Code of Conduct
May 2024

Table of Contents
Purpose and Values

3

3. Ethical Personal Conduct

11

Leadership Message

4

4. Protection of Intellectual Assets

14

1. Introduction

5

5. Fair and Ethical Business Practices

17

2. Fair Labor and Employment
Practices82

Purpose and Values
The Purpose of TechInsights is to support innovation and decision making in thesemiconductor industry through independent research and analysis. Our reason forbeing is to support our customers in advancing the world around us.
TechInsights conducts business ethically, honestly, and in full compliance withapplicable laws and regulations. This applies to all areas of work and businessdecisions worldwide.
The following Values guide all our business activities:
Complying with laws
Respect and comply with all applicable federal, provincial, state, andmunicipal laws.
Honesty and Integrity
Demonstrate honesty and high ethical standards in all business dealings.
Respect and Diversity
Treat customers, partners, suppliers, employees, and others with respect andcourtesy. Harness diversity and varying viewpoints.
Confidentiality
Protect TechInsights’ confidential information, content and the information of
our customers, partners, suppliers, and employees.

3

Leadership Message
TechInsights is the information platform for the semiconductor industry.
Regarded as the most trusted source of actionable, in-depth intelligence related to semiconductor
innovation and surrounding markets, TechInsights’ content informs decision makers andprofessionals whose success depends on accurate knowledge of the semiconductor industry—past,present, or future.
Over 650 customers and 95,000 users access the TechInsights Platform, the world’s largest verticallyintegrated collection of unmatched reverse engineering, teardown, and market analysis in thesemiconductor industry. This collection includes detailed circuit analysis, imagery, semiconductor
process flows, device teardowns, illustrations, costing and pricing information, forecasts, market
analysis, and expert commentary. TechInsights’ customers include the most successful technology
companies who rely on TechInsights’ analysis to make informed business, design, and productdecisions faster and with greater confidence. For more information, visit www.techinsights.com.
Our Purpose is to support innovation and decision making in the semiconductor industry throughindependent research and analysis. Our reason for being is to support our customers in advancing
the world around us.
It is based on our Purpose that we create value through our authoritative information platform for thesemiconductor industry.
In pursuing our Purpose in accordance with our Values: complying with laws, honesty and integrity,
respect and diversity, and confidentiality, it is crucial that everyone in our organization follows the
TechInsights Code of Conduct (the ‘’Code’’), which serves as a guide for our daily business
operations.
We ask each and every one of you to apply our Code to your daily activities and ensure our values
are upheld and practiced in our daily work.

Chief Executive Officer

Gavin Carter4

1. Introduction5

1. Introduction
TechInsights’ Code of Conduct governs both TechInsights’ corporate
commitment to its customers and professional conduct expected of
employees and consultants acting on behalf of TechInsights.
TechInsights is committed to corporate social responsibility and responsible
sourcing to ensure safe working conditions, respect of worker rights, andenvironmentally conscious business operations. This applies to ourrecruitment and employment practices, procurement and subcontracting,health and safety and environmental policies.
TechInsights employees are expected to adhere to this Code and exercise
honesty and integrity in the performance of their duties, and to act
professionally and ethically when dealing with customers and otherprofessionals both within and outside the organization. The purpose of thisCode is to clearly outline TechInsights’ expectations of its employees andother representatives of TechInsights.
All employees and contractors worldwide are included in this Code whether
they are on TechInsights’ property, traveling on TechInsights’ behalf to meetwith customers or prospective customers, interacting with suppliers, or
attending a conference or training event.
All employees, contractors, and other relevant parties who are granted
access to TechInsights’ information or any of TechInsights’ Information andcommunications technology resources must abide by this Code.

Your
Responsibilities
Your Responsibilities as a TechInsights employee are to:
Follow the Policy and Laws
Comply with the content and spirit of this policy and all applicable federal, provincial,state, and municipal laws.
Demonstrate Honesty and Integrity
Always treat one another with dignity and respect—especially when there is adisagreement—and always respect the rights of others.
Speak UpIf you see or hear of any violation of this policy, other policies, or legal or regulatory
requirements, you must notify either your manager, People Team, or Legal andCompliance Team.
Use Good Judgment and Question
Apply TechInsights’ principles of ethics and business conduct and review our policies andlegal requirements. When in doubt about how to proceed, discuss it with your manager,
your People Team, or Legal and Compliance Team.
Protect Our Property
Show proper care and regard for company property and the property of others.

