HoloX of Business Conduct and Ethics
Issued by HoloX | Effective March 20251. Introduction
At HoloX, we believe that how we work is just as important as what we create. Our technology serves critical industries: governments, defense, finance, and global brands, and our conduct must reflect the trust they place in us. This Code outlines our expectations for ethical behavior, integrity, and responsibility and applies to all HoloX employees, contractors, subsidiaries, and third-party representatives.
We are committed to maintaining a culture where decisions are guided by fairness, transparency, and accountability—regardless of role, location, or seniority.
2. Compliance with Laws and Regulations
We operate in multiple jurisdictions and must comply with all applicable local, national, and international laws. This includes, but is not limited to, regulations related to:
• Data protection and privacy (e.g., GDPR)
• Export controls and trade restrictions
• Labor and employment laws
• Environmental regulations
• Fair competition and anti-corruption
All employees are expected to understand and follow the rules relevant to their responsibilities.
3. Integrity and Fair Dealing
We conduct business honestly and with respect. We:
• Communicate transparently and truthfully
• Deliver on our commitments
• Compete fairly and ethically
• Avoid deceptive, misleading, or manipulative practices
We do not seek advantage through dishonesty, misrepresentation, or unlawful conduct.
4. Conflicts of Interest
Employees must avoid situations where their personal interests could conflict with HoloX’s interests. This includes:
• Accepting gifts or benefits from suppliers or clients
• Holding a financial interest in a competing or related company
• Hiring or supervising close personal relationships
Any potential conflict should be disclosed to management for review.
5. Confidentiality & Data Security
We protect the privacy of our partners, clients, and colleagues by safeguarding confidential information. This includes:
• Product designs, technical data, and trade secrets
• Financial, legal, or strategic documents
• Personal data of employees or clients
• Proprietary R&D or client-specific information
Unauthorized disclosure, misuse, or careless handling of confidential material is strictly prohibited.
6. Respectful Workplace
We maintain a workplace that is safe, inclusive, and respectful. Harassment, discrimination, bullying, or retaliation—on any basis, including gender, race, religion, orientation, or background—will not be tolerated.
Everyone at HoloX has the right to work in an environment free from hostility and bias.
7. Use of Company Resources
Company resources, including physical assets, digital tools, intellectual property, and communication platforms, must be used responsibly and only for legitimate business purposes. Misuse, theft, or negligence involving company assets may lead to disciplinary action.
8. Environmental & Social Responsibility
We recognize our responsibility to operate sustainably and ethically. We aim to:
• Minimize waste and resource usage
• Work with partners who share our environmental and human rights values
• Promote innovation that enhances global security, not undermines it
• Uphold responsible sourcing and ethical production practices
9. Speaking Up and Whistleblowing
We encourage everyone at HoloX to speak up if they witness behavior that violates this Code. Reports can be made to a manager, HR representative, or directly to:
We take all reports seriously and will not tolerate retaliation against anyone who raises a concern in good faith.
10. Enforcement and Accountability
Violations of this Code may result in disciplinary action, including termination of employment or contract. Serious breaches may also result in legal action or referral to regulatory authorities.
Managers are expected to lead by example and help their teams uphold this Code.
Legal Notice
This Code of Business Conduct and Ethics is issued by HoloX Global Holding B.V. and is intended to provide internal guidance to employees and third parties. It does not constitute a contract of employment or create legal rights for any party.
HoloX reserves the right to amend, update, or withdraw this Code at any time without prior notice. The most current version will be made available through official HoloX channels.
Issued by: HoloX Global Holding B.V. Date of Issue: March 2025 Contact: ethics@holox.com
