Code of Conduct
Committed to ethical behavior and speaking up
Our Code of Conduct (Code) is based on the ASML values of challenge, collaborate and care. These values are part of a shared belief system within ASML that defines who we are.
The Code influences how we make decisions and guides us in our interactions with colleagues, customers, suppliers, shareholders and society as a whole. The Code helps us maintain the highest standard of ethics, integrity and respect.
Our ethics program offers the necessary support, advice, training, and communication to enable employees and others to understand and follow our Code. We encourage and enable anyone to speak up if they observe behavior that violates our Code.
Speak Up & Non-retaliation Policy
Our Speak Up & Non-retaliation Policy allows anyone to report issues with respect to our Code. We are committed to an open culture of trust and honest communication, where violations of the Code are not tolerated. People who speak up will be protected for raising concerns about suspected misconduct in good faith. Reports will be treated confidentially and parties can report concerns anonymously.
How to Speak Up
The Ethics Office at ASML can be emailed directly at [email protected]. Alternatively, our Speak Up service enables anyone to call a local telephone number or send a message through an independent website by following the link from the name of the location in which you are located. Speak Up offers the possibility to report anonymously.
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Code of Conduct for Suppliers
At ASML, we conduct business on the basis of fairness, good faith and integrity, and we expect the same from our partners and suppliers. ASML became a member of the Responsible Business Alliance (RBA) in 2011 and adopted the RBA Code of Conduct, which provides guidance in four critical areas: labor, health & safety, environment and ethics. To reinforce our commitment to the supplier network, we expect our key suppliers and their suppliers to comply with the RBA Code of Conduct and to develop their own strategies, policies and processes to follow it.
Anti-Bribery & Anti-Corruption Policy
We are committed to conducting business with business fairness, integrity and respect for the law and our values. Our Anti-Bribery & Anti-Corruption Policy details our commitment and the measures we take to prevent bribery and corruption at ASML. The Policy is designed to help employees and affiliates understand the internal and external requirements to report any suspicious or actual anti-corruption behavior and to help comply with these requirements.
Competition Law Compliance Policy
We are committed to fair competition and fairness in dealing with our business partners including suppliers, co-developers, customers and other industry peers. ASML does not condone any form of conduct that is considered illegal under applicable competition laws or is contrary to our Code. Our Competition Law Compliance Policy demonstrates our ongoing commitment to ensuring compliance with applicable competition laws and our Code.
Human Rights Policy
ASML is committed to respecting universal human rights and honoring our Code and values. Our Human Rights Policy applies to all our organizations and subsidiaries around the world, as well as to our suppliers.
Our Human Rights Policy is in line with various key international human rights standards and guidelines, including:
ILO Declaration on Fundamental Principles and Rights at Work
UN Declaration of Human Rights
UN Global Compact
OECD Guidelines for Multinational Enterprises
Code of Conduct of the Responsible Business Alliance (RBA)
We also make sure that within our value chain human rights are:
Respected: As a company we aim to avoid any human rights violations in operations in which we have direct or indirect involvement .
Protected: We frequently assess actual and potential human rights risks, both in our own operations and in our supply chain. We educate employees about the importance of human rights and cooperate with the international community and our business partners in preventing human rights violations.
Remediated: We ensure that any (potential) human rights violations within our value chain can be reported to ASML (through our Speak Up & Non-retaliation Policy) and that all reported incidents are addressed.
California Supply Chains Act and UK Modern Slavery Act Disclosure
The California Transparency in Supply Chains Act (2010) and the United Kingdom (UK) Modern Slavery Act 2015, Chapter 30, Part 6, Provision 54 require companies to disclose their efforts to eradicate slavery and human trafficking from any of their supply chains and in any part of their business. ASML is committed to ensuring that all levels of its supply chain comply with the highest international standards of fairness, sustainability and ethical conduct, including a strict prohibition on forced and involuntary labor and illegal trafficking in persons.
Insider Trading Rules
According to Dutch law, members of ASML’s Board of Management and Supervisory Board are required to notify the Dutch Authority Financial Markets (AFM) of any ASML financial instruments they hold or that are held on their behalf, as well as any transactions in those holdings that they make or that are made on their behalf.
The AFM publishes all reported transactions on its website.
All employees, including members of ASML’s Board of Management and Supervisory Board, are bound by ASML’s Insider Trading Rules.