Marvell Technology, Inc.

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Table of Contents
Our Code of Business Conduct and Ethics.............. 3

Harassment and discrimination

The way we do business worldwide

Confidential employee information

Marvell’s core behaviors

Workplace privacy

Applicability of the CodeUsing social media appropriately
Endorsements

How To Speak Up or Get Help........................ 5
Our Shareholders........................................................ 25
A Note from Matt Murphy............................. 6

Avoiding insider trading and tipping

Our Business Practices................................ 7

Communications with the media andthe financial community

Avoiding corrupt activities

Industry consultants or industry experts

Business partners

Public speaking and publications

Giving and receiving gifts, entertainment or hospitality

Financial matters and business practices

Gifts and entertainment with government officials

Business records

Business expenses

Records retention and legal holds

Fair competition
Competitive information

Our Communities........................................................ 30

Complying with global trade regulations

Political contributions

Avoiding money-laundering situations

Public service and volunteering
Human rights

Our Workplace............................................................ 13
Avoiding conflicts of interest

Taking Action.............................................................. 31

Disclosing actual or potential conflicts of interest

Compliance with the CodeFamily and personal relationships in the workplace

Reporting procedures and other inquiries

Family and personal relationships with third
party business partners

Resources

Outside employment, business or inventions

Investigations

Corporate opportunities
Personal investments

Confidentiality of reporters and individuals
assisting in investigations

Protecting Marvell’s assets

Marvell will not tolerate retaliation

Technology use

False allegations

Marvell confidential information

Provisions applicable to financial professionals

Marvell intellectual property

Amendments to the Code

Confidential information and intellectual property of others
Use of third-party software and open-source software

Concern LineKey Resources............................................................. 35

Technical standards groups
Contracts and commitments
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Our Code of Business Conduct and Ethics
The way we do business worldwide. Marvell’s Code of Business Conduct and Ethics (the Code) is our guide forthe way we do business, ethically and with integrity, every day and in every place where we do business, and inaccordance with all applicable laws and regulations. The principles in the Code may be further expanded in other
Marvell policies and standards of conduct that may be referenced throughout the Code. These other policies andstandards are separate from the Code and may be more restrictive than the Code. You may access these otherpolicies and standards at my.marvell.com or by requesting copies from your manager or the Compliance Team.

Marvell’s Core Behaviors
Our core behaviors define who we are as a global company and how we conduct our relationships
with each other and our stakeholders: customers, suppliers, competitors, shareholders andcommunities. Our core behaviors are:

ACT WITH INTEGRITY AND TREAT EVERYONE WITH RESPECT• Say what you mean, do what you say• Be inclusive and embrace our diversity of people and opinions• Lying and arrogance are unacceptable

INNOVATE TO SOLVE CUSTOMER NEEDS• Understand the customers’ needs and focus innovation to make them successful• Be creative—take calculated risks and learn from failures• Build close and trusted customer relationships and be easy to do business withEXECUTE WITH THOROUGHNESS AND RIGOR• Make decisions objectively based on data
• Strive for excellence and minimize waste, delays and inconsistency• Deliver superior quality on time

HELP OTHERS ACHIEVE THEIR OBJECTIVES• One Marvell—put Marvell objectives ahead of individual or team objectives• Act like an owner of the entire business• Share information, resources, technology and opportunities across the organization

Applicability of the Code
The Code applies to all Marvell employees and members of the Board of Directors, who may be individually orcollectively referred to in this Code as “you,” “Marvell employees,” “we” and/or “us.” We expect all Marvell
independent contractors, consultants, suppliers and others who do business with Marvell to comply with this or
a comparable code, as set forth in Marvell’s Supplier Code of Conduct, which may be found at www.marvell.com.

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Marvell Expects You to:• Demonstrate our core behaviors every day. Act with the highest levels of professional
ethics with zero tolerance for illegal or unethical conduct.
• Understand and comply with the Code. Comply with the Code and all applicableregulations. We may revise the Code from time to time, and you are expected to become
familiar with any and all revisions.
• Speak up. You are encouraged to speak up if you have concerns regarding compliancewith the Code or law. If you become aware of violations of the Code or other Marvell
policy, the law, or any regulatory requirements, you are obligated to speak up. Marvell
will not retaliate, and will not tolerate retaliation, against anyone for making a goodfaith report of actual or potential wrong-doing, or for participating in the investigationof such report. For more information about how to report violations or about Marvell’s
no retaliation policy, or to get help with interpretation of the Code, see the section“How to Speak Up or Get Help” on page 5, or the “Taking Action” section on page 32.

Ask for help. The Code is not intended to address every situation or issue you may
encounter as a Marvell employee, but is designed to reinforce our core behaviors and tohelp guide you in making good decisions and using good judgment when faced with asituation in which you are unsure of the right business, legal or ethical choice. When in
doubt about the best course of action in a particular situation, first ask yourself:• Is my proposed action legal?
• Does it comply with Marvell policies?
• Is it consistent with our core behaviors?

• Is it in the best interests of our shareholders?
• Would I be comfortable if my decision were made public?

If the answer to any of these questions is “no,” don’t take the proposed action.
If you are unsure, speak up or seek guidance from the Compliance Team.

• Read, certify and disclose. You are required to read and certify your understandingof the Code, and to disclose all actual and potential conflicts of interest.
• All onboarding employees are required, as part of their onboarding process, to readand certify their understanding of the Code, and disclose all actual or potential
conflicts of interest.
• All employees are required to certify their understanding of the Code on an annual
basis, and disclose all actual or potential conflicts of interest.
• You are expected to notify the Compliance Team promptly after you become aware of
any actual or potential conflicts of interest.
 ther training and certifications. From time to time, you may be required to participateOin other legal, ethics and compliance-related training or provide other certifications as
Marvell determines to be necessary or appropriate. These trainings and certifications arepart of Marvell’s commitment to ethical behavior and are designed to provide you withinformation to ensure your continued understanding of, and commitment to, Marvell’s
expectations. You are expected to complete any required training and/or certifications
in a timely manner. Failure to do so may result in disciplinary proceedings, up to andincluding termination of employment.
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How to Speak Up or Get Help

For questions about the applicability of the Code or the law, or if you are unsure whether
a proposed action complies with the Code or the law, contact the Compliance Team. If
you would like to report compliance failures or express concerns regarding compliancematters, your manager may be in the best position to assist you (provided you do notbelieve your manager is involved in the violation); however, there are a number of otherresources available to you that can offer guidance in addressing a difficult situation.
You are encouraged to speak up if you have concerns regarding compliance with theCode or law. If you become aware of a violation of the Code or law, you are obligatedto report it. You should choose the resource you feel most comfortable with inspeaking up or reporting, including:

Visit “TAKING ACTION”
on page 32 for more
information on reporting,investigations, Marvell’s noretaliation policy and otherinformation.

• An executive or another manager you trust• Human Resources• The Compliance Team• The Conflict of Interest Review Committee

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• A member of the Legal Department

Report a Concern 24/7 atconcernline.marvell.com• The Marvell Concern Line, which may be used anonymously and is available
24 hours per day, every day, at http://concernline.marvell.com. You may also callthe local phone numbers listed on the Concern Line.

