B. Treatment of Business Partners and Third Parties

Our Company’s reputation depends not only on how successful we are financially. It also depends on how we treat the people we deal with every day in the conduct of our business. Every Infineon Employee is therefore encouraged to deal fairly with the Company’s customers, suppliers, competitors, business partners and the employees of each of these. No one should take advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts and any unfair-dealing practice. 

Every Infineon Employee is obligated to abide by the rules of fair competition and anti-trust laws. Anti-trust evaluation can be difficult in individual cases. However, some types of behavior regularly constitute a violation of anti-trust laws, e.g.: Infineon Employees and competitors may not have talks in which information about prices is exchanged or prices or capacities are arranged. It is also prohibited to enter into an agreement not to compete with a competitor, to submit bogus offers for bidding or to divide up customers, territories, or production programs.

Infineon Employees must not exert any influence upon the resale prices charged by our purchasers, nor may they attempt to put through export or import prohibitions.

If Infineon has a dominant position in a market, Infineon will not abuse it. Different treatment of customers for no objective reason (discrimination), a refusal to supply customers or imposing unreasonable purchase or sales prices and terms, for example, may constitute such an abuse.

We battle for orders with the quality and the price of our innovative products and services.

Infineon Employees may not directly or indirectly offer or grant unjustified advantages to others, such as public officials, e. g., civil servants, judges or any other persons exercising a public function for or on behalf of a country ("Public Officials"), suppliers, customers, and other business partners ("Business Partners") in connection with performing their job.

Unjustified cash payments must neither be granted to Public Officials nor to Business Partners.

Gifts and other pecuniary benefits to Public Officials are prohibited. Invitations to Public Officials may only be made after prior approval by the responsible Compliance Officer.

Infineon Employees concluding contracts with consultants, intermediaries, agents, or comparable third parties must see to it that these also offer or grant no unjustified advantages.

Invitations to restaurants or the like and other invitations as well as gifts of insignificant value to Business Partners are allowed as long as they are appropriate, in line with usual social behavior and courtesy and avoid any appearance of bad faith or impropriety in the mind of the recipient. It has to be ensured that the value of the entertainment is appropriate when considering the status and the standard of living of the recipient. In case of doubt the Business Partner shall be asked to seek permission for the invitation by Infineon by his or her supervisor.

Invitations to entertainment events, like a soccer match or an opera visit, can only be made after the Infineon Employee has received the approval of the responsible Compliance Officer.

An invitation or hospitality to spouses or partners of a Business Partner or Public Official always requires the approval of the responsible Compliance Officer.

Infineon Employees may not use their job title to demand, accept, obtain, or be promised personal advantages. Cash payments must not be accepted.

Invitations to restaurants or the like and other invitations as well as gifts of insignificant value can be accepted, as long as they are appropriate and are in line with usual business practices.

Gifts of other than insignificant value shall be refused. If this would appear discourteous they should be donated to charity, used for internal company drawings, or used for other internal company purposes. In case of doubt the Infineon Employee has to obtain approval by his or her responsible Compliance Officer.

Invitations to entertainment events can only be accepted after the Infineon Employee has received approval from the respective Compliance-Officer. The invitation of spouses or partners of the Infineon Employee also requires the approval of the respective Compliance Officer.

Infineon Employees whose work involves the awarding of contracts must particularly abide by the following rules:

• The Infineon Employee must inform his/her supervisor of any personal interest he/she could possibly have in connection with the execution of his/her professional duties.
• There must be no unfair discrimination for or against any suppliers in their competition for contracts.
• Invitations from business partners may only be accepted if the occasion and scope of the invitation are appropriate and if refusing the invitation would be discourteous.
• Gifts from business partners must be refused and returned unless they are occasional gifts of insignificant value.
• No Infineon Employee may have private orders fulfilled by companies with which he/she has company business dealings if he/she could derive any advantage therefrom. This is particularly applicable if the Infineon Employee exercises or is capable of exercising a direct or indirect influence upon having that company receive a contract from Infineon Technologies AG or one of its subsidiaries.

As a Corporate Citizen, Infineon makes monetary or product donations for education and science, art and culture, and public welfare. The following rules apply to granting donations:

• Applications for donations submitted by individuals are to be rejected in principle.
• Payments to private accounts are inadmissible.
• In no case may the grant be made to any person or organization that would damage our reputation.
• The donation must be transparent. The recipient of the donation and the recipient's actual use thereof must be known. One must at any time be able to justify the reason for the donation and its use for the purpose served thereby.
• The donations should be tax-deductible.

Quasi-donations are prohibited as violating the principles of transparency. Quasi-donations are grants which are intended to look like compensation for a particular performance. At least in part, it is thus a matter of a grant for other purposes.

Donations to authorities to which Infineon maintains or intends to establish a business relationship are prohibited. Donations to third parties, e.g. to a sponsors' association or a non-profit organization, if requested by a public official, to whose authority Infineon maintains or intends to establish a business relationship are also prohibited.

Infineon makes no donations to political parties, politicians or political organizations

Every Infineon-Employee shall abide by all domestic and foreign money laundering regulations. "Money laundering" within the meaning of these regulations is, in particular, the introduction – e.g. by exchange or transfer – of illegally earned money into the legal business and financial system. If Infineon Employees are not sure whether a financial transaction involving the transfer of cash is permissible, they must contact their responsible Compliance Officer in good time.

Infineon abides by all export control and customs laws and regulations that apply internationally and in the countries where it does business. All employees involved in importing, exporting or transferring goods, services, hardware, software or technology are obliged to comply with all applicable sanctions programs, export control and customs laws and provisions and all guidelines and processes to comply with in relation to their activity.