Intel Code

of Conduct

MARCH 2020
MARCH 2020
Table of Contents

A Culture of Uncompromising Integrity ............................................................... 1

Our Values ...................................................................................................... 2
Your Responsibility ........................................................................................... 3
Code Principles ................................................................................3
Asking Questions and Reporting Concerns ........................................................... 4
Ways to Seek Guidance and Report Concerns ........................................ 4
Non-Retaliation Policy ....................................................................... 5
Conduct Business with Honesty and Integrity....................................................... 6
Communicating Clearly and Professionally in Business ............................ 6
Conducting Business with Customers, Suppliers, Distributors and Others ... 6
Being a Responsible Corporate Citizen ................................................. 6
Preparing Accurate Financial and Other Records .................................... 7
Follow the Letter and Spirit of the Law ................................................................ 7
Antitrust .........................................................................................8
Bribery and Anti-Corruption ............................................................... 8
Environmental, Health and Safety ....................................................... 9
Product Safety & Regulatory............................................................... 9
Import and Export Compliance ........................................................... 9
Insider Trading .............................................................................. 10
Intellectual Property ....................................................................... 10
Privacy ......................................................................................... 11
Public Communications .................................................................... 11
Treat Each Other Fairly ................................................................................... 12
Open and Honest Communication...................................................... 12
Equal Employment Opportunities and Diversity.................................... 12
Anti-Harassment ............................................................................ 12
Respect for Human Rights ................................................................ 12
Safety .......................................................................................... 13
Workplace Violence ......................................................................... 13
Act in the Best Interests of Intel and Avoid Conflicts of Interest ........................... 13
Handling Conflicts of Interest ........................................................... 14
Gifts, Meals, Entertainment, and Travel .............................................. 14
Protect the Company’s Assets and Confidential Information ................................. 15

MARCH 2020
 Protecting Physical Assets ................................................................ 15
Protecting Confidential Information ................................................... 15
Safeguarding Trademarks and Brands ................................................ 16
Representing Intel .......................................................................... 16
Approvals and Waivers.................................................................................... 16
Reminders ..................................................................................................... 16
Code of Conduct Glossary Terms and Definitions ................................................ 18

MARCH 2020
 INTEL CODE OF CONDUCT

A Culture of Uncompromising Integrity

Since the company began, uncompromising integrity and professionalism
have been the cornerstones of Intel's business. In all that we do, Intel
supports and upholds a set of core values and principles. Our future growth
depends on each of us understanding these values and principles and
continuously demonstrating the uncompromising integrity that is the
foundation of our company.
The Code of Conduct sets the standard for how we work together to develop
and deliver product, how we protect the value of Intel and its subsidiaries
(collectively known as ‘Intel’), and how we work with customers, suppliers,
distributors and others. All of us at Intel must abide by the Code, our
Employment Guidelines, and other applicable policies when conducting Intel-
related business.

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Our Vision
If it is smart and connected, it is best with Intel.

Our Values

Customer Orientation Risk Taking

• Listen and respond to our customers, • Embrace a growth mindset in
suppliers and stakeholders everything we do
• Clearly communicate mutual • Foster innovation and creative
intentions and expectations thinking
• Deliver innovative and competitive • Embrace change and challenge the
products and services status quo
• Make it easy to work with us • Listen to all ideas and viewpoints
• Excel at customer satisfaction • Learn from our successes and
mistakes
• Encourage and reward informed risk
taking
An Inclusive, Great Place to
Work
Discipline
• Create an inclusive work environment
• Conduct business with
that fosters diversity
uncompromising integrity and
professionalism • Treat one another equally, with
dignity and respect
• Ensure a safe, clean and injury-free
workplace • Be open and direct
• Make and meet commitments • Promote a challenging work
environment that develops our
• Properly plan, fund and staff projects
workforce
• Pay attention to detail
• Work as a team with respect and
• Keep Intel information secure trust for each other
• Win and have fun
• Recognize and reward
accomplishments
• Manage performance fairly and firmly
• Be an asset to our communities
worldwide
Quality Results Orientation
• Achieve the highest standards of • Set challenging and competitive goals
excellence • Focus on output
• Do the right things right • Assume responsibility
• Continuously learn, develop and • Constructively confront and solve
improve problems
• Take pride in our work • Execute flawlessly

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Your Responsibility
Intel’s Code of Conduct applies to all employees and sets expectations for
Intel Corporation and its subsidiaries (referred to collectively as ‘Intel’) as
well as our non-employee members of the Board of Directors regarding their
Intel-related activities. The Code of Conduct also applies to independent
contractors, consultants, suppliers and others who do business with Intel;
those that do business with Intel can establish more restrictive policies, but
cannot operate under less restrictive policies.
Specifics on seeking guidance and reporting ethical concerns, as well as other
specifics, such as supplemental policies or guidelines related to this Code of
Conduct, may differ by company and/or country and are subject to local
laws.
Employees are encouraged to review the Code of Conduct Frequently Asked
Questions and other related resources for further guidance. If you have
questions on how the Code of Conduct may apply, please contact Legal or
Ask Ethics.
Each employee is responsible for reading, understanding, and following the
Code. Employees who violate the Code are subject to discipline, up to and
including termination of employment. Anyone who violates the law may also
be subject to civil and criminal penalties.

