Page 1 of 6

Policy Title: Anti-Bribery and Anti-Corruption Policy
Policy Number: CP500.05

Version Number: 05

Functional Area: Legal

Effective Date: April 21, 2023

Policy Owner: Gwen Chapman

Policy Interpreter(s):Lesa Hutnak (Global)
Jared Bevills (AMR)
Robert Whyte (Europe)
Angela Zhu (AMEA/Greater China)

PurposeThe purpose of this Policy is to advise Illumina personnel of their anti-bribery and anti-corruption
obligations and to ensure compliance by Illumina personnel with anti-bribery and anti-corruption
laws, including but not limited to the U.S. Foreign Corrupt Practices Act, the UK Bribery Act andother local anti-bribery and anti-corruption laws.

Scope
This policy applies to Illumina, Inc. and its subsidiaries and affiliates globally (collectively referred
to as “Illumina”). All Illumina personnel, including employees as well as all third parties working on
behalf of Illumina, must comply with this Policy.

Definitions
TermDefinition

Bribe

A bribe is “anything of value given in an attempt to influence aperson’s actions or decisions in order to gain or retain business oran improper advantage.”
Kickbacks are considered bribes.

Business Courtesy

A business courtesy is “anything of value provided in furtheranceof legitimate business for which fair market value is not paid by
the recipient.”
Business courtesies can include, but are not limited to, travel,
hotel accommodations, meals, hospitality, entertainment(including tickets or passes to entertainment or sporting events),
recreation (e.g., golf or sailing), gifts, and prizes.

Corruption

Corruption is “the misuse of public office or power for private gainor the misuse of private power in relation to business.”

1Page 2 of 6

TermDefinition

Facilitation Payment

A facilitation payment is “a small sum paid to a government
official/employee to facilitate or expedite a routine, nondiscretionary action of the government official/employee.”
Examples include a small sum paid to expedite customs clearance,schedule a government inspection, or issue a work visa.

Government Official

A Government Official is “any officer or employee of a foreign
government or any department, agency, or instrumentality thereof,
or of a public international organization, or any person acting in an
official capacity for or on behalf of any such government ordepartment, agency, or instrumentality, or for or on behalf of any
such public international organization.”
Examples of Government Officials include, but are not limited to:

Healthcare Professional

Improper Advantage•HCPs and non-HCPs employed by a hospital, clinic, university,
research center, or other entity or institution that is fully or
partially owned or funded by a government,•Elected or appointed government legislators and members ofa government ministry,•

Political party officers and candidates for public office,•Employees or individuals acting on behalf of a public
international organization (e.g., IOC, World HealthOrganization, United Nations),•

Member of the military, and•Members of a royal family.

Healthcare Professional means “anyone that is:• Authorized or licensed to provide healthcare services topatients (e.g., physicians, nurses, pharmacists, etc.),•

Involved in providing healthcare services to patients (e.g.,laboratory personnel, allied health professionals such asgenetic counselors, etc.),•Involved in using a medical device for human use, or•Involved in the decision to purchase, prescribe, order, use orrecommend medical devices, technologies, or relatedservices.”

An improper advantage is “an advantage that is illegal or to which
a company is not clearly entitled.”
For example, a company would obtain an improper advantage if aperson with decision-making authority were to misuse theirauthority by doing any of the following because they had beenoffered or received a bribe from the company: authorize thepurchase of products, award a contract, issue an operating permit,or provide a product registration approval.
2Page 3 of 6

TermDefinition

Kickback

A kickback is “an illegal payment intended as compensation for
preferential treatment or any other type of improper advantage
received.”

Money Laundering

Money laundering is “any act or attempted act to conceal or
disguise the true origin and ownership of illegally obtained
proceeds so that they appear to have originated from legitimate
sources thereby avoiding prosecution, conviction and confiscationof the illegal proceeds.”

Related Policies
Policy or Document Title

Policy or Document Number

Providing and Receiving Business Courtesies, Gifts, andHonoraria Policy

CP 500.13

Integrity CodeCP 500.16

Policy1. Bribery and Corruption are Prohibited
Illumina does not engage in Bribery or Corruption in the course of its business. Illumina
employees and all third parties acting on Illumina’s behalf, including but not limited toconsultants, contractors, distributors, sales agents and other channel partners, marketing
agencies, meeting/event planners, and import/export companies, are prohibited from:•offering, promising, authorizing, or providing anything of value to any customer,business partner, vendor or other third party that is intended to be, or that could
reasonably be interpreted as, a reward for business or an attempt to gain preferential
treatment or an Improper Advantage, or•

providing anything of value to anyone in order to induce to them to use, purchase,prescribe, or recommend the use, purchase, or prescription of Illumina’ products orservices.

