Hybrid Core Policies

Code of Conduct and Business Ethics Policy

1. Purpose

This policy sets out the standards of behaviour and ethical conduct expected of all individuals working at or on behalf of Hybrid Core BV. It reflects the company's commitment to operating with integrity, transparency, and accountability in all its activities and relationships.

2. Scope

This policy applies to all employees, directors, contractors, consultants, agents, and any other individuals acting on behalf of Hybrid Core BV, regardless of location or the nature of their engagement. It applies to all business activities, including research and innovation projects, commercial operations, and interactions with partners, clients, and public institutions.

3. Policy statement

Hybrid Core BV is committed to the highest standards of business ethics and professional conduct. We expect everyone who represents or works with the company to act honestly, fairly, and responsibly. This commitment is not only a legal and regulatory requirement - it is fundamental to our reputation, our relationships, and our long-term sustainability.

4. Principles

4.1 Integrity and honesty

We act with integrity in all our dealings. We are truthful in our communications, accurate in our reporting, and transparent in our intentions. We do not make false or misleading statements to clients, partners, public bodies, or funding agencies.

4.2 Conflicts of interest

Employees and representatives must avoid situations where personal interests conflict, or may appear to conflict, with the interests of Hybrid Core BV. Any potential conflict of interest must be disclosed promptly to management. Relevant examples include:

  • Financial interests in companies that are clients, suppliers, or competitors
  • Personal relationships that could influence business decisions
  • Involvement in external activities that compete with or affect the company's interests

4.3 Fair dealing

We treat all business partners, clients, competitors, and stakeholders fairly. We do not engage in deceptive, manipulative, or unfair commercial practices. We compete on the merits of our products and services.

4.4 Gifts and hospitality

Modest, appropriate gifts and hospitality are acceptable where they are consistent with normal business practice and do not create any obligation or expectation of favourable treatment. Gifts or hospitality that could be perceived as an attempt to influence a business decision must not be offered or accepted. All non-trivial gifts and hospitality must be recorded. Cash gifts are never acceptable.

4.5 Confidentiality

Employees must protect confidential business information, including commercially sensitive data, intellectual property, personal data, and information shared under non-disclosure agreements. Confidential information must not be disclosed to unauthorised parties or used for personal gain.

4.6 Use of company resources

Company resources - including equipment, systems, data, and working time - must be used responsibly and primarily for legitimate business purposes. Incidental personal use may be permitted where it does not interfere with business activities or create risk for the company.

4.7 Compliance with laws and regulations

All employees must comply with the applicable laws, regulations, and standards relevant to their role and location. This includes, but is not limited to, data protection law, competition law, export control regulations, and anti-corruption legislation.

5. Responsibilities

5.1 Management

Management is responsible for modelling ethical behaviour, communicating this policy to all relevant individuals, providing guidance where conduct questions arise, and taking appropriate action in response to any breaches.

5.2 Employees and representatives

All employees and representatives are responsible for understanding and complying with this policy, raising concerns promptly when they become aware of potential violations, and cooperating with any investigation into potential misconduct.

6. Reporting and compliance

Any employee or representative who becomes aware of a potential breach of this policy should report it through the company's internal reporting channels or via the Whistleblowing Policy, which provides for confidential and protected reporting. Hybrid Core BV does not tolerate retaliation against anyone who raises a concern in good faith.

Breaches of this policy may result in disciplinary action, up to and including termination of employment or contract, and may be referred to relevant regulatory or law enforcement authorities where required.

7. Monitoring and review

Compliance with this policy will be monitored through internal audits, management oversight, and the operation of the company's reporting mechanisms. This policy will be reviewed at least every two years, or sooner in response to significant legal or operational changes.

8. Communication and awareness

This policy will be made available to all employees and relevant contractors upon commencement of their engagement and will be published on the company's internal systems. Training on business ethics and conduct will be provided as part of the induction process and refreshed periodically.

9. Review cycle

This policy is reviewed every two years by the Hybrid Core Management Team or sooner if required by changes in applicable law, regulation, or company operations.

10. Version control

Version: 1.0

Owner: Hybrid Core Management Team

Approved by: Hybrid Core Management

Effective Date: 01.06.2026

Review Period: Every 2 Years