A note from our CEO

Our dream is to improve human health by unlocking single-molecule and cell analysis. Caring as much about what we do as about how we do things, we are committed to conduct our business with integrity and fairness, with respect for the law, and in line with our culture and values.

This Code of Conduct (“Code”) provides guidelines to ensure compliance with the laws, regulations, and policies that govern us, and to ensure protection of our business interests, including corporate assets and information. The Code serves as a moral compass and is intended to promote honest and ethical conduct. Anyone who works at or with the Company, including LUMIs, customers, shareholders, and business partners, is expected to follow this Code when carrying out their daily business activities.

We recognize that living by our values and this Code is not always easy. You may face conflicting pressures and dilemmas. We know that making the right decisions takes courage, but we are confident that this Code can give you the guidance you need to do so. When in doubt, be open and discuss possible dilemmas with your colleagues, manager, Ethics Officers or HR. If you have concerns about a possible violation of our Code or the underlying policies, speak up through one of our trusted Speak Up channels.

Acting in accordance with our Code and underlying policies is a responsibility we all share. This starts in my office and extends to everyone in the team. So please read them, discuss them, and apply them to your daily work. LUMIs are at the heart of our company and our success begins with you. By staying true to our values and this Code, together we can put integrity at the heart of our business and pave the way for future success.

– Yours sincerely, Olivier

What is the Code?

The Code outlines standards for ethical behavior that each of us must observe when acting for or on behalf of LUMICKS. This Code does not summarize every applicable law or regulation nor does it address every issue or situation in which ethical decisions must be made. Compliance with our Code is about promoting ethical conduct and creating an open and honest work environment. The Code, together with its underlying policies, helps us make the right decisions and take the right actions, regardless of where we work or the type of work we do.

We all share the responsibility and commitment to comply with the Code, LUMICKS’ policies and laws that govern our activities. The Code applies to anyone who works at or with LUMICKS, including all LUMICKS employees, officers, directors, and others working under the supervision of LUMICKS regardless of the type of contract, business unit, or location of work. Our business partners, such as suppliers, distributors, and other contractors, are expected to commit to the same values and principles.

Failure to act in line with the Code and its policies can have very serious consequences for LUMICKS as well as the individuals involved. Whenever we become aware of a violation of the Code, underlying policy or the law, we will act to address the problem and prevent future occurrences.

Our principles

I. We conduct business with fairness and integrity

Conflicts of interest

We avoid contact or conduct that may lead to or could be perceived as a conflict between business and private interests or damage our reputation. If personal interests, relationships, or activities outside of work influence or could be perceived to influence any business-related activities, there is a conflict of interest.
We understand that employees have lives outside of LUMICKS and that it is important to contribute to society through external organizations, which we encourage. However, we discourage actions or collaborations that potentially lead to or present a conflict of interest that negatively impacts our reputation or any individuals involved. When in doubt, contact your manager to confirm whether a specific situation is considered a conflict of interest or not.

Bribery prevention

We will only engage in business activities with reputable third parties who share our commitment to integrity. We will not tolerate improper or corrupt payments, including bribes or kickbacks, made directly or indirectly to or from a customer, government official, or third party. Bribery and corruption could seriously harm our reputation, lead to considerable financial losses, or embarrass our business partners. Therefore, we are committed to preventing LUMIs and our business partners from giving or receiving advantages that may constitute or be perceived as bribery or corruption. We have anti-corruption and anti-bribery policies that provide practical rules and guidelines on how to prevent and detect corruption-related issues and how to act accordingly. Every year, we give training to our employees, distributors, and agents.

Anti-money laundering, combating the funding of terrorism and adhering to export regulations

We will not engage in business activities with third parties that are involved in unethical or illegal behaviors, such as money laundering, funding of terrorism, or violating export regulations.
We are committed to complying with all applicable financial record-keeping and reporting requirements and all other applicable anti-money laundering laws and regulations. We also comply with all applicable laws and regulations regarding terrorist financing, facilitation of tax evasion, and export regulations.
We only engage with parties involved in legitimate business activities, with funds derived from legitimate sources.

Fair competition

We are a fierce but fair competitor. We believe that competitive advantage should be achieved through excellence, innovation, and service. In most countries, competition or antitrust laws regulate company activities to ensure fair competition for the benefit of consumers and market participants. We will always comply with these competition laws since we do business through fair competition.

Compliance with law and regulations

We will comply with applicable laws and regulations as well as our policies and rules and take appropriate action against any illegal or criminal acts or any violation of our policies and rules. We will make no exceptions to this commitment regardless of the motivation behind those acts.

Customer relations

We strive to create and maintain long-standing relationships with customers. We are committed to providing our customers with the highest quality products and services. Sometimes we make mistakes, but we learn from those. We handle comments and complaints regarding our services seriously and quickly. We believe this approach best meets the customer satisfaction we desire.

Business partner relations

We seek productive, ethical, and transparent relationships with business partners. To this aim, we thoroughly check the background of our potential business partners and expect all our partners to follow all applicable laws and regulations and share the values expressed in our Code.

Healthcare Professional relations

We should all be aware of the need for transparency in our engagement with healthcare professionals. We understand and follow applicable laws and regulations that govern any promotional activities, and any educational and commercial relationships we may have with healthcare professionals.

II. We respect people

Work environment

We are committed to providing an inclusive place of work that encourages and welcomes diversity. We understand that, to succeed, we must attract and retain outstanding employees and create a work environment where they can thrive, collaborate and innovate. This means building teams that represent diverse backgrounds, perspectives, talents and experiences, and helping them to work together free from any fear of harassment and discrimination. We value and manage diversity through an inclusive environment for all LUMIs, since we believe it is a critical aspect for creating innovative discoveries and engaging our employees.

