Standards of Business Conduct
Standards of Business Conduct
TABLE OF INTRODUCTION MOST VALUED WINNING TEAM RESPONSIBILITY WORLD CLASS RESOURCES 2 CONTENTS PARTNER & INTEGRITY PERFORMANCE Back Next Last Page Table of Contents 3. Introduction 4. Leader Messages 5. Expectations 6. Speaking Up MOST VALUED PARTNER tner Wi WINNING TEAM OUR STANDARDS Par nni OUR STANDARDS 8 We protect intellectual property ed ng T 11 We continually build a culture and confidential information alu ea of inclusion and integrity 8 We protect our innovation V m 11 We create and maintain a positive, 9 We protect our information t safe and productive work s Collaborate Achieve environment systems o broadly to solve great results 11 We honor our commitments 9 We honor our commitment to M customer high-value together to human rights privacy and safeguarding data problems faster in an environment and better where employees 12 We commit to sustainability, do their best and we support our communities OUR CORE VALUES 14 We support a fair and open R 18 We are committed to quality securities market e e 18 We compete fairly 15 We prohibit all forms of corruption sp c 18 We communicate accurately 15 We avoid conflicts of interest o Operate Create an 19 We choose suppliers with 16 We comply with international n with mutual trust and competitive integrity trade regulations respect to make a advantage and m si r 19 We work responsibly with 16 positive contribution deliver superior We adhere to government b fo business partners contracting requirements ili to the industry and results that generate r 19 We uphold our standards 16 We keep accurate records ty community value and fuel Pe OUR STANDARDS & growth s OUR STANDARDS Int las RESPONSIBILITY & INTEGRITY egrity orld C WORLD CLASS PERFORMANCE W
TABLE OF INTRODUCTION MOST VALUED WINNING TEAM RESPONSIBILITY WORLD CLASS RESOURCES 3 CONTENTS PARTNER & INTEGRITY PERFORMANCE Back Next Last Page Leader Messages Expectations Speaking Up Introduction
TABLE OF INTRODUCTION MOST VALUED WINNING TEAM RESPONSIBILITY WORLD CLASS RESOURCES 4 CONTENTS PARTNER & INTEGRITY PERFORMANCE Back Next Last Page Chief Executive Officer Chief Legal Officer Gary Dickerson Teri Little At Applied Materials, our innovations At Applied, we are privileged and Make Possible® a Better Future. Over proud to do business in many the past five decades, we have built countries around the world. As a a reputation for being an innovation global company, we are subject to leader, a responsible corporate citizen a number of laws and regulations, and a great place to work. At the and are committed to respecting foundation of our success is a strong sense of purpose and a set of and complying with them in all jurisdictions where we do business. shared values – to be the most valued partner, to work as a winning team, to act with responsibility and integrity, and to deliver world Our Standards of Business Conduct is instrumental in our ability to class performance. do that. It reflects our core values, as well as the policies, procedures and conduct that guide us every day, in everything we do. Acting with As we work together to Make Possible a Better Future, operating integrity, demonstrating a culture of inclusion, and complying with with the utmost integrity in all aspects of our business is vital to laws – putting our values into action – is how we, individually and our success. The Standards of Business Conduct is our guidebook collectively, protect and preserve our company’s reputation. for acting responsibly and ensuring the highest ethical standards in our interactions with colleagues, customers, suppliers and the communities where we work and live. It is the responsibility of everyone – including our executives, officers, Board of Directors, Teri Little and each and every employee – to read, understand, and comply Senior Vice President, Chief Legal Officer and Corporate Secretary with these Standards, as well as other Company policies. Applied Materials, Inc. Gary E. Dickerson President and Chief Executive Officer Applied Materials, Inc.