6

Reporting and
Sanctions
Any employee experiencing or witnessing conduct contravening or not incompliance with this Code, or having reasonable grounds for believing that suchconduct has occurred should:

No Retaliation
TechInsights will not tolerate retaliation against any individual for reporting a
good-faith concern or complaint to a manager, People Team, Legal andCompliance, or any other relevant department, or for participating in theinvestigation of a concern or complaint. TechInsights does not tolerate
misrepresentation and knowingly false reporting.

1. advise the person who is suspected of wrongdoing that he or she
is violating the Code, and that corrective action should be taken
immediately; and/or
2. if you are not comfortable advising, or if advising the individual
was not effective, or if there remains any outstanding concern,
employees must report the incident to a member of our People
Team, or Legal and Compliance Team.
Managers who were previously notified about the Code violation must also report
the incident to a member of our People Team, or Legal and Compliance Team. Any
failure to comply with this Code—or failure to report a violation—may result in
disciplinary action, up to and including termination of employment.
You are also required to fully cooperate in any investigation, and keep any
information shared with you confidential to safeguard the integrity of theinvestigation.
You are also encouraged to use the TechInsights’ Confidential Reporting process
as described in the Whistleblower and Confidential Reporting Policy.

7

2. Fair Labor and
Employment
Practices82. Fair Labor and
Employment
Practices

TechInsights will ensure that it adheres to United
Nations International Labor Organization
conventions including but not limited to:
2.1. Equal Employment Opportunity and NonDiscrimination

TechInsights strives to promote diversity. Employees will betreated equally in terms of establishing and terminating
employment and in terms of employment, promotion, andaccess to training to improve professional qualifications
regardless of sex, age, disability, race, religion, nationality,
political beliefs, trade union membership, ethnicity, religion,
sexual orientation and regardless of employment for a fixed
or indefinite period or full-time or part-time.

2.2. Employee Relations

TechInsights recognizes and respects the rights of
employees to freely associate, organize, and bargain
collectively in accordance with local laws. We believe inopen communication and direct engagement between
employees and management as a means by which tosupport positive employee relations. We also provide fair
and appropriate pay and benefits that match local living
wages. Lastly, TechInsights does not require employees towork more than the maximum hours of daily labor set byapplicable laws and we ensure that all overtime work is
voluntary, and employees are not required to exceed the
local legal limits for regular and overtime hours.

2.3. No Forced Labor/Child Labor

TechInsights has a zero-tolerance approach to modern
slavery, including child and forced labor, and we arecommitted to acting ethically and with integrity in all ourbusiness dealings and relationships and to implementing
and enforcing effective systems and controls to ensure
modern slavery is not taking place anywhere in our own
business or in any of our supply chains.

2.4. Anti-Harassment/Anti-Discrimination

TechInsights is dedicated to maintaining a creative,
culturally diverse, and supportive work environment, anddoes not tolerate discrimination or harassment of
employees or non-employees with whom we have abusiness, service, or professional relationship. This applies toall interactions where you represent TechInsights, includinginteractions with employees, customers, suppliers, andmembers of the public. TechInsights complies with allapplicable laws that prohibit discrimination andharassment. We will not tolerate any form of discrimination,or harassment of any kind, including sexual harassment,
bullying, acts of violence, or other behaviors that create ahostile work environment.

92. Fair Labor and
Employment
Practices

2.5. Substance Abuse

TechInsights recognizes a responsibility to help provide asafe and productive work environment for all employees.
We believe that working under the influence of alcohol ordrugs can affect an employee’s productivity and efficiency
and jeopardize the safety of the employee, coworkers, andthe public.
TechInsights will not tolerate, and absolutely prohibits, theuse, possession or being under the influence of a drug:(1) On Company property(2) When the employee is performing Company
business off premises, or(3) When activity away from Company premises orbusiness affects the employee’s suitability for continued
employment or may harm the reputation of theCompany or its employees.
No Exception for Legal Marijuana Use – All employees must
understand that marijuana is an impairing drug and thatusing it at work or coming to work high renders them unfit
for duty and in violation of this Code. This is true regardlessof whether their use of marijuana is legal under federal orstate drug laws.

2.6. Health and Safety

TechInsights is committed to providing a safe and healthy
workplace. The protection of employees from injury andoccupational hazards is a major continuing objective forour organization.
TechInsights will take measures to prevent incidents,
injuries and illnesses and will comply with the requirements
specified under the relevant laws and regulations.
Supervisors are accountable for the health and safety of
their employees. They are responsible for ensuring thatmachinery and equipment are safe and that theiremployees work in compliance with established work
practices and procedures. Where required, employees will
receive adequate training in their specific work tasks toprotect their health and safety.
Each employee must protect his or her own health andsafety by working in compliance with the law and with safe
work practices established by TechInsights. All employees
should consider health and safety in every activity andraise any concerns without fear of reprisal.

