Lepton Code of Business Conduct

Purpose and scope

Lepton conducts its business lawfully, honestly and with respect for people and the environment. This Code sets the standards we hold ourselves to and expect from everyone who works with us.

• Who it covers: Lepton's directors, officers, employees, contractors and representatives, and the suppliers and business partners who provide goods or services to Lepton.
• Compliance with law: We comply with all federal, state, local and international laws that apply to our business. Where a customer contract is stricter than this Code, the contract governs.
• How we uphold it: Proportionate to our size, Lepton maintains processes to communicate this Code, train employees on it, investigate concerns promptly, and correct and, where appropriate, disclose any violations.

Business integrity

We win business on the merits of our products and services, never through improper means.

• Anti-corruption: No bribes, kickbacks or facilitation payments of any amount, to anyone, directly or through others.
• Fair competition: No price fixing, bid rigging, market or customer allocation, or sharing of competitively sensitive information with competitors. We describe our own and others' products truthfully.
• Conflicts of interest: Employees avoid situations where personal interests conflict, or appear to conflict, with Lepton's or a customer's interests, and disclose any that arise, including to the affected customer.
• Insider trading: No trading on, or tipping others about, material non-public information learned through business relationships.
• Accurate records: Our books, records, certifications, test results and submissions to customers and regulators are complete and accurate. Documents are never altered or destroyed to misrepresent facts.
• Government contracting: When supporting U.S. Government programs, we follow the applicable procurement rules, including restrictions on gifts to government employees, accurate cost and pricing data, allowable costs only, and conforming deliveries.
• Trade compliance: We comply with export, re-export and import laws (including the EAR and, where applicable, ITAR), economic sanctions and embargoes, and U.S. anti-boycott rules.
• Information protection and cybersecurity: We respect the intellectual property and confidential information of customers and others, use it only for its intended purpose, protect personal data, and maintain risk-based cybersecurity controls for our systems and products.

People and human rights

Everyone who works for or with Lepton is treated fairly, paid lawfully and works free from abuse.

• Equal opportunity: Employment decisions are made without regard to race, color, religion, sex, pregnancy, gender identity or expression, sexual orientation, national origin, ancestry, age, disability, medical condition, genetic information, marital status, military or veteran status, citizenship status, or any other legally protected status.
• No harassment: We do not tolerate physical, verbal or psychological harassment, intimidation or abuse.
• No child labor: We do not employ anyone below the legal minimum working age where the work is performed.
• No forced labor or trafficking: We prohibit forced, bonded, indentured or involuntary prison labor, slavery and human trafficking.
• Wages and benefits: We pay at least the legal minimum wage, provide all legally required benefits, and pay overtime as the law requires.
• Drug- and alcohol-free work: Work may not be performed under the influence of alcohol, illegal drugs or misused medications, and their use, possession or sale on the job is prohibited.

Safety, quality and supply chain

We deliver safe, conforming, genuine products through a secure supply chain.

• Environment, health and safety: We comply with all applicable EHS laws, provide a safe and healthy workplace, and work to prevent pollution and reduce waste, emissions and energy use.
• Quality: Our quality processes detect, correct and report defects to customers. Required inspections and tests are performed by qualified, authorized personnel, and certifications are accurate.
• Counterfeit parts: We buy from authorized sources and maintain processes to prevent, detect, report and remove counterfeit parts and materials.
• Supply chain security: We protect shipments and goods from tampering and comply with the customs security requirements that apply to our shipments.

Our suppliers

Lepton's suppliers and subcontractors are expected to meet the standards in this Code.

• We select suppliers carefully and apply diligence and oversight proportionate to the risk.
• We flow these principles down to suppliers whose goods or services support our customers' programs, and require them to do the same with their own suppliers.
• Suppliers must cooperate with reasonable assessments of their compliance, including by Lepton's customers where our contracts require it, and correct any gaps found.

Speaking up

Anyone, inside or outside Lepton, can raise a concern about a possible violation of law or of this Code, without fear of retaliation.

• How to report: Email [info@leptonsys.com] or contact any Lepton officer. Reports may be made anonymously.
• What happens next: Lepton reviews every report promptly and confidentially, investigates where warranted, and takes corrective action. Where a concern involves a customer's business, we notify that customer and cooperate fully with its investigation.
• No retaliation: Lepton prohibits any adverse action against a person who reports a concern in good faith. Retaliation is itself a violation of this Code.

Questions about this Code can be sent to the same address.