TABLE OF MOST VALUED RESPONSIBILITY WORLD CLASS CONTENTS INTRODUCTION PARTNER WINNING TEAM & INTEGRITY PERFORMANCE RESOURCES Back Next Last Page 5 Expectations of our leaders Expectations of each other Expectations of our Everyone at Applied is responsible for Applied relies on each of us to conduct business partners adhering to our Standards of Business ourselves with the utmost integrity and We expect our business partners to adhere Conduct. Our directors and officers, as professionalism in our interactions with each to our Standards of Business Conduct as well as other executives and members of other, with our business partners, and when well. We seek out partners who share our management, have a special responsibility to representing Applied. values and high standards for integrity and lead by example and model our core values professionalism. When providing goods and day-in and day-out. services or acting on our behalf, all partners are required to understand and comply with Leaders’ responsibilities: Our responsibilities: the Applied Materials Standards of Business ■ Lead by example. Set the tone for ■ Be accountable. Read, appreciate and Conduct for Business Partners. integrity within your team, not just through comply with the policies and procedures words, but through your daily actions. that apply to your roles and functions. ■ ■ Communicate expectations. Talk to Speak up. Ask questions and seek help your team about making ethical decisions, when we need it. Raise concerns if we see acting with integrity, and the importance of behavior inconsistent with our values, understanding the policies that apply standards, and policies. to them. ■ Cooperate and protect. If asked to ■ Be clear in your messages. Set participate in a company investigation, we expectations that are clear and consistent all must cooperate. Be open and truthful, with our values. Doing what is right is an protect confidentiality, and preserve expectation. company records if asked to do so. ■ Create a safe and respectful ■ Exercise oversight. When managing our environment. Take steps to make sure business partner relationships, make sure your team is comfortable raising concerns they are aware of our values, policies, and and feels heard when they do. expectations.
TABLE OF MOST VALUED RESPONSIBILITY WORLD CLASS CONTENTS INTRODUCTION PARTNER WINNING TEAM & INTEGRITY PERFORMANCE RESOURCES Back Next Last Page 6 What is the Ethics Helpline? It takes courage to speak up when something is not right. We understand We ask questions and We speak up, even when We do not tolerate that employees and business partners raise concerns it’s hard retaliation might be uncomfortable and anxious. That’s why we have established the If we witness or are asked to engage in If one of us is asked to engage in, or witness Applied prohibits any retaliation against Ethics Helpline. conduct that is not consistent with Applied’s others engaging in, conduct that is not anyone for asking questions or reporting The Ethics Helpline is available 24 hours values or policies, we are expected to speak consistent with Applied’s values or policies, we issues in good faith. We should feel free to ask a day, 7 days a week and is staffed up and seek guidance, and will be supported are expected to speak up and seek guidance, a question, make a report, or participate in by professionals who speak 11 when doing so. and can expect to be supported in doing so. any investigation without fear. different languages. It is managed by There are many resources available to assist While it is not always easy to come forward If you feel you, or someone else, has been an independent service provider that you with questions or concerns. with concerns, especially when we feel retaliated against, you should immediately provides confidential and anonymous ■ Your manager should be available to listen uncertain whether something is a violation, it contact your manager, Global Ethics & reporting services to companies around and address your concerns. is important to do so. Compliance or another member of the Legal the world. If you use the Ethics Helpline, Applied takes all reports seriously and treats & Compliance Organization, Global Employee the independent service provider ■ Relations, Human Resources, or Global will send a report to Global Ethics & You can always reach out directly to Global them with sensitivity and discretion. Ethics & Compliance or another member of Internal Audit. Compliance. the Legal & Compliance Organization. Anyone who retaliates against those who In certain countries, anonymous ■ speak up in good faith will be disciplined, up reporting is not available due to You can also reach out to Global Employee applicable laws. You can still contact Relations, Human Resources or Global to and including termination. Internal Audit. Global Ethics & Compliance at [email protected] or another member of the Legal & Contact Us Compliance Organization, Global [email protected] Employee Relations, Human Resources helpline.appliedmaterials.com or Global Internal Audit.
