Optikos Corporation

Code of Conduct
November 2023

Optikos Purpose

Optics is what we do. And we do it all.

Optikos Mission Statement

Our mission is to provide a core competence in optical engineering that we can offer to our service customers and to leverage this core competence in optical engineering to support contract manufacturing of optically related assemblies and to develop a line of proprietary optically based products and technologies that we can market ourselves or license to others. Our objectives are to find opportunities that utilize our optical expertise that will yield high value to our customers and Optikos, to discern unmet needs that can be satisfied using optical technology, and to be the best at what we do.

Optikos Quality Policy

At Optikos, we recognize that our well-being depends on our reputation and that our reputation, in turn, depends on the quality of our products and services. We define quality as meeting or exceeding the requirements and expectations of our customers as well as the appropriate regulatory agencies. We strive to continually improve the effectiveness of the quality of our processes, products, and services through measurement of our quality objectives.

The Optikos Experience™

We strive to provide a thoughtful, gracious, and authentic experience for everyone who connects with Optikos. Clients, employees, suppliers, or service providers are all entitled to our attention and consideration when they interact with us. We want their experience to be a positive and memorable one.

We view Optikos as a premium brand, and that means we aim to provide our customers with nothing less than a premium experience.

But it doesn’t stop there. We want that experience to extend to anyone who is connected with Optikos – from suppliers to community members to professional organizations to fellow employees (and how we treat each other).

1 Introduction

This Code of Conduct (the “Code”) outlines the standards of integrity and responsible conduct that apply to everyone who works for or represents Optikos Corporation (“Optikos”). We believe that integrity is critical to our success and that it is not just the responsibility of our President and the senior team, but it is the responsibility of every Optikos employee.

1.1 — Ethics Code

Optikos will conduct business honestly and ethically wherever operations are maintained. We strive to improve the quality of our services, products, and operations and will maintain a reputation for honesty, fairness, respect, responsibility, integrity, trust, and sound business judgment. Our managers and employees are expected to adhere to high standards of business and personal integrity as a representation of our business practices, at all times consistent with their duty of loyalty to Optikos.

We expect that officers, directors, and employees will not knowingly misrepresent Optikos and will not speak on behalf of Optikos unless specifically authorized to do so. The confidentiality of trade secrets, proprietary information, and similar confidential commercially-sensitive information (i.e., financial or sales records/reports, marketing or business strategies/plans, product development, customer lists, patents, trademarks, etc.) about Optikos or its operations, or that of its customers or partners, is to be treated with discretion and only disseminated on a need-to-know basis (see policies relating to privacy).

1.2 — How to use this Code of Conduct

This Code is organized into seven (7) sections based on the tenets of The Optikos Experience:

with our Co-Workers
with Clients
with our Employees
with the Community
with Authorities
with Suppliers
with Professional Organizations

This Code addresses such topics as fostering a positive work atmosphere, handling business courtesies, using Optikos assets, avoiding conflicts of interest, maintaining confidentiality of information, and ensuring compliance with laws, among others. Section 9 of this Code provides resources available to you if you have questions or concerns.

1.3 — Who Must Follow this Code

All employees of Optikos are expected to carefully read and adhere to the policies set forth in this Code. As an employee, you must comply with this Code and are bound by this Code as a condition of employment. Employees include all individuals employed by Optikos on a regular or temporary basis, regardless of whether the individuals work on a full- or part-time basis.

We also expect all Optikos contractors, consultants, representatives, agents and others who may be temporarily assigned to work for or provide services to Optikos to comply with this Code in connection with any work or services performed on behalf of Optikos.

Optikos reserves the right to modify or revise this Code at any time, with or without notice, subject to applicable law. Please note that this Code does not set forth all policies and guidelines applicable to every Optikos employee.

1.4 — The Responsibility of Management

Optikos managers, including officer and director level employees and any employees who have supervisory responsibilities, have a special responsibility for instilling a culture of unwavering integrity, ethical business practices, and a commitment to The Optikos Experience.

Managers must lead by example and set a tone of absolute compliance. Managers cannot ignore Code violations or potential Code violations that they learn of through any means; rather, managers are required to report their concerns and the basis for their concerns to their manager and the Human Resources Manager.

1.5 — Making the Right Decisions

Compliance with applicable laws, this Code, corporate and local policies and The Optikos Experience may be confusing at times. If you are ever in doubt, ask yourself:

Is the action lawful?
Is the action consistent with The Optikos Experience?
Is my action, or that of another employee, responsible? Is it good for the business? Could it harm Optikos’ reputation? Am I setting a good example?
How would I feel if I read about my actions, or those of other employees, in a newspaper? What would my family, friends, managers or co-workers think?

If still in doubt, refer to Section 9 of this Code.

