Code of Business

Conduct and Ethics

July 2009
Contents 3 From Flextronics’s CEO
4 Flextronics’s Culture
5 Introduction
5 Approvals, Amendments and Waivers
6 Prompt Reporting and Non-Retaliation
7 Conflicts of Interest
7 Service on Outside Boards
7 Outside Employment or Consulting
7 Outside Commercial Interests 18 Flextronics Funds
and Investments
7 Corporate Opportunities
8 Gifts, Entertainment and Kickbacks
9 Family and Close Personal Relationships
10 Compliance with Laws
10 Antitrust and Competition Laws
10 Advertising
10 Employment and Labor Laws
11 Data Privacy
11 Environmental Laws
12 Intellectual Property Rights
13 Software
13 Confidential Information
16 Anticorruption Laws
16 Government Officials
16 Political Contributions
17 Importing, Exporting and
Supply Chain Security
18 Accurate Books and Records
18 Use and Protection of
Flextronics’s Assets
18 No Expectation of Privacy
18 Facility Security
18 Prohibition against Use of
Flextronics Assets to Aid Terrorists
19 Additional Standards
19 Selecting Suppliers
19 Government Contracts
19 Enterprise Record Retention Policy
19 Corrective Actions
20 Flextronics Ethics Hotline
Toll-Free Numbers

14 Obligations under Securities Laws

14 External Communications and
Company Spokespeople
14 Compliance with Regulation FD
15 Prohibition against “Insider” Trading
From Flextronics’s CEO Although Flextronics is a large and complex company operating in many different countries
and cultures, the people of Flextronics share fundamental values around business conduct and
ethics. The Code of Conduct is important to our business because it reflects our values and
embodies our commitment to high ethical standards. The Code of Conduct provides direction
as we navigate challenges in our work. It also helps us make the best decisions when clear and
easy answers may not be readily available. In other words, the Code of Conduct enables us to
uphold the highest ethical standards in all situations, and across all Flextronics locations.

For me, the easiest way to think about the meaning of ‘ethical standards’ is to view them
simply as a commitment to make decisions that are in the best interest of our stakeholders.
Through this commitment to working hard and doing right, we will continue to satisfy
our customers, win new business, and grow as a sustainable, profitable company.

The Code of Conduct contains general principles and rules that we need to follow to guide
our behavior every day. The instructions and explanations for how to comply with the Code
of Conduct requirements are described in our company-wide directives, policies, and
procedures. The Code of Conduct provides guidance on how you can locate the specific
directives that relate to your job and how to find resources for additional information.

Our commitment to act with uncompromising ethics and integrity at all times, in all
situations, has been critical to the success of our business. It has helped us to earn
and keep the trust and confidence of all of our stakeholders, including our employees,
customers, suppliers, investors and the communities in which we all live and work.

Thank you for your commitment to understanding this Code of Conduct and integrating
its principles into your work for Flextronics.