TABLE OF INTRODUCTION MOST VALUED WINNING TEAM RESPONSIBILITY WORLD CLASS RESOURCES 7 CONTENTS PARTNER & INTEGRITY PERFORMANCE Back Next Last Page IP and Confidential Information Innovation Information Systems Privacy and Data Most Valued Partner … collaborate broadly to solve customer high-value problems faster and better
TABLE OF MOST VALUED RESPONSIBILITY WORLD CLASS CONTENTS INTRODUCTION PARTNER WINNING TEAM & INTEGRITY PERFORMANCE RESOURCES Back Next Last Page 8 WE COLLABORATE BROADLY TO SOLVE CUSTOMER HIGH-VALUE PROBLEMS FASTER AND BETTER. WE BUILD TRUST BY MEETING OUR COMMITMENTS AND RELENTLESSLY SAFEGUARDING IP AND DATA. DID YOU KNOW? Confidential Information (also referred to as CI) is any business or technical information belonging to Applied, its customers, suppliers We protect intellectual property and We protect our innovation or other third parties that is not publicly known or that has been provided or received under an confidential information All inventions, whether patentable or not, that our employees obligation of confidentiality. They are the bedrock of our innovation and drive our competitive innovate are the property of Applied Materials. An exception to this APPLIED VALUES IN ACTION advantage in the marketplace. We all have a responsibility to rule is for inventions that are not related in any way to Applied’s Can I share confidential information with protect this information from theft and unintended disclosure. products, research or business, are developed entirely on an other Applied employees? In addition, we are responsible for respecting and protecting the employee’s own time, and are developed without the use of any of You should only share confidential information intellectual property rights of our customers, suppliers, and other Applied’s assets, equipment, facilities, or resources. with employees who are authorized to see it and third parties with whom we do business. Under no circumstances have a need to know the information as part of do we improperly acquire or attempt to acquire the proprietary or After conceiving an invention, employees are expected to promptly their job duties. confidential information of others. submit an Invention Disclosure Form to the patent management FIND OUT MORE: system (IPMatters/), even if they are unsure whether the invention If we need to disclose confidential information to any company or is patentable or will be used in a product. Global Social Media Policy person, we first obtain the appropriate authorization and ensure Management of Confidential Information a non-disclosure agreement approved by the Legal & Compliance Protection of Trade Secrets Organization has been executed. We also seek guidance from the ipmatters/ Legal & Compliance Organization before requesting confidential vip/ information from an external party.
TABLE OF MOST VALUED RESPONSIBILITY WORLD CLASS CONTENTS INTRODUCTION PARTNER WINNING TEAM & INTEGRITY PERFORMANCE RESOURCES Back Next Last Page 9 We protect our information systems We honor our commitment to privacy and In our dynamic business, we must use Company assets as safeguarding data DID YOU KNOW? efficiently as possible and remain alert to opportunities to improve Many countries have data privacy laws that govern the appropriate Here are some information security best practices: performance and reduce costs. We are each responsible for the collection and use of personal information. This means information • Keep computer updates current proper use of Company property, facilities, systems, and equipment. that can be used to identify an individual, either alone or when • Only open emails from known senders In addition, we are each responsible for protecting the resources combined with other identifying information, such as email address, • Request permission before installing software entrusted to us. We protect the security of our technology systems physical address, government identification number, or phone • Do not bypass security controls and networks from cybersecurity threats, hacking, service denial number. We recognize the importance that our employees place on • Do not use unauthorized removable storage devices • Keep passwords secure, never share them attacks, ransom demands and theft by adhering to policies and their personal information, and we are committed to fairly, sensitively • Do not trust public Wi-Fi (at airports, hotels, etc.) infosec alerts. and respectfully collecting and using this data while incorporating the • Avoid commingling business and personal files core data privacy principles of lawfulness, transparency, and security. Personal Information is any information relating to If we become aware of a potential or actual cybersecurity issue, we an identified, or identifiable, natural person, or other will immediately report this to the GIS Service Desk. We believe responsible stewardship of personal information and information that constitutes personal data under data helps maintain trust in Applied – whether personal information any applicable law. This includes, for example, name, We use Applied’s systems only for business purposes or incidental of our employees, customers, or other third parties with whom we contact information, national identification number, personal use for lawful, non-commercial activities. We take employee ID, face, fingerprints or handwriting, digital reasonable care and exercise sound judgment about such use do business. We help to maintain that trust by being