Anti-Corruption Policy

Background Information

The Plexus Code of Conduct & Business Ethics (the “Code of Conduct”) prohibits employees from engaging in any corrupt transaction (described further in Section 6 below). In addition, many countries maintain laws prohibiting corrupt transactions. This Policy establishes guidelines for complying with the anti-corruption requirements under the Code of Conduct and the anti-corruption laws applicable to Plexus.

General Guidelines

Corrupt Transactions Prohibited

Plexus employees are prohibited from engaging in corrupt transactions. A corrupt transaction is giving or receiving anything of value for an improper purpose. Examples of corrupt transactions include bribes and kickbacks.

Giving or Receiving

Plexus employees are prohibited from participating in any manner in a corrupt transaction. This includes transactions where Plexus is on either the giving or receiving end of a transaction.

Anything of Value

The term “anything of value” should be interpreted very broadly, and includes, but is not limited to, any of the following:

Cash, discounts, and gifts
Airfare and other transportation, and upgrades for such transportation
Entertainment, drinks, meals, and lodging
Promises of future employment or a benefit to a person's family
Charitable donations or political contributions

The amount or value of the payment or benefit does not matter—even small payments or benefits are considered something of value.

Improper Purpose

An improper purpose means the purpose or motivation behind the transaction is any of the following purposes or goals:

To influence a person to misuse his or her position
To unfairly win or retain business
Gaining access to non-public information
Evading taxes or penalties
Obtaining exceptions to regulations
To secure an improper advantage
To induce or encourage violation of the law
To obtain money, property or services through threats or force

Whether a transaction is motivated by an improper purpose, should be judged by whether an independent third party would view the transaction as being motivated, or even being possibly motivated, by an improper purpose.

All Transactions and Business Relationships

The prohibition on engaging in any corrupt transaction applies to all transactions and business relationships, including transactions and business relationships with customers, suppliers, consultants, government officials and any other person or entity.

Conflicts of Interest

Plexus provides guidance by giving examples of situations of how a conflict of interest may occur and how Plexus employees should avoid such conflicts of interest in carrying out their duties. The existence of a conflict of interest does not necessarily mean that a person has engaged in wrongful conduct. However, to ensure that Plexus properly manages all conflicts of interest, Plexus employees are encouraged to report all conflicts of interest by completing the Conflict of Interest Disclosure Form, so that the matter can be evaluated and addressed to reduce the risk of improper influence on applicable business activities. If the conflict is critical and may raise the appearance of improper bias, the employee will be required to withdraw from the decision making process that relates to the conflict.

Gifts, Meals & Entertainment

Reasonable gifts, meals and entertainment that are not given or received for an improper purpose are permissible if such transactions comply with the Plexus Gifts and Entertainment Policy. However, corrupt transactions, such as bribes, kickbacks, extortion and embezzlement, can take many forms and some companies have disguised corrupt transactions as travel and entertainment expenses and expensive gifts. The Plexus Gifts and Entertainment Policy provides detailed guidance and examples to help Plexus employees distinguish between appropriate business gifts, meals and entertainment and improper corrupt transactions.

Intermediaries

Plexus may engage the services of intermediaries (agents or third parties) to assist in conducting business. Some examples of such intermediaries include, but are not limited to, consultants, customs brokers, and sales and marketing representatives. Plexus is prohibited from participating in any corrupt transaction through an intermediary.

Employees choosing to engage intermediaries should follow the applicable indirect supplier evaluation process:

SOP 114 - Identification, Evaluation, Approval and Maintenance of Indirect Suppliers (for manufacturing-related suppliers) and

SOP 3525 - Supplier Performance and Evaluation Procedure (for engineering-related suppliers)

Facilitation Payments

Facilitation payments (sometimes called “grease payments”) are payments of small sums of money to expedite or secure the performance of a routine governmental action, such as a visa application. Facilitation or “grease payments” are often corrupt transactions. For this reason, facilitation or “grease” payments are prohibited unless approved in advance and in writing by a representative of Plexus Legal.

Political & Charitable Contributions

Plexus employees are prohibited from making a political or charitable contribution in Plexus’ name or for Plexus’ benefit unless the contribution is pre-approved by the Plexus Charitable Foundation. Local human resources representatives can assist in submitting political or charitable contribution requests to the Plexus Charitable Foundation.

Identifying Red Flags

To assist Plexus in detecting and preventing any corrupt transaction, employees should look for and report any “red flags” signaling the possibility of a corrupt transaction. Examples of “red flags” include the following:

The other party refuses to certify that he or she will abide by any global anti-corruption law (such as the U.S. Foreign Corrupt Practices Act or U.K. Bribery Act)
The other party has family or business ties to a foreign official
The other party insists that his or her identity not be disclosed
The other party is chosen by a customer
The other party lacks appropriate staff and facilities to perform services
The other party requests excessive or up-front payment
The other party requests payment to be made through convoluted means
The other party requests checks to be made out to “Cash” or “Bearer”
The other party operates in a country that has a history of corruption
The other party operates in an industry that has a history of corruption

Recordkeeping

All Plexus employees involved in any transaction must work to ensure that the transaction is recorded completely and accurately so that the purpose and amount of any such payment is clear. No undisclosed or unrecorded funds or assets of the company should be established for any purpose. False, misleading, or artificial entries should never be made in the books and records of Plexus for any purpose whatsoever.

Questions & Guidance

For answers to questions or guidance relating to this Policy, contact the Corporate Compliance Officer or any other representative of Plexus Legal.

Reporting Violations or Concerns

If any employee suspects a violation of the law or this Policy, the employee must immediately raise the concern through the employee’s local human resources representative, the Corporate Compliance Officer or any other representative of Plexus Legal, or any of the people named in the Code of Conduct.

Alternatively, employees may report concerns via the Ethics Hotline (instructions posted on CONNECT and in the Code of Conduct).

Any violation of this Policy is grounds for immediate disciplinary action, including termination. A violation of this Policy may result in violations of legal requirements in the countries where Plexus conducts business. Substantial civil and criminal penalties, including fines and imprisonment, may be imposed for violations.