Mike McNamara
Chief Executive Officer
Flextronics’s Culture

In today’s constantly changing

business environment, Flextronics’s
culture is our greatest sustainable
competitive advantage. It is the
heart of who we are as a company.
Our culture provides the foundation
for how we act and operate on a
daily basis, both internally and
externally. And it is the framework
that enables us to create value
that increases customer
competitiveness and
win more market share.
Introduction
We established this Code to educate all of our employees, officers and Board
members about our standards for business conduct, and to assist you in
resolving ethical questions that may arise in your work.
This Code does not and cannot cover every ethical situation
or issue you may face in your work. We encourage you to
seek guidance on any ethical or legal question. If you have
any doubt about the best course of action or response to a
situation, you can discuss the situation with your immediate
manager. If you are not comfortable raising the matter with
your manager, we have other channels that you can use to
express your concerns that we discuss later in this Code.
This Code is implemented in accordance with the laws
of the countries in which we operate. Operating units or
subsidiaries may adopt specific “Local Rules,” such as local
policies, procedures, employee handbooks, guidelines or
memoranda that satisfy the needs of a particular function
or location. This Code is not intended to supersede more
restrictive terms of any Local Rules, or any additional topics
that are covered in the Local Rules but which are not covered
by this Code. If this Code conflicts with any Local Rules or
any other policies or guidelines, this Code governs. Nothing
in this Code, in any Local Rules, any company policies and
procedures, or in other related communications creates
or implies any rights related to employment or any contract with any third party.
Approvals, Amendments and Waivers
For the areas of the Code that require you to obtain written approval prior to taking
action, you should first seek the approval of your direct manager. Your manager will
help determine what further approvals are needed, consistent
with this Code and company policies and procedures.
QUESTION: My site has a policy with
Flextronics may determine that it is appropriate to amend
detailed requirements for disposing of
or waive the application of any provision of the Code. Any
scrap material that contains lead. The
amendment of this Code or any waiver of the application
Code does not cover specific procedures
of any provision of this Code for the benefit of a member
for scrapping materials that contain lead.
of Flextronics’s Board of Directors or the Chief Executive
What should I do?
Officer, Chief Financial Officer, Principal Accounting
Officer, General Counsel, Chief Compliance Officer or
any other executive officer requires the prior and express
ANSWER: Comply with your site’s policy
written approval of Flextronics’s Board of Directors. We
and follow its stated procedures for
will disclose any waivers approved for the directors and
disposal of materials that contain lead. If
executive officers to the extent and in the manner required
your site has a policy or guideline that is
by law, regulation or stock exchange listing standards.
not covered by the Code, then follow the
site policy or guideline. Interpreting this Any waiver of any provision of this Code with respect to any
Code and local policies can be confusing; other employee must be approved in advance and in writing
do not hesitate to ask your manager or by the employee’s manager and the Chief Compliance Officer,
any compliance officer for help in who will consider the request in consultation with others,
understanding the rules. such as executive management and the Legal Department.
T h e C ode O f B usiness C onduct A nd E t h ics
Prompt Reporting and Non-Retaliation
Your commitment to compliance makes all the difference. We want to enable you to We will handle discretely all reports of
report suspected violations quickly, easily and confidently. If you are aware of any suspected violations of the law, this
conduct that you believe is a violation of this Code, any company policy or any law, it is Code or any other Flextronics policy or
your responsibility to report it promptly. Do not knowingly make a false report of a other company guidelines no matter
violation for any reason. how you report your concern. Every
effort will be made to maintain, within the
There are also specialized resources for handling legal and ethical limits allowed by the law, the anonymity of
questions at Flextronics, including the Internal Audit Department, anyone requesting guidance or reporting a
the Legal Department, the Human Resources Department and the possible violation. Flextronics strictly
Compliance Directors who are subject matter experts on the regula- prohibits retaliation against any employee,
tory and legal areas that are covered by this Code. officer or Board member who reports any
suspected violation of the law, this Code, or any
other Flextronics policy or other company
There are several ways you can communicate any concerns you may have. You can
guidelines. If you believe that you have experienced
discuss the situation with your manager. If you are not comfortable raising the matter
retaliation for reporting possible violations, you
with your manager (or your manager may be involved in a violation), you may report
should contact your local Human
it to any other person in the management chain, including any Flextronics officer.
Resources Department
Finally, you may report suspected violations anonymously, either by telephone or representative or the Legal
over the Internet, using the Flextronics Ethics Hotline. If you have access to the Department.
Internet, you can file a report on http://www.flexethicshotline.com. You can also
access our anonymous reporting tool on http://www.ethicspoint.com — click on
“File a new report” and type in “Flextronics.” If you prefer to communicate by
telephone, dial the Flextronics Ethics Hotline toll-free number for your country.
You can find the toll-free number for your country at the end of the Code or
http://www.flexethicshotline.com. Information about reports made to the Flextronics
Ethics Hotline is monitored and brought to the attention of Flextronics’s Board of
Directors regularly.

T h e C ode O f B usiness C onduct A nd E t h ics

Conflicts of Interest Outside Commercial Interests and Investments

In order to assist you in upholding our ethical standards, our policy requires that you
avoid situations where you have a conflict of interest or where it appears that you may
have a conflict of interest. While it is not possible to list all situations where a conflict of
interest may arise, this Code provides guidance on avoiding actual or potential conflicts
of interest in certain situations. If a situation raises any questions or doubts in your
mind, consult your manager.
Examples of potentially inappropriate financial interests include material stock holdings
or other investments in a competitor, supplier or customer of Flextronics; and any
material interest in property or assets which are sold or leased to Flextronics.
Ownership of less than 1% of the stock of a public corporation, or 5%
of the stock of a private corporation, rarely poses a conflict of interest.