Health and safety

We are committed to providing a healthy and safe workplace for LUMIs and others who visit our premises. We accomplish this through the consistent implementation of internal processes that meet the applicable regulatory requirements. However, our commitment to promote health and safety is shared by everyone at LUMICKS. Look out for one another, work together to help ensure that our operations are safe, and notify your manager if you are concerned or uncertain about potential hazards in your work area. We also expect this commitment from our customers and business partners. We help contractors, customers, and others we work with to understand and follow our safety procedures. If you get injured on the job, notify your manager immediately, no matter how minor.

Human rights

At LUMICKS, we are committed to respecting the human rights and dignity of everyone, and we support international efforts to promote and protect human rights. We treat people equally and fairly, based on the principles of non-discrimination. We comply with all applicable laws pertaining to fair employment practices, freedom of association, collective bargaining, immigration, working time, wages and hours, as well as laws prohibiting forced labor, compulsory labor, child labor, employment discrimination and human trafficking. We will not tolerate the abuse of human rights in our operations or in our supply chain. More specifically, we do not tolerate physical, verbal, sexual or psychological harassment, bullying, abuse, or threats.

Privacy

We respect privacy. We are committed to protecting the data of customers, business partners, and employees with the highest standards of protection. We do this in compliance with our security and privacy standards and with applicable security and privacy laws and regulations. Privacy is a fundamental value for us as a trustworthy and ethical company. We employ appropriate safeguards to protect personal data from unauthorized use or disclosure.

III. We respect our planet and commit to social responsibility

Environment

We take responsibility for the social, environmental, and economic impact of our activities, while fulfilling our moral and legal obligations. Sustainability is an integral part of our business and we believe it is our responsibility to actively reduce our impact on the environment. Within our entire value chain and wherever we operate, we pay specific attention to reduce our CO2 emissions and consumption of water, energy and raw materials, and to increase the use of renewable energies. We also focus on reducing waste through recycling and reusing. We expect you to contribute to these ambitions and we encourage you to continuously introduce, develop and improve sustainable initiatives in your daily work.

Community engagement

We contribute to the communities in which we operate. LUMICKS is committed to having a positive impact on the communities in which it operates, creating additional social value by giving back to society. We believe in collaborative, consultative and partnership-based approaches to our community involvement.

IV. We protect our assets

Intellectual property

Our intellectual property – including but not limited to patents, software, and other copyrighted materials, brands, and trademarks – is among our most valuable assets. The protection of our intellectual property is taken very seriously by complying with our policies and procedures and providing guidelines for the use of our intellectual property. We respect the intellectual property rights of others and expect third parties to respect ours as well. We will take appropriate action against third parties that infringe on our intellectual property rights.

Respect for trade secrets and confidential information

Our confidential information, including but not limited to know-how, trade secrets, customer-, business partner- and employee data, is another valuable asset. We are committed to protect this information with the highest standard of security and use this information only in an appropriate manner. We respect the confidential information of others and do not tolerate the unauthorized use of such confidential information.

V. We encourage you to communicate and speak up

We ask for your help to identify areas for improvement or concerns by reporting suspected violations of policies, laws, or regulations that govern our operations. We encourage LUMIs to report any misconduct through the normal reporting channels and maintain an open dialogue within LUMICKS. However, a LUMI may feel unable or uncomfortable raising a concern through the normal reporting channels. To this end, we have established a Speak Up policy that encourages LUMIs and business partners to report suspected or actual occurrences of fraudulent, unethical, or inappropriate events. This policy enables LUMIs and business partners to (anonymously) report concerns without retribution and enables us to address and correct improper conduct and actions. We prohibit retaliation against anyone reporting or participating in an investigation linked to a possible violation of our Code, relevant policies, or the law.

Living the Code to maintain the highest ethical standards

Respect the law

Apart from our policies and standards, you must honor the language and spirit of the law of every nation, including international legislation, industry standards, global and local policies.

Encourage integrity

We promote a culture of integrity through mutual respect, trust, and high standards of ethics in all our business activities. We avoid any conduct that potentially harms or contributes to damaging our integrity, and we discourage actions or behavior that may lead to a conflict with our integrity.

Be accountable

We hold each other accountable to this Code, and we expect and ask from our LUMIs, as well as our business partners, to promptly report any indication of a potential violation.

Set an example

By being honest and fair, we set an example for each other and others. What you reap is what you sow. In other words, we believe that treating others with honesty and fairness will reciprocate to us.

Where can I go for advice and guidance on our Code?

You are not alone! We have processes, guidance and procedures in place to help you follow this Code. Take advantage of the breadth of capabilities, resources and expertise that exist globally within LUMICKS, including:

1. Managers

Who are available to answer questions and are generally most familiar with LUMICKS’ guidelines that apply to your business activities.

2. HR

Who can explain and answer questions about employment policies, benefits and workplace issues.

3. The Legal Department

Who can help explain and interpret this Code and can provide guidance about how to conduct business on behalf of LUMICKS in compliance with the law.

4. The Ethics Officers

Who are your point of contact to raise concerns about suspected misconduct, for example if you prefer not to raise a concern with your line manager. They are there for you to discuss your concerns in confidence and advise on any next steps.

5. The Speak Up Service

Which is available 24 hours a day, 7 days a week. It is independent, secure and confidential. It provides an online tool for anyone (including employees, business partners, customers, and others) to report potential violations of the Code, other LUMICKS policies or applicable laws and regulations in our countries of operation. To file a concern online, please visit the Speak Up Service’s website at lumicks.integrityline.com where you can fill in a form to submit your concern.