103. Ethical Personal
Conduct

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3. Ethical Personal
Conduct

3.1. Personal Conflicts of Interest

Employees have an obligation to conduct business in a waythat avoids any actual or potential conflicts of interest. An
actual or potential conflict of interest occurs when an
employee is in a position to influence a decision that may
result in a personal gain for that employee, or for a person
related to that employee, as a result of TechInsights’business dealings. An actual or potential conflict of interest
may also occur when an employee’s non-work activities
divert their attention from their job responsibilities. Even if
nothing wrong is intended, the appearance of a conflict
can cause stakeholders to doubt our fairness and have anegative effect on our business.
Each of us should refer to applicable conflict of interest
policies for guidance in the event of any situation thatmight be or might appear to be, a conflict with
TechInsights’ interests. If you are unsure about a potential
conflict, talk to your manager, the People Team or Legaland Compliance Team.

3.2. Insider Trading

TechInsights policy, and the law, strictly prohibit any
employee from trading securities, either personally or on
behalf of another, while in possession of material, nonpublic information. We (and the law) also strictly prohibit
employees from communicating material, non-public
information to others. This conduct is frequently referred toas “insider trading”.

If any officer, director, employee, freelancer, independent
contractor, or other agent of TechInsights has obtained,
during the course of his or her employment or relationshipwith us, any material, non-public information relating to
any other company, then neither that person, nor any
family members or others living in that person’s household,may buy or sell securities of such company or engage inany other action to take advantage of, or pass onto others,
that information. For definitions of ‘’material information’’and ‘’non-public information’’ see the Conflict-of-Interest
Policy (Individuals) available in the internal Policy Index.
The consequences of violating insider trading laws can be
extremely severe. Individuals who trade on inside
information (or tip information to others) may be subject
to termination of employment, criminal and civil penalties
including large fines and monetary damages, and lengthy
prison terms.
When in doubt about the appropriateness of entering asecurities transaction involving our customers, pleasecontact the CFO. Even the appearance of an impropertransaction must be avoided to preserve our reputation foradhering to the highest standards of conduct.

123. Ethical Personal
Conduct

3.3. Media Relations and Public Statements

It is our policy to limit the number of people in ourorganization who are authorized to talk to the press on
Company matters. If you receive any inquiries from thepress, or any third party, regarding the Company or its
clients, please refer them to our Corporate Development
Director. No one should at any time answer any press
inquiries, or discuss any work or Company matters withanyone from the media, without prior authorization.

3.5. Training

All employees are required to complete annual training
and certify their understanding of this Code. Mandatory
training covers the following topics: sanctions & export
controls, security awareness, workplace violence &harassment prevention, discrimination, bribery andcorruption, modern slavery, data privacy, ESG, andaccessibility in the workplace. Employees may be required
to participate in additional mandatory training on specifictopics as required by applicable law.

3.4. Corporate Assets

All employees are prohibited from misusing, personally or
through third parties, the company's assets. Our assets areto be used only for legitimate business purposes and only byauthorized employees or their designees. ‘’TechInsights’assets’’ cover both tangible and intangible assets including
brand, trademark, proprietary information, confidential
information, and information systems.
To the extent permitted under applicable laws and inaccordance with our Electronic Monitoring Policy,
TechInsights reserves the right to monitor and inspect how
its assets are used by TechInsights employees, including
inspection of all email, data, and files kept on personal
computers or other devices.

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4. Protection ofIntellectual Assets

144. Protection ofIntellectual Assets

4.1. Intellectual Property

Intellectual property is one of our most valuable assets
and it sets us apart from our competitors. All employees
must work together to protect TechInsights’ intellectual
property such as our patents, trademarks, trade secrets,business decisions, procedures, strategies, products,
software, inventions, discoveries, manufacturing
processes and methods, formulas, recipes, techniques,
processes, works of authorship, know-how, ideas, designs,
drawings, models, specifications, practices, flow charts,
data, software, plans, records, customer information,
prices, price lists, and financial information. This includes
all copyright, proprietary, and intellectual property rights
related to all the reports and other content we produce
and make available on our Platform.
Employees should not misuse the intellectual property ofothers or violate their intellectual property rights. To theextent permitted by and subject to applicable laws andregulations, all inventions and creations generated by
TechInsights employees belong to TechInsights.

