SOITEC 31062021 Pierre Jayet003 2

Ethics

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CEO Statement

"Soitec keeps growing and has become a large multinational group, and a key player of the microelectronics value chain, permanently creating industry standards by making possible the adoption of innovative technologies. This growth goes hand in hand with our commitment to sharing the values that underpin our identity with our employees, customers, suppliers, partners and other stakeholders with whom we interact.

As defined in Soitec’s corporate purpose, "we are the innovative soil from which smart and energy efficient electronics grow into amazing and sustainable life experiences".

Our Code of conduct, based on this commitment, in conjunction with the Group Policies, defines our values, our principles and the expectations we place on our employees, business partners and stakeholders in order to maintain the highest standards of integrity, respect of people and the environment, health and safety when carrying on our business and activities.

Compliance with our Code of conduct and Group Policies is mandatory and Soitec will not tolerate any violation. Our Code of conduct and Group Policies are cornerstone to our Group sustainable growth and success, and you can count on me and the management as we count on each of you to comply and promote them."

Pierre BARNABÉ

Chief Executive Officer

Our Code of Conduct

Soitec is committed to its values and to the highest standards set by law and the semiconductors industry. Soitec’s Code of conduct illustrates this commitment by setting out the rules and ethical values that we commit to respect in the conduct of our business, and that we expect each and all of our stakeholders to adhere to.

Our Code of conduct is articulated around three key principles:

  • Complying with human rights, health, and environment highest standards;

  • Operating safely and protecting our assets;

  • Acting with integrity.

These principles and rules must guide each and all of us in our behavior, decision-making and activities, and Soitec does not tolerate any deviation from them.

Our policies and procedures

In addition to its Code of conduct, the Soitec group is committed to developing a compliance program through the implementation of specific internal policies and procedures to ensure all employees understand how to meet ethics expectations. These policies and procedures more particularly focus on:

Our compliance program

Each year, our compliance team establishes a specific action plan under the supervision of the Audit and Risks Committee and the Environmental, Social and Governance Committee of the Board of Directors in order to raise awareness of the risks to which the group is exposed in the conduct of its activities and to train them to comply with the rules defined by law and in its dedicated internal procedures. More specifically:

  • New Soitec employees are required to complete an online training course on the Code of Conduct upon their on-boarding. As of March 31, 2023, 72% had completed the training, with the objective of reaching a rate of 100%.

  • 88% of employees exposed to antitrust risk were trained in FY23.

  • Employees exposed to the risk of corruption (sales, purchasing, HR, finance, etc.) will receive anti-corruption training before June 30, 2023.

  • An e-learning module on export control rules will be deployed in the first half of FY24 to all relevant employees.

Our organization

To support the monitoring of our compliance program, a specific governance has been implemented at different levels within the Soitec group:

  • At the Board of Directors’ level, the Audit and Risks Committee as well as the Environmental, Social and Governance Committee, are in charge of setting the Board’s ambitions and objectives in terms of compliance, and are closely involved in external and internal control and risk management assignments;

  • The Executive Committee is involved in setting objectives in line with the expectations of our stakeholders as well as in the program’s rollout and in the monitoring of related actions;

  • A team composed of different experts is in charge of implementing our compliance program.

Our ethics alert system

The Soitec group is committed to a “speak up” culture of trust and honest communication, and encourages everyone, including external stakeholders, to report, in good faith, any concerns they might have regarding suspected violations of our Code of conduct, Group Policies, or the law.

Suspected misconducts can be reported on the Maât platform. Reports, which may be submitted anonymously, are treated on a confidential basis and people who speak up are protected against retaliation measures. Our ethics alert procedure is appended to Soitec’s Code of conduct.