Bribery is prohibited when dealing with any third party whether they are in the public or private
sector and regardless of where they are located in the world. Illumina shall not use any thirdparty to make or receive a Bribe, directly or indirectly.
All requests or demands for Bribes must be reported to the Corporate Compliance Department
as soon as possible.
2. Facilitation Payments are Prohibited
Facilitation Payments are illegal in most countries and Illumina employees and all third parties
acting on Illumina’s behalf, including but not limited to consultants, contractors, distributors,
sales agents and other channel partners, marketing agencies, meeting/event planners, and3

Page 4 of 6

import/export companies, are prohibited from making facilitation payments. Report all
requests or demands for Facilitation Payments to the Corporate Compliance Department assoon as possible.
If you are ever required to make a payment as a result of an imminent threat to your health,safety or welfare, the demanded payment may be made. However, you must immediately
report the payment, including the amount and the circumstances under which it was made, tothe Corporate Compliance Department. Illumina will ensure such payments are accurately
recorded in Illumina’s books and records.
3. Providing Business Courtesies to Third PartiesAll Business Courtesies provided to third parties must be comply with Illumina’s Providing andReceiving Business Courtesies, Gifts, and Honoraria Policy (CP 500.13). The totality ofcircumstances must be considered to avoid even the appearance that a Business Courtesy
might be considered a Bribe.
4. Interactions with Government Officials and Healthcare Professionals
All interactions with Government Officials and Healthcare Professionals, including but notlimited to payments for services and other transfers of value, must comply with Illumina’sIntegrity Code (CP 500.16). The Integrity Code establishes specific rules and standards on how
we at Illumina must conduct business with Government Officials and Healthcare Professionals
around the globe in support of our business objectives while simultaneously ensuring ourcompliance with applicable anti-bribery and anti-corruption laws, regulations, and standardsof conduct.
5. Political Contributions
No Illumina funds, products, or services of any kind may be given to any candidate orprospective candidate for public office, to any political party, or to any other political initiative
or campaign without the prior approval of the Government Affairs department.
6. Employment and Internships
Illumina may not provide a job or internship to a Government Official, or a member of theirfamily, in order to gain influence or curry favor with the Government Official. If a Government
Official offers to give a benefit to Illumina or threatens to take adverse action in connection
with a hiring decision, the suggested candidate cannot be hired.
7. Anti-Money Laundering
Illumina is committed to complying fully with all applicable Anti-Money Laundering Laws,
which prohibit market manipulation, trade of illegal goods, corruption of public funds, fundingof terrorist organizations, and tax evasion, as well as any actions that aim to conceal theseactivities.
8. Accurate Books and Records and Internal Controls
It is Illumina’s policy to keep books and records that accurately and fairly reflect Illumina’stransactions in reasonable detail and to maintain internal controls to prevent and detect
potential violations of Illumina policies or of applicable law. No false, artificial, or misleading
4

Page 5 of 6

entries may be made in the books and records for any reason, and all payments andtransactions, regardless of value, must be recorded accurately.
9. Compliance with this Policy
Failure to follow this Policy may result in disciplinary action, up to and including termination ofemployment in accordance with Illumina’s Disciplinary Guidelines. 1 Any Illumina
representative or agent who violates this Policy or who misleads investigators making inquiries
into potential violations of this Policy, may have their contracts re-evaluated or terminated.
10. Reporting Potential Violations or Concerns
Everyone has an obligation to promptly report violations of this Code. Not reporting a violationthat you are aware of may result in discipline up to and including termination of employment.
You have several options to report potential violations:•Speak with your manager or the Human Resources department. Managers and Human
Resources department personnel that become aware of conduct that may violate thisCode are responsible for conveying the compliance concern to the Chief Compliance
Officer or other senior member of the Corporate Compliance Department within fortyeight (48) hours.

•You may submit concerns to the Corporate Compliance Department via email atcompliance@illumina.com.

•You may submit concerns directly to the Chief Compliance Officer or other senior
member of the Corporate Compliance Department.

•You may also submit a concern via the third-party managed Compliance and Fraud
Prevention Hotline via the Internet through the anonymous hotline link found on theCorporate Compliance Insider Page or by calling one of the global toll-free phone
numbers available on the Hotline website. Reports made through the Compliance andFraud Prevention Hotline may be made anonymously unless prohibited by local law.

Generally speaking, every effort will be made to maintain the confidentiality of reports about
potential violations; however, depending on the circumstances, it may not be possible in allcases to protect the identity of the person making the report.
11. Additional Resources
Send questions to: compliance@illumina.com or visit the Corporate Compliance Department
Insider page.

Illumina will not directly or indirectly pay any fine imposed on an Illumina employee as a resultof a breach of this Policy or a violation of any anti-bribery laws.
15

Page 6 of 6

Release History
Version00

Version Date1009872

Policy Owner
John ChristianDescription of Change
Initial Release in SAP

01

John Christian02

September 4,2018
July 17, 201903

October 13, 2020

Lesa Hutnak

04

April 6, 2022

Lesa Hutnak

05

April 21, 2023

Gwen Chapman

Updates to add clarification around pre-review by the legal
department; adding China and Korea specific information
Initial Release into new Corporate Policy Website. No
content change.
Administrative change to correct the link to the Compliance& Fraud Prevention Hotline tool and correct the phone
number.
Added Jared Bevills, Mahrukh Bashir, and Angela Zhu asinterpreters. Removed Lesa Hutnak as interpreter and left
her as Owner.
Update to align with Illumina’s current Anti-Bribery
Compliance Program policies and procedures and applicablelaw.

Lesa Hutnak

6