1.6 — Violations of this Code

Failure to comply with this Code may result in disciplinary action, up to and including termination of employment. The degree of discipline imposed may be influenced by the existence of voluntary disclosure of any ethical violation and whether or not the violator cooperated in any subsequent investigation.

Optikos, at its discretion, may take other appropriate action, such as training or revising of policies or processes. Optikos will terminate the services of contractors, consultants, and others who are assigned to work for, or provide services to, Optikos if they fail to comply with this Code.

2 The Optikos Experience – With Our Co-Workers and in Our Workplace

We must remain a high-integrity organization that satisfies customers, values each employee, and performs responsibly. We strive to be the best place to work in our industry as determined by our employees. There are many aspects to this vision, including how we treat and respect each other. The following section of this Code, The Optikos Experience – With Our Co-Workers and in Our Workplace, outlines what is expected from each of us in our personal conduct and treatment of others. More information can be found in the Optikos Employee Handbook.

2.1 — Health & Safety

Your safety is important to many people: your family, your co-workers and your community. Optikos complies with all safety laws and believes that safety comes before anything else. We recognize that the work that we perform and the environment in which we work may have health and safety risks. It is the responsibility of all Optikos employees to maintain a healthy and safe work environment, know and comply with all safety standards, laws and regulations that apply to their jobs, report any health or safety hazards, and follow Optikos’ health and safety rules. Employees should never take risks that could endanger themselves or others in doing their jobs. All occupational illnesses or injuries should be reported to your manager as soon as reasonably possible and an occupational illness or injury form be completed on each reported incident.

We strive to eliminate accidents in all of our facilities by ensuring a safe and healthy work environment for all employees and others on our sites, and by looking for ways to continuously improve. Our written Safety Procedure provides guidelines for protecting Optikos’ employees and equipment, defines the roles and responsibilities for workplace safety and material handling, documents the procedures for managing and reporting workplace accidents, and provides a means for reporting unsafe conditions and situations. The Safety Procedure is provided to employees upon hire and is located in the Optikos PDMVault.

If you have any safety concerns, bring them to the attention of your manager, the Human Resources Manager, or anyone else on the senior team. Additional information on avenues to raise your concerns can be found in Section 9 of this Code.

2.2 — Diversity & Inclusion

Optikos is committed to fostering, cultivating, and preserving a culture of diversity and inclusion. We believe that each employee brings different experiences and perspectives, as well as a unique set of abilities to Optikos and that the best place to work is characterized by an appreciation of our employees’ diversity in all its forms. This diversity in background and creativity of people and ideas provides us with a competitive business advantage, which will help us grow and expand into new markets. We believe that by hiring the best people we can find that understand and embrace what we intend The Optikos Experience to be, we can make Optikos more successful in the marketplace, increase our ability to innovate, be more responsive to our customers, and become an even better place to work for our employees.

2.3 — Discrimination & Fair Treatment

Optikos is dedicated to providing a positive work environment where everyone is treated with respect, dignity, and fairness. Discrimination or retaliation against employees on any basis will not be tolerated. Our working relationships need to reflect our commitment to fairness and respect, and be businesslike and free of any bias or prejudice.

As an equal opportunity employer, Optikos is committed to treating all employees and applicants for employment with respect and dignity and maintaining a workplace that is free from unlawful discrimination. We recruit, hire, develop, promote, discipline, and provide other conditions of employment without regard to race, color, religion, national origin, gender, age, disability, sexual orientation, or any other status protected by local, state, or federal law. We also provide reasonable accommodations to qualified employees and applicants as required by law.

For more information about the commitment of Optikos to equal employment opportunity, please see the Optikos Employee Handbook provided upon hire. If you believe that you have been subjected to discrimination in violation of our policy, including retaliation, please contact your manager. If you feel uncomfortable or believe your manager is or could be involved in the misconduct, there are several other resources available to you. Contact information may be found in Section 9 of this Code, as well as in the Optikos Employee Handbook.

2.4 — Workplace Harassment, Bullying & Violence

Optikos values a working environment where everyone is welcome and diversity in our employees is highly respected. We will not tolerate harassment, bullying, or violence of any type, including physical and emotional, that targets an individual’s race, gender, sexual orientation, religion, disability, age or other protected personal characteristics. This extends to colleagues, suppliers, customers, and anyone else who does business with Optikos. This prohibition also extends beyond the workplace, to any work-related setting, such as business trips, meetings and related social events, and on electronic media, including blogs, texting, instant messaging, and social media. Harassment is contrary to our values, creates an offensive and otherwise harmful work environment, and interferes with work performance.