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A Note from Matt Murphy

As a leading technology company, Marvell has earned its reputation for
extraordinary innovation. To continue building on this success, we want employees
and partners to feel they can do their best work with total clarity, confidence andintegrity—especially in a competitive industry. That’s why we have a Code ofBusiness Conduct and Ethics.
Our Code of Business Conduct and Ethics applies to each of us as individuals, no matter
what our job may be. So it is our responsibility to both understand and honor thesepolicies and values in all Marvell-related matters, including our work with customers,
investors, partners and each other.
While our Code of Business Conduct and Ethics covers many topics, it cannot
anticipate every situation that might arise. So I’m asking that every Marvell employee
consistently exercise good judgment, and always take the high road consistent withthe highest standards of business ethics. If you are ever unsure about the most ethicalcourse of action, ask your manager or the Compliance Team for guidance.
By acting with uncompromising integrity every day, we will continue to build the mostvaluable asset in any business—trust. Along the way, we’ll also demonstrate that
Marvell is not just a company with great technology, but with great people, too.
Thank you.
Matt Murphy
President and CEO

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Our Business Practices

Avoiding Corrupt Activities
Marvell is committed to strict compliance with the letter and spirit of the UnitedStates Foreign Corrupt Practices Act (the FCPA) and other applicable anti-corruption
laws around the world (collectively the Anti-Corruption Laws). The Anti-Corruption
Laws generally prohibit making payments, promises or offers of anything of value
to government officials or employees (at any level), political candidates, or politicalparty officials to obtain or retain business or to secure an improper advantage. The
Anti-Corruption Laws also generally prohibit bribery in the commercial setting; thatis, providing anything of value to improperly influence anyone, whether they are agovernment official or a private business partner.
Anti-corruption laws also require that all of our financial information, business records
and transactions be fully, fairly and accurately recorded in our books and records.
The jurisdictional reach of the Anti-Corruption Laws can be broad, and Marvell requires
full compliance with all Anti-Corruption Laws and Marvell policies by all employees,
consultants, officers and representatives of Marvell as well as all other stakeholdersof Marvell acting on Marvell’s behalf.

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Business Partners
Marvell can be held accountable for and suffer significant harm based on the conductof its business partners. Business partners should be selected based on objective
criteria, such as value (quality for price), price, technical excellence, service reputation,compliance record and production/service capacity.

Giving and Receiving Business Gifts, Entertainment or Hospitality
Promoting Marvell and building business relationships of mutual trust and value areimportant elements for Marvell’s business success. This can properly include giving or
receiving gifts, meals, entertainment or hospitality. In some circumstances, however,gifts, entertainment or hospitality may be viewed as improper payments or a bribe,and may violate local laws, our policies or the policies of our business partners.
Marvell permits offering gifts to suppliers, customers or other business associates for
legitimate business purposes, such as building goodwill and strengthening working
relationships, provided the gift:• is valued at or below US$250 (even if promotional in nature), and• does not exceed any specific limits established by local law or by contract between
Marvell and the recipient.
If you intend to provide a gift valued above US$250―an exceptional circumstance―
you must seek prior written approval by Compliance. You may not provide a gift to thesame recipient more than two times per calendar year regardless of the value, andtherefore, the cumulative value of all gifts an employee may provide to any one
recipient during a calendar year cannot exceed US$500, unless pre-approved in writing
by Compliance.
• Marvell employees may provide business Entertainment offered for legitimate
business purposes, such as building goodwill and enhancing relationships withcustomers, suppliers or other business partners, provided that it:• does not exceed the value of US$500 per person, without prior approval
from Compliance,• complies with the Marvell Global Travel & Expense Policy.
If you intend to provide entertainment valued above US $500―an exceptional
circumstance―you must seek prior written approval by Compliance. You may notprovide entertainment to the same recipient more than four times per calendar year
regardless of the value, and therefore, the cumulative value of all meals, entertainmentand hospitality an employee may provide to any one recipient during a calendar year
cannot exceed US$2,000, unless pre-approved in writing by Compliance.

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Employees may not give or receive gifts or entertainment to or from current or
potential vendors, suppliers, customers or other business partners unless all of theconditions below are met. These conditions apply everywhere in the world, even
where different practices may be considered the “normal way of doing business”:• Business purpose. The gift or entertainment must have a legal,business-related purpose.
• Nominal value. The value of the gift or entertainment is reasonable and does notexceed the pre-approved values set forth in the Global Anti-Corruption Compliance
Policy. Exceptions must be submitted to and pre-approved by the Compliance Team.
• No favored treatment. The purpose of the gift or entertainment is not to obtainspecial or favored treatment, or not to improperly influence acts or decisions.
• Legal. Giving or accepting the gift or entertainment is appropriate to the business
relationship and local custom, and is legal in both your country and the countryof the recipient.
• Conduct and agreements. Does not violate the standards of conduct of therecipient’s organization or any contractual agreement with a business partner.
• Documented. Gifts and entertainment must be properly documented, and,
where necessary, proper approval must be obtained prior to giving any gift,
entertainment or hospitality.
• Compliance with policy. Must be otherwise permitted under Marvell’s policies,
including the Anti-Corruption Policy and the Global Travel and Expense Policy.
Your department may impose requirements that are more restrictive than thosein the policy, with which you are required to comply. If you are giving the gift orentertainment, you must also comply with any applicable policies or standardsof conduct imposed by the recipient’s organization.

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Gifts and Entertainment with Government Officials
Marvell has specific requirements that apply to interacting with government officials
on behalf of Marvell, including obtaining pre-approval from Marvell’s Compliance Teamfor certain types of gifts, meals or entertainment of government officials or theirfamilies. Government officials do not have to be high-ranking officials; they can be any
employee of a government agency or state-owned or -controlled private company, or afirefighter or customs agent. Review the Anti-Corruption Policy, or contact theCompliance Team for guidance.

Business Expenses
All costs and expenses relating to gifts, entertainment or hospitality must be completely
and accurately recorded as required by Marvell accounting and reimbursement policies
and procedures, the Travel Policy, and our Anti-Corruption Policy. When an expense
reimbursement form is submitted, the form must accurately describe the expense andits business purpose and state the name, title, and company or other organization of therecipient(s), including whether the recipient is a government official. For more information
about who may be considered a government official, please see our Anti-Corruption Policy.

Q. My co-worker and I took a customer to dinner. We ordered two very expensive
bottles of wine and I knew my boss would never approve it. So I had the waiter
split the bill and I paid for half and my coworker paid for half, and we submitted
separate expense reports. Is this okay?

Q&A

A. No. By submitting half the expense, both of you only told half the story. You
also created a false and inaccurate record of the transaction and intentionallytried to avoid the approval process.
Q. I work in one of our locations in Asia, supporting a design team. Last week, a pieceof equipment broke down and the replacement part is stalled in customs. My bossis telling me to do whatever it takes to get the part. The customs agent told me if
I give him $500, he can make the process go a lot faster. My colleague told me it’sperfectly normal to pay the customs agent, or get one of our logistics providers
to pay it for me, and no one would even know about it. Can I pay the $500?
A. No. The payment being requested, whether given directly or through a third party, is a“facilitation payment,” and is expressly prohibited by Marvell, whether or not it is legal
in the country where the payment is being requested. Asking a vendor to make thepayment for us is also expressly prohibited. Marvell can be liable for the acts of ouragents, such as the logistics provider, and we cannot instruct a vendor to engage incorrupt practices on our behalf. Additionally, by attempting to disguise the payment
by asking someone else to make it for you, you are intentionally circumventing
Marvell’s policies and creating inaccurate business records for Marvell.

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Q. A new security company start-up created by a public university in Brazil isevaluating using one of our products and wants to visit our offices in Santa Clara.
Two of the team have never been to the United States, and want to bring theirspouses and visit Disneyland on the way. Can Marvell pay for this trip?