respectful and identity, birthdays, and IT user credentials. while maintaining our obligation to protect our intellectual transparent, and by following our policies and all applicable data APPLIED VALUES IN ACTION property and confidential information. Because our technology privacy laws, when collecting, using, processing, storing, or disclosing systems are owned and controlled by Applied and are intended for personal information. Can I use my company computer to check my personal email and blogs? business uses, we have no expectation of privacy, subject to local As Applied employees, each of us is responsible for ensuring Some incidental personal use of company resources law and policy, with respect to any communication and data. This compliance with applicable laws and regulations, contractual is permitted, but if you wish to engage in discussion includes the information that we access, store, or transmit through obligations, and company policies when handling personal or promotion of political, social, religious, personal, the systems, networks, and devices during the course of our information and business partner data. When questions, issues, financial, or commercial views, you must do so on employment with Applied. or concerns arise, we consult a member of the Privacy & Data non-work personal time using your own personal email account and equipment. We ensure personal use of Applied’s systems does not conflict Governance team or others in the Legal & Compliance Organization. FIND OUT MORE: with the company’s interests, violate these Standards of Business Conduct, create security or legal risk, or associate the company with Document Retention Policy religious, political, or commercial messages that it has not approved. Global Internal Privacy Policy Global Security Image Taking & Audio Recording Policy Information Systems Security Governance Policy help/ privacy/
TABLE OF INTRODUCTION MOST VALUED WINNING TEAM RESPONSIBILITY WORLD CLASS RESOURCES 10 CONTENTS PARTNER & INTEGRITY PERFORMANCE Back Next Last Page Culture of Inclusion Work Environment Human Rights Sustainability Winning Team … achieve great results together in an environment where employees do their best
TABLE OF MOST VALUED RESPONSIBILITY WORLD CLASS CONTENTS INTRODUCTION PARTNER WINNING TEAM & INTEGRITY PERFORMANCE RESOURCES Back Next Last Page 11 WE ACHIEVE GREAT RESULTS TOGETHER IN AN ENVIRONMENT WHERE EMPLOYEES ARE SUPPORTED AND ABLE TO DO THEIR BEST WORK. DID YOU KNOW? WE LEVERAGE OUR TALENT TO BRING HIGH QUALITY PRODUCTS AND SERVICES TO THE MARKET. It is unlawful to make workforce-related decisions based on race, color, national origin, ancestry, religion, age, sex (including pregnancy, We continually build a culture of inclusion We create and maintain a positive, childbirth, or related medical conditions), sexual and integrity safe and productive work environment orientation, gender identity, marital status, physical disability, mental disability, medical condition, genetic information, family care We are inclusive in all our interactions and leverage our diversity and We share the responsibility for promoting teamwork and leave status, veteran status, or any other basis integrity to solve problems and innovate. We act with respect for cooperation, as well as maintaining a work environment in which prohibited by law. our colleagues and promote an inclusive, positive workplace where discrimination, harassment, and unsafe work practices are not APPLIED VALUES IN ACTION everyone feels a sense of belonging. We take action to increase tolerated. We use only merit and job criteria, such as experience and employment opportunities for women, underrepresented minorities, performance, in decisions regarding recruitment, hiring, promotion, Employees who know or suspect that they or people with disabilities, and veterans. We provide reasonable training, compensation, benefits, termination, and social programs. someone else have experienced discrimination accommodations to qualifying employees to enable them to perform should report this immediately – either to We must each adopt safe work practices, complete required safety their manager, Global Employee Relations, the essential functions of their job. We appreciate and value the training, and comply with all health and safety laws, regulations, and Human Resources, Global Ethics & Compliance, differences of others and always treat our colleagues and business another member of the Legal & Compliance partners with the utmost respect. company policies to protect the safety, health, and general well- Organization, or Global Internal Audit. being of our workforce. FIND OUT MORE: We honor our commitments to Corporate Responsibility human rights Global Policy Against Child and/or Forced Labor We respect the human rights and dignity of people throughout our Human Resources Policy Manual operations and our global supply chain. We comply with and expect Human Rights Statement of Principles our business partners to comply with: (i) laws that promote a diverse Statement under the California Transparency workforce, safe working conditions, and individual security; (ii) laws in Supply Chain Act that prohibit forced labor, the employment of underage children, ehs/ and human trafficking; and (iii) laws that prevent discrimination er/ against employees and workers based on their engagement in any lawful association. Our commitment and approach to these issues are demonstrated in our Human Rights Statement of Principles.