Code Principles
The Code affirms Intel’s five principles of conduct:
• Conduct business with honesty and integrity. Conduct business
with uncompromising integrity and professionalism, demonstrating
honesty and high ethical standards in all business dealings and
treating customers, suppliers, distributors, and others with fairness,
honesty and respect.
• Follow the letter and spirit of the law. Ensure that business
decisions comply with all applicable laws and regulations of the many
countries in which Intel does business.
• Treat each other fairly. Work as a team with respect and trust for
each other.
• Act in the best interests of Intel and avoid conflicts of interest.
Avoid situations where our personal or family interests interfere — or
even appear to interfere—with our ability to make sound business
decisions in the best interest of Intel.
• Protect the company’s assets and confidential information.
Protect the value of Intel’s assets, including physical assets,
intellectual property, confidential information, Intel brands, and its
name and reputation as well as the confidentiality of information of our
customers, suppliers and employees.

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Asking Questions and Reporting Concerns

To help our company conduct business with uncompromising integrity and
professionalism, every employee has an obligation to report possible
violations of the law, the Code, and other company guidelines.
Managers and employees who learn of a possible violation of law, regulation,
or Intel legal policy must immediately report that concern to Legal or Internal
Audit.

Ways to Seek Guidance and Report Concerns

Because the Code cannot address every situation, you should seek guidance
whenever you are unsure about the correct course of action. There are many
ways to ask questions about the Code or report concerns:
• In accordance with Intel’s Open Door Guideline, you can ask questions
and report concerns about the Code with any manager, such as your
direct manager, a department head, a division general manager, or
another manager up to and including the Executive Office;
• You can ask questions or report concerns with internal groups who
specialize in handling such issues, including Human Resources,
Internal Audit, Legal, Corporate Security, Information Security, or your
group or site Ethics & Compliance Business Champion;
• You can find answers to your questions at the Ask Ethics portal; and
• You can report an ethics or compliance or safety concern online or by
phone through the Intel Ethics and Compliance Reporting Portal, which
is hosted by a third party and allows anonymous reporting where
permitted by law.
Employees of Intel subsidiaries may have additional reporting channels for
asking questions and reporting concerns.
For other work related concerns, you are encouraged to contact the
confidential reporting e-mail account at harassment.concerns@intel.com, Get
HR Help, your Human Resources representative, or Employment and Labor
Legal (ELL).
An employee does not need to be certain about a concern, have evidence of
misconduct, or even know that a violation of the Code, policy or law has
occurred to report. No matter how you choose to raise a concern, we take all
reports seriously. An Intel team will promptly review the matter to determine
what actions are appropriate based on the findings consistent with applicable
law, Intel’s Code of Conduct, and other applicable company guidelines.
All employees of Intel and its subsidiaries are required to cooperate fully with
internal investigations, including providing honest, truthful and complete
information (except where that would result in disclosure of the employee’s
participation in concerted activity under the U.S. National Labor Relations
Act). Employees who fail to do so are subject to disciplinary action up to and
including termination of employment, in accordance with applicable local

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laws. For investigations into alleged violations of the U.S. National Labor
Relations Act, an employee’s participation, while encouraged, is voluntary.

Non-Retaliation Policy
Intel does not tolerate retaliation against anyone who in good faith reports
possible violations of law, the Code, or other company policies or procedures,
questions on-going or proposed conduct, or participates in an internal
investigation. Retaliation can include, among other things, demoting,
transferring, or terminating anyone for raising a question or speaking up in
good faith about a possible violation of the Code, company policy, or law.
Employees who retaliate or attempt to retaliate against anyone who reports a
concern in good faith or participates in an internal investigation are subject
to discipline up to and including termination.
Employees who believe they have experienced retaliation should contact ELL
immediately.

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Conduct Business with Honesty and Integrity

One of our core values is to conduct business with uncompromising integrity
and professionalism. We put this value into practice by:
• Communicating clearly, respectfully, and professionally in business,
• Treating customers, suppliers, distributors, and others fairly,
• Acting as a responsible corporate citizen, respecting human rights, and
managing the impact of our business on the world around us, and
• Keeping accurate financial and other books and records.