Employees are encouraged to immediately report to their managers any concerns of observed or suspected harassment, bullying or violence. However, if you feel uncomfortable or believe your manager is involved in the misconduct, there are several other avenues available to you. Contact information may be found in Section 9 of this Code, as well as in the Optikos Employee Handbook provided upon hire.

We treat complaints of discrimination, retaliation, harassment, bullying or violence very seriously, and all reported complaints will be promptly and thoroughly investigated. To the extent possible, confidentiality will be maintained throughout the investigatory process. Employees will not be subject to retaliation for making a good faith complaint or participating in an investigation.

2.5 — Use of Drugs or Alcohol

Optikos cares about the health and safety of our employees. Employees are expected to comply with Optikos’ guidelines regarding alcohol, drugs, and smoking, whether it is in the workplace, at Optikos-sponsored events, or while conducting Optikos business. Employees are not permitted to be under the influence of any legal or illegal drug that impairs their ability to perform their job, and are prohibited from manufacturing, soliciting, distributing, possessing, or using any illegal drugs or substances in the workplace, or while working. Employees should use good judgment and keep in mind that they are expected to perform to their full ability at work. For more information, see the Optikos Employee Handbook.

2.6 — Personal Conduct

Being the best place to work takes commitment from each of us, every day. Our personal conduct has a direct impact on the reputation of Optikos and should never be taken for granted. The way we conduct ourselves in the workplace or in any other work-related setting, including while on business trips, at business meetings and at business-related social events, directly affects the reputation of Optikos. Care should also be taken when presenting yourself online and in web-based forums or networking sites. Each employee is expected to follow this Code and exercise good judgment in their decisions and actions. Employees are expected to conduct themselves in a responsible, respectful, and honest manner at all times.

3 The Optikos Experience – With Our Clients

Our employees must conduct business with transparency that can stand the test of a reasonable person’s scrutiny. Optikos strives to be the most customer-responsive company in the industry as determined by our customers. We are driven by our mission to provide customers with value-added offerings that exceed their current and future needs. We will achieve this by competing fairly, with the highest level of integrity, in every market where we operate. This is integral to our Mission and Quality Policy and key to our long-term success. The following section of this Code, The Optikos Experience – With Our Clients, outlines what is expected from each of us to accomplish this.

3.1 — Commitment to Product Quality & Safety

Being a responsible corporate citizen requires that we provide quality products that are safe to use. The products manufactured by Optikos should meet all applicable laws, regulations and standards for use in their markets. To accomplish continual improvement of our products and services, we listen to our customers and strive to exceed customer expectations at every opportunity. By doing this, we believe our customers will view us as the most customer responsive company in the industry.

3.2 — Fair Dealing

We operate with integrity in the marketplace and compete based on the merits of the products we produce and the services we provide. We deal honestly and fairly with our customers, suppliers, employees, distributors, business partners, competitors and other stakeholders. Employees must never misrepresent facts, conceal information, abuse confidential information or use manipulation to obtain an unfair advantage when conducting business on behalf of Optikos.

3.3 — Antitrust & Fair Competition

We are committed to competing honestly and fairly and we support and comply with all antitrust and fair competition laws in all markets where we do business. Antitrust and fair competition laws vary by country, but all are designed to stop competitors from creating agreements that prevent, restrict or distort the exercise of free competition. All Optikos employees and third parties acting on behalf of Optikos must strictly adhere to the letter and the spirit of these laws. This means Optikos employees are prohibited from:

working with competitors to fix prices or to allocate markets or customers, and
setting, dictating or controlling the resale prices set by Optikos distributors or other customers.

In situations where employees may be more likely to interact with competitors, such as at trade shows, conventions, trade association meetings or other industry events, it is important that even the appearance of impropriety is avoided. Sometimes even innocent conversations or actions can be misconstrued.

Violating antitrust and fair competition laws can result in criminal prosecution, as well as significant financial penalties. If you have a question or would like additional information, contact your manager or the President. Additional resources may be found in Section 9 of this Code.

3.4 — Gifts

Sales personnel, trade-marketing, special events and other employees work closely with existing or potential clients to understand the customer’s needs and gain their trust. It is common and appropriate for Optikos employees to participate in recreational activities or social events hosted by a company with whom Optikos has an active or developing relationship, provided such activities are of modest value and appropriate taste.

Optikos employees must behave transparently and honestly at all times when engaging in activities with customers in order to not violate any established guideline with this Code.

Optikos employees shall not solicit or accept for personal benefit directly or indirectly any gift, loan, discount or any item of monetary value from any person or company that is seeking to conduct or is currently conducting business with Optikos. Gifts received that are not consistent with this Code will be evaluated by Optikos to determine if they can be used internally, sold, or donated. Ownership and final disposition of these types of gifts will belong to Optikos.

