Compliance Program Framework

Illumina, Inc.

The Compliance Committee (“Committee”) has adopted this Compliance Program Framework,
which is based upon the seven fundamental elements of an effective compliance program
established by the Office of Inspector General (“OIG”) in various industry guidance documents1
and the United State Sentencing Guidelines2. Those seven fundamental elements are:
1.
2.
3.
4.
5.
6.
7.

Designating of compliance officer and compliance committee
Establish written policies and standards of conduct
Provide training and education to employees
Provide effective lines of communication between employees and management
Conduct internal monitoring and auditing to ensure compliance
Enforce policies and standards of conduct through disciplinary guidelines
Respond to detected offenses and take corrective action

I. COMMITTEE AND LEADERSHIP STRUCTURE

Illumina’s General Counsel has been designated as its Chief Compliance Officer. As a member ofthe Committee, he has overall responsibility for oversight of the Company’s complianceprograms. Along with the Committee, he is responsible to guide and manage the development
and operation of the programs, including developing and implementing policies, procedures, andpractices designed to ensure Illumina’s compliance with applicable federal and state laws,regulations and with Illumina policy.
The Committee will meet quarterly or more frequently if needed to oversee the implementationand maintenance of robust compliance programs in all areas subject to such legal, regulatory andpolicy compliance.
A. Appropriate Executive Owners – The Committee will identify and designate appropriate

executive owners to address identified areas of compliance oversight. These executive
owners will function as the contact point for employees in their area of compliance toreport actual or suspected compliance issues. The executive owners are responsible toreport to the Committee all compliance matters brought to his or her attention.

B. Illumina Employees – Illumina employees, at all levels of the organization, areresponsible for conducting themselves in an honest and ethical manner consistent withapplicable laws and Illumina policy.

1OIG Compliance Program Guidance for Pharmaceutical Manufacturers (Federal Register 68, May 5, 2003);
Publication of OIG Compliance Program Guidance for Clinical Laboratories (Federal Register 63, August 24, 1998)
2United States Federal Sentencing Guidelines, 2018 Guidelines Manual

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Illumina, Inc.

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Compliance Program Framework

Illumina, Inc.
II. WRITTEN POLICIES AND PROCEDURES FOR COMPLIANCE

At the core of our compliance program are ethical standards and compliance principles that guideour daily conduct as stated in our Code of Ethics. The Code of Ethics and other policy and guidance
documents at Illumina set forth Illumina’s expectation and requirement that all employees andagents of the Company act in accordance with all laws, regulations and applicable Companypolicies and otherwise uphold Illumina’s high standards of business ethics.
III. EFFECTIVE TRAINING AND EDUCATION OF ILLUMINA’S EMPLOYEES

Education and training is critical to the success of the compliance programs. Illumina iscommitted to implementing programs to effectively and timely communicate to affected
personnel. Code of Conduct Training is currently required of all employees and will be enhanced
and updated on an as-needed basis. Additional risk-specific compliance training is assigned toemployees with job roles and responsibilities that encounter these risks and such training will bereviewed and updated on an ongoing basis.
IV. EFFECTIVE LINES OF COMMUNICATION

Illumina is committed to fostering a culture of compliance. Critical to its efforts is open
communication. Illumina is “open, physically and philosophically” and the Committee encourages
employees to discuss all issues, concerns, problems and suggestions with their immediate
supervisor or other managers without fear of retaliation and with the assurance that the matter
will be kept as confidential as possible. If an employee prefers, where lawful, such issues,concerns, problems or suggestions, including those from outside the Company, may be made on
an anonymous basis, 24 hours a day, 7 days a week, via the Compliance and Fraud Prevention
Hotline by calling 800-461-9330, or it can be made electronically on this website, which is alsoavailable via a link on the corporate intranet site.
The Company will not permit acts of retaliation or retribution against an employee who in goodfaith reports a potential, suspected, planned or actual violation. Such acts will be dealt withappropriately.
V. INTERNAL AUDITING AND MONITORING

Illumina’s compliance programs will continue and expand the Company’s practice of internallymonitoring, auditing, and evaluating compliance issues. These activities will be expanded under
the direction of the Committee to address new identified areas of compliance. These monitoring
activities are intended to identify potential or existing problem areas and to take corrective
measures in an effort to prevent the recurrence of non-compliance.

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Illumina, Inc.

VI. RESPONDING TO POTENTIAL VIOLATIONS

An additional role of the Chief Compliance Officer, or his designee, is to oversee the review of
non-compliance reports and determine whether further investigation is necessary. Whendeemed necessary, the Chief Compliance Officer, or his designee, will conduct an investigation
into potentially non-compliant activity to determine whether a violation has occurred.
VII. CORRECTIVE ACTIONS

It is expected that the compliance programs will increase the likelihood of preventing, or at least
identifying unlawful and unethical behavior. However, even an effective compliance program
may not prevent all violations. In order to address such violations, the Committee will take action
as necessary to respond promptly to potential violations of law or company policy, takeappropriate disciplinary action, assess the root cause of the violation, and take appropriate
corrective measures. Corrective measures take into account the findings of reviews of noncompliance, and may include appropriate and consistent disciplinary action regardless of theindividual's position within the organization (up to and including termination), assessing whether
enhancements should be made to our policies, practices, training, or internal controls, and taking
action to prevent future non-compliance.

Last Updated March 16, 2021

Illumina, Inc.

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