If you need a waiver in connection with a potential conflict of interest,

You may borrow from a financial institution that does business with Flextronics so
please review the Conflict of Interest Screening Process available on
long as the financial institution applies its standard underwriting standards and the
our Intranet. The process includes instructions and a checklist for
terms of the loans are substantially similar to the terms offered by the financial
seeking approval relating to a potential conflict of interest.
institutions to other third parties.

Service on Outside Boards
Serving on the board of directors of a company creates a fiduciary duty to that
company that may require you to put that company’s interests ahead of the interests of
Flextronics. To help you avoid business relationships that can create conflicts of
interest, you are required to get prior written approval to serve on the board of a current
or potential supplier, customer or competitor of Flextronics.
Outside Employment or Consulting
Simultaneous employment with, or consulting for, a supplier, customer or competitor of
Flextronics creates a conflict of interest. You must obtain written approval prior to
beginning employment or consulting that may lead to a conflict of interest.
You may not hold a financial interest or make an investment in an outside concern that
creates a conflict of interest with your responsibilities to Flextronics unless you obtain
prior written approval.
Corporate Opportunities
On occasion, through your position with Flextronics, you may become aware of a
business opportunity. You must not take personal advantage of such an opportunity
unless you have offered it to Flextronics first. You must offer it to Flextronics by
notifying your manager and by contacting the Chief Compliance Officer. If Flextronics
declines in writing to pursue the opportunity, then you may pursue it.

T h e C ode O f B usiness C onduct A nd E t h ics

Gifts, Entertainment and Kickbacks

You must not give or receive kickbacks in any form under any good taste and they do not create any kind of obligation, influence a
circumstances. Kickbacks are gifts, entertainment or other payments that business decision, or create an appearance of bias. Appropriate items
are intended to influence the recipient to make a favorable business include modest meals, reasonable entertainment, and gifts of a
decision. Kickbacks damage our reputation for acting with integrity and nominal value. However, a gift of cash or its equivalent is always
ethics and may violate laws, regulations and our policies and guidelines. prohibited, regardless of the value.
Kickbacks may also create a conflict of interest for you.
QUESTION: One of our suppliers wants to take me to
lunch. He also said he’s sending out cash gift cards to all
Kickbacks aren’t just cash. Payments of cash are always prohibited,
his clients as a token of appreciation. Can I accept?
but other gifts or offers also can be considered kickbacks. A
kickback can be any offer, promise of, or payment of anything of
ANSWER: You cannot accept the cash gift card. A gift of
value. For example, you can accept a special discount on
cash or its equivalent is always prohibited. You may accept
an appliance (such as a washer or dryer) offered by
lunch, as long as it does not influence a business decision
a customer only if that discount is available to
or create an appearance of bias. If you are involved in
all Flextronics employees in your region.
procurement activities, you also have to follow the
Procurement Practices Guidebook.
This policy does not apply to your gift or receipt of
customary business amenities, provided that the Before offering or giving a gift, you must be sure that it
amenity does not exceed our guidelines or any does not violate any policies of the recipient’s company
Local Rules, is not prohibited by law and does not or applicable law. If you receive a gift that seems
create a perception of a conflict of interest. excessive or creates a sense of obligation, please
consult with your manager or the Chief Compliance
Gifts and entertainment are often expressions of
Officer. If you are involved in procurement activities, you
cordial business relationships, but they can
are also obligated to understand and follow the
interfere with a person’s independent business
Flextronics Procurement Practices Guidebook, which
judgment and should be approached with
you can locate on the Compliance portal on our
caution. You may give or receive meals,
Intranet.
entertainment, and gifts as long as they are in

T h e C ode O f B usiness C onduct A nd E t h ics

Family and Close Personal Relationships

If you have a relative or friend who holds a senior management position with, or has to your manager, who will then decide how to proceed. Even if you are not a decision
a financial interest in, a company wanting to do business with Flextronics, you have maker, you must not influence or even appear to have influence over the situation.
a potential conflict of interest. You probably would find it difficult to remain objective The important thing is that the
and unbiased if you were involved in facilitating business transaction is conducted in a
with Flextronics for your relative or friend. Even manner that does not provide QUESTION: My department is looking for
if you were careful to remain objective, still it the friend or family member with a new manager. The woman I am dating
would appear to others that you were biased. any preferential treatment. If the just graduated with an MBA, and I thought
situation involves a significant of her right away. She would be perfect for
If doing business with a relative or friend is
transaction that is material to the position. Can my department hire her?
unavoidable, you must
Flextronics, then Flextronics’s
remove yourself from
Audit Committee may need to
any decision-
give prior written approval.
making role ANSWER: Hiring someone you are

related to the Personnel decisions can dating would most likely create a conflict

transaction and become complex where an of interest. You would need approval

fully disclose employee and manager are from the Human Resources Department

the nature of related or otherwise have a before considering the woman you are

the relationship close personal relationship dating for employment. It is unlikely that

outside of the office. A conflict the Human Resources Department

of interest may arise when would permit a manager to supervise

you and your relative or a someone he is dating.