Communicating Clearly and Professionally in Business

We value clear, accurate, respectful and professional communication in all of
our business interactions. Ambiguous and unprofessional communications –
whether oral or written – can harm Intel. Even well-intentioned
communications can be misinterpreted. Examples of communications include
email, presentation materials, voicemails, text messages, and instant
messaging, as well as content in social media and websites.

Conducting Business with Customers, Suppliers, Distributors and

Others
Our success is based on strong relationships of mutual respect and trust with
our customers, suppliers, distributors and others. To maintain these strong
relationships, we treat everyone we deal with the way we would expect to be
treated: with fairness, honesty, and respect.
In our marketing and in our interactions with customers and potential
customers, we always represent Intel products and services fairly and
accurately.
We expect our suppliers to comply with all applicable laws and regulations,
Intel’s Code of Conduct and the corporate responsibility principles consistent
with the Responsible Business Alliance (RBA) Code of Conduct. We expect
our suppliers to hold their direct supply chain accountable to these
expectations.
Independent contractors, consultants, suppliers, distributors and others who
conduct business with Intel risk termination of their relationship with Intel for
violations of the Code.
When conducting business or engaging with the U.S. Government, Intel
employees or others acting on Intel’s behalf, must comply with requirements
set out in our Intel Policy on Doing Business with the U.S. Government.

Being a Responsible Corporate Citizen

Intel has a long-standing, global reputation as a responsible corporate
citizen. For us, corporate responsibility means achieving business success in

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ways that demonstrate respect for people and the planet and upholding the
values and high standards of ethics expressed in our Human Rights Principles
and our Environmental, Health and Safety Policy. Intel is a leader in
supporting education and enhancing the communities in which we live and
work.
As reflected in our Corporate Responsibility Report, we demonstrate respect
for people and the planet and ask all our employees to consider the short and
long-term impacts to the environment and the community when they make
business decisions. In all our activities, we need to uphold Intel’s long-
standing, global reputation as a role model for ethical and socially
responsible behavior.

Preparing Accurate Financial and Other Records

Our financial and other business records shape the business decisions we
make. We are responsible for ensuring that Intel’s books and records are full,
fair, accurate, timely, and understandable reflections of the company’s
operations and business activities.
Any records required by our jobs, such as contractual arrangements, time
cards and expense reports must be accurate, complete and properly
authorized. If questions arise, ask a direct or other manager for assistance.
If you become aware of records that may be inaccurate, report the situation
immediately to Finance or Legal. We do not support or condone preparing
false records under any circumstances.
We employ auditors to ensure that the way we conduct business and keep
records is consistent with relevant accounting standards. We must cooperate
with auditors and ensure that anyone acting under our direction also
cooperates with auditors.

Follow the Letter and Spirit of the Law

As a global company Intel must comply with the laws of the many countries
in which it does business. We are each responsible for knowing and following
all applicable laws or regulations.
We also must act in a manner that upholds the spirit and the intent of the
law. Where the Code or company guidelines differ from local laws or
regulations, we must always follow the higher standard. If you believe the
requirements of the Code conflict with local law, consult Legal.
Violations of laws and regulations have serious consequences, both for the
company and for the individuals involved. Therefore, when questions arise on
these or other legal matters, you should always seek guidance from Legal.
Some of the legal topics we encounter include antitrust, anti-corruption,
environment, import-export, insider trading, intellectual property, privacy,
and public communications.

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Antitrust
Antitrust laws encourage free competition by prohibiting certain agreements
and conduct that make it more difficult for companies to compete. Intel
complies with antitrust laws everywhere we do business. Violating an
antitrust law is a serious matter and can result in prison time for employees
and large financial penalties and reputational damage for Intel.
We compete vigorously and legally:
• We are truthful when communicating about our products and our
competitors’ products.
• We focus on what customers should do with Intel, not what they
should not do with our competitors.
• We make design decisions that are based on improvements to our
products.
• We do not agree with other companies to limit hiring or recruiting of
each other’s employees or to set employee compensation.
• We do not communicate with competitors about price, cost, terms of
sale, production levels, allocation of markets or other competitively
sensitive information.
• We do not agree with competitors not to sell to or buy from another
company.
For more guidance, read Intel’s Antitrust Policy. When questions arise,
contact Intel Legal.

Bribery and Anti-Corruption

Intel strictly prohibits all forms of bribery. Intel’s policy is to comply with all
anti-corruption laws and to accurately reflect all transactions in Intel’s books
and records. We must never offer or accept bribes or kickbacks and must not
participate in or facilitate corrupt activity of any kind. Many countries’ laws
define facilitation payments made to government officials as bribes. We do
not make facilitation payments on behalf of Intel to any government official.
Intel’s prohibition against offering, promising or paying bribes also applies to
third parties who provide services or act on Intel’s behalf, such as suppliers,
agents, contractors, consultants and distributors. We must never engage a
third party whom we believe may attempt to offer a bribe in connection with
company business. Our anti-corruption expectations for third parties are set
out in our Third Party Anti-Corruption Policy and Gifts, Meals, Entertainment
and Travel (“GMET”) Policy for Third Parties.