If you are uncertain about the appropriateness of accepting gifts, inviting, or participating in any event and/or activity with a customer, you should consult with your manager or the President, as necessary, so as to not violate any provision established by this Code.

3.5 — Corruption

We choose to be a leader in ethical behavior and operate with integrity. We comply with all applicable anti-corruption laws. Optikos will not condone, under any conditions, the offering, authorizing or receiving of bribes, kickbacks or any other improper payment for the purpose of obtaining or retaining business for Optikos or for any other reason relating to our business. You must never accept, give, or promise anything that could be interpreted as intending to improperly influence a commercial or governmental transaction. The use of intermediaries, agents, contractors, distributors, freight forwarders or other third parties, subsidiaries or joint ventures to do what Optikos itself cannot do, is prohibited.

Anti-corruption laws and Optikos policy prohibiting corrupt activities applies in all countries where we do business. Violating these laws can result in criminal prosecution, as well as significant financial penalties. For more detailed information, refer to the Optikos Employee Handbook. If a bribe or kickback is requested from or offered to you, immediately contact your manager, the Human Resources Manager, or the President. Additional resources may also be found in Section 9 of this Code.

3.6 — Trade Controls

Various trade laws control where we can send or receive our products and services, as well as travel or conduct business. These laws are complex and apply to:

Importing and exporting goods to or from the United States and other countries.
Exporting services or providing services to non-U.S. persons.
Exporting technical data, especially data originating in the United States.
Travel restrictions to certain countries and regions.

If you are involved in sending or making available products, services, software, equipment, or technical data from one country to another, work with your manager and the Director of Operations to ensure that the transaction stays within the bounds of applicable laws.

You should familiarize yourself with Optikos’ export compliance manual. If you or your manager are not sure, contact the Director of Operations or the President.

4 The Optikos Experience – With Suppliers

At Optikos we hold ourselves to the highest ethical standard. We expect our suppliers to abide by all applicable federal, state, and local laws/regulations in the market in which they operate and adhere to high standards of safe working conditions, fair and respectful treatment of employees, and ethical business practices. The following section of this Code, The Optikos Experience – With Suppliers, outlines what is expected from each of us to accomplish this.

4.1 — Transactions & Relationships with Suppliers

Operating with a high level of integrity means we choose our suppliers objectively, based on criteria such as safety, quality, delivery, total cost of service, and the supplier’s reputation. We base our supplier relationships on principles of fairness and mutual respect. We believe in doing business only with suppliers who share our high standards of business conduct and expect that our suppliers will demonstrate a steadfast commitment to the health and safety of their workers, and operate in compliance with human rights laws.

Transactions must adhere to usual market terms and specific policies and procedures in relation to the purchase of goods and services by Optikos. Providers of goods and services must comply with established policies and procedures, as well as agree to keep transactions with Optikos confidential, unless disclosure has been approved by authorized personnel within Optikos or legal requirements. Employees responsible for the relationship with a supplier may never mislead a supplier into thinking they may unduly influence a purchase decision for Optikos. Regarding business offerings towards a supplier, Optikos employees may not offer nor suggest any business or service may be interrupted or granted in exchange for said business. Real or apparent conflicts of interests must be avoided and proactively disclosed during the purchase process. In cases of existing relationships that could cause a real or perceived conflict of interest, an employee must disclose such relationships immediately, even if a commercial agreement is not currently in place.

Information related to purchases by Optikos is confidential. It may only be shared internally with employees designated by authorized personnel and may not be shared outside Optikos unless authorized.

5 The Optikos Experience – With Our Employees

We will not sacrifice integrity for profits at Optikos under any circumstances. We will not look the other way when faced with questionable situations – we have to do the right thing.

As an organization, we are focused on serving customer needs while also creating the best place to work in our industry. We have responsibilities to deliver on our commitments as we strive to be a superb operating company. The following section of this Code, The Optikos Experience – With Our Employees, describes what is expected of employees to help meet this goal.

5.1 — Accounting & Financial Reporting

All Optikos books, records, and accounts shall be maintained in accordance with all applicable regulations and standards and accurately reflect the true nature of the transactions they record. The integrity of our financial transactions and records is critical to the operation of our business and is a key factor in maintaining the confidence and trust of our employees, clients, and others stakeholders.