person with whom you have

a close personal relationship
share a direct or indirect supervisory relationship within Flextronics. You must
avoid any such vertical reporting relationship with anyone with whom you
are related or have a significant personal relationship. You should disclose
any such supervisory relationship to your Human Resources manager.

T h e C ode O f B usiness C onduct A nd E t h ics

Compliance with Laws
We are required to comply with the laws of the countries where we work and conduct
business and we are each expected to have a basic working knowledge of the laws
that apply to us. Due to the nature and scope of our business, it would be impractical
to cover all of the requirements that may apply to each of our respective functions or
locations. Some of these legal requirements are outlined in this Code and others are
described in the Local Rules, which are available from your local Human Resources
contact. In addition, you are expected to participate in training when we offer it on
subjects that apply to you. Our policy is to review applicable laws and regulations
regularly to adapt our business to changes in legal requirements.
Antitrust and Competition Laws
Most countries have antitrust or competition laws that are designed to enhance and
protect free and fair competition. We are required to comply with those laws.
Antitrust and competition laws generally address a wide
range of practices, including:
• communications or arrangements between competitors,
particularly relating to pricing or terms of sale;
• participating in a trade association or in a standards-creation body;
• mergers and acquisitions, as well as joint ventures
or other collaborations;
• boycotts and allocations of customers, products or territories;
• exclusive dealing arrangements;
• certain restrictions on, or tying arrangements with,
suppliers or customers; and
• many other practices.
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T h e C ode O f B usiness C onduct A nd E t h ics
In addition, certain activities are prohibited by Flextronics, whether or not local
competition laws prohibit them. Please see the Antitrust and Competition Policy
available on our Intranet for more information about our antitrust and competition
compliance policies and procedures. If you have any questions regarding our policy,
please consult with the Legal Department.
Advertising
We developed our reputation for integrity in part through our commitment to always be
truthful in our promotional efforts for our business. In that regard, we must refrain from
misrepresenting Flextronics in our advertisements or promotions of Flextronics or our
products or services.
Employment and Labor Laws
We are committed to providing a safe and quality work environment for our employees.
It is our policy to act in accordance with all applicable employment and labor laws and
regulations, including:
• compliance with all non-discrimination requirements;
• maintaining an environment where individuals are free from any physical, sexual,
psychological, verbal or visual harassment or abuse;
• observing all applicable restrictions on the maximum hours employees are legally
permitted to work;
• paying employees at least the minimum wage required by local law and providing all
legally mandated benefits;
• ensuring that no forced labor, indentured labor, or bonded labor is used;
• requiring a minimum age requirement for employment consistent with local law; and
• offering a safety and health program that conforms to the best practices of
organizations of our type, to reduce the number of occupational injuries and
illnesses to a minimum.
Data Privacy

We respect the privacy rights and

interests of all of our employees and QUESTION: I am an administrative
individual stakeholders in their personal assistant. I received a call from an
information. We are committed to outside lawyer who asked for informa-
taking appropriate measures to protect tion on one of the employees in our
your personal information against department. How should I respond?
unauthorized access and to use it for
legitimate business purposes. When
ANSWER: You should never give
we collect, use and process personal
employee data to anyone without
information, our policy is to handle
checking whether disclosure is
that information responsibly and in
allowed under data privacy laws.
accordance with applicable laws. We
You should ask your manager or the
expect all employees to comply with
Human Resources Department.
our Global Employee Privacy Policy,
which is available on our Intranet.

Environmental Laws

Flextronics is committed to complying with all applicable environmental laws and

regulations. We seek to provide a safe and healthy workplace, protect the environment,
conserve energy and natural resources, and prevent pollution by applying appropriate
management practices and technology.