TABLE OF MOST VALUED RESPONSIBILITY WORLD CLASS CONTENTS INTRODUCTION PARTNER WINNING TEAM & INTEGRITY PERFORMANCE RESOURCES Back Next Last Page 12 We commit to sustainability, and we support our communities We believe in taking meaningful action to advance our vision of making the world a better place. Caring for the environment is part of our DID YOU KNOW? corporate responsibility to current and future generations. Our holistic approach to sustainability considers our direct impact and how we run our The Applied Materials Foundation works business (1X), our industry’s impact and that of our customers and suppliers (100X), and how our technology can be used to advance sustainability with nonprofits to advance education, civic on a global scale (10,000X). engagement, arts and culture, the environment and girls’ empowerment. Through the foundation’s We are committed to contributing to the communities in which we do business and living up to a shared vision of leaving the world a better place. matching grant and volunteer programs, our As part of that commitment, we maintain a corporate philanthropy program to support organizations and activities in these communities and employees are able to make a valuable impact on ensure that our program complies with all applicable governmental guidelines, as well as internal policies. our communities. APPLIED VALUES IN ACTION What if I would like to make a donation to a local charity in lieu of giving a gift to a business partner? How should I proceed? You must first obtain pre-approval by completing and submitting the Corporate Donations Form, which will then be routed to your manager, Communications & Public Affairs (C&PA), and Global Ethics & Compliance for approval. FIND OUT MORE: Corporate Donations Form Corporate Responsibility RBA Code of Conduct esg/ ethics/ giving/
TABLE OF INTRODUCTION MOST VALUED WINNING TEAM RESPONSIBILITY WORLD CLASS RESOURCES 13 CONTENTS PARTNER & INTEGRITY PERFORMANCE Back Next Last Page Insider Trading Anti-Corruption Conflicts of Interest International Trade Government Contracts Accurate Records Responsibility & Integrity ... operate with mutual trust and respect to make a positive contribution to the industry and community
TABLE OF MOST VALUED RESPONSIBILITY WORLD CLASS CONTENTS INTRODUCTION PARTNER WINNING TEAM & INTEGRITY PERFORMANCE RESOURCES Back Next Last Page 14 WE OPERATE WITH MUTUAL TRUST AND RESPECT TO MAKE A POSITIVE CONTRIBUTION TO THE INDUSTRY AND COMMUNITY. WE SEEK GUIDANCE WHEN NEEDED AND TAKE RESPONSIBILITY FOR OUR ACTIONS. DID YOU KNOW? WE COMPLY WITH ALL APPLICABLE LAWS AND REGULATIONS. WE ACT WITH INTEGRITY AND WE HOLD Material, non-public information can include: OURSELVES ACCOUNTABLE. • Undisclosed financial results and projections • Unannounced mergers and acquisitions We support a fair and open securities market • Unreleased products • Other information not generally known that a We do not trade securities when we have material, non-public (“inside”) information, nor do we provide such information to others. reasonable investor would consider important We may occasionally have access to information that the general public does not have and that a reasonable investor would consider important in APPLIED VALUES IN ACTION making a decision to buy, sell, or hold securities of Applied or that of our business partners. If we possess any material, non-public information of What should I do if my broker contacts me Applied or a business partner, we cannot buy or sell securities of Applied or the business partner until after the information has been disclosed to about a short sale transaction involving my the public – even if our reasons for trading are not based on that information. Applied shares? You should not engage in speculative We cannot disclose (or “tip”) material, non-public information to others, including friends, family members, or work colleagues who do not need to transactions relating to Applied’s securities, know the information and might buy or sell securities on the basis of that information. We also cannot make recommendations or express opinions including short sales, derivative securities and about Applied’s or another company’s securities on the basis of material, non-public information. other hedging transactions, or any transaction that has or is designed to have the effect of In advance of quarterly earnings releases and other special occasions, certain individuals will receive blackout notices from the Legal & Compliance hedging or offsetting any decrease in the market Organization. Recipients of a blackout notice must not trade in Applied’s securities during the specified blackout period. value of Applied’s securities. We can help to ensure a fair and open securities market by following Applied’s Insider Trading Policy and understanding the prohibitions on insider FIND OUT MORE: trading, tipping, and communications around material, non-public information. Insider Trading Policy ethics/
