Corruption and Bribery Prevention Policy

Credo’s Anti-Corruption Policy is simple.

No one may offer, give, or receive bribes in connection with their work for Credo Technology Group Holding Ltd or any of its subsidiaries (“Credo”) at any time for any reason.

Corruption means paying bribes or kickbacks. At Credo, no one may offer or accept, directly or indirectly, anything of value that may influence, or even appear to influence, business decisions involving Credo whether in the private or public sector.

Anything of Value. This regulatory term is broadly construed by enforcement authorities and, for purposes of this Policy, can include anything the recipient would find interesting or useful and is not limited to tangible items or economic value. Anything of value includes, but is not limited to:

      • Cash
      • Cash equivalences (gift card, etc.)
      • Gifts
      • Entertainment, meals and travel
      • Training
      • Business, employment or investment opportunities
      • Personal discounts or credits
      • Assistance to or support of family member and other benefits
      • Payment of medical expenses
      • Political contributions
      • Charitable contributions
      • Job offers

      No one should ever ask anyone else to engage in bribery on Credo’s behalf. We expect all third parties that do business with Credo to understand and comply with this Policy and with all applicable anti-corruption and anti-bribery laws.

      Employees confronted with a request or demand to pay a bribe or are offered a kickback must refuse. Explain to the third party that these types of payments are illegal and are against Credo’s policies.

      Facilitation Payments. Facilitation payments are a type of bribe made to a government employee to expedite or secure performance of a routine, non-discretionary action, such as obtaining utility services, clearing customs, or getting a permit. Facilitation payments are strictly prohibited by this policy and Credo’s Code of Business Conduct and Ethics.

      Accurate Recordkeeping. All expenses, including gifts, business entertainment, and travel, must be accurately recorded in Credo’s books and records. Expenditures must be fully and accurately described in all business documentation and paid directly to the vendor of the services.

      Conflicts of Interest. All Credo personnel must act and make business decisions in the best interests of Credo and refrain from intentionally or unintentionally engaging in activities that create a conflict of interest or an appearance of impropriety. In general, we avoid any activity or personal interest in a transaction or relationship that creates or appears to create a conflict between our own private interests and Credo’s interests, or that might impair our ability to perform our Credo duties and responsibilities honestly, objectively, and effectively. We never use Credo’s property, information, or business opportunities for our own personal gain or benefit, or that of anyone else.

      Scope and Penalties. This Policy applies to all Credo employees, including directors, officers, and managers. This policy also applies to third parties, including (1) agents; (2) consultants; (3) sales representatives; (4) vendors; (5) suppliers; (6) and any other representatives who conduct business on Credo’s behalf. Failure to comply with this Policy may result in civil and criminal penalties for both Credo and for the individuals involved, and is grounds for disciplinary action, up to and including termination. Any employee who engages a third party to act on Credo’s behalf must ensure that appropriate diligence has been conducted and appropriate contractual commitments have been made with that third party. Any questions regarding the appropriate steps to take in engaging a third party should be directed to Credo’s Legal Department.

      Where to Get More Information. If you have any questions, you should contact your supervisor or Credo’s Legal Department. Further information can be found in Credo’s finance policies and guidelines, such as guidelines regarding gifts, business entertainment and travel expenses.

      Investigating and Reporting Violations of this Policy. Employees, officers, and members of our Board of Directors are expected to cooperate fully with any investigation involving a suspected violation of this Policy. You should raise any concerns or suspected violations of this Policy with your supervisor or with Credo’s Legal Department. Additionally, you may also report issues in either of the following ways:

      • Website:
      • Toll-Free Telephone:
        • Direct Dial
          • English speaking USA and Canada: 855-222-3801
          • Spanish speaking USA and Canada: 800-216-1288
          • French speaking Canada: 855-725-0002
          • Spanish speaking Mexico: 01-800-681-5340
        • AT&T USA Direct
          • All other countries: 800-603-2869 (must dial country access code first; click here for access codes and dialing instructions)
      • E-mail: (must include Credo’s name with report)
      • Fax: (215) 689-3885 (must include Credo’s name with report)

      Credo will not discipline, discriminate against, or retaliate against any employee who, in good faith, reports violations or suspected violations of this Policy.