When doing business with governments, consult with Legal to be certain you
are aware of any special rules or laws that apply. Obtain the required
approvals in our Worldwide Business Gifts, Meals, Entertainment, and Travel

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Policy (“GMET Policy”) before providing anything of value to a Government

Official.

Environmental, Health and Safety

A number of environmental laws, standards, requirements, and policies apply
to our worldwide business operations, practices, and products. We have a
responsibility to understand and follow these requirements, including:
• Conserving energy, water, raw materials and other natural resources,
• Managing materials and wastes properly, and
• Complying with environmental permits and health and safety
requirements.
We support a precautionary approach to the materials used in our products
and strive to reduce and minimize the use of hazardous materials and the
environmental impact of our manufacturing technologies.
We expect our suppliers and others to comply with all applicable
environmental, health and safety laws and standards in their operations.

Product Safety & Regulatory

We protect people, property, and the environment through world-class
product regulatory practices. Intel is committed to the safety of its
employees, customers, and anyone who encounters our products. Our
product design teams incorporate regulatory and safety compliance into the
product regulatory lifecycle to ensure that we deliver the highest quality
products to our customers and consumers. All safety and regulatory concerns
and incidents are handled by Intel’s Product Safety and Regulatory Council.

Import and Export Compliance

In every country in which we do business, laws and regulations govern
imports and exports. Many of these laws and regulations restrict or prohibit
the physical shipment of our products or the transfer or electronic
transmission of software and technology to certain destinations, entities, and
foreign persons. In many cases, the law requires an export license or other
appropriate government approvals before an item may be shipped or
transferred.
We have a responsibility to comply with these laws and regulations.
Therefore, we must clear all goods through customs and must not:
• Proceed with a transaction if we know that a violation has occurred or
is about to occur;
• Transfer controlled software and technology unless appropriate
authorizations are obtained; or
• Apply an inappropriate monetary value to goods and services

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Violations, even inadvertent ones, could result in significant fines and

penalties, denial of export licenses, loss of export privileges, and/or customs
inspections and delays. Because these laws and regulations are complex and
unique in each country, we provide guidelines and training.

Insider Trading
Many countries have insider trading laws that restrict securities trading and
other activities by anyone who is aware of material, non-public information.
Material, non-public information is any information not generally known to
the public that a reasonable investor might find significant in executing
transactions to buy or sell securities in a company.
Any employee who is aware of material, non-public information regarding
Intel or any other company must not:
• Trade in or execute transactions regarding that company’s stock or
other securities,
• Disclose that information to others who may buy or sell securities
because of the information, or
• Otherwise use the information for personal advantage or the personal
advantage of others.
When you have regular access to material, non-public information concerning
Intel or another company, you need to take special care in planning
securities trades. Intel has guidelines and policies to help you plan
transactions consistent with the requirements of the securities laws. You can
find more information in our Insider Trading Compliance page.
Intel’s directors and employees may not invest in (buy or otherwise receive
or sell) derivatives of Intel securities, such as puts, calls, and forward
contracts, or enter into any short sales or short positions (positions that
allow the person to profit if the price of Intel securities goes down) with
respect to Intel securities, with the limited exceptions noted in Intel’s
Insider Trading Policy.

Intellectual Property
Intellectual property rights are crucial to protecting the investments that
companies and individuals make in developing new products and ideas. We
protect our intellectual property and respect the intellectual property rights of
others.
We may not copy, reproduce, or transmit protected material, such as writing,
artwork, music, video, photographs, movie clips and software unless we have
authorization or license.
We must use the confidential information of Intel or others only for business
purposes and disclose it only to those who are authorized and have a need to
know. Even after we leave Intel employment, we must continue to protect

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confidential information (whether Intel's or another party’s) and not use or

disclose it without authorization.
Furthermore, we must not request or encourage anyone to use or disclose
privileged or confidential information unless they are authorized to do so by
the owner of that information.

Privacy
Many countries have privacy laws that govern the appropriate collection and
use of personal information, which includes any information relating to an
identifiable individual such as an email address, physical address, payment
card information or government identification number.
We are committed to protecting the reasonable privacy expectations of
everyone with whom we do business, including our customers, consumers
and employees. We believe responsible stewardship of personal information
helps maintain trust in Intel and in our products and services. We recognize
the importance individuals place on the ability to control the collection and
use of their personal information. We have adopted the Intel Privacy
Principles, the Intel Corporate Privacy Rules, and Intel’s Philosophy on
Protecting Personal Information to demonstrate and define our commitment
to privacy.
As Intel employees, we each have a responsibility to comply with our privacy
and security requirements.
When questions, issues or concerns arise, consult your legal department or a
member of your privacy compliance team.