TABLE OF MOST VALUED RESPONSIBILITY WORLD CLASS CONTENTS INTRODUCTION PARTNER WINNING TEAM & INTEGRITY PERFORMANCE RESOURCES Back Next Last Page 15 We prohibit all forms of corruption We avoid conflicts of interest We must strictly abide by anti-corruption laws everywhere that We avoid situations where our personal interests could affect our DID YOU KNOW? Applied operates. This includes, but is not limited to, the United ability to perform our jobs or appear to place our personal interests “Government” is defined broadly and includes States Foreign Corrupt Practices Act (FCPA) and United Kingdom over Applied’s interests. We disclose any actual or potential conflict any government department, agency, office, or Bribery Act (UKBA), which prohibit all forms of bribery and of interest, as well as anything that could be perceived as a conflict. instrumentality at any level, including a government- corruption by our directors, officers, employees, agents, and others This includes the following: owned or -controlled company or a public institution acting on our behalf. This means that we never offer, promise, (such as a government-funded hospital, university, ■ You want to serve as a member of an outside board or school, or research institute), a public international accept or facilitate bribes, kickbacks, or other corrupt activities – advisory group. organization (such as the World Bank or United including money, favors, gifts, entertainment, donations or other Nations), a political party, or a royal family. Visit the benefits or gratuities that are intended to improperly influence Global Ethics & Compliance webpage (ethics/ in your ■ You or a family member have a financial interest or leadership Applied browser) to view a list of government-linked the decision-making of the recipient. This prohibition applies to position in a current or potential supplier, customer, other companies with which Applied works. both public sector and private sector interactions, but we must business partner, or competitor of Applied. APPLIED VALUES IN ACTION exercise extra caution when interacting with a Government Entity ■ or Government Official. You are involved in business activities outside of Applied, such What should I do if I am asked by a technology When exchanging gifts, meals, entertainment, or travel – or other as consulting work, part-time employment, or ownership of an start-up to join its technical advisory board? I outside business. won’t receive a salary, but I will receive stock items or experiences of value – with business partners, you must in the company, and I will have access to its ■ confidential information and intellectual review and comply with the Global Policy on Giving and Receiving You have a close personal relationship (familial or romantic) property. Is this a conflict of interest? Business Gifts, Meals, Entertainment and Travel (“GMET Policy”), with someone working for a current or potential supplier, Yes, the above situation presents a potential conflict including applicable pre-approval requirements. customer, or competitor of Applied, or a Government Official (a of interest. Global Ethics & Compliance should “Government Official” is an employee of a government agency, evaluate whether the company is an existing or government-owned or -controlled company, public institution, potential supplier, customer, or competitor of or a political candidate). Applied, or a potential acquisition or investment target. If it is, it most likely would not be approved. ■ You have a close personal relationship (familial or romantic), or FIND OUT MORE: a business relationship, with any director, officer, employee, or Conflict of Interest Disclosure Form contingent worker of Applied. Corporate Donations Form Global Ethics & Compliance reviews each disclosure, evaluates how Employment of Relatives Policy the conflict can be managed or whether the conflict is so significant Global Anti-Corruption Policy that it cannot be managed. Global Conflicts of Interest Policy Global Policy on Giving and Receiving Business Gifts, Meals, Entertainment and Travel (“GMET Policy”) GMET Approval Form ethics/
