Global Policy Code of Conduct

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Table of Contents

1 Scope and Purpose .................................................................................. 2

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Global Policy Code of Conduct

Document Number: BE-00200 ATT 1

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1 Scope and Purpose

This Code of Conduct (hereinafter the "Code") applies to directors, officers, employees, consultants, representatives, and agents of Benchmark and its subsidiaries (the "Company"). The Code is fundamental to how we do business and reinforces the responsibilities we all share in protecting the Company's reputation.

The Company's commitment to ethics and excellence sets the foundation for the Code, which defines the standards for how we do business. It reflects our commitment to conducting our global operations according to the highest ethical standards.

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Global Policy Code of Conduct

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Dear Fellow Employee,

Benchmark has a long history of operational excellence, which is reflected in our commitments to the Company and to our customers. That standard of excellence applies not only to our operations, but to the way we treat each other, our customers and others. At Benchmark, we commit to act ethically and honestly in all that we do. Because we cannot cover every issue or challenge we may face in the workplace, our Code of Conduct provides general guidance as to the ethical standards we adopt, and introduces some of our Company policies.

You should review the Code frequently and be familiar with it as it is intended to be a statement of our Company principles and how we conduct ourselves in our interactions with others. The Code reflects standards that we must adhere to, not simply aspire to. All employees, officers and directors who represent the Company or act on its behalf of Benchmark must abide by the Code.

Each of us plays an important role in ensuring the integrity, reputation, and success of our organization. If you need additional information or have questions and/or concerns about specific conduct, you can always contact your supervisor, your Human Resources representative, the Office of Ethics and Compliance or any of the other resources listed in this Code.

Thank you for your hard work and continued commitment to making the right choices every day to ensure the success of our Company.

Sincerely,

Jeff Benck President and CEO

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Our Mission

Our mission is to be our customers' trusted partner; providing comprehensive solutions across the entire product lifecycle; leading through our innovative technology and engineering design services; leveraging our optimized global supply chain; and delivering world-class manufacturing services.

Our Vision

Our vision is to positively impact lives by solving complex challenges with our customers, creating innovative products that no one imagined were possible.

Our Values

Our values define how we do things, as we strive to make a positive difference in the lives of the people we touch.

  • • We act with integrity by doing what we say we are going to do, exhibiting accountability and building trust at all times.

  • • We value inclusion by respecting diverse opinions to collaborate effectively.

  • • We are committed to customers, both internally and externally, with dedication to excellence in every encounter.

  • • We promote ingenuity by proactively attacking challenges, creating innovative solutions and constantly learning to drive continuous improvement.

  • • We genuinely care for each other, our customers, and our communities.

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2 References

Export Administration Regulations (EAR)

Foreign Corrupt Practices Act (FCPA)

International Traffic in Arms Regulations (ITAR)

BE-00003 Global Anticorruption Policy BE-00005 Gifts and Entertainment Policy

3 Definitions

None

4 Ethical Behavior

4.1 Make Ethical Decisions

In all situations, the Company expects employees to shape their business decisions and behavior as guided by the Code, as well as the ethical values the Code exemplifies. While the Code provides guidance on a wide scope of topics, it cannot address every ethical question or situation that you may face on a day to day basis. When faced with an ethical decision, you might ask:

  • • Is my decision fair, honest, and consistent with the spirit and principles set forth in the Code?

  • • Is my decision consistent with all applicable laws and regulations?

  • • Will my decision advance the Company's goals and objectives?

  • • If called upon, would I be comfortable explaining my decision to my co-workers, superiors and the general public?

If you have doubts about your decision, you should seek the advice and counsel of your manager, or local Human Resources representatives as appropriate. If you are not comfortable with these avenues of addressing your concerns, there are other ways that you can pose questions or seek advice detailed later in this Code.

4.2 Avoid Conflicts of Interest

The Code requires directors, officers, employees, consultants, representatives, and agents to avoid conflicts of interest between their obligations to the Company and their personal affairs, and situations that may appear to present a conflict of interest. Generally, a conflict of interest may arise when:

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  • • Your position or job responsibilities present an opportunity for personal gain.

  • • An obligation or situation resulting from your personal activities or financial interests may influence your judgment or actions in the performance of your job duties.

  • • Conduct occurs that is prohibited by or is inconsistent with the Code.

It is impossible to describe every situation that could be viewed as a conflict of interest. The following discussion describes a few general examples of conflicts of interest.