Q&A

A. Paying for spouses or non-business side trips is typically not permitted. Also, because
the company appears to be owned by a public university, the employees are probably
government officials. This would need to be reviewed by the Compliance Team.

Key Resources
Global Anti-Corruption Compliance Policy
Global Travel and Expense Policy
Gifts and Entertainment Pre-Approval Form
Employee Handbook

Fair Competition
At Marvell we compete vigorously yet fairly for business. Marvell will not permit any
activity that has the effect or intent of unlawfully reducing or diminishing competition.
We must all abide by U.S. antitrust laws, as well as the competition laws of all countries
in which we do business. Failure to comply with these laws can have serious
consequences for the company and the individuals involved, including criminal liability.
You should never enter into agreements, take actions or have discussions withcompetitors that have the effect of reducing competition or harming consumers,
including but not limited to:• exchanging information (or agreeing to exchange information) with competitors on
pricing, policies, contract terms, cost, inventory, market share, capacity planning orother competitive terms;• dividing or allocating markets or territories or boycotting suppliers or customers.

Competitive Information
Business intelligence about our competitors and the market must be obtained legallyand ethically. You must not steal or unlawfully use the information, material, products,
intellectual property or proprietary or confidential information of anyone, including
competitors, business partners and customers.

Key Resources
Anti-Trust Guidelines
Employee Handbook

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Complying with Global Trade Regulations
Marvell engages in trade activities around the globe every day, and the applicableregulations are complex. Trade activities subject to export regulations include theexport and import of products, sending product schematics across borders, hiring an
employee from one country to work in another country, and hand-carrying prototypes
or samples of our products across international borders. We are prohibited from doing
business with customers in certain countries. In some cases we must obtain a license
before transferring certain information or products to certain people or customers. We
also must screen our business partners to ensure we are not conducting business witha person with whom or in a country where we are legally prohibited from doing so.
Marvell is committed to complying with applicable trade regulations, and expects its
employees that are involved in any aspect of trade activity to understand and comply
with all applicable regulations. For more information, contact Marvell’s Trade
Compliance Team, and review Marvell’s detailed Global Trade Compliance Policy.

Key Resources
Global Trade Compliance Policy
Global Trade Compliance Intranet Site

Avoiding Money-laundering Situations
Money laundering is the process of making illegally gained proceeds, often referred toas “dirty money,” appear legal or “clean.” People involved in illegal drugs, terrorism or
fraud often try to engage in money-laundering activities. It is vital that we work toprevent money laundering by conducting appropriate due diligence on our business
partners, monitoring their activities and reporting any suspicious activities. Examples
of suspicious activity include a request to pay in cash, a single payment being split into
multiple transactions, the use of offshore bank accounts or other unusual methods of
payment. Money laundering and anti-terrorism issues can be complicated. If you
encounter any transaction that doesn’t seem right, promptly bring it to the attentionof your manager, or contact the Legal Department.

Q. We’re selling to a customer located in China. They want to pay their bill throughan unrelated company in Cyprus because they said it will simplify their currency
restrictions. Is this okay?
A. The involvement of an unrelated company is suspicious and is a red flag requiring
closer examination. There are strict laws governing the movement of money into andout of the United States and many other countries. Anytime someone other than theparty to the contract tries to pay us or seeks payment from us, it is a red flag thatneeds to be looked into, because although the party may not have any intent to breakthe law, complying with his request may put you—and us—at risk of violating several
financial laws including those that prohibit money laundering. It is not sufficient tojust take the word of the vendor—you need to raise the issue to the Legal Department
immediately to make sure that we perform adequate due diligence.
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Our Workplace

Avoiding Conflicts of Interest
A conflict of interest is any activity or relationship that is inconsistent with orcontradictory to Marvell’s best interests, gives the appearance of impropriety or
divided loyalty, or interferes with your job performance or independent judgment whencarrying out your duties on behalf of Marvell. All of our business decisions and actions
should be based on the best interests of Marvell and not on personal relationships or
personal gain. Potential conflicts of interest are not uncommon, and may be acceptable
if properly disclosed and managed. Even if you do not intend for your actions to create
a conflict of interest, the perception of a conflict by others can be just as damaging to
you or Marvell. Therefore, it’s important to recognize and disclose actual or potential
conflicts of interest so that precautions can be taken to protect both you and Marvell.

All new hire employees and employees who join Marvell through an acquisition orother transaction will certify to the Code as part of their onboarding, at which timethey must disclose any actual or potential conflicts of interest. Every year, allemployees will be required to recertify their compliance with the Code, including theconflicts of interest provisions.

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Disclosing Actual or Potential Conflicts of Interest
As part of the annual certification to the Code, you will be asked to disclose inwriting any actual or potential conflicts of interest. In addition, you may berequired to make additional disclosures throughout the year as conflicts arise,or the facts of a previous disclosure regarding conflicts of interest change.
Your disclosure should include potential conflicts of interest involving yourfamily members or individuals with whom you have a significant relationship.
 xecutives and members of the Board of Directors make disclosures under aEprocess that is managed by Marvell’s Legal Department and reviewed by the
Board of Directors or a committee thereof.
 isclosures made by all others will be reviewed by the Conflict of Interest
D
Review Committee (the COI Committee), a subcommittee of Marvell’sinternal Ethics and Compliance Committee. The COI Committee may consult
with other personnel within the company, which may include your supervisor
or others in your reporting chain. A recommendation regarding whether
your reported activities constitute a conflict of interest will be provided toyou, with a copy to your supervisor.

Family and Personal Relationships in the Workplace
Positive, professional relationships are key to building trust andcollaboration, and given the amount of time that colleagues spend together,
employees may form close personal relationships. Marvell respects theprivacy of its employees and is generally not concerned with any employee’s
family or other close personal relationship. However, when a family or close
personal relationship between co-workers affects or may affect anemployee’s responsibility to make decisions in the best interest of thecompany, it is of concern to the company because the relationship may
create a real or perceived conflict of interest. For example, personal financial
business relationships between co-workers like partnering in an outsidebusiness endeavor, renting property, or loaning money to one another, arediscouraged because a disagreement or even failure or inability to repay theloan can create tension between employees in the workplace.
Family members include your spouse, domestic partner, significant other,parent, step-parent, child, step-child, siblings, in-laws, or anyone residing
in your home or the home of a family member (other than a tenant or
employee). Close personal relationships may include dating, romantic,
sexual, boyfriend/girlfriend, spouse, significant other, domestic partneror similar types of relationship.

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Family members and individuals in close personal relationships are never permitted
to engage with each other in the following ways within Marvell:• Manager/subordinate relationships: Family members or individuals with close
personal relationships may not report to each other. Reporting relationships canbe direct or indirect (dotted-line), and include an engagement manager managing
a contractor or contingent worker.
• Ability to make employment-related decisions: Family members or individuals withclose personal relationships may not directly or indirectly be involved in each other’s
employment-related decisions such as hiring, work assignments, compensation,
performance reviews, disciplinary actions, or recommendations for promotions.
If you have a family member employed or to be employed by Marvell; or are in a close
personal relationship with another Marvell employee or contractor, you must consult the
Employee Handbook for additional guidance, including when you should disclose such
relationships to Marvell. Depending on the nature of the relationship and your role
within the Company, disclosure and / or changes to work arrangements may be required.

Employees should neverallow their personal
relationships to disrupt theworkplace, or interferewith their work or
independent judgment.

