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 business integrity is everyone’s job and responsibility, and that conducting our business with the highest ethical standards is critical to our long-term success.

Philippe Dereeper

Chief Ethics and Compliance Officer, and Executive Secretary of the Supervisory Board

Cultivating a culture of ethics, accountability, and respect is critical to the success of any organization. By upholding these values, we not only ensure the integrity of our Company, but also create a workplace culture that attracts and retains top talent, builds trust with our stakeholders and creates a foundation for 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.

An Addendum to our Code of Conduct, published in 2022, provides supplementary guidance and practical information to help prevent and detect risks related to corruption or influence peddling. It also includes specific recommendations regarding charitable donations or sponsorship, gifts, meals and entertainment, 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 2-232-242-27

Yearly declaration

In 2023, we ran our annual 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 it and, as applicable, identify any follow-up action plan.

Communication and awareness

In 2023, we continued to deploy our Compliance, Ethics and Privacy multi-channel communication and awareness strategy via our intranet pages (generating more than 100,000 views in 2023), through our mobile application ST Integrity, and our Viva Engage community ‘Building Trust Together’. Compliance, Ethics and Privacy was also a topic of interest for external users in 2023, leading to more than 87,000 views on our new Compliance, Ethics & Privacy internet page and Privacy Portal. Finally, we participated for the fourth time in the Distribution and Sales Convention for Asia Pacific, with more than 300 business partners.

Privacy

In 2023, we continued to monitor and adapt to the evolving privacy environment as we faced many new personal data protection laws with varying requirements, deadlines, enforcement dates, and rulemaking. The ability of multinational companies to export personal data from the European Union and Mainland China has been challenged in recent years. We welcomed the EU-US Data Privacy Framework, which stabilizes cross-border transfers and makes it easier to provide services to our stakeholders. To this end, we updated our Privacy Portal at www.st.com to comply with several new personal data protection laws (for example, Mainland China, Switzerland, California) and to provide our stakeholders with dedicated privacy notices to expand our transparency obligations.

In 2023, we did not receive any formal grievance made by individuals or personal data protection authorities regarding our handling of personal data.

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 www.st.com) 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 reporting of concerns

At ST, we believe that maintaining a culture of transparency and ethical behavior is crucial to our success. That’s why we encourage everyone, including our external business partners, to speak up and report any concerns they might have regarding possible violations of our Code of Conduct, policies, or the law. Our managers are accountable for creating a working atmosphere where employees feel comfortable speaking up and expressing their concerns freely. We take all concerns raised seriously and review them thoroughly. To make it easy for our employees, business partners, and stakeholders to report any concerns, we have an independent multilingual Ethics Hotline that is available 24/7 online or via phone. We communicate this Ethics Hotline to all employees through various channels, including our Code of Conduct, dedicated intranet web pages, and our ST Integrity app. A link to our Ethics Hotline is also accessible on our intranet, our website, many communication and training materials, and our ST Integrity app.

We apply the highest standards of confidentiality in handling all reports received, and we ensure that no employee who reports a concern suffers retaliation in the form of harassment, or adverse employment or career consequences. 2-252-26

FOCUS

Speak Up campaign

In 2022, we refreshed our Ethics Hotline, which is available 24/7 online and via phone in more than 30 languages. We accompanied this with a new global communication and training campaign ‘See something? Say something!’ focusing on the importance of speaking up and building a culture of trust, accountability, and transparency within the Company.

The campaign continued throughout 2023, and since its launch, we have published 22 communications on our internal channels, generating 53,000 views. We also created posters, business cards, flyers, and videos that were made available to sites. 

In addition, we updated all Compliance, Ethics & Privacy e-learnings to include a module on our new Speak Up policy and tool, which were taken 20,895 times in 2023, demonstrating a high level of engagement and commitment from employees at all levels.

To ensure that our managers are equipped with the knowledge and skills to create and maintain an environment where employees feel free to speak up and report any concerns, we also trained 5,243 managers on the importance of fostering a culture of transparency and ethical behavior throughout the Company.

All these actions resulted in a 3-fold increase in the number of concerns raised through the Ethics Hotline in 2023, strenghtening a speak up culture.

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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 Ethics and Compliance Officer, Philippe Dereeper, the committee comprises senior managers representing various ST organizations.

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. 2-16