Code of conduct

We take our obligations seriously. See below how.

1. Purpose and scope

1.1. Purpose

This Code of conduct sets out essential rules and provides guidelines to ensure that all LUMIs and our business partners act with honesty and trust, as well as comply with the laws, regulations, and policies that govern us. Our daily business operations are built upon and supported by the principles and values laid down in this Code of conduct. The Code serves as a moral compass, containing examples of actions as well as explanations of the issues we must be aware of when carrying out our daily business activities.

1.2. Scope

The Code of conduct outlines standards for ethical behavior by LUMIs and business partners. We have set out four fundamental principles and 14 key risk areas, each explained in detail. We all share the responsibility and commitment to comply with the Code of conduct. The Code applies to directors, managers, and employees. We will strive to have our business partners, such as suppliers, agents, and other contractors committing to the same values and principles as those presented here.


2. The fundamental principles of LUMICKS’ Code of conduct

2.1. 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.

2.2. 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.

2.3. 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 of it.

2.4. 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.


3. LUMICKS’ way of business

3.1. Conflict 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 supervisor to confirm whether a specific situation is considered a conflict of interest or not.

3.2. Bribery prevention

We are committed to integrity, and we will only engage in business activities with reputable third parties who share this commitment. 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.

3.3. 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.
– all applicable laws and regulations regarding:

– terrorist financing
– facilitation of tax evasion
– export regulations

We only engage with parties involved in legitimate business activities, with funds derived from legitimate sources.

3.4. 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.

3.5. Compliance with law and regulations

We will comply with applicable laws 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.

3.6. 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.

3.7. 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 of conduct.


4. Respecting LUMIs and the community

4.1. 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.

The description above leads to our three core principles:

– DIVERSITY: We strive to create diverse teams and make employment decisions on job qualifications, and legitimate business considerations, without discriminating. When multiple candidates qualify equally, we will choose for candidates that add to our diversity, whether that is culture, ethnical background, religion, sex, sexual orientation, etc.
– INCLUSION AND BELONGING: We treat others with respect, dignity and fairness, and expect others to do the same
– EQUITY: We are committed to fair treatment of all LUMIs and people who seek employment at LUMICKS; thus creating equal opportunities for development and advancement.


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. The variety in backgrounds, cultures, languages, thoughts, and ideas of our employees make us who we are and helps us maintain a competitive advantage. We are committed to preventing any discrimination at LUMICKS, and we arrange our hiring and developmental processes to remove any possible barriers for marginalized groups.

Inclusion and belonging

Our goal is to make sure that people from different backgrounds feel valued and welcomed at LUMICKS. We believe that a truly inclusive workplace allows everyone to feel safe and relaxed about their identity and be recognized as a valuable member of the team.

We work to create an environment that is open-minded, respectful, and accepting of all. We value different perspectives and actively invite LUMIs to share new ideas and ways of working, which contribute to realizing our full potential. We use tools and processes that allow us to continuously reflect on how people with different identities experience their day-to-day work. We assess how new company policies and processes at LUMICKS may affect members of our team to prevent any negative impact. We encourage open feedback, but also ensure there are safe channels to share sensitive feedback anonymously.

This principle demands that we, amongst other things:

– Treat each other with courtesy and respect.
– Communicate to each other in a professional manner.
– Give directions in a professional and courteous manner.
– Acknowledge effort and good performance wherever possible.
– Maintain confidentiality when the situation demands it.
– Avoid spreading rumors and gossip about others.
– Respect the privacy rights of all individuals.
– Avoid discriminatory behavior of any kind.
– Follow all reasonable directions from those in authority.
– Act in a socially acceptable manner that acknowledges the diversity of our employees.
– Progress any complaints about employee behavior using the appropriate procedures.


Equity is about equal opportunity and equal distribution. LUMICKS is committed to provide LUMIs with what they need, in order to make things fair. It is simply providing more or different things to those who need it, which is proportionate to their own circumstances, in order to ensure that everyone has the same opportunities.

We seek to identify imbalances and create fair and equitable processes across all facets of our organization, ranging from hiring, firing, promoting, and assigning tasks to celebrating successes, running meetings, or making introductions. We continuously improve our performance and management processes to ensure that all LUMIs have the opportunity to grow, contribute, and develop — regardless of their identity or background.

Our values of equity equally applies to our interactions with external stakeholders, including customers, suppliers, and contractors. It also extends to events or incidents outside the workplace or work time that may impact work relationships and standards.


LUMIs are expected to stand by the principles outlined above and contribute to our diverse and inclusive work environment and in their dealings with customers, business partners, candidates. If a LUMI feels bullied, discriminated, intimidated, harassed, or otherwise mistreated by anyone at LUMICKS or a third party (such as customers and business partners), we strongly encourage the person to make this clear to the one conducting such behavior. If a LUMI feels unable to do so, we strongly encourage the person to immediately report the incident to either HR or the respective supervisor. Complaints will be promptly and thoroughly investigated, and appropriate action will be taken.

4.2. 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.

We will not tolerate:

– Threats or intimidation of others, whether physically or verbally.
– Acts of vandalism, arson, or other criminal activities.
– Weapons within LUMICKS’ premises unless specifically authorized by the company and subject to applicable law.

4.3. 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 comply with all applicable laws pertaining to fair employment practices, freedom of association, privacy, 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.

Each of us can help support efforts to eliminate human rights abuses:

– Report any suspicion or evidence of human rights abuses in our operations or in the operations of our business partners to your manager, or e-mail to
– Remember that respect for human dignity begins with our daily interactions with one another,our customers, and business partners. It also includes promoting diversity and inclusion, accommodating disabilities, and doing our part to protect the rights and dignity of everyone with whom we do business.

4.4. 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. You can find more information about these safeguards in our privacy policy:

4.5. Whistle-blower policy

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 (i.e., immediate or next higher-level manager) 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 whistle-blower 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. If you suspect fraudulent, unethical, or other inappropriate events, you can report these to Your report will be taken seriously and treated with the utmost discretion.


5. Protecting LUMICKS’ assets

5.1. 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.

5.2. 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