TABLE OF MOST VALUED RESPONSIBILITY WORLD CLASS CONTENTS INTRODUCTION PARTNER WINNING TEAM & INTEGRITY PERFORMANCE RESOURCES Back Next Last Page 16 We comply with international trade We adhere to government contracting regulations requirements DID YOU KNOW? Our ability to quickly deliver our products to customers, Applied sometimes enters into product or service contracts with Applied is prohibited from participating in trade wherever they operate around the world, enables Applied to the United States Government as well as governments of other boycotts that are not sanctioned by the United be the trusted supplier of choice. Applied is firmly committed countries, government agencies, and government contractors. States government. To ensure compliance with anti- to complying with all applicable import and export regulations These contracts and related procurement processes may be subject boycott laws, always have the Legal & Compliance in the countries where we do business. We uphold these trade to special regulations and impose unique requirements on the Organization review agreements, transactions, and letters of credit that contain potential boycott- policies and procedures to avoid serious consequences to the Company and our workforce. If involved in the bidding process for related language. company such as product delivery delays, increased audits, government contracts or performance under those contracts, we APPLIED VALUES IN ACTION seized merchandise, fines, loss of reputation, loss of export must understand any special rules and seek guidance as needed and import privileges, and even criminal penalties. from the Legal & Compliance Organization. What should I do if I feel pressured to “make the numbers work”? When engaging in international business activities, you We keep accurate records Your first responsibility is to record and report should refer to Applied’s internal Global Trade site to further information accurately and honestly. If you feel understand Global Trade’s policies and procedures. If at any Applied is a public company with an obligation to maintain accurate pressure to do otherwise, speak with someone in time you are unclear about international trade requirements, financial records and issue accurate reports to its shareholders and Global Ethics & Compliance or another member of you should first contact Global Trade with any questions the U.S. Securities and Exchange Commission (SEC). We adhere to the Legal & Compliance Organization. You always the company’s financial controls and policies as well as to generally have the option of contacting the Ethics Helpline, or concerns. anonymously if you prefer. accepted accounting principles. We do not make, or induce others to make, false or misleading entries, reports or documentation in FIND OUT MORE: connection with expenses, expenditures, or other transactions, or ethics/ in connection with any other employment or business record. globaltrade/ legal/
TABLE OF INTRODUCTION MOST VALUED WINNING TEAM RESPONSIBILITY WORLD CLASS RESOURCES 17 CONTENTS PARTNER & INTEGRITY PERFORMANCE Back Next Last Page Quality Fair Competition Communications Supplier Integrity Business Partners Upholding Our Standards World Class Performance … create competitive advantage and deliver superior results that generate value and fuel growth
TABLE OF MOST VALUED RESPONSIBILITY WORLD CLASS CONTENTS INTRODUCTION PARTNER WINNING TEAM & INTEGRITY PERFORMANCE RESOURCES Back Next Last Page 18 WE PERFORM AMBITIOUSLY AND WITH UNCOMPROMISING INTEGRITY TO DELIVER EXCEPTIONAL PRODUCTS, SERVICES, AND BUSINESS RESULTS. DID YOU KNOW? We are members of the Responsible Business Alliance, “the world’s largest industry coalition dedicated to social responsibility in global We are committed to quality We communicate accurately supply chains.” At Applied, quality and continual improvement are everyone’s Unless specifically authorized, we do not communicate on matters APPLIED VALUES IN ACTION responsibility. We focus on delivering reliable products, quality related to Applied with the media, government representatives, What if I become aware of any side deal services, and innovative solutions that meet requirements investors, analysts, or other interested parties. We refer all inquiries made outside of the required contract and delight our customers. We are dedicated to creating and from the press or media about the Company to Media Relations. approval process? maintaining a culture where defect prevention is a routine part We also refer all requests for Applied participation in third-party If you become aware of any side deal, side letter, or agreement made outside of the of everyone’s job. Delivering quality and reliability solutions to press releases, including those from customers and