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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 1 Intel Confidential 19/08/2011
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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 2 Agenda Intel’s Corporate Values Intel’s Code of Conduct (COC) Internal programs External activities Summary
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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 3 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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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 4 The Intel Code of Conduct (COC) Five Basic Principles of our COC 1. Intel Conducts Business with Honesty and Integrity 2. Intel Follows the Letter and Spirit of the Law 3. Intel Employees Treat Each Other Fairly 4. Intel Employees Act in the Best Interest of Intel and Avoid Conflict of Interest 5. 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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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 5 Following the Letter & Spirit of the Law As 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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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 6 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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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 7 Bribery & Anti-Corruption Foreign 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 party FCPA Training: Annual training requirements to specified employees ;
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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 8 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.” 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 Otellini INTEL President and CEO Tone from the TOP
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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 9 Internal programs and mechanism Training: COC training as part of orientation program for new hires; Reinforcement workshop within first six months; Annual COC online refresh training Communications: Cartoons in weekly newsletter; Controls month: several activities like quiz, video clip, poster contest, etc. Case study sharing
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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 10 Internal programs and mechanism Tone & 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 tool Controls drop box.
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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 11 Intel’s Investigation Process Evidence supports or refutes allegation 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 Lead Investigator Interview Witnesses Interview Subject Collect Data/ Research Review Evidence w/Team Formal Review: Evidence / Recommendation with Mgmt Update Ethics DB Reporting: Exec Mgmt Audit Committee ECOC Team Agree Recommendation Investigator & HR
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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 12 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 ask.ethics@intel.com. 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 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 Tree 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 position on integrity?
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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 13 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 Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 14 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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Intel Confidential A9 – Vietnam Site Integrity & Excellence A9 – Vietnam Site Integrity & Excellence 15 Q & A
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