HoloX Anti-Bribery & Integrity Compliance Policy

1. Introduction

HoloX is committed to the highest standards of ethical conduct, transparency, and legal compliance in all its business operations globally. This Anti-Bribery & Integrity Compliance Policy outlines our expectations and rules regarding bribery, corruption, and improper influence. It applies to all HoloX entities, employees, subsidiaries, contractors, and third-party representatives worldwide.

We operate in sensitive, high-trust sectors, including defense, government, and financial markets, where integrity is not negotiable. Compliance is mandatory; Failure to adhere to this policy may result in disciplinary action or termination.

2. Scope

This policy applies to:

• • All employees, directors, and officers of HoloX

• • Subsidiaries and controlled entities

• • Contractors, consultants, agents, distributors, and any third parties acting on HoloX’s behalf

It applies across all jurisdictions, regardless of local customs or practices.

3. Definition of Bribery

Bribery is the direct or indirect offering, giving, requesting, or receiving of anything of value to improperly influence a business outcome. Bribery may involve:

• • Government officials or regulators

• • Private business partners

• • Procurement decision-makers

• • Anyone with the ability to influence commercial or public outcomes

Bribes may be financial (cash, commissions) or non-financial (gifts, travel, entertainment, employment offers, donations, etc.).

4. Facilitation Payments

Facilitation payments—small, unofficial payments to speed up routine actions—are strictly prohibited. Even where legal under local law, HoloX does not permit them. Employees must report any request for such payments immediately.

5. Gifts, Hospitality, and Travel

Gifts, entertainment, and hospitality may only be offered or accepted if they:

• • Are reasonable and infrequent

• • Are not linked to a business decision or intended to create obligation

• • Are permitted under applicable law and HoloX policy

• • Are fully transparent and pre-approved if exceeding defined limits

Lavish, excessive, or concealed benefits will be treated as potential bribery.

6. Charitable Contributions & Sponsorships

Donations and sponsorships may not be used to influence business decisions or win contracts. All such contributions must:

• • Serve a legitimate public or community purpose

• • Be properly recorded and approved in accordance with internal guidelines

• • Never be made at the request of a government official or business partner as a condition for doing business

7. Political Contributions

HoloX does not make political donations on behalf of the company. Employees may participate in political activities in a personal capacity but must not represent the company or use company resources for such purposes.

8. Third Parties and Intermediaries

HoloX may be held liable for the actions of third parties. Therefore:

• • Due diligence must be conducted before engaging any party that represents HoloX or interacts with government, procurement, or regulated sectors on our behalf

• • All third parties must agree to comply with this policy

• • Contracts must contain appropriate anti-bribery language and audit rights where relevant

9. Books and Records

All payments, expenses, and business activities must be accurately recorded in HoloX’s books and records. No undisclosed or unrecorded accounts may be maintained.

10. Reporting & Whistleblowing

All employees and third parties are encouraged and expected to report suspected violations of this policy immediately. Reports may be made to your manager, legal counsel, or anonymously to: ethics@holox.com

HoloX will not tolerate retaliation against any individual who reports concerns in good faith.

11. Investigations & Consequences

All reports will be investigated promptly, confidentially, and professionally. Violations of this policy may result in:

• • Disciplinary action up to and including termination

• • Civil or criminal prosecution

• • Blacklisting or termination of business relationships with third parties

12. Training & Communication

All employees must receive anti-bribery training as part of onboarding and at regular intervals. Third-party compliance expectations will be communicated through contractual clauses and onboarding documentation.

13. Oversight & Review

This policy is reviewed periodically by the Compliance Officer and approved by HoloX Global Holding B.V. management. Updates may be issued without prior notice.

Legal Notice

This policy is issued by HoloX Global Holding B.V. and is intended to communicate internal standards of conduct related to anti-bribery, corruption, and compliance. It does not constitute a contract of employment or create legal rights for any employee or third party.

HoloX reserves the right to amend, update, or withdraw this policy at any time without prior notice. The most current version will always be available through official HoloX communication channels.

Issued by: HoloX Global Holding B.V. Date of Issue: March 2025 Contact: ethics@holox.com