charitable donations or sponsorship, gifts meals and entertainments, and other risky situations that employees may encounter. 

Our Code of Conduct and its Addendum are distributed to all our employees, including newcomers. They are available on our website (see www.st.com/code_of_conduct ), our ST Integrity app, and in 10 languages on our intranet. I 2-23 I 2-24 I 2-27 l

Yearly declaration

In 2022, we successfully ran a worldwide campaign asking all eligible employees to sign and confirm our business ethics declaration, in line with the values and principles described in our Code of Conduct. Employees who have not completed their yearly declaration are contacted to understand the reasons behind and, as applicable, identify any follow-up action plan.

Training

Following up on our initiative started in 2021 to update our training modules with high quality distance learning and an excellent user experience, in 2022 we deployed our new e-learning modules focusing on topics such as: anti-bribery and corruption, conflict of interest, anti-harassment and discrimination, and insider trading. These e-learnings enable users to take an active role in their training through practical cases and quizzes. Accessible via our training platform, they are available in 10 languages and include a glossary and quick access to other useful resources. Overall, our training and e-learning programs were taken by more than 24,500 employees in 2022. 

Communication and awareness

We continued to deploy our Compliance, Ethics and Privacy multi-channel communication and awareness strategy, via our intranet pages (generating more than 96,000 views), through our mobile application ST Integrity, and our Yammer community 'Building Trust Together'. Compliance, Ethics and Privacy was also a topic of interest for external users in 2022, leading to more than 80,000 views on our Code of Conduct page and Privacy portal available on our public website. Finally, we participated for the third time in the Distribution and Sales Convention for Asia Pacific, with more than 900 business partners in attendance physically and virtually.

Philippe Dereeper

Chief Compliance Officer and Executive Secretary of the Supervisory Board

By designing an effective compliance, ethics and privacy program and promoting a culture of integrity, respect and accountability, we are creating long-term value for all our stakeholders."

Privacy

We respect the privacy of our stakeholders, including our employees, in the way we collect and use their personal data. 

During 2022, we further strengthened our data protection program by ensuring uniformity across all ST’s legal entities wherever located by adopting the EU GDPR to put human beings at the center of our privacy practices. Thus, we harmonize data protection law across our global presence while leaving some discretion to follow the data privacy laws of certain countries or states (such as the US states of California, Connecticut, Colorado, Utah and Virginia who have developed their own data protection and privacy laws). At country level, 2022 was a year in which China’s data protection legislation was further refined. Although, we continued to manage and process data subjects’ access and deletion requests via our generic email privacy@st.com, we have not received any complaints on privacy breaches during 2022.

Bribery and corruption

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

This applies to all our employees, organizations and third parties acting on behalf of ST and all transactions in any country where we operate and do (or seek to do) business. Any violation will be deemed a serious violation of our Code of Conduct and lead to disciplinary action, including termination of the relationship with ST.

Our Anti-Bribery and Corruption policy (see investors.st.com/highlights) provides clear definitions regarding instances of bribery and corruption and includes detailed descriptions of the Company’s rules for engaging with third parties. It also explains how to report actual or suspected violations and outlines the potential disciplinary actions and legal consequences of any non-compliance.

Speak up and misconduct reporting

Our position is clear: we encourage everyone, including external business partners, to express any concerns they might have regarding possible violations of our Code of Conduct, our policies, or the law. Managers are accountable for maintaining a working atmosphere where employees are comfortable speaking up and expressing their concerns freely. All concerns raised are taken seriously.

Our speak up process is communicated to all employees through, among other things, our Code of Conduct, dedicated intranet web pages and our ST Integrity app. In addition, in 2022 we replaced our previous hotline with a new independent multilingual Ethics Hotline, which is available 24/7 online or via phone. A link to our Ethics Hotline is accessible on our intranet, our website (see www.st.com), many communication and training materials, and our ST Integrity app. It can be used by any employee, business partner or stakeholder.

We apply the highest standards of confidentiality in handling all reports received, and 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. I 2-25 I 2-26 I

Ethics committees

The purpose of our Corporate Ethics Committee is to support ST management in its efforts to foster a consistent ethical culture across all regions, functions, and organizations. Formed in 2007 and chaired by our Chief Compliance Officer, Philippe Dereeper, the committee comprises senior managers representing various ST organizations, appointed for three-year terms by our President and Chief Executive Officer.

The role of the Corporate Ethics Committee includes:

• evaluating the principles in our Code of Conduct, with reference to our culture and commitment to business ethics
• reviewing the main ethical breaches, allegations, and related investigations
• providing guidance on ethical dilemmas that may be faced by the Company, upon request from our Managing Board or our Chief Compliance Officer
• promoting and coordinating the activities of our four local ethics committees in France, Italy, Asia Pacific and the Americas

Our four local ethics committees contribute to this mission within their respective geographical areas. Their activities are complementary to the Corporate Ethics Committee, with which they are in regular communication. l 2-16 l