Code of Conduct

As members of the Holos Group workforce, the communities in which we operate are all affected by our actions, and benefit when we do the right thing. Without guiding principles it is not always easy to identify the right path - or, once we identify it, to follow it. That is why we need them.

The Holos Code of Conduct is one of the ways we put our values into practice. It is built around the recognition that everything we do in connection with our work will be, and should be, measured against the highest possible standards of ethical business conduct. Neither the code nor any of its principles, practices or procedures creates contractual rights; each of us has a personal responsibility to incorporate - and to encourage others to incorporate - its principles into our work. If you ever think that a colleague, or the company as a whole, may be falling short of our commitment, don't be silent: we want and need to hear from you.

Who must follow our code?

We expect all employees and board members to know and follow the code; failure to do so can result in disciplinary action, up to termination. We also expect contractors, consultants and others temporarily assigned to work for Holos to follow the code in connection with that work.

Questions and concerns

If you have a question or concern, you can contact your manager, your Human Resources representative, or Ethics & Compliance. You can also raise a suspected violation through the Ethics & Compliance Helpline atethicsandcompliance@holos.pt. If you believe a violation of law has occurred, you may raise it through the helpline or with a government agency.

No retaliation

Holos prohibits retaliation against anyone who reports, or participates in the investigation of, a possible violation of our code, our policies or the law. If you believe you are being retaliated against, please contact Ethics & Compliance.

I. Serve our users

Users value Holos not only because we deliver great products and services, but because we hold ourselves to a higher standard in how we treat them.

1. Integrity

Our reputation as a company users can trust is our most valuable asset. All of our communications and interactions should increase that trust.

2. Usefulness

Our products, features and services should make Holos more useful for all of our users, guided by one principle: is what we are offering useful?

3. Privacy, security and freedom of expression

We are asking users to trust us with their personal information. Each of us must respect and protect the privacy and security of that information, and collect, use and access it only as authorised by our security and privacy policies and applicable data-protection laws. Holos is committed to advancing privacy and freedom of expression for users around the world.

4. Responsiveness

Part of being useful and honest is being responsive: we recognise relevant user feedback and act on it. If something is broken, fix it.

5. Take action

Any time you feel our users aren't being well served, let someone in the company know. Improving our products and services takes all of us.

II. Support each other

We are committed to a supportive work environment, free of harassment, intimidation, bias and unlawful discrimination, where everyone can reach their fullest potential.

1. Equal opportunity employment

Employment is based solely on individual merit and qualifications. We strictly prohibit unlawful discrimination or harassment on the basis of race, colour, religion, veteran status, national origin, ancestry, pregnancy, sex, gender identity or expression, age, marital status, disability, medical condition, sexual orientation or any other characteristic protected by law.

2. Harassment, discrimination and bullying

Holos prohibits discrimination, harassment and bullying in any form - verbal, physical or visual. Report any incident to your supervisor, Human Resources, or both; HR will promptly and thoroughly investigate and take appropriate action.

3. Drugs and alcohol

Substance abuse is incompatible with the health and safety of our employees and is not permitted. Use good judgement and never let alcohol lead to impaired performance or endanger others. Illegal drugs in our offices or at sponsored events are strictly prohibited.

4. Safe workplace

We are committed to a violence-free workplace and will not tolerate violence or its threat. Under no circumstances should anyone bring a weapon to work. Report any violation to Human Resources immediately.

III. Avoid conflicts of interest

A conflict of interest arises when competing loyalties could lead you to pursue a personal benefit at the expense of Holos or our users. Avoid conflicts and circumstances that reasonably present the appearance of one. If you are considering an action that creates a conflict, don't; if you are already in such a situation, review it with your manager and Ethics & Compliance. Conflicts often arise in seven areas:

• Personal investments in competitors or business partners that might cause, or appear to cause, you to act against Holos's interests.
• Outside employment, advisory roles, board seats and your own business - notify your manager before accepting a board seat, and do not start a business that competes with Holos.
• Business opportunities found through work belong first to Holos, except as otherwise agreed.
• Inventions related to Holos's products, your role, or developed with company resources may create conflicts and be subject to your employment agreements.
• Friends and relatives; co-worker relationships - avoid managing or deciding on Holos business relationships that involve relatives, partners or close friends.
• Gifts, entertainment and business courtesies - acceptance of inexpensive token items is generally fine, but anything significant can create the appearance of a conflict.
• Use of Holos products and services in a way that improperly benefits you or someone you know, or creates the appearance of an unfair advantage.

IV. Preserve confidentiality

Certain company information, if leaked prematurely, can harm our product launches and competitive advantage. Beyond not revealing confidential Holos material, we must securely store, label and dispose of it, safeguard confidential information received from others under non-disclosure agreements, and protect our trade secrets and intellectual property.

• Confidential information classified as "Need to Know" or "Confidential" must be handled per our data-classification guidelines and disclosed only as needed and under a non-disclosure agreement.
• Holos partners - do not disclose confidential information received from partners, and accept it only under an approved NDA.
• Competitors and former employers - we compete fairly and do not want their confidential information.
• Outside communications must not disclose confidential proprietary information or imply you speak for Holos unless authorised.

V. Protect Holos's assets

Our ability to remain open with information internally depends on how well we conserve resources and protect company assets.

• Intellectual property - respect copyright, trademark and other IP laws, and never use Holos's marks for outside ventures without pre-clearance from Marketing. We comply strictly with open-source licence requirements.
• Company equipment - funds, equipment and physical assets are not for purely personal use.
• The network - follow all security policies and promptly report any suspected breach (a lost device, a compromised password).
• Physical security - secure your equipment and belongings, don't disable safety devices, and report suspicious activity.
• Use of facilities - anything done on corporate facilities or stored on our premises may be disclosed, including where required by law.

VI. Ensure financial integrity and responsibility

The money we spend on behalf of Holos is the company's and, ultimately, our shareholders'. Everyone - not just Finance - helps ensure money is spent appropriately, records are complete and accurate, and internal controls are honoured.

• Spending Holos's money - make sure costs are reasonable, related to company business and supported by documentation.
• Signing a contract - only when authorised, approved by the board, and after you understand its terms. All contracts are in writing; Holos does not permit side agreements.
• Recording transactions - be familiar with applicable policies and report anything not recorded correctly.
• Reporting irregularities - never interfere with audits or falsify records; report any irregularity to Ethics & Compliance.
• Hiring suppliers - strive for the best deal for Holos, usually by soliciting competing bids and weighing quality and reliability.
• Retaining records - keep records for the appropriate length of time per the Records Retention Policy and any legal requirements.

VII. Obey the law

Each of us is expected to comply with applicable legal requirements. Several laws are easy to violate unintentionally:

• Trade controls govern where Holos can send or receive products and services.
• Competition laws prohibit arrangements that restrain trade, abuse of IP rights, and the use of market power to unfairly disadvantage competitors.
• Insider-trading laws - never use non-public information to trade, or pass it to others to do so.
• Anti-bribery and anti-corruption laws - don't bribe or corrupt anybody, anytime, for any reason.
• Non-government and government relationships - keep gifts and courtesies infrequent and moderate, and never offer anything of value to a government official to influence official action.
• Facilitation payments are not allowed at any time, for any reason.

VIII. Conclusion

It's impossible to spell out every ethical scenario. Instead, we rely on one another's good judgement to uphold a high standard of integrity. We expect all Holos workers to be guided by both the letter and the spirit of this code. If you aren't sure, ask your manager or Ethics & Compliance. And remember - be honest, and if you see something you think isn't right, speak up.