Public Communications
As a publicly traded company, Intel must comply with a variety of regulations
that govern public communications to investors and the public and promote
transparency in financial markets. Intel has specific requirements for financial
reports and documents that the company files with or submits to the U.S.
Securities and Exchange Commission and in other public communications.
Therefore, if you are responsible for preparing such reports or contributing
information for such reports, you need to ensure that the disclosures are
accurate, reliable, and complete.
In addition, only authorized spokespersons may make public statements on
behalf of Intel to the media or investors.
If you are contacted by a reporter, blogger, analyst or the public requesting
comments on behalf of Intel on a topic for which you are not authorized by
the Global Communications Group and the General Manager of your business
group to speak on behalf of the company, do not respond. Immediately refer
the inquiry to the Global Communications Group or Legal.

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Treat Each Other Fairly

One of our core values is to work as a team with respect and trust for each
other. We strive to uphold open and honest communication and to protect
employees from discrimination, harassment, or unsafe practices.

Open and Honest Communication

We value the free flow of thoughts, ideas, questions, and concerns. We
encourage employees to raise work-related issues or concerns through our
established processes as soon as issues or concerns arise.
We do not tolerate any retaliation against employees for asking questions or
making good faith reports of possible violations of law, the Code, or other
guidelines.

Equal Employment Opportunities and Diversity

We value diversity in our workforce, as well as in our customers, suppliers,
and others. We provide equal employment opportunity for all applicants and
employees. We do not discriminate on the basis of race, color, religion,
religious creed, sex, national origin, ancestry, age, physical or mental
disability, medical condition, genetic information, military and veteran status,
marital status, pregnancy, gender, gender expression, gender identity,
sexual orientation, or any other characteristic protected by local law,
regulation, or ordinance. We also make reasonable accommodations for
disabled employees and applicants, as required by law.
We follow these principles in all areas of employment including recruitment,
hiring, training, promotion, compensation, benefits, transfer, and social and
recreational programs.

Anti-Harassment
We are committed to providing a workplace free of harassment based on
personal characteristics such as race, color, religion, religious creed, sex,
national origin, ancestry, age, physical or mental disability, medical
condition, genetic information, military and veteran status, marital status,
pregnancy, gender, gender expression, gender identity, sexual orientation, or
any other characteristic protected by local law, regulation, or ordinance. We
strongly disapprove of and do not tolerate harassment of employees by
managers or co-workers. We must treat everyone we interact with while
performing work with dignity and respect.

Respect for Human Rights

Human rights are the fundamental rights, freedoms and standards of
treatment to which all people are entitled. Respect for human rights is rooted
in our values and applies wherever we do business. Our Global Human Rights
Principles formalizes Intel’s commitment to respect human rights.

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We are committed to respecting human rights in our operations, our supply

chain, our business partnerships, and our products. While we do not always
know nor can we control what products our customers create or the
applications end users may develop, Intel does not support or tolerate our
products being used to violate human rights. We expect our suppliers and
business partners to make the same commitment to respect human rights.
We also believe human trafficking, forced, debt bonded, indentured, and
slave labor are unacceptable. Intel’s Code and policies prohibit harsh or
inhumane treatment, including corporal punishment or the threat of corporal
punishment. Our policies prohibit the employment of anyone under the age
of 16 in any position, and workers under the age of 18 are not to perform
hazardous work. We also expect our suppliers to meet these expectations.

Safety
Intel is committed to providing a safe workplace for employees, customers,
vendors, contractors, and others on Intel property.
We comply with the safety laws, standards and guidelines that apply to our
business. Sound safety practices are important in all of our workplaces.
To protect our employees, the public, and our communities, we conduct no
activity without the proper safety precautions and produce no product
without the proper safeguards.
We believe workplace injuries and illnesses are preventable. We
communicate our expectations and safety protocols to employees and
suppliers and explain the potential health and safety risks and implications of
not following these requirements. We must not begin or continue any work
activity contrary to safety requirements.

Workplace Violence
In keeping with our commitment to safety, Intel will not tolerate threats of
any kind, whether explicit or implicit, threatening behavior, stalking or acts
of violence. We take all reports of threatening behavior or violence seriously,
look into the matter, and take appropriate action. For additional information,
please visit Intel’s Workplace Violence Prevention website. In case of an
emergency, contact Corporate Security.

