Ethics and Compliance

Putting respect, accountability, and integrity at the core of our decision-making process is vital to support our ambition, create value and earn the trust of all our stakeholders. These values are some of our most valuable assets and an integral part of our long-term strategy. I 102-16 I

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 that conducting our business with the highest ethical standards is critical to our long-term success. We believe that ethics and compliance are everyone’s job and responsibility.

Code of Conduct

Our Code of Conduct is all about our values, which are shared throughout the Company. It sets clear expectations for all 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.

Our Code of Conduct is distributed to all our employees, including newcomers. It is available in 10 languages on our website (see www.st.com/code_of_conduct), our intranet and our ST Integrity app.

Yearly declaration

At the beginning of each year, we run 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.

At the end of the year, we updated our process and refocused the yearly declaration on three pillars:

• the principles described in our Code of Conduct
• the disclosure of (potential) conflicts of interest
• our speak up policy

We also refreshed our follow-up process to find out why some employees may not complete their yearly declaration.

Communication, awareness, and training

Our compliance and ethics communication and awareness campaign ‘Building Trust Together’ continued in 2020. It now includes a variety of tools to engage our employees and managers. Much of this was done remotely in 2020 while the COVID-19 pandemic prevented us from holding face-to-face and townhall meetings. For example:

• Our ST Integrity app, which includes useful and easy-to-use resources on compliance and ethics topics, has now been downloaded by more than 11,700 employees worldwide.
• Our Ethics and Compliance intranet (beST@compliance) was refreshed and updated. It received nearly 12,000 unique visitors and more than 100,000 page views during the year.
• Our e-learning modules on ST Code of Conduct, Data Privacy and Conflict of interest, were taken by more than 17,000 employees.

Building Trust Together

In 2020, we organized our annual Distribution and Sales Convention for Asia Pacific, with more than 900 business partners (physical and virtual) invited. Due to COVID-19 travel restrictions, the event was decentralized and held simultaneously across Wuhan (China), Hong Kong (China), New Delhi (India), Tokyo (Japan), Seoul (South Korea), Singapore, and Taipei (Taiwan), as a hybrid event with both virtual and (when possible) physical activities. Compliance, Ethics and Privacy were themes of the convention, focusing this year on topics such as bribery and corruption, data privacy, respect for intellectual property and our speak up hotline. We received very positive feedback from participants.

Privacy

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

In 2020, our personal data protection program became part of the Ethics and Compliance organization, renaming it Compliance, Ethics and Privacy.

We updated our public website www.st.com with a privacy portal to explain how we process the personal data of our visitors, and undertook several initiatives to strengthen our compliance with personal data protection laws and regulations.

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 of 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

We encourage everyone, including external business partners, to express 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 are comfortable about speaking up and expressing their concerns freely. All concerns raised are taken seriously.

Speak up!

culture

Our misconduct reporting 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 to internal local and corporate reporting channels, we have an independent multilingual misconduct reporting hotline. A link to our hotline is accessible on our intranet, our website (see www.st.com) and our ST Integrity app. It can be used by any employee, business partner or stakeholder.

We apply the highest standards 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

We have a Corporate Ethics Committee whose purpose is to support ST management in its efforts to foster an ethical culture consistent across all regions, functions, and organizations. This committee was formed in 2007 and is chaired by our Chief Compliance Officer, Philippe Dereeper. The committee comprises senior managers representing various Company organizations, appointed for three-year terms by our President and Chief Executive Officer. It met three times in 2020.

The role of the Corporate Ethics Committee includes:

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

Our four local committees were established to 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.