Family and Personal Relationships with Third Party Business Partners
Marvell interests can be compromised when you have a family member, or someone
with whom you have a close personal relationship who owns or is employed by athird party involved in Marvell’s business, such as a Marvell supplier, customer orcompetitor. Such situations are not prohibited, but they call for increased sensitivity
to confidentiality and conflicts of interest. Such relationships must be disclosed
to compliance@marvell.com as soon as possible, and you may not conduct Marvell
business with these family members or persons with whom you have a close
personal relationship without prior approval from the COI Committee.

Q: My brother owns a business that is a Marvell vendor. Marvell frequently buys
supplies from my brother’s business. Is this a conflict of interest for me?
A. Not necessarily. If your brother’s company is selected as a Marvell vendor solely
based on the quality of the products it provides, and the business between his
company and Marvell is conducted in a fair, arms-length manner, it’s probably nota conflict. However, you are required to remove yourself from the decision-making
process and to disclose the relationship to both companies so that the nature of
the relationship can be properly assessed. At Marvell, the COI Committee will look at
the facts and circumstances of the relationship between your brother’s company
and Marvell, including how your role or team interacts with your brother’s company,
and will determine if any potential conflict can be successfully mitigated.

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Outside Employment, Business or Inventions
 mployment or business. Before accepting a simultaneous job outside of Marvell orEparticipating in work that competes with or relates to Marvell’s present or reasonably
anticipated business, products or services, you must receive approval from the COI
Committee. If you have approval to engage in outside employment or an outsidebusiness, you must ensure that those activities do not conflict or interfere with your
Marvell responsibilities or your ability to perform your duties for Marvell.
I nventions. To the extent permissible by law, Marvell owns the rights to anything you
develop as a result of your employment with or services to Marvell. Developing an
invention outside of Marvell may create a conflict of interest. It is your responsibility topromptly and fully disclose to Marvell any inventions you are developing, alone or withothers, including any inventions that you believe are potentially not owned by Marvell.
Disclosures may be made to the Compliance Team. Any determination aboutownership will be evaluated pursuant to the disclosures and the related facts andcircumstances and Marvell’s Procedures for Assigning Ownership of Employee
Inventions. Please see the section on Marvell intellectual property, below, for more
information about reporting inventions.
In addition, you may not:• Use any Marvell work time or assets for your outside job or work outside of Marvell, or yourwork on an invention that Marvell has determined to be personal to you. This includes
using Marvell facilities, phones, computers, internet access, copy machines, or any other
Marvell assets or services, including consulting with any other Marvell employees.
• Use your position at Marvell to solicit work or obtain favored treatment for, or ask other
Marvell employees to help you with, your outside job or work outside of Marvell, or yourwork on an invention that Marvell has determined to be personal to you.
• Use or otherwise disclose Marvell confidential or proprietary information to benefit
your other employer or your outside job or work outside of Marvell, or your work on
an invention that Marvell has determined to be personal to you.

Key Resources
Employee Handbook
Conflict of Interest Disclosure Form
Procedures for Assigning Ownership of Employee Inventions

Corporate Opportunities
You have a duty to Marvell to advance Marvell’s business interests and pursue
opportunities solely on behalf of Marvell. You must never compete with Marvell or use
Marvell’s assets or your position with Marvell for personal gain. Therefore, you mustnever take for yourself or your family members any business or investment opportunities
presented to Marvell, or discovered by you during the course of your employment,
without first presenting it to Marvell.

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Personal Investments
Marvell respects your right to manage your personal investments. However, having
investments in organizations that do business with or compete with Marvell may giverise to a conflict of interest if you are involved in or attempt to influence transactions
between Marvell and the organization in which you are invested. If you or your family
members have financial interests or investments in Marvell customers, suppliers,
competitors or other business partners, you must disclose that information to the
COI Committee, which will determine whether there is a conflict of interest and, if
appropriate, the best approach to manage or eliminate the conflict. When evaluating
your ownership in other entities for conflicts of interest, the COI Committee will look at
the size and nature of the investment, the relationship between the entity and Marvell,
your ability to influence transactions with the entity, and other information as required.

Q. I hold shares in a mutual fund that buys stock in high-tech companies, including
semiconductor companies. Do I need to disclose this type of ownership?
A. If you are not involved in the investment decisions made by the mutual fund, it is nota conflict of interest to own shares in a diversified mutual fund operated by fundmanagers. However, you may not make investment decisions to buy or sell a specificfund based on material nonpublic information relating to Marvell, its customers,
suppliers, competitors or other business partners.

Q&A

Protecting Marvell’s Assets
You are responsible for protecting Marvell’s assets, including physical assets, andsafeguarding the assets from loss, waste, theft or unauthorized use. You must
appropriately secure all assets within your control to prevent loss, waste, theft or
unauthorized use. If you notice or become aware of any situation or incident that could
lead to the loss, waste, misuse or theft of company assets, you must immediately report
it to Marvell Security, your manager or HR Business Partner, or the Compliance Team.
What are Assets? Physical assets include things like equipment, furniture, supplies, computers, facilities,
company-provided cellphones and corporate credit cards. Other Marvell assets include things like your work
product; cash and accounts; intellectual property such as patents, copyrights, trademarks, inventions,
technology, hardware, software and trade secrets; and other confidential, proprietary or nonpublic information.

Technology Use
Marvell provides various technology for use in performing our jobs, such as telephones,
networked computers, laptops and internet access, and these things are Marvell property,
and should be used primarily for conducting Marvell business. Marvell permits limited,reasonable personal use, provided that use does not negatively affect the performance ofyour job, and is lawful and appropriate. Unless otherwise protected by applicable law, you
should not expect privacy when using Marvell-provided technology. You may not use any

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Marvell systems or other assets in violation of Marvell policies; to commit any unlawful
or illegal act, including but not limited to harassment, fraud, trafficking in contraband,or viewing or distributing pornography; or to operate a side business.

Q. I run some systems at home to mine bitcoin. I want to bring my computer systems
in to work, so I can more closely monitor them. Is this okay?
A. No, this isn’t okay. First, Marvell does not permit personal, non-Marvell computers
to be connected to the corporate network. In addition, mining cryptocurrency is an
improper use of Marvell assets, including Marvell workspace, power and the time
you should be devoting to your responsibilities for Marvell.

Q&A

Q. I’m volunteering my time to organize and promote a fundraiser for my church.
I need to print a few hundred copies of the flyer for the event, and want to print
them at work and donate them to the church. It’s for a good cause, so it should
be okay, right?
A. While Marvell supports its employees providing volunteer hours to organizations of
their choice, using Marvell assets for non-Marvell related projects is not acceptable.
Making several hundred copies of a flyer using Marvell’s assets violates our policy on
the proper use of the company’s assets, and bringing in your outside work to do on
Marvell time, even if it is volunteer work, is a conflict of interest.

Marvell Confidential Information
We are all responsible for protecting Marvell confidential information at all times.
“Confidential information” is company information not generally known to the public orthe industry, and includes Marvell proprietary information, technical data, trade secrets
or know-how, including, but not limited to, research, product plans, products, services,
customer lists and customers, markets, software, developments, inventions, processes,
formulas, technology, designs, drawings, engineering, hardware configuration information,marketing, finances or other business information. Unauthorized disclosure of confidential
information could harm Marvell’s business and our ability to compete. Improper disclosure
could subject the individuals involved to liability, including criminal liability.
To the extent you need access to confidential information in order to perform your job,
you are responsible for ensuring that the information in your possession is protectedfrom theft, damage, unauthorized disclosure and/or inappropriate use. Always store
confidential information in a secure place, and follow Marvell’s security procedures forthe systems you use and the confidential information you have in your possession.
Never discuss confidential information in places where it can be overheard, such as at a
trade show or in the airport. Never disclose confidential information to any non-Marvell
person without verifying with your manager that the disclosure is appropriate, andensuring that, before any disclosure is made, a nondisclosure agreement is in place.