4.2. Confidential or Proprietary Information

Information is an extremely valuable corporate asset.
All employees must safeguard TechInsights’
confidential or proprietary information as well as
information that our suppliers, business partners or
customers entrust to TechInsights. “Confidential
information” includes, without limitation, allinformation made available in tangible and intangible
form relating to and/or including business decisions,procedures, strategies, products, software, inventions,discoveries, manufacturing processes and methods,
formulas, recipes, techniques, processes, works ofauthorship, know-how, ideas, designs, drawings,
models, specifications, practices, flow charts, data,
software, plans, records, customer information, prices,
price lists, financial information, and other informationand intellectual property of TechInsights.
All of us must ensure we use such information only forthe purpose permitted by the Company in connection
with our duties at TechInsights.

15

4. Protection ofIntellectual Assets

4.3. Personal Information

Personal information shall not be obtained from third parties
without confirming with the TechInsights Privacy Office(privacy@techinsights.com). Examples of personal
information include but are not limited to; name, email
address, job title, company name, country/location, andtelephone number. TechInsights respects the privacy of
individuals, such as customers, employees of suppliers,
business partners, and our employees. We have developedand implemented policies and internal procedures
regarding personal information. TechInsights will observeand comply with all applicable privacy laws and regulations.

4.4.(a). Third Party Information

4.4.(b). Third Party Information

If you obtain confidential non-public information,
accidentally or provided by unknown sources, or in breachof a non-disclosure agreement immediately contact theLegal and Compliance Team.

4.5. Information Security

TechInsights has established rigorous information security
policies and procedures in accordance with the ISO
standards to help protect our information resources andsystems. All employees must help keep our information
resources and systems safe by following our information
security policies and procedures and complete thedesignated information security training.

Employees must ensure that any collection of information
about customers, competitors, and markets in which we
operate complies with TechInsights Privacy Policy(https://www.techinsights.com/privacy-policy).
It is never appropriate to engage in theft, espionage, or
breach of a non-disclosure agreement (NDA). Ensure that
NDAs are in place for all business transactions as specified
in our internal NDA Process Guidance. Moreover, whenengaging with and collecting information from third parties,
you must make sure that they are authorized to speak withyou. Make sure that you request confirmation that yoursources are not providing information to you in breach of
duty owed to their current or former employer.

16

5. Fair and EthicalBusiness Practices175. Fair and EthicalBusiness Practices

5.1. Environment

TechInsights is committed to operating in anenvironmentally responsible manner to reduce our impact
on climate change, conserve natural resources, and operate
in compliance with environmental regulations.
We encourage our employees to reduce their impact on theenvironment. We actively promote the approach of apaperless office environment.
We seek to comply with all local environmental legislation
and work to minimize the impact of our activities on theenvironment by:
Reducing waste going to a landfill by providing in-officerecycling facilities for office waste.
Using FSC-certified paper where possible.
Maintaining a flexible work policy which reduces
commuting related energy consumption.
Encouraging our employees to reduce energy
consumption within the office environment; andUsing energy efficient off-site servers where practicable..

5.2. Political and Charitable Donations

It is TechInsights’ policy not to make any political
donations. Employees may choose to make paymentsfrom their own money, but not with a view to influencea third party for the benefit of TechInsights, or in any
way that might give the impression that such influence
was intended.
We support contributing to the communities in which
we do business. Many fundraising and sponsorship
activities are undertaken at the divisional level. In
selecting charities to support, we must be able tosatisfy ourselves that there is no potential conflict ofinterest—an example of this might be where a person
who could influence the decision in awarding animportant contract has a connection to a charity towhich a donation is made.
Any charitable donations must be conducted inaccordance with our Charitable Donations Policy.

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5. Fair and EthicalBusiness Practices

5.3. Anti-Corruption

As part of our commitment to ethical business practices, wewill not tolerate acts of bribery or corruption in connection
with any of our business dealings, as per our Anti-Bribery
and Corruption Policy. TechInsights prohibits corrupt
practices in any form, including but not limited to bribery,
kickbacks, facilitation payments, in both the public(government) and the private (commercial) sectors.
You must not offer, pay, make, seek, or accept a personal
gift, payment or favor in return for favorable treatment or togain any business advantage. You must comply with theanti-bribery and corruption laws to which you and/or
TechInsights are subject. Involvement in bribery or
corruption could result in criminal penalties both for thecompany and the individual involved, including unlimited
fines and possible imprisonment.
The exchange or provision of gifts or hospitality in thenormal course of business can be an important element indeveloping and maintaining good business relationships.
However, it can sometimes be difficult to draw the line
between what is reasonable and what could be perceived
by others as aimed at obtaining a business advantage or
rewarding improper conduct.