Optikos requires that all transactions be properly recorded, classified, and summarized in its financial statements, books, and records in accordance with its policies, controls, and procedures, as well as all generally accepted accounting principles, standards, and applicable laws. If you have responsibility for, or any involvement in, financial reporting or accounting, you should have an appropriate understanding of, and you should seek in good faith to adhere to, relevant accounting and financial reporting principles, standards, applicable laws, and Optikos’ financial and accounting policies, controls, and procedures. In addition, you must abide by Optikos’ Delegation of Authority Matrix (Form AD-02), as it is the basis for your authority to act on behalf of Optikos. If you are a senior manager, you should seek to ensure that the internal controls and procedures in your business area are in place, understood, and followed. Even if you are not directly involved in financial reporting or accounting, you are likely involved with financial records or reports of some kind, e.g., time sheet, invoice, or expense reports. In addition, most employees are involved with product, marketing, or activities that can affect Optikos’ financial condition. Therefore, Optikos expects you, regardless of whether you are otherwise required to be familiar with finance or accounting matters, to use all reasonable efforts to ensure that every business record or report with which you deal is accurate, complete, and reliable.

5.2 — Fraud & Misrepresentation

Fraud involves deliberate, intentional deception or misrepresentation of information. As an organization of high integrity, engaging in any type of fraudulent activity at Optikos is never acceptable. The stage is set for fraud to occur whenever there is pressure to deliver to the high expectations of our clients or management. When this pressure is on, we need to be on our highest guard. Even with the best intentions, some might believe that “making the numbers” is more important than performing accurate tests and recording accurate facts, or that by covering up problems, it actually helps Optikos “look good.” This is simply not the case.

Most fraud can be avoided by carefully following the systems and controls designed to prevent individuals from having total control over money, supplies or records. When you learn of a potential fraud, the fastest way to stop it is to report it promptly. If you discover anything fraudulent, do not try to cover it up. Optikos will be in a much better position to correct the problem early on than if it is hidden and discovered later.

Report any fraudulent activity or concerns of fraudulent activity to your manager and to the Director of Finance and Administration. Additional resources are also set forth in Section 9 of this Code.

5.3 — Conflicts of Interest

Optikos is concerned with conflicts of interest that create actual or potential job-related concerns, especially in the areas of confidentiality, customer relations, safety, security, and morale. All employees are expected to act in the best interest of Optikos at all times and be aware of potential conflicts of interest. A conflict of interest occurs when our private interests interfere in any way with the interests of Optikos.

Actual conflicts – as well as the appearance of conflicts – must be avoided. Some examples include:

Having a personal financial interest in a supplier, customer, competitor, or distributor.
Having a close family member (e.g., spouse, parent, sibling, child or in-law), or anyone you treat like a family member (e.g. fiancé, domestic partner or domestic partner of a family member), work for or have a financial interest in a supplier, customer, competitor, or distributor.
Receiving any form of compensation from a supplier, customer, competitor, or distributor.
Having a personal interest or potential for gain in any Optikos transactions.

If a change in personal relationships occurs for current employees that results in an actual or potential conflict of interest, Optikos will make reasonable efforts to minimize problems of supervision, safety, security or morale through reassignment of duties, relocation or transfer.

Optikos employees are expected to devote their full working time and attention to their duties for Optikos. Outside business activities or investments are permitted only if they do not involve cooperating with or becoming a competitor, customer, or vendor of Optikos. Outside business activities may be conducted during non-working hours only and cannot interfere with the employee’s satisfactory work performance.

In addition, Optikos property and information or your position with Optikos should never be used for personal gain, nor should you take advantage of a business opportunity for yourself that is discovered because of your job with Optikos.

If there is any actual or potential conflict of interest between you and a competitor, supplier, distributor, or contractor to Optikos, you must disclose it to your manager. If an actual or potential conflict of interest is determined to exist, Optikos will take such steps as it deems necessary to reduce or eliminate this conflict.

5.4 — Protecting Company Assets

We are all responsible for safeguarding tangible and intangible Optikos assets, as well as assets under your control that are owned by customers or suppliers, ensuring their appropriate usage based on the guidelines established in this Code. Optikos assets may only be used for legitimate purposes and/or activities. Undue appropriation, neglecting, or squandering of Optikos assets is a violation of your duties and may be considered fraud.

All ideas, methods, inventions, discoveries, and developments, whether patentable or not, that relate to your work with Optikos and are conceived by you solely or with others are the property of Optikos.

All economic rights over any invention, improvement, or discovery made by employees in their jobs are Optikos’ property. These must be disclosed to your manager when they take place. When the employment relationship with Optikos ends, Optikos keeps ownership of rights and information generated or obtained as part of your job.

Partial or full reproduction, sale, use or distribution of information, software and other forms of intellectual property in violation of license terms and copyright, is prohibited.

You must not gain financial benefits derived from tangible or intangible assets or information you may possess because of your position at Optikos. Misuse of Optikos assets may be considered theft and you may be subject to termination of employment and criminal prosecution.

Except in circumstances prohibited by law, Optikos reserves the right at all times and without notice, to inspect Optikos assets in order to determine if they are being used according to the guidelines established in this Code and/or in any internal policy or procedure Optikos may have published, or to promote occupational safety or compliance with applicable laws.