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Marvell Intellectual Property
Our intellectual property is one of our company’s greatest assets, and we are each
responsible for protecting and preserving it. “Intellectual property” is anything wecreate on Marvell time, at Marvell expense or within the scope of Marvell business.
Examples include ideas, inventions, designs, plans and other work product. To theextent permissible under the law, Marvell owns the rights to anything we develop as aresult of our employment with or services to Marvell, whether or not this property ispatentable, protected by copyright, trade secret or trademark. Subject to local law, thisapplies no matter where or when we create such intellectual property. We must eachreport the intellectual property we develop to Marvell, and we must protect it like anyother Marvell confidential information. Even if the intellectual property developed does
not relate directly to Marvell’s current or anticipated business, and was not the result ofor suggested by a Marvell work assignment, it still may be owned by Marvell and must
be disclosed to Marvell’s Chief Technology Officer (or the head of central engineering)or the head of the intellectual property function in Marvell’s Legal Department. Any
determination about ownership will be evaluated pursuant to the disclosures and therelated facts and circumstances and Marvell’s Procedures for Assigning Ownership of
Employee Inventions.

Confidential Information and Intellectual Property of Others
Just as you need to protect Marvell confidential information and intellectual property,
you must take special care to responsibly handle and protect the confidential
information and intellectual property of third parties. A nondisclosure agreement witha third party must be in place before receiving any of that third party’s confidential
information and/or intellectual property. Once that information is in our care, we mustcomply with the terms of the nondisclosure agreement, and limit our use of theinformation or intellectual property to the specific purpose for which it was provided
to us. If you have a question as to whether third-party materials should be considered
confidential or if a nondisclosure agreement is appropriate, please ask your manager
and the Legal Department for assistance.
If you have confidential information or intellectual property from a prior employer
or from a prior professional relationship, you may not bring it to Marvell in any form,
disclose it to Marvell employees or use it for any Marvell-related purpose without
express permission from the owner of the information or intellectual property.
If you obtain the confidential information or intellectual property of a third party
accidentally or from an unknown source, it may be unethical or illegal to use it.
You must contact the Legal Department to determine how to proceed.
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Use of Third-party Software and Open-source Software
We license third-party software and technology, including open-source software,for use in our products. Such use must be done in accordance with the applicable
license and the rights granted under such license. Downloading or using open-source
software, or releasing our software under an open-source license, is subject toMarvell’s policy on open-source software, including the approvals required by thepolicy. If you are unsure about the license rights for the use of any third-party or
open-source software, or about the requirements for releasing our software underan open-source license, contact a member of the Legal team before proceeding.

Q. I was visiting a distributor, and while waiting for my meeting to start, I saw somedocuments from one of our competitors on the table. I noticed that one of the
documents appeared to be our competitor’s three-year product roadmap. The
documents were labeled “Confidential.” What should I have done?

Q&A

A. First of all, although it might be tempting, don’t read through the documents,
and don’t take them with you. Using another business’s confidential, proprietary orcompetitive information could damage Marvell’s reputation, and could subject you
and Marvell to legal liability. The best approach would be to point out the documents
to your business contact when he or she joins you.
Q. A friend of mine works for a high-tech company and always wants to “talk shop”
when we get together. He’s not in management or anything, so what’s the harmof comparing notes about our jobs?
A. It’s fun to compare notes about new techniques, ideas and solutions with a friend
who can appreciate innovation—but it may be harmful. You must always be careful
to avoid revealing Marvell confidential or nonpublic information. Even though yourfriend may have a genuine and innocent interest in your job, you have no way of
preventing him from disclosing the information you gave him.

Key Resources
Employee Handbook
Information Systems Acceptable Use Policy
Open Source Policy

Marvell Concern Line
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Technical Standards Groups
Marvell participates in industry organizations that develop or promote technicalstandards for wider adoption and interoperability. Participation in technical standards
groups may conflict with your responsibilities to protect Marvell’s confidential or
proprietary information or our intellectual property, and it may also raise legal issues.
It is important to get approval before you begin engaging in activities related totechnical standards, including joining a standards organization or working group, or
contributing technology to a standard. Work with your manager and the Standards
Committee to determine whether Marvell already participates with the organization.
If we don’t, the Legal Department must review and approve the organization’s by-laws,
membership agreement or intellectual property policy, as applicable, prior to yourparticipation. Once the approvals and the agreement are in place and you begin
working with the organization, take care not to disclose any confidential or proprietary
Marvell information, and take appropriate steps to ensure that you are protecting
Marvell’s intellectual property and other confidential or proprietary information.

Key Resources
Worldwide Contract Management Policy
Contracts Intranet Site
Standards Committee Intranet Site

Contracts and Commitments
Marvell has policies and procedures regarding the negotiation and execution ofcontracts, including which contracts need to be reviewed by the Legal Department. It is
critical that our contracting policies and procedures are followed in all cases to ensurethat all agreements between Marvell and third parties are properly recorded, and allcommitments have been approved in accordance with Marvell policies and procedures.
IMPORTANT
Written or verbal business communications saying “we promise,” “Marvell commits” or “I agree” are likely
agreements that require review and approval.

Side Letters
Side letters or side agreements are agreements that are created outside of the formal
contract, that modify or attempt to circumvent the terms of an existing contract
without being documented and approved in accordance with Marvell’s policies.
Examples of possible side letters include verbal or written commitments or promises
about extended payment terms, free or discounted products, return rights, rebates, orother commitments or incentives to buy product. Unless documented and approved inaccordance with Marvell’s policies, side letters increase the risk of accounting andfinancial reporting irregularities, and are prohibited by Marvell.

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Q. I could grow our market in my sales region with a small marketing budget.
However, marketing has other priorities and will not give me the budget. If I giveour distributor a larger standard discount, the distributor has agreed to set aside
the incremental amount for a marketing program that I and the distributor will
manage. Is this creative idea okay because its purpose is to help Marvell?

Q&A

A. No, this proposal has many problems. Setting up “slush funds” or off-the-books accounts
with third parties is never permitted. The arrangement you propose hides the true nature of
the transactions by misrepresenting what should be treated and recorded on our books as
expenses and as revenue. It is also likely an improper side letter. All marketing arrangements
must be fully documented in a contract approved in accordance with our policies.
Q. Marvell has a written sales contract to sell a large amount of product to Big
Customer. Big Customer is concerned that its demand for the units may fall in the
future, and asks my manager, Big Customer’s sales representative, if they canreturn any unused product sometime in the future. My manager emailed Big
Customer (copying me) and wrote: “We’ll make sure you don’t have any problems
if that happens.” Is this a side letter?
A. The manager’s email is a commitment, and if it hasn’t been properly approved inaccordance with Marvell’s policies, it would be an undisclosed side letter. You must
immediately contact the Legal Department or the Marvell Concern Line.