Act in the Best Interests of Intel and Avoid Conflicts of

Interest
We seek to avoid any activity that is or has the appearance of a conflict of
interest with Intel. We do not engage in activities that compete with Intel or
interfere with the proper performance of our duties or responsibilities to
Intel. We do not use confidential company information, company assets
(except as permitted under Intel’s Electronic Communications Guideline), or
our role or position at Intel for personal gain. We avoid situations where our

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personal, outside business, or family interests could impair our ability to

make sound business decisions in the best interest of Intel.

Handling Conflicts of Interest

All employees must disclose to their managers in writing any conflict or
appearance of a conflict of interest with Intel; directors and executive officers
may choose instead to disclose the issue to the General Counsel, Chief
Compliance Officer or the Board of Directors. Managers or other permitted
persons to whom disclosures are made will determine, in consultation with
Legal, ELL Legal, Internal Audit, or the Board, as necessary, if a conflict, or a
perception of a conflict, exists, and if so, how to resolve it. The employee is
responsible for memorializing the resolution in writing. In addition to these
requirements, when conducting outside business activities, employees must
also follow the Conducting Outside Business Guideline. Disclosure is
mandatory; failing to disclose a conflict or a perceived conflict is a violation
of the Code.

Gifts, Meals, Entertainment, and Travel

The exchange or provision of gifts, meals, entertainment and travel (“GMET”)
may create a real or perceived conflict of interest or a situation where those
expenses could be viewed as a bribe under applicable laws and international
standards. Intel expects its employees and third parties to comply with the
following principles when giving or receiving GMET:
• We comply with anti-corruption laws.
• The GMET must be for a legitimate purpose, such as to promote,
demonstrate, or explain a company product, position, or service.
• The GMET must not place the recipient under any obligation. We do
not offer, promise, or give anything of value with the intent to
improperly influence any act or decision of the recipient in Intel’s or
your company’s favor, or with the intent of compromising the
recipient’s objectivity in making business decisions.
• The GMET must be made openly and transparently, be reasonable, and
appropriate to the business relationship and local customs, and not
cause embarrassment by its disclosure.
• Accurately record all GMET provided on Intel’s behalf.
• We give GMET to a Government Official (including employees of
government agencies, public institutions and state-owned enterprises)
only in limited circumstances and only with the proper approvals.
For more information, consult Intel’s Worldwide Business Gifts, Meals,
Entertainment, and Travel Policy (“GMET Policy”). For questions and
additional guidance, consult Legal.

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Protect the Company’s Assets and Confidential

Information
We spend considerable resources to develop and maintain assets used for
the company’s business. We each have a responsibility to comply with all
procedures that protect the value of Intel’s assets, including physical assets,
information, Intel brands, and its name and reputation, and to protect
confidential information customers and others have entrusted to us.

Protecting Physical Assets

Our physical assets include facilities, equipment, and computer and
communications systems. We are to use these assets primarily for our
business. As a narrow exception, we may use computer and communications
systems for reasonable, personal use.
We need to follow applicable security and use procedures to protect the
company’s physical assets from theft, loss, damage, and misuse, including
unauthorized access. Report the theft, loss, damage, or misuse of company
physical assets to Corporate Security as soon as possible.
While we respect employee privacy, we should not assume that our desk,
cubicle, or use of compute devices or telephone equipment is private or
confidential. Subject to local laws and under the guidance of Legal, Intel may
search and review both incoming and outgoing communications and all
device information, including any password-protected employee
communications.

Protecting Confidential Information

Confidential information is valuable to Intel. It gives Intel a competitive
advantage, helps maintain the trust of our customers, and sustains the solid
reputation on which Intel was built. Confidential information includes
information about unreleased products, product roadmaps, manufacturing
dates and more. It also includes confidential information transmitted orally or
by tweets, posts, blogs and other forms of social media.
Each of us has a responsibility to protect and not to leak Intel confidential
information or the confidential information of our customers and business
partners, and we must not disclose or use this information without clear
authorization. Physical assets and documents must be handled in compliance
with information security policies. Improper disclosure of Intel or third party
confidential information is a terminable offence, subject to applicable local
law.
If you become aware of unauthorized disclosure or loss of confidential
information, contact Information Security or Legal. For questions or guidance
on sharing on social media, contact social.media@intel.com.

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Safeguarding Trademarks and Brands

Among our company’s most valuable assets are its trademarks and brands.
To protect the value and recognition of our trademarks, we have established
guidelines that specify how and when they may be used.
We must follow these guidelines whenever we use the company’s trademarks
and brands, whether in internal and external communications or in materials
prepared by third parties, such as marketing agencies, channel distributors,
and Original Equipment Manufacturers.