5.5 — Confidentiality and Nondisclosure of Trade Secrets

As a condition of employment, Optikos employees are required to protect the confidentiality of Optikos trade secrets, proprietary information, and confidential commercially-sensitive information (i.e. financial or sales records/reports, marketing or business strategies/plans, product development, customer lists, patents, trademarks, etc.) related to Optikos. Access to this information should be limited to a "need to know" basis and should not be used for personal benefit, disclosed, or released without prior authorization from management. If Optikos’ confidential information will be shared with another company or with an individual from outside of Optikos, that person or company must sign a confidentiality agreement.

It is also always important to use discretion in discussing or communicating any confidential information. Be particularly careful when using the phone, fax, e-mail or other electronic means of storing and sending information, and do not discuss confidential information in public places where others may overhear.

Be aware that even when your service to or employment with Optikos ends, you still have an obligation not to disclose or in any way provide Optikos’ confidential and proprietary information to other parties.

We must also respect the intellectual property rights of others. We will not use materials of external parties in a manner inconsistent with the rules governing intellectual property rights, including copyrights. Unauthorized use of others’ intellectual property can expose Optikos and even individual employees to civil lawsuits and damages.

You are required to inform your manager or the President if you have information that leads you to suspect that employees or competitors are obtaining such information. If you have questions about Optikos’ intellectual property, copyrights, trademarks and patents, or other proprietary information, contact the President. Additional resources and information can be found in Section 9 of this Code and in the Optikos Employee Handbook.

5.6 — Competitive Information

Gathering information about our competitors is a routine element of business. Deceit or unlawful means should not be used to obtain competitive information. An employee who learns of a competitor’s confidential information must not review, copy, or disclose such information.

Employees who have previously worked for an Optikos competitor must not be asked or permitted to disclose a competitor’s confidential information.

5.7 — Use of E-Mail, Voicemail & Computer Systems

Optikos provides various tools to help employees work more efficiently. Based on your job responsibilities, you may have access to e-mail, computers, printers, fax machines, telephones and/or voicemail. These tools are the property of Optikos. You should be aware that, unless local law provides differently:

all communication and information transmitted, received or stored through these systems is the property of Optikos;
Optikos systems must never be used for offensive, defamatory or harassing material;
you should have no expectation of privacy when using Optikos’ e-mail, voicemail, computer, telephone and other communication systems; and
Optikos reserves the right to monitor and access an employee’s company e-mail account, voicemail, computer, telephone and other records, including communications and/or internet activity, in order to ensure the protection of Optikos trade secrets, proprietary information, and similar confidential commercially-sensitive information; manage the use of computer systems; and/or assist employees in the management of electronic data during periods of absence.

More information on our policies relating to the use of information technology can be found in the Optikos Employee Handbook.

5.8 — Data Privacy & Protection

Optikos respects the privacy of its employees’ personal data. Optikos will collect and retain personal data only as required to operate efficiently or as required by law. Only employees who have appropriate authorization and a legitimate business need may have access to employee personal data. Employees who are entrusted with employee personal data may only use such data for the purposes collected and must protect the confidentiality of the data.

Many countries where we do business have privacy or data protection laws requiring the responsible handling of personally identifiable information, including the transmission of data across country borders or to third parties. Optikos is committed to handling personal data with care and to safeguarding and protecting such information to ensure it is not lost, misused, accessed without authorization, disclosed, altered or destroyed.

More information on data privacy and protection can be found in the Optikos Employee Handbook and in our Written Information Security and Theft Prevention Program for Personal Information (“WISP”).

5.9 — Document Retention

Optikos complies with all applicable federal and/or state records retention laws and regulations, and with ISO 9001 and ISO 13485 requirements for retention of records. All Optikos employees are expected to be familiar, and comply, with these requirements, as well as with Optikos’ Records Retention Policy, which is provided to employees upon hire.

Records are defined as documents, regardless of format, which facilitate the operations and business of Optikos and which are thereafter retained for a set period to provide evidence of its activities and transactions.

Records that relate to any actual or imminent legal proceeding or regulatory investigation are subject to compulsory retention (so-called “legal hold” or “law hold”). Optikos employees are not allowed to destroy these records and must retain them until such hold is lifted. If you are uncertain or have questions about what to keep and for how long, contact your manager, the Quality Manager, or the Director of Operations. Additional resources may also be found in Section 9 of this Code.

5.10 — Media & Public Inquiries

Communications with the news media and others outside of Optikos are important and can have an impact on our business and the reputation and image of Optikos. It is essential that communications from Optikos are consistent, accurate, responsible, and professional. For those reasons, employees must refer any requests for Optikos information to the Director of Marketing.