Key Resources
Worldwide Contracts Management Policy

Harassment and Discrimination
Marvell is committed to a work environment in which all individuals are treated withrespect. Marvell expects that all relationships among Marvell employees will be businesslike and free of bias, prejudice and harassment. Marvell will not tolerate discrimination orharassment of employees or non-employees with whom we have a business, service orprofessional relationship, including interactions with employees, customers, suppliers, andapplicants for employment, or in any other interactions in which you represent Marvell.

IMPORTANT
Marvell has zero tolerance
for harassment anddiscrimination, both ofwhich are inconsistent with
Marvell’s core behaviors.

Examples of unacceptable conduct are: insults; threats; intimidation; ridicule;vulgarity; discrimination; harassment; physical or verbal abuse; sexually explicit humor,
conversation or behavior; gossip; slurs or stereotyping; unwelcome sexual advances;
unwelcome touching or invasion of personal space; ignoring the rights of others; andinsensitivity to the beliefs and customs of others.
If you feel you have been harassed or discriminated against, or if you have witnessedsuch behavior, report the incident to any member of Human Resources or any
supervisor or manager, up to and including the Chief Executive Officer.

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Key Resources
HR Intranet Site
Employee Handbook

Confidential Employee Information
In your role at Marvell, you may have access to personal information about other
Marvell employees, or applicants, including their employment history, name, address,
national identification number (such as a Social Security number), background checkinformation, compensation, health information, or performance and disciplinary
matters. This information is confidential, and Marvell will protect all personal andconfidential employee information it collects for legal and operating purposes. If you
have access to confidential employee information, you must comply with all applicabledata privacy and data protection policies and laws regarding the collection, use anddisclosure of that information. Before sharing employee confidential information, youmust check with Legal to ensure you have appropriate approvals first.

When signing up a new service provider that requires or stores Marvell employee data, such as payroll
information, employees’ personal information or employment records, you are responsible for working with
the Legal team to determine whether or not a Data Processing Agreement (DPA) is in place.

Workplace Privacy
While Marvell respects your privacy, it reserves the right to inspect Marvell facilities
and property, including computers, phone records, lockers, emails, files, businessdocuments, offices and workstations. In addition and without prior notice, Marvell may
disclose to law enforcement information discovered during any searches that indicate
possible unlawful behavior. Unless otherwise protected by applicable law, you should
not expect privacy when using Marvell-provided services or equipment.

Key Resources
Employee Handbook

Using Social Media Appropriately
Electronic messages (like email and text messages) and posts on blogs, chat rooms,
social media and networking sites (like Facebook, Twitter and LinkedIn) are permanent,
transferable records, and can impact Marvell’s reputation and business interests. Take
precautions when drafting these types of communications and consider how theyreflect on Marvell. Posting to social media and networking sites may only be done inyour personal capacity, and not on behalf of Marvell, unless you are specificallyauthorized to do so by Marvell. However, you may never post any Marvell confidential
information on any social media or networking sites.

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Endorsements
As a representative of Marvell, you may not endorse another company’s products orservices without approval from your vice president and the Corporate Marketing team.

Q.I work with a vendor that supplies a cloud-based tracking tool for Marvell. I talkwith this vendor all the time for tech support, reports, etc. Recently he asked me
if I’d sign a letter saying how great his services are. The services are really good.
Can I sign the letter?

Q&A

A. Not without approval from your vice president and the Corporate Marketing team.
Even if the services are great, Marvell’s policy does not permit you to sign the letter
without the appropriate approvals, because by doing so, you are representing that
Marvell is endorsing the vendor’s product.
Q. I have a friend that just opened a bagel shop, and is looking for customer
endorsements for her website. Is this kind of endorsement okay?
A. Yes, as long as you provide the endorsement in your personal capacity, and notwith your Marvell job title or affiliation.

Key Resources
External Communications Policy
Social Media Policy
Employee Handbook—section: Publication Policy

Marvell Concern Line
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Our Shareholders

Avoiding Insider Trading and Tipping
You must comply with applicable securities laws. Marvell has adopted an Insider
Trading Prohibition Policy and Guidelines, which applies to our directors and all
employees worldwide. The policy sets forth your obligations regarding trading in the
securities of Marvell and other companies, including the prohibition against tradingwhen aware of information that has not been publicly announced and could have amaterial effect on the stock price. This applies not only to buying and selling Marvell
stock, but also to third-party stock, such as the stock of a Marvell supplier or customer.
It is also against Marvell policy, and is illegal, for you to give others tips on when to buy
or sell stock when you are aware of material, nonpublic information concerning thatcompany’s stock.
Marvell employees, executive officers and members of the Board of Directors are
subject to blackout periods during which they are prohibited from trading in Marvell
stock, as described in the Insider Trading Prohibition Policy and Guidelines. Even if
Marvell is not in a blackout period, you may never buy or sell stock when aware ofmaterial, nonpublic information.

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Q. How do I know if information could have a material effect on the value of acompany’s stock?

Q&A

A. Information is material if it would be important to an investor making a decision
about buying or selling a company’s stock. In particular, information is material if
you or any reasonable investor would expect it to affect the price of the company’s
stock. Both positive and negative information can be material. Remember that yourdecision to buy or sell a company’s stock may be evaluated after the fact with thebenefit of hindsight; accordingly, questions concerning the materiality of particular
information should be resolved in favor of materiality, and trading should be avoided
if you are uncertain about whether information is material.
Q. When does information become “public”?
A. Information is not considered available to the public until it has been released tothe public through appropriate channels, such as a press release, a filing with the
Securities and Exchange Commission (SEC) or a public statement from one ofMarvell’s senior officers, and enough time has elapsed to permit the investment
market to absorb and evaluate the information. At Marvell, information is considered
nonpublic for one full trading day after the public disclosure of that information.
Q. What exactly is “material, nonpublic information?”
A. Common examples of material, nonpublic information include a company’s
financial results, earnings estimates, significant business acquisitions or sales,
gain or loss of a major customer or supplier, changes in management or the boardof directors, stock splits, major litigation, and some communications or rulings
from government agencies.

Marvell Concern Line
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Q. I have some vested RSU and ESPP shares, and I would like to write a covered call
contract, also known as selling an option contract, using Marvell shares as
collateral. Is this allowed?

Q&A

A. No, it isn’t. Marvell employees, directors, contractors and consultants are prohibitedfrom trading in “derivatives securities,” including swap funds, call options and put
options tied to Marvell securities, as well as engaging in “short sales” of Marvell
securities. Please review the section in the Insider Trading Prohibition Policy andGuidelines titled “Policy on Short Selling, Hedging, Pledging and Trading in
Derivative Securities.”
Q. I’m an engineer at Marvell and am not involved with any M&A activity at thecompany. My boyfriend told me that his company is in talks with Marvell about
getting acquired, and that I should buy stock in his company now, since it willprobably skyrocket once the acquisition is announced. Since we’re not married,
and we have separate bank accounts, and I’m not involved in the M&A discussions,is it okay for me to buy stock in his company?
A. No, using material nonpublic information for personal purposes or disclosing it toothers is illegal, and it violates Marvell’s Insider Trading Prohibition Policy andGuidelines. Under these circumstances, both you and your boyfriend are potentiallyin trouble. If your boyfriend gave you material nonpublic information, a court mightfind that he was trying to help you profit or gain something by tipping you to theinformation about his company’s pending acquisition, and that you used material
nonpublic information for personal gain.

