Business Practices

Ethical Business Conduct

For more than 15 years, Sun has published our internal Standards of Business Conduct and required that our employees worldwide fully participate in meeting these ethical guidelines. Since 2004, members of Sun's Board of Directors have also been required to adhere to the Standards of Business Conduct.

In 2001, Sun established a Business Conduct Office (BCO) to develop and manage a global business conduct program. This program is focused on providing board members and employees with the necessary resources, guidelines, and training to help ensure that they understand the high standards of business conduct that Sun expects them to uphold.

All newly hired employees receive a copy of Sun's Standards of Business Conduct booklet and must complete online training within their first 120 days of employment. In addition to general business conduct training, Sun also requires employees to complete online training specifically related to:

• Export Control Compliance
• Antibribery and Corruption Compliance
• Conflicts of Interest
• Intellectual Property Protection
• Information Technology Security

Specifically, the role of the BCO is to:

• Advise: Assist all Sun employees in fulfilling their obligations to Sun with respect to responsible business practices and legal compliance
• Educate: Ensure that Sun employees understand ethical and legal implications involved in the performance of their duties
• Respond: Provide a confidential resource for employees to seek advice, obtain information, and report violations concerning Sun's Standards of Business Conduct
• Communicate: Articulate expectations regarding Sun's legal and business conduct standards

Updates
Updates to Sun's Standards of Business Conduct are made approximately every two years, with input from specific stakeholders throughout the company. When the Standards are updated, they are translated into nine languages. All employees are made aware of the specific changes via Sun internal communications.

Employee Integrity Survey

To help ensure that Sun's Business Conduct program continues to evolve and reflect our ever-changing business environment, the BCO annually conducts a global employee survey. This survey is designed to measure employees' perceptions of integrity in the workplace as well as the effectiveness of Sun's current Business Conduct program. The survey is randomly distributed to 4,000 employees in various work locations, all of whom are invited to complete the survey and submit it anonymously.

Advice Resource for Employees

In 2001, Sun implemented the Adviceline, a resource for our employees to seek help and report violations of the Standards of Business Conduct or the law. The Adviceline is available 24 hours a day, 7 days a week. In addition, we implemented an online reporting tool that allows employees to seek information or report violations anonymously via the Web.