Ethics and compliance

Our Code of Conduct expresses our ethical position on issues such as:

• Respect for the different cultural identities of our employees, stakeholders and customers

• A zero-tolerance policy for any form of discrimination or harassment

• Promoting honest, ethical and transparent conduct including in the handling of actual or apparent conflicts of interests between personal and professional relationships

• Conducting our business in good faith and with integrity

• Compliance with all applicable laws and regulations

The complete Code of Conduct can be found in the corporate governance section of our website.

We conduct business on the basis of fairness, good faith and integrity, and expect the same from parties with whom we do business. ASML expects its suppliers to show the same ethical behavior in their business conduct. Hence we have adopted the Electronics Industry Citizenship Coalition (EICC) Code of Conduct and are committed to promoting compliance with this code across our supply chain. More details can be found in the chapter ‘Sustainable value chain’.

Code of Conduct awareness

All new employees receive an introduction to the Code of Conduct as part of the program we offer them to familiarize themselves with our company. In addition, the Code of Conduct has been translated into an internal set of practical Business Principles, which contain rules for day-to-day operations for employees. These Business Principles focus on five areas:

1. Show respect for people and planet

2. Operate with integrity

3. Preserve intellectual property and other assets

4. Manage exposures by following processes

5. Adhere to our Business Principles, applicable laws and speak-up

A global program to raise employee awareness of the updated Code of Conduct and the Business Principles was launched in 2011 and its implementation will continue in 2012. The program consists of compulsory online training, the launch of an ethics and compliance website as well as intranet articles and videos highlighting ethical dilemmas. In 2011, about 10,500 employees worldwide completed the online training in an average time of 30 minutes.

Code of Conduct complaints

We encourage employees to discuss or report any behavior that may violate our Code of Conduct. ASML has a procedure for reporting issues with respect to the Code of Conduct, including complaints of a financial nature (our Whistleblower's Policy). The reporting procedure regarding Code of Conduct violations can be found in the corporate governance section of our website.

Code of Conduct standards

ASML supports employees' rights to freedom of association and to form workers' organizations.

As a global business, ASML respects the rule of law and complies with all national laws, regulations and administrative practices of the countries in which it operates. Within that legal framework, ASML conducts its activities in a competitive and ethical manner - in particular through constant compliance with competition law.