Our operations are subject to a number of regulatory requirements relating to the

use, storage, discharge, and disposal of hazardous chemicals used during our
manufacturing processes. We are also required to comply with certain hazardous
substance content regulations. We monitor our compliance with these laws to maintain
our status as a responsible corporate citizen in all locations in which we operate.
In addition, we review our practices and procedures regularly to address changing
circumstances, and to continually improve our performance. For more information,
please consult the environmental policies and procedures available on our Intranet.

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T h e C ode O f B usiness C onduct A nd E t h ics

Intellectual Property Rights

Intellectual property includes patents, trademarks, copyrights, trade QUESTION: I have just been hired from
secrets and any other intangible personal property that is created another company. I have materials from my
through the intellectual efforts of its creator. Intellectual property previous job that would be helpful in the work
owners generally expend considerable time and money to create, I will be doing for Flextronics. May I bring the
perfect and enforce intellectual property rights and as a result, materials with me?
generally consider those rights to be valuable assets. Intellectual
property may take many forms. For example, intellectual property ANSWER: You can use reference materials and
may include: an oral presentation about a company’s product other publicly available information. But you
development plans; a customer or employee list; a proprietary cannot bring any materials that may contain
design; information disclosed during a new product demonstration; confidential information or trade secrets from
or software source code. your former employer, customers or suppliers.

Flextronics and our customers, suppliers and other third parties with whom we If you have confidential or proprietary information that
do business make substantial investments in intellectual property rights. We belongs to your former employer, you have an
respect the intellectual property rights of third parties. We are each expected to obligation to protect that information even though you
have a basic working knowledge of the intellectual property laws applicable to our no longer work for that employer. You must not reveal
work. In addition, we must comply with the restrictions on the use of intellectual any information to Flextronics that would be
property rights that may be included in our contracts with third parties. considered a trade secret of your former employer.

The unauthorized use or disclosure of the intellectual property of others can subject us Please consult with the Legal Department if you
to significant liability. Infringement of third party intellectual property also can seriously have any questions or concerns about intellectual
damage our reputation and relationships with third parties. Stealing or unlawfully using property rights.
the intellectual property or proprietary or confidential information of anyone, including
our suppliers, customers, business partners or competitors, is a violation of this Code.

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T h e C ode O f B usiness C onduct A nd E t h ics

Software
QUESTION: Everyone in my
department uses a design
software tool provided by a third
party software vendor. Can our
administrator copy it and install it
on my computer’s hard drive?
ANSWER: The software is
protected by intellectual property
rights owned by the software
vendor or other third parties. You
need to check the applicable
license agreement before you
make any copies or install a copy
locally. Contact your IT
representative for assistance.
We use software in our business that was
created by other companies. We may not
make copies, resell or transfer software
created by another company unless
we are authorized to do so under the
applicable software license agreement.
Unauthorized use of software may breach
the agreement that allows us to use the
software. Unauthorized software use may
also constitute copyright infringement,
which may expose Flextronics and the
individual employees who engage in this
conduct to potential civil and criminal
liability. The Information Technology
Department may inspect our computers
periodically to verify that only approved
and licensed software has been
installed. Any unlicensed or unsupported
software that you have installed may be
removed by the Information Technology
Department unless you pay for a license.
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T h e C ode O f B usiness C onduct A nd E t h ics
Confidential Information�
Confidential information is information that is disclosed by Flextronics or its customers,
suppliers or other third parties with the expectation that it will be maintained as
confidential and only be used for a specific business purpose. Confidential information
can be disclosed through different media such as presentations and emails. It may or
may not be marked as “confidential”.
Confidential information may include ideas, designs, engineering and
manufacturing processes, drawings, formulas, procedures, business
and strategic plans, pricing data, financial information, employee
records, customer or supplier lists, trade secrets, inventions, and
patent applications.
Confidential information is a valuable asset. We are obligated as a condition of our
employment by Flextronics to safeguard the confidential information of Flextronics and
its customers, suppliers and other parties with whom we do business. Improper
disclosure of confidential information includes disclosure on Internet sites, chat rooms
and message boards.
Obligations under Securities Laws
We are committed to providing timely, transparent, consistent and credible or informal, and cover communications regarding Flextronics or its customers,
information to the investing public, in accordance with securities laws. suppliers or other partners. Reporters and members of the financial analyst community
may not visit any company

