Sathom

SATHOM

Valid from January 1, 2021 • Revision 0.01

Foreword

At SATHOM, we are committed to conducting our business with the highest standards of integrity, ethics, and professionalism. This Code of Conduct outlines the principles and standards that guide our behavior and decision-making processes.

Every employee, contractor, and business partner is expected to understand and comply with this Code, as well as all applicable laws and regulations in the jurisdictions where we operate.

We believe that by maintaining these high standards, we not only protect our company's reputation but also contribute to building trust with our customers, suppliers, and the communities in which we operate.

Michael Arnac
CEO
Waldenburg, January 2021

1. Confidentiality and Information Security

SATHOM recognizes the critical importance of protecting confidential information and maintaining the highest standards of data security and privacy.

2.1 Confidentiality Obligations

All employees must protect confidential information belonging to SATHOM, our customers, suppliers, and business partners. This includes technical data, business strategies, financial information, and any other proprietary information.

2.2 Data Protection and Privacy

We are committed to protecting personal data and respecting privacy rights in accordance with applicable data protection laws and regulations, including GDPR where applicable.

2.3 Information Technology Use

Company IT systems and resources must be used responsibly and in accordance with established policies. Personal use should be minimal and must not interfere with work responsibilities.

3. Business Ethics and Compliance

3.1 Business Conduct

SATHOM conducts business with integrity, honesty, and in full compliance with all applicable laws, regulations, and industry standards.

3.1.1 Import Regulations

We strictly comply with all import regulations and customs requirements in the countries where we operate, ensuring proper documentation and declaration of all goods and materials.

3.1.2 Export Controls

We adhere to all export control laws and regulations, including dual-use technology restrictions and embargoed countries lists, to ensure responsible international trade.

3.1.3 Conflict Minerals

SATHOM is committed to responsible sourcing and works to ensure that our supply chain does not contribute to conflict or human rights abuses through the use of conflict minerals.

3.1.4 Counterfeit Parts Prevention

We maintain strict controls to prevent counterfeit parts from entering our supply chain, implementing robust verification and traceability procedures for all components.

3.2 Conflicts of Interest

Employees must avoid situations where personal interests could conflict with company interests and must disclose any potential conflicts to management.

3.3 Gifts and Entertainment

Gifts and entertainment must be reasonable, appropriate, and in compliance with company policy and applicable laws. Any gifts of significant value must be reported and approved.

3.4 Anti-Corruption and Bribery

SATHOM has zero tolerance for corruption, bribery, or any form of improper payments. All business must be conducted through legitimate and transparent means.

3.5 Complaints and Reporting

We encourage the reporting of any suspected violations of this Code or applicable laws through appropriate channels, and we prohibit retaliation against those who report in good faith.

4. Company Values and Workplace Standards

4.1 Health and Safety

We are committed to providing a safe and healthy work environment for all employees, contractors, and visitors, and we comply with all applicable health and safety regulations.

4.2 Equal Opportunity and Non-Discrimination

SATHOM promotes equal opportunity and does not tolerate discrimination or harassment based on race, gender, religion, nationality, age, disability, or any other protected characteristic.

4.3 Company Property and Resources

Company property and resources must be used responsibly and for legitimate business purposes. Theft, misuse, or waste of company resources is strictly prohibited.

4.4 Environmental Responsibility

We are committed to environmental stewardship and sustainable business practices, striving to minimize our environmental impact through responsible operations and continuous improvement.

5. Implementation and Compliance

This Code of Conduct applies to all SATHOM employees, officers, directors, contractors, and business partners. It is each individual's responsibility to understand and comply with this Code.

Violations of this Code may result in disciplinary action, up to and including termination of employment or business relationships, and may also result in civil or criminal liability.

This Code is reviewed regularly and updated as necessary to reflect changes in laws, regulations, and business practices. All updates will be communicated to relevant stakeholders.