Key Resources
Insider Trading Prohibition Policy and Guidelines
Employee Handbook

Communications with the Media and the Financial Community
As a public company, Marvell must disclose full, fair, accurate, timely andunderstandable information regarding our financial results, operations and othersignificant developments. Further, facts may not be misstated, critical information
may not be omitted, and records or reports may not be modified to mislead others.
To ensure that Marvell’s disclosures are communicated appropriately and comply
with Marvell’s policies and the law, Marvell has authorized certain employees tocommunicate with the press and the financial community. Marvell will not tolerate
unauthorized leaks or disclosures of corporate information to the press or financial
community. Any inquiries from the press or financial community must immediately
be directed to Marvell’s Investor Relations Department. No employee is permitted
to speak to the media on Marvell’s behalf unless he or she is pre-approved to do soin accordance with our External Communications Policy.

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Industry Consultants or Industry Experts
On occasion, other organizations may offer you the opportunity to consult with themor provide your opinion about the technology industry, the semiconductor industry or
about Marvell. Sometimes these offers come with a financial incentive. This kind of“consulting,” however, poses serious risk to you and to Marvell, including the potential
exposure of material nonpublic or other confidential or inside information about
Marvell. Therefore, you are prohibited from engaging as an “industry consultant” or“industry expert,” whether or not you are being paid.

Q. I got a message through my LinkedIn email from a research analyst. He wrotethat he works for an expert network firm that connects clients with industry
professionals, and he’s hoping to get a high-level overview on the semiconductor
industry. He offered to pay me to talk about industry-related questions. Thissounds like easy money to me. Can I take the consulting opportunity?

Q&A

A. No, Marvell does not permit its employees to serve as industry “consultants” or“experts” without appropriate authorization. If you are not a designated spokesperson
for Marvell, you are not authorized to speak on behalf of Marvell. In addition, you may
not use for personal gain any nonpublic, confidential or proprietary information about
Marvell or its suppliers, customers or competitors obtained in the course of youremployment with or service to Marvell. You should not accept the consulting
opportunity without first notifying and getting approval from the COI Committee.

Public Speaking and Publications
Public speaking engagements that relate to Marvell or its products must be pre-approved
pursuant to the External Communications Policy. If you are requested to speak, in person
or virtually, where you will share information that relates to the Marvell products,
operations, business, and plans, you must obtain pre-approval from the Technical Review
Board by completing a Publication and Speaking Authorization Form.
If you are requested to speak, in person or virtually, at a business conference or meetingthat is not of a technical nature (for example participation in a panel about diversity),
you must obtain pre-approval from the COI Review Committee by completing a
Conflicts of Interest Disclosure Form. Any form of personal compensation or honorarium,or reimbursement for expenses (e.g., travel and lodging expenses) must also be preapproved by the COI Review Committee.
If you are requested or plan to write an article, white paper or other document related to
Marvell or its products or business, you must ensure that you comply with the Publication
Policy section in the Marvell Employee Handbook prior to publication. You also mustobtain pre-approval by completing a Publication and Speaking Authorization form.
Examples of printed publications include, articles, papers, presentations or blogs, andpublic speaking engagements typically involve conference presentations or contribution to
standard bodies.
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Financial Matters and Business Practices
All transactions and business records must be fully, fairly and accurately recorded inour books and records in compliance with our policies and the applicable laws.

Key Resources
Conflicts of Interest Disclosure Form
Publication and Speaking Authorization FormBusiness records
Business records are any documents or communications in paper or electronic form
(including email) exchanged and retained in the course of business. Business records may
include point-of-sale reports, invoices, purchase orders, inventory reports, quality control
tests, travel and expense reports, timecards, contracts and legal agreements, and otherdocumentation and communications. Maintaining accurate and complete businessrecords is critical to meeting Marvell’s legal, financial and management obligations, andall business records and reports must be full, fair, accurate, timely and understandable.
You must never misstate facts, omit critical information, falsify a record, or attempt tohide or disguise the true nature of a transaction, and never assist others in doing so.

Q. I recently learned that some accounts payables were incorrectly recorded asadvertising when they were actually for entertainment. The total amount spent
was the same, and no payments were made in error. Is it a big deal if wemisclassify the expense in our books?

Q&A

A. Yes. Marvell’s books should always be kept up to date and fully reflect the accurate
details of all of our transactions. If you become aware of an error, you should takeappropriate steps to correct it. False transactions or misrepresentations about
finances violate Marvell’s policies and may also violate the law.
Q. I have been asked by my manager to sign a financial record that I do not believe
is accurate, but my manager insists is correct. What should I do?
A. Never sign a business record if you believe it is not complete, accurate and truthful.
Neither your manager nor anyone else should apply pressure to influence, coerce
or manipulate you to produce or sign off on an inaccurate record. If you feel you arebeing pressured, you should share your concerns with your manager or the Legal
Department and/or make a report on Marvell’s confidential Concern Line.
Marvell Concern Line
Report a Concern 24/7 atconcernline.marvell.com

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Records retention and legal holds
Business records must be managed and disposed of consistent with Marvell’s
Data Retention Policy and Schedule. From time to time, Marvell may become
involved in disputes or inquiries that require us to implement a “legal hold”
and indefinitely preserve certain documents and records relevant to thematter. If you receive notice that information in your possession is subject toa legal hold, you must not destroy, delete, alter or modify records or
supporting documents under any circumstances.

Key Resources
Data Retention Policy and Schedule
Global Anti-Corruption Compliance Policy

Marvell Concern Line
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Our Communities

Political Contributions
Any proposed political contributions or engagements with lobbyists, in any form, madeor undertaken on Marvell’s behalf or in its name, must be pre-approved by theCompany’s Chief Administration and Legal Officer.

Public Service and Volunteering
Marvell works with and contributes to charitable organizations to benefit and enrich thecommunities in which we live and serve. Marvell encourages its employees to be active intheir communities; however, you must avoid any conflicts of interest between Marvell
and your public service or volunteering, and you must make it clear to the organization
for which you are volunteering that you are not acting for or on behalf of Marvell.

Human Rights
Marvell doesn’t engage in child labor, human trafficking, forced, bonded or indentured
labor, or physical punishment. We are committed to preventing these practices in ouroperations and supply chain. We respect internationally recognized human rights
where we operate, and support the rights of employees in our suppliers’ operations.

Marvell Concern Line
Report a Concern 24/7 atconcernline.marvell.com

Key Resources
Global Human Rights Policy
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Taking Action

Resources
Marvell provides several resources, which you may contact at any time, for you to ask
questions or raise concerns. For questions about the applicability of the Code or thelaw, or if you are unsure whether a proposed action complies with the Code or the law,
contact the Compliance Team. If you would like to report compliance failures or
express concerns regarding compliance matters, your manager may be in the best
position to assist you (provided you do not believe your manager is involved in theviolation); however, there are a number of other resources available to you that canoffer guidance in addressing a difficult situation. You are encouraged to speak up if
you have concerns regarding compliance with the Code or law. If you become awareof a violation of the Code or law, you are obligated to report it. You should choose
the resource you feel most comfortable with in speaking up or reporting, including:• an executive or another manager
you trust;• Human Resources;• the Compliance Team;• the COI Review Committee;• the Marvell Concern Line, which
may be used anonymously and isavailable 24 hours per day every day
at http://concernline.marvell.com.
You may also call the local phone
numbers listed on the Concern Line.

Marvell Concern Line
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Compliance with the CodeViolations of the Code will subject employees to disciplinary action, up to andincluding termination. Violations of the Code by independent contractors, consultants
and others who do business with Marvell may subject that individual’s company tocontract termination, or require Marvell to refer such violation for criminal prosecution
or civil action.