External Communications and Company Spokespeople QUESTION: The local newspaper wants to facilities without the prior and
visit our site in order to do a story on a express written approval of
To safeguard our compliance with the securities laws, we strictly limit who may prestigious award we recently won due to the Chief Financial Officer, the
communicate information to the press or to our strong performance and community Corporate Communications
members of the financial analyst community. relations. Is that a problem? Department or the Investor
We have designated our Chief Executive Relations Department. You
Officer, Chief Financial Officer and our should refer any inquiries
ANSWER: You need to refer the inquiry by
Investor Relations Department as the that you receive either
the newspaper to the head of Corporate
official company spokespeople for directly or indirectly from any
Communications. This person will coordinate
financial matters. We have designated news media or any member
with the press and decide whether granting
our Corporate Communications of the financial analyst
access to the site is appropriate in light of
Department as the official company community to an appropriate
compliance considerations.
spokespeople for marketing, Flextronics spokesperson.
technical and other such information.

Unless you are designated as an official Compliance with Regulation FD

spokesperson, you may not talk to, or
We are committed to compliance with Regulation FD. Regulation FD prohibits the
share information with, any form of news
selective disclosure of material, nonpublic information to any securityholder or to any
media or reporters or any member
member of the financial analyst community. Regulation FD requires that whenever
of the financial analyst community
Flextronics or any person acting on its behalf discloses any material, nonpublic
about Flextronics. These rules
information to a securityholder or member of the financial analyst community, we
apply to all communications,
disclose the information in a publicly available forum. If you have any questions
whether written, verbal, formal
regarding compliance with Regulation FD or are aware of any disclosure of information
that you believe may violate this policy, please consult with the Legal Department.

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Prohibition against “Insider” Trading
Insider trading laws restrict securities trading and other
activities by anyone who is in possession of material,
nonpublic information. We are prohibited from trading in
Flextronics securities if we are aware of material, nonpublic
information about Flextronics (such as financial results,
customer transactions or major corporate events such as
an acquisition, divestiture or restructuring). This restriction
also applies to transactions in the securities of other
publicly-traded companies if we learn material,
nonpublic information about them while working
for Flextronics. We are also prohibited from
communicating or “tipping” material, nonpublic
information to anyone else that might trade in
Flextronics securities (or any other publicly
traded securities). Likewise, we may not
have any other person trade Flextronics
securities (or any other publicly traded
securities) for us based on material,
nonpublic information. We are also prohibited
from engaging in derivative transactions in
Flextronics’s securities. We may not, at any
time, trade in any interest or position relating
to the future price of Flextronics’s securities,
such as a put, call or short sale, other than
in a “collar” or similar hedging transaction
that has been specifically approved in
writing or by email by the Chief Financial
Officer or the General Counsel. For further
information, please see our Insider Trading
Policy, which is available on our Intranet.
QUESTION: Flextronics employee
Juan learns from a procurement
officer at one of Flextronics’s largest
customers that the customer is
planning to default on its payments to
Flextronics and will be declaring
bankruptcy. The result would be a
huge loss for Flextronics. Juan
discusses the matter with his friend,
Peter. A few days later, when the
bankruptcy makes the national news,
the price of Flextronics stock drops.
Peter tells Juan: “Right after we
talked, I called my brother. He owned
several thousand shares of
Flextronics. He dumped his shares
and avoided taking a huge loss.” Juan
is caught off guard. He had no idea
that Peter’s brother had investments
in Flextronics. Has Juan violated our
insider trading policy?
ANSWER: Regardless of his intention,
Juan has violated our policy by
tipping and providing Peter with
material, nonpublic information. Juan,
Peter, and Peter’s brother also have
all violated insider trading laws.
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T h e C ode O f B usiness C onduct A nd E t h ics
Anticorruption Laws
Many countries have laws
QUESTION: I am traveling to Malaysia Who is a government official?
prohibiting corruption and bribery.
next week to visit a customer that is The definition of a government official includes:
One example is the U.S. Foreign
government-owned. I want to bring a gift Corrupt Practices Act (FCPA). • Any officer or employee of a government department or agency,
for my hosts to thank them for their whether elected or appointed;
There are similar laws in every
hospitality. Would that violate our Code • Any person acting in an official capacity on behalf of a
country in which Flextronics does
of Conduct? government department or agency;
business. Violations of these laws
• Any officer or employee of a company that is owned in whole
subject each of us and the
or in part by the government;
company to civil and criminal
ANSWER: Review the Compliance portal • Any officer or employee of a public international organization
liabilities. Winning the right way
on our Intranet for specific information such as the World Bank or United Nations;
means winning in compliance with
relevant to your situation before you • Any political party or any official thereof; or
anticorruption laws. We expect all
give any gift. The portal offers detailed • Any candidate for political office.
employees to comply with our
resources that can help you answer
Anticorruption Policies and
questions about gifts and hospitality in
Procedures, which are available
a particular country. Political Contributions
on our Intranet.
We may not use Flextronics’s funds for political
Government Officials contributions of any kind to any political candidate or
holder of any government office without prior written
To ensure compliance with the laws prohibiting corruption and bribery, we are approval. “Political contributions” include direct and
prohibited from offering or giving anything of value to a government official for the indirect payments, loans, advances, deposits, or gifts of
purpose of obtaining or retaining business, to win a business advantage or to money or any service. It also includes subscriptions,
improperly influence a decision regarding Flextronics. memberships, tickets, purchases of advertising space,
payment of expenses or compensation of employees for a
We cannot use a third party (such as an agent, consultant or business representative)
political organization, candidate or public official.
to offer or give anything of value to a government official for the purpose of obtaining or
retaining business, to win a business advantage or to improperly influence a decision You may make any political contributions of your choice on an
regarding Flextronics. Please see the Anticorruption Policy for more information. individual basis, with your own money and on your own time.

