intel confidential a9 – vietnam site integrity & excellence a9 – vietnam site integrity...

Intel Confidential

A9 – Vietnam Site Integrity & Excellence 1 A9 – Vietnam Site Integrity & Excellence Intel Confidential

Intel Values and Code of Conducts

Ho Thi Thanh Hien Lam Vu Thao

19/08/2011

Intel Confidential

A9 – Vietnam Site Integrity & Excellence 2

Agenda

Intel’s Corporate Values Intel’s Code of Conduct (COC) Internal programs External activities Summary

Intel Confidential


Intel Values Customer Orientation

Clearly communicate intentions & expectations Discipline

Conduct business with uncompromising Integrity & professionalism Results Orientation

Assume Responsibility & execute flawlessly Risk Taking

Learn from our successes and mistakes Great Place to Work

Provide a safe work environment and treat each other fairly Quality

Do the right things right

Our Corp Values form the basis of our Code of Conduct

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The Intel Code of Conduct (COC) Five Basic Principles of our COC

1. Intel Conducts Business with Honesty and Integrity2. Intel Follows the Letter and Spirit of the Law3. Intel Employees Treat Each Other Fairly4. Intel Employees Act in the Best Interest of Intel and Avoid

Conflict of Interest5. Intel Employees Protect the Company's Assets and

Reputation All Intel Employees are trained on the COC

Today’s discussion will focus on principles 2 and 4.

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Following the Letter & Spirit of the LawAs a global company, Intel must comply with

US law as well as the laws of the countries in which it does business.

Where Intel’s COC differs from local laws or regulations, we must always follow the higher standard.

Some Key Areas: bribery & anti-corruption, environmental compliance, import & export compliance, Intellectual Property, etc.

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Act in the Best Interests of Intel & Avoid Conflicts of Interest

Conflicts of Interest (COI) must be avoided.A COI occurs when an employee’s personal or

family interests interfere, or appear to interfere, with the best interests of Intel.

Gifts & Entertainment – must be modest, infrequent, business related, not be a bribe, not be a conflict of interest, and must be <$25.All gov’t gifts & entertainment must get prior

approval from the Intel Legal Department

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Bribery & Anti-CorruptionForeign Corrupt Practices Act:

US law applies to US subsidiaries, imposing heavy penalties for violations;

Prohibits payment - or an offer or promise to pay – money or anything of value, directly, or through a third party to a foreign official for the purpose of influencing an official act or decision of that person in order to assist the company in obtaining or retaining business or in directing business to any person or to secure an improper advantage;

Bribery & Anti-Corruption Intel’s Policy on Bribes, Kickbacks & Commissions Is Simple:

They Are NOT Allowed Bribes and kickbacks may not be offered or solicited, whether

directly or through a third partyFCPA Training:

Annual training requirements to specified employees;

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Our values of executing flawlessly and doing the right things right

reflect our company's heritage and they will define our future. I’m

counting on you to continue playing a major role in this area – by

demonstrating uncompromised integrity in all your dealings both

with employees and external stakeholders.”

Paul OtelliniINTEL

President and CEO

Tone from the TOP

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Internal programs and mechanismTraining:

COC training as part of orientation program for new hires;

Reinforcement workshop within first six months;

Annual COC online refresh trainingCommunications:

Cartoons in weekly newsletter;Controls month: several activities like quiz,

video clip, poster contest, etc.Case study sharing

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Internal programs and mechanismTone & Accountability Program (TAP):

Excursions are tracked and documented for sharing with MMs

A network of “Business Champions” are used to bring learnings back to the business groups

BC’s feedback shared and tools/training continually improved

“Learnings Forum” available to review excursions and evaluate what can be shared with other MM’s to avoid the same mistakes

Channels for raising issues:Anonymous toolControls drop box.

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Intel’s Investigation Process

Evidence supports or refutesallegation

We have a clear investigation process

IA, Security, HR Legal, Legal

Receive Allegation

Log in Ethics DB

Determine Validity

Dispo Case Ethics DB

Define R&R

Notify Team

Assign LeadInvestigator

Interview Witnesses

Interview Subject

Collect Data/Research

Review Evidence w/Team

Formal Review: Evidence /

Recommendation with Mgmt

UpdateEthics DB

Reporting:Exec Mgmt

Audit CommitteeECOC

Team Agree Recommendation

Investigator& HR

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Step 3: If you are still not comfortable with the decision, keep asking questions, consult your manager, escalate to HR or Intel Legal, or contact [email protected].

Is this action in the best long-term interest of the company? Is this action in the best long-term interest of the company?

Is this action legal – does it follow the letter and spirit of the law?Is this action legal – does it follow the letter and spirit of the law?

Is this action in keeping with the Code of Conduct and other applicable Intel Policies and Guidelines?

Is this action in keeping with the Code of Conduct and other applicable Intel Policies and Guidelines?

No

Yes

Yes

Yes

No

No

No

No

No

Yes

Yes

Yes

STOPSTOP

STOPSTOP

STOPSTOP

Step 2: Core Value Questions These questions are necessary, but not always sufficient. If you answer no to any of the questions above, do not proceed. Even if you answer yes, you need to ask additional questions.

DISCUSSDISCUSS

DISCUSSDISCUSS

DISCUSSDISCUSS

Step 1: Core Code of Conduct Questions

Ethics & Compliance Decision TreeEthics & Compliance Decision Tree

Would you be comfortable if this action was made public? Would you be comfortable if this action was made public?

Is this action consistent with Intel’s values and global standards? Is this action consistent with Intel’s values and global standards?

Is this action consistent with Intel’s position on integrity? Is this action consistent with Intel’s position on integrity?

mailto:[email protected]

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External acvitivities • Supplier Training

• Set clear expectations and deliver necessary warnings

• COC MOU with SHTP:• Intel announced the construction of a $1B Semi-

conductor Assembly-Test plant in Vietnam in 2006• Vietnam’s CPI suggested that ethics needed to be

a strong focus area• Local Government displayed a willingness to

discuss ethical challenges• Parties entered an MOU on doing business

ethically

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Intel & Saigon High Tech Park-Sign MOU

Ken Fairfax – US Consul General; Rick Howarth – GM of Intel; Mr. Nguyen Dinh Mai – President of SHTP; Mr. Pham Van Bay – Representative of District 9 Government

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Q & A

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