6 The Optikos Experience – With Our Community

Optikos is a good steward of the environment and of the communities in which we live. We strive to make the world we live in a better place. We are good global, national, and local citizens. We operate in an environmentally conscious and respectful manner and support and build our communities, nurturing local development. The following section of this Code, The Optikos Experience – With Our Community, describes our commitment to being good corporate citizens and what is expected of all employees in this regard.

6.1 — Respecting Our Environment

Optikos is committed to full compliance with both the spirit and the letter of all environmental laws and regulations in every country where we operate. Optikos strives to conduct our operations and activities in a manner that protects the environment, through the prevention of pollution, waste management, conservation of natural resources, and recycling. We operate in an environmentally conscious and respectful manner and help others understand their environmental responsibilities when they use our products. Our commitment to protecting the environment is a responsibility shared by each of us.

6.2 — Corporate Citizenship

Consistent with our ethical culture, Optikos is committed to good corporate citizenship through its involvement in charitable organizations and community activities. We encourage employees to volunteer in our communities.

6.3 — Political Activity & Contributions

Optikos respects the right of employees to participate in political activities; however, that involvement must be conducted on an individual basis, on your own time, and at your own expense. At all times, you must make clear that your views and actions are your own, and not those of Optikos.

Because of strict limits on corporate political activity, employees may not make any direct or indirect political contribution on behalf of Optikos or with Optikos’ funds unless authorized in advance, in writing, by the Director of Finance and Administration or the President. Many countries prohibit corporations from donating corporate funds, goods or services (including employees’ work time), directly or indirectly, to political candidates or parties. Violating these laws can result in very serious penalties, including individual imprisonment.

7 The Optikos Experience – With Authorities

Optikos complies with all nations’ laws while adhering to our own high standards. We compete fairly and with the highest level of integrity in every market where we operate. Complying with all laws – in letter and spirit – is part of how we do business. This section of our Code, The Optikos Experience – With Authorities, describes what is expected of all Optikos employees in complying with laws and dealings with public officials.

7.1 — Compliance with Laws

Optikos conducts business in many countries around the world. As a result, our operations are subject to the laws of many countries, provinces, states, municipalities and organizations, such as the European Union.

An important challenge for all of us is to understand how these laws apply to our operations. As a U.S.-based company, in many cases the laws of the United States extend to our operations and affiliates and to Optikos employees located in other countries where we do business. Other countries may also apply their own laws outside of their borders.

Optikos is committed to operating with the highest level of ethical behavior and to complying with all applicable laws, regulations and industry codes in every country where we do business, including those prohibiting child labor and forced labor. We will not engage in unlawful conduct or fraud through third parties.

In some instances, there may be a conflict between the applicable laws of two or more countries or between the applicable laws and the provisions of this Code. In those instances, always comply with the law or standard that requires the highest level of ethical behavior and contact the President to assist in resolving the conflict.

7.2 — Business with Governments & Public Officials

Operating with integrity also applies to Optikos’ dealings with public officials. The term “Public Official” is broadly defined and includes, for example, employees of government agencies and state-owned entities, any person acting in an official government capacity, employees of joint ventures in which the government is a partner, a political appointee, and family members of a public official.

What is acceptable in the commercial business environment may be entirely unacceptable in dealings with public officials. With few exceptions, public officials have strict prohibitions against accepting any business courtesies.

When third parties, such as agents, distributors, brokers or freight forwarders, work with public officials on behalf of Optikos, liability may result for Optikos from actions undertaken by these third parties. Due diligence about a third party’s ownership and reputation must be conducted and documented by the appropriate employee before Optikos can establish new business relationships with agents, distributors or other third-party intermediaries.

Laws concerning appropriate gifts and hospitality with respect to governments and public officials are complex and can vary from country to country—and even within a country (e.g., local versus national laws). Violations of these laws have serious consequences, including possible criminal prosecution and/or fines. Therefore, except as otherwise permitted by regulation or prior written approval from the President, employees are prohibited from offering or providing gifts, hospitality, or other business courtesies to public officials.

8 The Optikos Experience – With Professional Organizations

Optikos maintains substantial involvement with professional societies including: Optica (formerly The Optical Society), the SPIE, and the local Optica section, NES/Optica. Each of these organizations has its own Code of Conduct and expectations of participating organizations and individual members. Optikos employees interacting with such organizations or while attending their meetings are expected to comply with both the Optikos Code of Conduct and any codes of conduct of the organizations with which they are interacting. An employee’s attendance at the meetings places them in an ambassadorial role in which they are representatives of Optikos. These meetings are an opportunity to display what we, as representatives of Optikos, mean by The Optikos Experience and in doing so provide a leadership example to the community.