Reporting Procedures and Other Inquiries
If you ever have questions or concerns about anything in the Code, other Marvell
policies or the law, you should raise them as soon as possible. If you have any doubt
about the best course of action in a particular situation, ask for assistance. If you
suspect any unethical conduct or violation of the Code, other Marvell policies or thelaw, or if you see something that doesn’t seem right, you should report it immediately.
Marvell takes seriously all good-faith conversations, calls and reports made pursuant
to the Code, and your prompt action to report any suspected misconduct can help
prevent or limit any damage to Marvell and its reputation.
Please consult the resources listed below. Supervisors are expected to promptly reportany violations or concerns brought to their attention in their supervisorial capacity.
If you prefer to make an anonymous report, you may contact Marvell Concern Line.
When submitting concerns, please provide as much detailed information as possible
to ensure an effective investigation of your concern. This is especially important when
you submit a complaint on an anonymous basis, since we may be unable to contact
you with requests for additional information or clarification.
You may also report concerns regarding the following to Marvell’s Board of Directors
or the Audit Committee:• accounting, internal accounting controls and auditing matters, or concerns
about the accuracy of financial statements or auditing matters;• corporate fraud;• conduct that may result in a violation of applicable laws, rules or regulations
by Marvell, or in a substantial mismanagement of Marvell resources;• unethical or illegal business conduct, or a violation of the Code and other Marvell
policies, including the Insider Trading Prohibition Policy and Guidelines.
• a violation of the rules or regulations of the principal market on which Marvell’ssecurities are traded, currently the NASDAQ Global Select Market.
Marvell Concern Line
Report a Concern 24/7 atconcernline.marvell.com

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Concern Line
Marvell’s confidential Concern Line is administered by a third-party service provider, andis available 24 hours per day, 7 days per week. The Marvell Concern Line may be accessedat http://concernline.marvell.com or by phone using the numbers listed on the Concern
Line website. Reports to the Concern Line may be made anonymously, local law
permitting. Whether you identify yourself or not, your contact will be kept strictly
confidential to the extent reasonably possible within the objectives of the Code, Marvell’s
policies and any applicable laws. Reports received through the Concern Line are assessedby the Compliance Team, are assigned to the appropriate investigator and are elevatedto the Board or a committee of the Board to the extent necessary or appropriate.

Investigations
Marvell will promptly respond to reports of employee misconduct, and to any
government investigations or inquiries from government agencies concerning Marvell.
As a Marvell employee, you may be called upon to assist with investigations, bothinternal and external. You must cooperate with, and provide complete and accurate
information related to, any Marvell-related inquiry or investigation, and you may notdestroy any related records, books of account or other documents relating to theinvestigation unless otherwise advised by Legal. You must never attempt to cause any
employee’s noncompliance with these investigations. You may not conduct any
investigation on your own without the proper authorization from the ComplianceTeam or from the Chief Legal Officer. As needed, Marvell investigators may consult
with Human Resources, Internal Audit, and/or the Board of Directors or the Audit
Committee of the Board.

Confidentiality of Reporters and Individuals Assisting in Investigations
Your written or verbal reports, questions and information will be treated confidentiallyto the extent possible and permitted by law. Concern Line reports may be madeanonymously, local law permitting. Investigation results will not be disclosed to or
discussed with anyone other than those who have a legitimate need to know in order to
conduct the investigation or take corrective action, to the extent permitted by the law.

False Allegations
Any allegations that are knowingly false or without a reasonable belief in the truth
and accuracy of such information will be viewed as a serious disciplinary offense.

Key Resources
Marvell Investigations Policy

Marvell Concern Line
Report a Concern 24/7 atconcernline.marvell.com

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Marvell will Not Tolerate Retaliation
Marvell prohibits retaliation against anyone who makes a good-faith report of actualor possible wrongdoing, whether such report is made internally or to an applicableregulatory agency, including the SEC. Marvell also prohibits retaliation against anyone
who participates in the investigation of such a report.

Provisions Applicable to Financial Professionals
The following provisions specifically apply to the CEO, CFO, Controller and Chief
Accounting Officer, and all employees in the accounting and financial reporting
functions (the Financial Professionals). The Financial Professionals will:• engage in and promote honest and ethical conduct, acting with integrity andexercising their best independent judgment at all times;• avoid actual or apparent conflicts of interest (COIs) between personal andprofessional relationships, and disclose such COIs in accordance with the Code;• produce full, fair, accurate, timely and understandable disclosure in reports anddocuments that Marvell files with, or submits to, the SEC and in other public
communications made by Marvell;• comply with applicable laws, rules and regulations, as well as the rules andregulations of self-regulatory organizations of which Marvell is a member; and• promptly report any possible violation of the provisions set forth above.
All Financial Professionals are prohibited from directly or indirectly taking any action
to coerce, manipulate, mislead or fraudulently influence Marvell’s independent
public accountant engaged in the performance of an audit or review of the financial
statements of the company for the purpose of rendering the financial statementsof Marvell misleading.
Waivers of the provisions relating to directors and executive officers shall be approvedby the Board of Directors, and any such waiver shall be disclosed promptly as requiredby law or SEC regulations.

Amendments to the CodeAny substantive amendments to the Code shall be approved by the Board of Directorsof Marvell and shall be disclosed promptly as required by law or SEC regulations.

Effective date: March 2022
This document is not an employment contract between Marvell and its employees, and does not modify your employment relationshipwith Marvell. This Code is intended to clarify your existing obligations for proper conduct. The standards set forth in the Code and the
supporting policies, guidelines or procedures may change from time to time at Marvell’s sole discretion. You are responsible for knowing
and complying with the current laws, regulations, standards, policies and procedures that apply to Marvell’s business. The most current
version of this document can be found on the intranet at my.marvell.com, or externally at http://investor.marvell.com/phoenix.
zhtml?c=120802&p=irol-govhighlights. All directors, officers and employees of Marvell will be held accountable for their adherence to theCode. Failure to observe the terms of the Code may result in disciplinary action, up to and including termination. Violations of this Codemay also constitute violations of law, and may result in civil and criminal penalties for the individual, his or her supervisor, and/or Marvell.

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Key Resources

Anti-Trust Guidelines

Human Resources Intranet Site

Concern Line

Information Systems Acceptable Use Policy

Conflict of Interest Disclosure Form

Insider Trading Prohibition Policy and Guidelines

Contracts Intranet Site

Investigations Policy

Data Retention Policy and Schedule

Open Source Policy and Annexes

Employee Handbook

Our Business Practices and Key Resources

External Communications Policy

Our Workplace

Global Anti-Corruption Compliance Policy

Publication and Speaking Authorization Form

Global Gifts and Entertainment Pre-Approval Form

Publication Policy

Global Human Rights Policy

Social Media Policy

Global Trade Compliance Policy

Standards Committee Intranet Site

Global Trade Compliance Intranet Site

Supplier Code of Conduct

Global Travel and Expense Policy

Worldwide Contract Management Policy

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remains at the heart of the company’s storage, networking and connectivity solutions. With leading intellectual property and deep system-level knowledge, Marvell
semiconductor solutions continue to transform the enterprise, cloud, automotive, industrial, and consumer markets. For more information, visit www.marvell.com.
© 2022 Marvell. All rights reserved. The MARVELL mark and M logo are registered and/or common law trademarks of Marvell and/or its Affiliates in the US and/or othercountries. This document may also contain other registered or common law trademarks of Marvell and/or its Affiliates.