4.2.1. Outside Commercial Interests and Investments

Outside ownership or financial interests could present a conflict of interest, if in a Company competitor, supplier or vendor, or any material interest in assets or property sold or leased to the Company. Except in rare circumstances, less than 1% stock ownership in a publicly traded company or less than 5% ownership in a privately held company do not represent a conflict of interest.

4.2.2. Service on Outside Boards of Directors

Directors of companies are charged with fiduciary duties toward that company, which could require the director to put that company's interests ahead of the Company's. For this reason, you must get prior written approval from the Company Board of Directors before you accept a directorship on the board of any outside company.

4.2.3. Gifts, Entertainment and Kickbacks

Business partners often use the exchange of gifts and entertainment to build goodwill. One basic principle underlies the exchange of gifts and entertainment worldwide: gifts or entertainment can become improper kickbacks if intended to obligate or unduly influence the recipient. Payments of cash are always improper. Kickbacks are not limited to cash payments, and can be any offer, promise of, or payment of anything of value, including gifts and entertainment, that are intended to influence the recipient to make a favorable business decision. Unsolicited modest gifts of nominal value, such as meals, tickets to the theater, or promotional items of a general advertising nature (such as imprinted pencils, memo pads and calendars) are generally acceptable to receive and give.

While gifts and entertainment are often expressions of cordial business relationships, they can nevertheless interfere with an employees' independent business judgment. Employees should exercise good judgment and moderation by only offering or accepting gifts or entertainment to the extent they are in accordance with reasonable customs in the marketplace and this Code. Accounting records and supporting documentation reflecting all gifts and entertainment and who received them must be accurately stated.

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For more information, see the BE-00005 Benchmark Gifts and Entertainment Policy and BE-00003 Global Anticorruption Policy.

4.2.4. Outside Employment

If you are a Company employee and also employed by a company that competes with or provides goods or services to the Company, or if your relationship with such an outside company could in any way influence your duties or decisions at the Company, you must immediately report this conflict of interest to your supervisor. These reports must be forwarded to Corporate Legal for review and approval. This type of situation may require you, as a Company employee, to terminate your outside employment. You cannot use Company resources in any way to further or facilitate your outside employment.

4.2.5. Avoid the Appearance of Conflict

Because the appearance of a conflict of interest can be just as harmful as an actual conflict, employees should avoid situations that might be viewed as conflicting with the best interests of the Company. If you find yourself in a position where a potential conflict of interest exists or could arise, contact your manager or Human Resources representative to disclose the information, or you may contact the Office of Ethics & Compliance or the HelpLine (see Section 9). Any relationship or activity which could or would influence, or appear to influence, performance of one's duties to the Company, must be disclosed to the Chief Compliance Officer or the General Counsel for review and resolution.

4.2.6. Corporate Opportunities

Directors, officers, and employees are prohibited from personally taking for themselves opportunities discovered through the use of Company information, position, or property without the consent of the Board of Directors. No Company information, position, or property may be used for improper personal gain, and no director, officer, or employee may compete with the Company directly or indirectly. Actual or potential conflicts of interest must be disclosed and resolved in accordance with Company policy, in consultation with the Chief Compliance Officer, the General Counsel, or, in certain cases, with the Board of Directors.

4.3 Market, Bid, Negotiate, and Perform in Good Faith

Truthful and accurate communication of information about our products and services is essential to meeting our commitments to our customers. Standards of fair business, advertising, and competition are to be upheld. Employees must be honest in marketing, in preparing bid proposals based on properly estimated cost and pricing data, and in truthfully negotiating contracts. Excellence in performance must be based on our compliance with contract specifications and associated quality and testing requirements. We seek to outperform our competition fairly and honestly, and never through collusion, unethical or illegal business practices.

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5 Respectful Behavior

5.1 Treat People with Respect and Dignity

Employees are expected to treat one another, customers, and business partners with respect and dignity. We value an inclusive workforce because it promotes diversity of thinking, reaching solutions that help us achieve excellence, and meeting the needs of our customers.

Exercise good judgment when performing your duties and act in an appropriate manner while at work or when representing the Company, even in a social or recreational setting. Remember that an employee's personal behavior affects the perception others have about the Company. Avoid all activities that could call into question the Company's compliance with legal requirements or ethical standards.