9 The Optikos Experience – To Ask for Help or Raise Concerns

We believe it is important to provide multiple ways for employees to obtain help and support. This section of our Code, The Optikos Experience – To Ask for Help or Raise Concerns, is intended to ensure that employees are comfortable expressing their opinions, ideas, questions, and concerns.

9.1 — Open Door Policy

Optikos strives to provide a comfortable, productive, legal, and ethical work environment. To this end, we want you to bring any problems, concerns, or grievances you have about the work place to the attention of your manager and, if necessary, to the senior team. Optikos employees should feel secure in seeking advice or raising concerns without fear of reprisal. All questions and concerns are taken seriously and will be promptly investigated.

Optikos offers the following resources to employees who have concerns or who are in doubt about how to assess or resolve a situation:

If you believe there is inappropriate conduct or activity on the part of Optikos, management, its employees, vendors, customers, or any other persons or entities related to Optikos, bring your concerns to the attention of your manager at a time and place that will allow the person to properly listen to your concern. Most problems can be resolved informally through dialogue between you and your manager. If you have already brought this matter to the attention of your manager before and do not believe you have received a sufficient response, or if you believe that person is the source of the problem, present your concerns to the Human Resources Manager or the senior team. Describe the problem, those persons involved in the problem, efforts you have made to resolve the problem, and any suggested solution you may have.

9.2 — Suggestion Policy

At Optikos, we welcome suggestions for continued improvement and welcome your ideas for better ways to do your job, produce or sell the products or services of Optikos, or meet customer and client needs. Discuss your ideas with your manager or another member of the senior team. There is a suggestion box located in the kitchen of Building 3, which is checked regularly by the Human Resources Manager, and an online suggestion box that can be accessed through our third-party provider.

We also encourage you to offer any suggestions derived from seminars, magazines, or other outside sources of information you believe would add value to Optikos. Understand that any suggestions, innovations, inventions, or other matter created by you on work time or with Optikos tools or property are considered to be the property of Optikos.

9.3 — Retaliation is Strictly Prohibited

Optikos is committed to creating an environment where employees can raise questions or concerns or participate in the investigation process without fear of retribution or retaliation. Our strict “no-retaliation” policy supports our commitment to you, our valued employee, and to The Optikos Experience. In exchange for these commitments, it is expected that any reports or concerns that you believe warrant investigation will be made in good faith. Should you ever feel retaliated against for making a report or participating in an investigation, for any reason, including if you believe your manager to be involved in the retaliation, there are several avenues available to you to express your concerns, which are outlined in Section 9.4 below.

9.4 — Where to Go for Help

When you have a question or are seeking additional information or guidance on any of the information in this Code, many resources are available to help you, including:

Optikos Employee Handbook: The Optikos Employee Handbook has detailed information on Optikos’ employment policies and benefits available to all employees. While this Code summarizes some of our key policies, the Handbook will provide further detail and information on the policies and guidance for reporting issues and concerns.
Your Manager: In most cases, the best way to get your questions answered and address issues and concerns is through open communication between you and your manager.
Senior Team: If you are unable to address your questions or concerns with your manager, speak to a member of the senior team.
Human Resources: The Human Resources Manager can help you with any issues and concerns you may have relating to employment, unfair treatment, harassment, or any other issues and concerns covered in this Code.
Director of Finance and Administration: The Director of Finance and Administration can help you with any issues, concerns, or questions relating to use of Optikos information technology, document retention, gift acceptance, accounting and financial reporting, or fraud and misrepresentation.
Director of Operations: The Director of Operations can help you with issues, concerns, or questions relating to health and safety violations, issues with suppliers, our trade control policy, or our Safety Procedure.
President: The President is a resource you can contact if you have a question or concern, suspect a violation of this Code, or are uncertain where to turn for help. The President can also provide guidance with questions concerning patents and trademarks, laws, regulations, and corporate policies.
Optikos Hotline: The Optikos hotline is a confidential, anonymous, toll-free hotline for employees to report issues and concerns. The hotline is administered by Syntrio Hotline, an independent third party, and is available 24 hours a day, 7 days a week, 365 days a year for anonymous reporting. There are flexible contact options, including web, fax, mail, email, and toll-free 1-800 live telephone service. Employees can choose from any of the contact methods. Representatives are available in English, Spanish, and over 140 languages. All reports filed with the hotline are reviewed and investigated.
- Website: https://report.syntrio.com/optikos
- Toll-Free Telephone:
  English-speaking USA and Canada: 833-214-2442
  Spanish-speaking USA and Canada: 800-216-1288
  Spanish-speaking Mexico: 800-681-5340
  French-speaking Canada: 855-725-0002

Code of Conduct