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T h e C ode O f B usiness C onduct A nd E t h ics

Importing, Exporting and Supply Chain Security
QUESTION: I am an engineer working efficient and secure international
on a project subject to U.S. export
license restrictions. Can I talk about my
project to a potential customer visiting
from another country?
ANSWER: Depending on the specific
license, you may not be allowed to
share information with people from
any other country. Export licenses
prohibit sharing items, technology or
software with people from certain
countries. Before you share any infor-
mation on a project covered by an
export license, you should work with
the local or corporate global trade
team to make sure you understand
the license restrictions.
we ship our finished products, components or technology as well as the export laws of
the United States, regardless of the shipping country. Therefore, we must perform both
local and U.S. “export determination” on each shipment to determine the authorization
requirements for a compliant transaction.
Our business depends on compliant, We have committed to government authorities and our customers that we will ensure
the integrity of our supply chain security practices. As part of this initiative we are
trade. There are many different laws, required to communicate our supply chain security practices to our business partners.
regulations and contract provisions
Flextronics is not permitted to conduct trade with certain countries and individuals.
which govern how we conduct
The list of prohibited countries and individuals changes depending on world events. If
trade because we operate in many
you are involved in importing and exporting for Flextronics,
countries and interact with numerous
you must check with your site’s Trade Compliance
customers. We are each expected
Coordinator or the Global Trade Organization to
to know and comply with these
ensure that the transactions you are working on
legal and contractual requirements
are in compliance with export control laws.
as they apply to our work.
To learn more about export and import
As an importer, we are responsible
controls, visit the Compliance portal on the
for accurately describing and
Intranet or check with your site’s Trade
classifying goods and accurately
Compliance Coordinator.
stating their value and country of
origin. We also must comply with
local customs and other government
agency import laws, regulations and
procedures.
As an exporter, we must comply with
any laws of the country from which
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T h e C ode O f B usiness C onduct A nd E t h ics
Accurate Books and Records No Expectation of Privacy
Our responsibilities to our stockholders require that our books and records are
prepared in compliance with U.S. generally accepted accounting principles (US GAAP)
and established corporate accounting policies. Our books and records may not
contain any false, incomplete or misleading entries or records. In addition, Flextronics
may not have any undisclosed or unrecorded corporate funds established for any
purpose. Payments made without appropriate supporting documentation and approval
are strictly prohibited. Additionally, all documentation supporting a transaction should
be complete and accurate and be processed in a timely fashion.
We engage auditors to ensure that our books and records are maintained in
accordance with applicable accounting standards. We expect all employees to provide
accurate information to our internal and external auditors.
Use and Protection of Flextronics’s Assets
We are each responsible for protecting Flextronics’s assets. We may not take,
misappropriate, loan, sell or donate any Flextronics assets without appropriate
authorization. We are each furnished with the equipment we need to efficiently and
effectively do our jobs. We must care for that equipment and use it responsibly and
primarily in the conduct of our job responsibilities, except Flextronics-owned laptop
computers or mobile phones, which may be used for personal purposes to the extent
permitted by Local Rules. If we use Flextronics equipment at home or off-site, we must
take precautions to protect it from theft or damage as if it were our own property. All
equipment must remain fully accessible to Flextronics and is the sole and exclusive
property of Flextronics.
If Flextronics no longer employs you, you must immediately return all Flextronics
equipment.
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T h e C ode O f B usiness C onduct A nd E t h ics
Flextronics respects the privacy of our employees. However you should not assume
that your use of any computer, telephone or other equipment is private. In addition, you
should not assume that your workspace, cubicle or office is private. To the extent
permitted by applicable law, we retain the right to access, search and review your
communications, equipment or workspace, either with or without your or a third party’s
knowledge, consent or approval.
Flextronics Funds
We are each responsible for all Flextronics funds over which we exercise control.
Agents and contractors should not be allowed to exercise control over Flextronics
funds. Flextronics funds cannot be used for any personal purpose or placed in a
personal or non-corporate account.
Facility Security
In order to ensure the safety and security of our employees and to safeguard our
assets, we have established facility security policies and procedures and implemented
physical access restrictions at our facilities. We are responsible for complying with the
policies and procedures in effect at any facility where we work or visit.
Prohibition against Use of Flextronics Assets to Aid Terrorists
We are expressly prohibited from using any Flextronics assets to aid any alleged
terrorists or terrorist activities.
Additional Standards
Selecting Suppliers
Our suppliers contribute significantly to our success. To create an environment where
suppliers want to work with us, they must be confident that they will be treated lawfully
and in an ethical manner. Our policy is to purchase supplies based on need, quality,
service, price, and terms and conditions. Agreements with suppliers may contain
restrictions on sales if those restrictions have been specifically reviewed and approved
by the Legal Department for compliance with applicable antitrust laws.
Government Contracts
Our policy is to comply with all applicable laws and regulations that apply to
government contracting and to strictly adhere to all terms and conditions of any
contract with any government entity. The Legal Department must review and approve
all contracts with any government entity.
Enterprise Record Retention Policy
We are each responsible for complying with our Enterprise Record Retention Policy,
which is available on our Intranet.
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T h e C ode O f B usiness C onduct A nd E t h ics
Corrective Actions
The matters covered in this Code are of the utmost importance to Flextronics, our
stockholders and our business partners. Compliance with this Code is essential to our
ability to conduct our business in accordance with our stated values and ethical
standards. We expect all of our employees, officers and Board members to adhere to
these rules in carrying out their duties for us. If you fail to comply with this Code, any
Local Rules or any other applicable policies or guidelines or you fail to act when you
are aware of criminal or unethical acts, we may take appropriate corrective and
disciplinary actions. Corrective actions for violations include discipline up to and
including termination of employment at our sole discretion. In addition, where we have
suffered a loss, we may pursue any remedies we may have against the responsible
individuals or entities. You should review the company’s Local Rules, policies,
procedures, employee handbooks and other guidelines for more detailed information
regarding policies that may apply to you.
Flextronics Ethics Hotline Toll-Free Numbers (24-hours-a-day)
To find updated numbers for your country, visit http://www.flexethicshotline.com.