Representing Intel
The value of our reputation and name must be upheld whenever we
represent our company. On occasion, Intel may request employees to act as
representatives of other entities (for example, as an officer, director, adviser,
agent or similar role). In those cases, an employee should discuss the
situation with the direct manager. You may need to follow special rules to
abide by the Code.
In other cases, such as when speaking on business or technology topics in a
public setting or posting on the Internet – including through social media
applications and websites – you must make it clear that you are expressing
your own views and not those of our company, unless you are speaking as an
authorized spokesperson of the company.
You must carefully follow special rules of conduct if you participate in or take
a leadership position with an industry trade association, to avoid antitrust
violations.

Approvals and Waivers

The Code sets out expectations for our company’s conduct. When certain
situations require permission from management or another person before
taking action, you need to raise the issue promptly to allow enough time for
the necessary review and approval.
In a particular circumstance we may find it appropriate to waive a provision
of the Code. To seek a waiver, speak with a manager, who will consider the
request in consultation with others, such as Internal Audit, Legal or Human
Resources. Waivers of the Code of Conduct require the permission of Intel’s
Chief Financial Officer, General Counsel, or Chief People Officer.
Directors and executive officers who seek a waiver should address the Board
of Directors or a designated committee of the Board. We disclose such
waivers for directors and executive officers to the extent and in the manner
required by law, regulation, or stock exchange listing standard.

Reminders
The Code serves as our guide for conducting business with integrity. It is not
an employment contract and confers no rights relating to employment.

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The Code is not a complete list of company guidelines. You are expected to
know and comply with all company guidelines related to your job. Violation of
these other guidelines may also result in discipline, up to and including
termination of employment.
Intel may amend the Code from time to time as it deems necessary or
appropriate.

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Code of Conduct Glossary Terms and Definitions

Topic Term Definition

Conduct Business with Honesty and Integrity

Preparing Accurate Auditors Includes both external and internal auditors.
Financial/Other
Records
Preparing Accurate Accounting Generally Accepted Accounting Principles (GAAP),
Financial/Other Standards International Accounting Standards (IAS), Securities &
Records Exchange Commission (SEC) regulations
Follow the Letter and Spirit of the Law
Bribery and Anti- Government official Government Officials: any officer, employee or
Corruption person acting in an official capacity for any
government department, agency or instrumentality,
including state-owned or -controlled companies, and
public international organizations, as well as a political
party, political official, or candidate for political office.
Some examples include: professors or researchers
from public universities or research and design
institutes; doctors from public hospitals and
employees of state-owned telecommunication
companies. Please consult Intel’s Worldwide Business
Gifts, Meals, Entertainment, and Travel Policy (“GMET
Policy”) for further details.
Bribery and Anti- Bribe Bribery, under Intel policy, means promising, offering,
Corruption or giving anything of value with the corrupt intent of
improperly influencing an act or decision of the
recipient or obtaining an improper advantage in order
to obtain or retain business.
Bribery and Anti- Facilitation payment A small payment made to obtain a routine government
Corruption action that involves non-discretionary acts, such
as processing government papers, or supplying phone
or water service. Paying an official to perform such
routine work is regarded a bribe under many country
laws. Expediting Fees: published government rates or
fees that a government agency or entity charges for
the purpose of expediting a service are permissible
payments. Such payments are made to a government
agency and an official receipt issued by the
government agency for the expedited service must be
obtained as proof of payment.
Environmental, Precautionary An approach where the health or environmental risks
Health and Safety approach from using a material and striving to find cleaner and
safer alternatives are carefully considered.

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Topic Term Definition

Import and Export Import An import is any item coming into a country or
Compliance crossing a border. Imports may be subject to customs
duty, quota restrictions, bans, or licensing
requirements, depending on the country of origin and
the item.
Import and Export Export The transfer of a physical item or technology, the
Compliance disclosure (oral or visual) of technology or act of
providing a service that is subject to an export
regulation.
Intellectual Property Privileged (attorney- The attorney-client privilege is a legal concept that
client privilege) protects communications between a client and his/her
attorney in which the communication involves seeking
or providing legal advice. Please note: the privilege
varies per jurisdiction. If you have questions about
whether a communication is privileged or not, you
should consult Legal.
Intellectual Property Intellectual property Intellectual property rights include patents/patent
rights applications, trademarks, copyrights, trade secrets,
know how, and mask work rights.
Privacy Privacy Privacy is defined as an individual’s right to keep
aspects of his or her personal life secret. This includes
an organization’s responsibility to respect an
individual’s privacy rights and to manage personal
information appropriately, including collection, use,
storage, or disclosure of an individual’s personal
information.
Note: An individual’s right to privacy is not limited to
personal information only, but also includes other
areas, such as behavioral privacy (an individual’s right
to choose what they do and to keep certain behaviors
from being shared with others) and communications
privacy (the right to communicate without undue
surveillance, monitoring, or censorship).
Privacy Personal information Any information relating to an identifiable individual.
Note: Personal Information is also known as Personal
Data or Personally Identifiable Information.
Examples of personal information include:
Address, Biometric Information, e-Mail Address, Fax
Number, Financial Information (such as Bank Account
or Payment Card Information), Government
Identification Number, Health/Medical information,
Name, Personal Profiles, Photographs, Social Security
Number, Telephone Number, etc.