partners, to required contract approval process, report our partners and customers is central to Applied’s competitive Media Relations. We recognize that social media provides unique it promptly to your manager, Global Ethics & advantage. opportunities to listen, learn, and engage with others. We use Compliance, or other member of the Legal & discretion and sound judgment when posting communications Compliance Organization. We compete fairly on social media that reference or could be viewed as relating FIND OUT MORE: Applied is committed to competing fairly and winning business to Applied. We recognize that as employees, our posts can be Global Social Media Policy in an ethical and legal manner by delivering quality products understood to represent the Applied Materials brand. RBA Code of Conduct and services in compliance with all applicable antitrust and Before posting on social media, we should know and adhere to Social Media Guidelines competition laws. We do not use unfair or deceptive practices to Applied’s Global Social Media Policy and Social Media Guidelines quality/ gain advantage over our competitors. and always make it clear that your views are your own and not Our teams work closely with the Legal & Compliance those of Applied. Organization when entering into a new relationship to ensure all terms and conditions are formally documented, defining the rights, obligations, and liabilities of Applied and the other party, as well as the accounting treatment for the particular transaction. We do not make any oral or written commitment that creates a new agreement or modifies an existing agreement without obtaining approvals from the Legal & Compliance Organization and Finance, as well as following other required processes.
TABLE OF MOST VALUED RESPONSIBILITY WORLD CLASS CONTENTS INTRODUCTION PARTNER WINNING TEAM & INTEGRITY PERFORMANCE RESOURCES Back Next Last Page 19 We choose suppliers with integrity We uphold our standards We strive to do business only with business partners that share At Applied, we are committed to upholding our shared values our values and our commitment to conducting business with and take violations of these Standards and our policies seriously. integrity and in compliance with the law. We make sure that our Non-compliance can have serious consequences to Applied’s extended supply chains do not include companies that abuse reputation for honest and fair business dealings. Violations of these human rights, harm the environment, source materials unethically, Standards, our Company policies, and the law can also carry serious or engage in unlawful or unethical behavior. consequences to the individuals involved, including disciplinary ■ We select suppliers based exclusively on their business action up to and including termination and possibly civil and practices, services, and products. criminal personal liability. ■ We build positive relationships with our suppliers built on trust, Waivers respect, and collaboration. Any waiver of the Standards of Business Conduct for an executive ■ We expect our suppliers to do business ethically and lawfully. officer or a director may be made only by the Board of Directors and must be promptly disclosed as required by law. ■ We deal objectively and honestly with our suppliers and compete fairly in the marketplace. We work responsibly with business partners At Applied, we are proud of our reputation for integrity and fairness in our commercial dealings with our customers, suppliers, and industry peers. When we engage in commercial dealings, we must ensure that we always treat our business partners in an ethical and respectful manner consistent with our Standards of Business Conduct.
TABLE OF INTRODUCTION MOST VALUED WINNING TEAM RESPONSIBILITY WORLD CLASS RESOURCES 20 CONTENTS PARTNER & INTEGRITY PERFORMANCE Back Last Page Resources 24-HOUR ETHICS HELPLINE Report concerns (includes option to report anonymously in most countries) helpline.appliedmaterials.com GLOBAL ETHICS & COMPLIANCE WEBSITE Ethics and compliance policies, procedures, and tips Go to ethics/ in your internal browser ASK QUESTIONS OR REPORT CONCERNS Asking questions or reporting concerns [email protected] CONTACTS Directly discuss your questions or concerns Global Ethics & Compliance Legal & Compliance Organization Global Employee Relations Human Resources Global Internal Audit COMPLIANCE CHAMPIONS Your Business Unit’s Compliance Champion is your primary contact for Ethics & Compliance, Confidential Information and Intellectual Property management related questions Go to vip/ in your internal browser to see the list of Compliance Champions