Compliance and ethics program

Micron Technology believes strongly in the importance of up-to-date, comprehensive and easy to understand and follow ethics and compliance policies and practices. Every employee, manager and officer at Micron is expected to live up to these standards and is required to attend regular training sessions on ethics and compliance issues.

Micron regularly updates and implements policies, practices and training programs designed to reflect changes in applicable legal requirements and our company’s operations, to thereby strengthen our compliance efforts and maintain our competitive position in the global marketplace.

The following summarizes some key features of our compliance and ethics program:

• A dedicated Compliance Helpline to report possible violations or raise concerns about Micron’s Code of Business Conduct and Ethics. Reports received on the Compliance Helpline are entered directly on a secure server managed by a third-party vendor, EthicsPoint. Except where prohibited by local law, Compliance Helpline reports may be filed anonymously.
• A Chief Compliance Officer responsible for compliance and ethics issues at Micron, a position currently held by Michael Ray, Senior Vice President, General Counsel and Corporate Secretary.
• Anti-bribery/corruption and antitrust training has been developed and deployed to educate employees on how to interact with competitors, suppliers and customers. The training is available for all finance, sales, marketing and purchasing employees, as well as any other employees who want to participate.
• Comprehensive governance policies related to Sarbanes-Oxley and NASDAQ Stock Market requirements and company-driven initiatives, including Board and Company committees, such as the Governance Committee and Compensation Committee, an Independent Audit Committee and a Disclosure Committee. The Company also has a Corporate Governance page on its web site containing its Code of Conduct and Business Ethics, Corporate Governance Guidelines and Board Committee Charters.
• Regular updates to a comprehensive, state-of-the-art compliance and ethics program covering a wide range of topics including anti-bribery and corruption, safety and health, employment, exports, environmental law, securities, antitrust, insider trading, privacy laws and business ethics.

Our corporate character is based on good corporate governance, legal compliance, transparency and cooperation, and as such, we will continue to review and revise our compliance policies and practices on a regular basis.