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Topic Term Definition

Public Authorized Authorized spokespersons are identified, selected and
Communications spokespersons approved by their respective Business Unit GMs, Geo
leads, and the Global Communications Group (GCG)
based on communications objectives and need. Less
than 1 percent of the Intel employee population is
authorized to speak to media on behalf of the
company.
Treat Each Other Fairly
Anti-Harassment Harassment Harassment under our Code of Conduct includes:
verbal, physical and visual conduct that creates an
intimidating, offensive, or hostile environment in the
workplace that interferes with work performance, even
if it is not unlawful. Harassment may be based on
race, color, religion, sex, national origin, ancestry,
age, disability, medical condition, genetic information,
military and veteran status, marital status,
pregnancy, gender, gender expression, gender
identity, sexual orientation, or any other characteristic
protected by local law, regulation, or ordinance.
Human Trafficking, Debt bonded Debt bonded labor arises from a pledge of personal
Child and Forced services or a family member’s services by a debtor as
Labor security for a debt. At the outset, the individual
typically understands that the pledge of labor is
security for a debt and that the rendering of services
will, in time, extinguish the debt; however, the debt is
open-ended and a rolling tab continues to accrue
making the debt and work arrangement self-
perpetuating.
Human Trafficking, Human trafficking Human Trafficking is defined as (1) the act of
Child and Forced recruiting, harboring, transporting, providing, or
Labor obtaining a person for labor services or commercial
sex acts (2) by means of force, fraud, or coercion (3)
for the purpose of exploitation, involuntary servitude,
peonage, debt bondage, slavery, or any commercial
sex act involving a minor.
Human Trafficking, Corporal punishment Corporal punishment refers to physical punishment.
Child and Forced For example, caning and flogging are examples of
Labor corporal punishment.
Avoid Conflicts of Interest

Conflict of Interest Significant interest An interest in something outside of an employee’s job

Examples at Intel is significant when this influences an
employee’s ability to make fair and impartial decisions
in the best interest of Intel.

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Topic Term Definition

Conflict of Interest Investment Investors, broker/dealers, and sell-side and buy-side
Examples professional analysts. For more information, please consult the
Guidelines for Communications with Investment
Professionals.
Protect the Company’s Assets and Confidential Information
Maintaining Confidential Confidential Information includes, without limitation:
Information Security information technical information (e.g. roadmaps, schematics,
source code, specifications), business information
(e.g. product information, marketing strategies,
markets, sales, customers, customer lists or phone
books), personnel information (e.g. organizational
charts, employee lists, skill sets, employee health
information, names, phone numbers, email addresses,
personnel files, employee compensation except where
the disclosure of such personnel information is
permissible under local labor law such as the right of
employees to discuss compensation and working
conditions under the US National Labor Relations Act),
and other non-public Intel data and information of a
similar nature.
Safeguarding Trademark A trademark is anything that identifies the source of
Trademarks and one’s goods or services and distinguishes them from
Brands those of another, including a word, a name, a
design, a color, a phrase, a sound, or even a
scent. It is a word (Tide*), name (Howard
Johnson*), symbol (McDonald’s Golden Arches*),
device (Pillsbury Doughboy*), phrase (The Ultimate
Driving Machine*) or sound (Intel Bong/Sonic) that is
used in trade with goods to indicate the source of the
goods and to distinguish them from the goods of
others. A trademark is a valuable asset worth millions
of dollars and signifies the standards of excellence and
consistent quality associated with the Intel products
and services. This gives the consumer an assurance
of quality when making future purchasing decisions in
the marketplace. Thus, a trademark is inherently
bound up with the “good will,” and reputation, that is
developed by the owner of the mark.

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Topic Term Definition

Safeguarding Brands 1. A brand is a collection of images and ideas
Trademarks and representing an economic producer; more specifically,
Brands it refers to the concrete symbols such as a name,
logo, slogan, and design scheme.
2. Is often used interchangeably with "trademark".
3. A brand is a sign identified by a distinctive word,
phrase, sign, package or label. It is a representation of
a company’s name, trademarks, products, designs and
symbols.
Safeguarding Channel distributors Re-sells company products to smaller accounts or end
Trademarks and users
Brands
Representing Intel Antitrust violations There are provisions of the antitrust laws in the United
States and worldwide that must be strictly complied
with in order to prevent Intel and you from being
accused of and found liable for violating these laws.

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