Office Locations Phone Office Locations Phone

Australia 1-800-339276 Malaysia 1-800-80-8641

Austria 0800-291870 Mexico 001-8008407907
Brazil 0800-8911667 Mexico 001-866-737-6850
Canada 1-888-238-1244 Netherlands 0800-0226174
China (Northern) 10-800-712-1239 Norway 800-15654
China (Southern) 10-800-120-1239 Poland 0-0-800-1211571
Czech Republic 800-142-550 Puerto Rico 1-888-238-1244
Denmark 80-882809 Romania 0808-03-4288
(At the prompt, dial 888-238-1244)
Finland 0800-1-14945
Russia 8-10-8002-6053011
France 0800-902500
Singapore 800-1204201
Germany 0800-1016582
Spain 900-991498
Hong Kong 800-964214
Sweden 020-79-8729
Hungary 06-800-17199
Taiwan 00-801-13-7956
India 000-800-100-1071
(At the prompt, dial 888-238-1244)
Indonesia 001-803-011-3570
Thailand 001-800-12-0665204
Ireland 1-800615403
Ukraine 8^100-11
Israel 1-809-214405 (At the prompt, dial 888-238-1244)
Italy 800-786907 United Kingdom 08-000328483
Japan/J5 0066-33-112505 United States 888-238-1244
Japan/JP 00531-121520
Numbers listed current as of July 2009.
Korea/K2 00308-110-480
Korea/KO 00798-1-1-009-8084
Korea 00798-14-800-6599