5.2 Observe Employment and Labor Laws

The Company is committed to fair employment practices for our employees and providing a safe and quality work environment. Company leaders at all levels have a special obligation to encourage an open work environment and ethical culture, where employees are treated respectfully and may raise issues or concerns without fear of retaliation. It is the Company's policy to act in accordance with all applicable employment and labor laws and regulations, including without limitation:

  • • offering a safety and health program that conforms to the best practices of organizations of our type, to reduce the number of occupational injuries and illnesses to a minimum;

  • • a work environment free from any physical, sexual, psychological, verbal or visual harassment or abuse;

  • • maintaining a drug-free, secure workplace;

  • • compliance with all non-discrimination requirements;

  • • complying with applicable local law on workweeks, days off and maximum hours employees are permitted to work;

  • • paying employees at least the minimum wage required by local law and providing all legally mandated benefits while not allowing deductions from wages as a disciplinary measure;

  • • ensuring that neither forced, indentured, involuntary prison, or bonded labor, nor slavery or trafficking of persons is used;

  • • returning all personal documents including government-issued identification, passports, or work permits to employees, including those employed at Benchmark through an employment agency; and

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  • • observing the minimum age requirement for employment while in no circumstances allowing the use of child labor under the age of 15, consistent with local law and Company policy.

You are responsible to follow safety and health rules and to report to your manager any accidents, injuries, and unsafe equipment, practices, or conditions. Your work environment should be safe - without threats of violence, bodily harm or physical intimidation. Don't even joke about it; it is simply not tolerated. Workplace violence includes:

  • • Physical, verbal or written threats

  • • Violent or threatening behavior

  • • Conduct that threatens safety in the workplace

It is your responsibility to report anything that could reasonably be considered violent or threatening behavior.

5.3 Personal Relationships

Intimate personal relationships between managers and subordinates are prohibited. This includes a dating or other intimate personal relationship between a manager and any person subject to their scope of supervision, influence or the ability to affect the terms, conditions or status of the subordinate's employment. Any such situation should be immediately disclosed to your Human Resources representative.

5.4 Data Privacy

Respect the privacy rights and interests of all employees and individual stakeholders in their personal information. The Company is committed to taking appropriate measures to protect employees' personal information against unauthorized access and to use it only for legitimate business purposes. Collect, use and process personal information responsibly and in accordance with applicable laws.

6 Protect the Environment

The Company strives to protect the environment, conserve energy and natural resources, and prevent pollution. The Company seeks compliance with applicable environmental laws and regulations by applying appropriate management technology and practices. All Company manufacturing facilities are either currently certified or undergoing certification to ISO 14001, which will drive continuous improvement in these areas. Each employee is responsible for observing sensible environmental practices. Together, we have a responsibility to be good neighbors and contributing corporate citizens in our communities.

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7 Comply with Laws and Regulations

7.1 Maintain Our Financial Integrity

The Company's financial books and records shall properly document all assets and liabilities, accurately reflect all transactions, and are retained in accordance with Company policy and applicable laws and regulations. Company funds may not be used for any unethical purpose. No false entries shall be made in the books or records of the Company or its subsidiaries for any reason. Undisclosed or unrecorded funds or assets may not be established.

All Company books, records, accounts, and financial statements must be maintained in reasonable detail, must appropriately reflect the Company's transactions, and conform to applicable legal requirements and to our system of internal controls. All transactions must be supported by accurate documentation in reasonable detail, recorded in the proper amount and placed in the proper accounting period. You should never feel pressured to make false or misleading financial entries on the Company books and records. You may not interfere with or improperly influence any audit of the Company's financial statements. The intentional manipulation of financial data violates Company policy and the law, and is considered fraud.

7.1.1. Prevent Fraud

The Company is committed to preventing fraud. Fraud includes "any intentional or deliberate act committed to secure unfair or unlawful gain or to deprive another of property or money by guile, deception or other unfair means." Examples of situations that might involve fraud include:

  • • Committing dishonest acts;

  • • Intentionally recording a false or misleading transaction or accounting entry;

  • • Manipulation of Company records;

  • • Forging or altering Company checks;

  • • Misappropriating assets of the Company, employee, customer or supplier;

  • • Submitting for reimbursement false or inappropriate expenditures;

  • • Engaging in bribery, embezzlement or money laundering; or

  • • Using or taking Company property or funds for private use.

Remember that fraud can be committed by either employees or external parties. The Company is committed to continuously enhancing its policies and procedures to help prevent, detect and deter fraud.

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Benchmark Electronics Inc. published this content on 22 March 2024 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 25 March 2024 14:56:43 UTC.