Intel’s Gifts, Meals, Entertainment & Travel (“GMET”) Policy for Third Parties

Code of Conduct: Intel’s Code of Conduct reflects our commitment to conduct business with uncompromising integrity and in compliance with all applicable laws. We expect all companies or persons who provide services or act on behalf of Intel (“Third Parties”) to comply with our Code of Conduct, including our anti-corruption policy, regardless of local business practices or social customs. Giving and Receiving Gifts, Meals, Entertainment and Travel (“GMET”): The exchange or provision of gifts, meals, entertainment or travel (”GMET”) may create a real or perceived conflict of interest or a situation where those types of expenses could be viewed as a bribe under applicable laws and international standards. Intel expects its Third Parties to comply with the following principles when giving or receiving GMET:  Compliance with Applicable Law: You must comply with anti-corruption laws, including the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and applicable local laws, when giving or receiving GMET in connection with Intel business.  Business Purpose: The GMET must be for a legitimate purpose, such as to promote, demonstrate, or explain an Intel product, position, or service.  No Improper Influence: The GMET must not place the recipient under any obligation. You must never 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.  Made Openly: The GMET must be given or received in an open and transparent manner.  Reasonable in Value: The GMET must be reasonable in value and neither lavish nor excessive.  Appropriate: The nature of the GMET must be appropriate to the business relationship and local customs, and not cause embarrassment by its disclosure.  Accurately Recorded: You must accurately record all GMET provided on Intel’s behalf. You must be able to produce receipts or proper documentation for all GMET expenses.  Government GMET: You may not give GMET on Intel’s behalf to a government official (including employees of government agencies, public institutions and state-owned enterprises) without prior approval from Intel. Approval will be provided only in limited circumstances and, in some cases, will require the approval of Intel Legal. All GMET provided on Intel’s behalf to a government official must be properly recorded, with appropriate receipts or proper documentation. GMET Involving Intel Employees: Intel employees must comply with Code of Conduct and internal policy requirements and restrictions, including pre-approval requirements, when giving or receiving GMET to or from a Third Party. We discourage Intel suppliers and vendors from giving any gifts to our employees and appreciate your support on this request. How to Raise Questions or Concerns: If you have questions or concerns, you have numerous avenues to report them to Intel. Click here to find more information on Reporting Ethics and Legal Concerns. December 2013