When exchanging gifts and hospitality, including withgovernment officials, all employees must strictly follow
our Anti-Bribery and Corruption Policy and report all
gifts or hospitality to the Gift Register, as required by
the Policy.
You must also remember that this policy applies
across TechInsights in all territories in which we
operate. Local customs and practices are not valid
reasons to derogate from the principles set out in thisCode and the Anti-Bribery and Corruption Policy.

5.4.(a) Competition and Trade Practices

TechInsights is committed to complying withapplicable laws and regulations including antitrustand competition laws. TechInsights will never seek toeliminate or reduce competition through illegal
agreements with competitors. Agreements withcompetitors including Mergers and Acquisitions are
subject to rigorous scrutiny and due diligence in all
countries.
Antitrust and competition law is a complex area of law.
How to apply the law is not always clear. When in
doubt, you should always seek advice from the Legaland Compliance Team.

19

5. Fair and EthicalBusiness Practices

5.4.(b) Competition and Trade Practices

You should not:Agree with competitors to divide or assign sales
territories, products, or dedicate customers.
Violate fair bidding practices, including bidding quiet
periods, or provide information to benefit one supplierover another supplier.
Agree with or exchange information with competitors
regarding price, policies, contract terms, costs,
inventories, marketing plans, capacity plans, or othercompetitively significant data.

5.5. Fair Procurement and Due Diligence

TechInsights selects its suppliers on the basis ofcompetitive price, quality, delivery and other objective
standards. Moreover, all supplies undergo a rigorous due
diligence process, and we expect our suppliers to adhere to
our Supplier Code of Conduct and complete a Supplier Risk
Questionnaire. Our supplier due diligence and risk
assessment process ensures that suppliers comply with
relevant laws, respect human rights, fair labor andemployment practices, environment conservation andtrade controls.

5.6. Regulatory Sanctions and Trade Restrictions

As a global company TechInsights complies with allapplicable regulatory sanctions and trade restrictions in all
countries in which we operate. Many countries periodically
impose restrictions on imports, exports, and other dealings
with certain countries, persons, or groups.

Export control laws may place limits on which content
TechInsights can allow certain customers to access.
Moreover, sanctions laws apply to all our products andservices and may completely prohibit businessengagements with customers that are located,
operating, resident, or organized in various sanctioned
jurisdictions and/or are identified on any list of restricted
parties.
Certain laws also prohibit participation in foreign (nonUS) boycotts and limit disclosure of information aboutbusiness activities and personnel, and may require thereporting of certain types of requests for information or
participation in boycotts.
As such we have developed a comprehensive Export
Control and Sanctions Compliance Program consistingof policies, procedures, processes, and training to ensure
all our business operations are compliant with theapplicable laws and regulations. All our employees are
required to always consult the Export Control and
Sanctions Compliance Policy before engaging in abusiness dealing with suppliers, customers, contractors,
or similar relationships.
Moreover, employees must consult the internal
compliance SharePoint and Viva Engage pages on aregular basis to ensure they stay up to date regarding
this topic.
For questions regarding sanctions and trade controls
please contact: compliance@techinsights.com
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5. Fair and EthicalBusiness Practices

5.7. Transactional Red Flags

Before engaging in a business transaction with customers,
suppliers, contractors, or similar relationships employees
must review the details of proposed transactions for any“Red Flags,” e.g., unusual arrangements, payment terms, or
customer addresses, that could increase the likelihood thatthe shipment/customer engagement could constitute orlead to a breach of applicable laws and regulations.
Common red flags include:
The customer or its address is similar to one of theparties found on the Commerce Department’s list ofdenied persons or other international sanctions lists;
The customer is small and little known (i.e., financial
information is unavailable from normal commercial
sources and the corporate principals are unknown bytrade sources);
The customer is reluctant to provide end-use/end-user
information;
The customer is reluctant to submit additional
documentation such as Certificate of Incorporation andOwnership Structure;
The customer requests unusual payment terms orcurrencies;
Order amounts, packaging, or delivery routing do notcorrespond with normal industry practice;
Performance/design characteristics of the item ordered
are incompatible with the customer’s line of business orstated end-use;

The customer uses only a “P.O. Box” address or has
facilities that appear inappropriate for thecommodity(ies) ordered;
The customer’s order is for parts known to beinappropriate, or for which the customer appears tohave no legitimate need;
The customer has little or no business background;
The customer is known to have, or is suspected ofhaving, unauthorized dealings with parties and/or
destinations on the Proscribed/Embargoedcountries list;
The customer submits instructions to make direct
shipments to trading companies, freight
forwarders, export companies or other companies
with no apparent connection to the customer;
Packing requirements are inconsistent with theshipping mode and/or destination;
Circuitous or economically illogical routing; orThe customer appears unfamiliar with the productor application.

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