Melexis Global Speak Up Policy

Policy objective

Melexis and its Colleagues commit themselves to do business on a daily basis with fairness, integrity and respect for the law and our values. Despite this commitment, you may one day observe behaviour that seems to violate the law, our values, the Melexis Global Code of Conduct or our policies. If you observe or suspect such Misconduct (you can find the definition of Misconduct and all other words with a capital letter at the bottom of this page), or if it is very likely to take place, then you are encouraged to use this policy to Speak Up and allow Melexis the opportunity to deal with the issue.

Partners who Speak Up in good faith, as well as any Other Protected Persons, are protected and will not suffer any disadvantages for raising concerns. Together these are the Protected Persons in this Speak Up policy.

Melexis reserves the right to unilaterally amend or revoke this policy.

Partners may request the most recent version of this policy from speakup@melexis.com at any time.

Application

This policy applies to all Melexis Partners.

Scope of the Policy

The Speak Up policy can be used to raise any Concern(s) about any Misconduct. The Speak Up policy can also be used to Report on any harm to public interest.

With regard to any violation of the law, Reports concerning the following domains are legally protected:

• Public procurement;
• Financial services, products and markets, prevention of money laundering and finance of terrorism;
• Product safety and compliance;
• Transportation safety;
• Environmental protection;
• Radiation protection and nuclear safety;
• Food safety, animal feed safety, animal health and welfare;
• Public health;
• Consumer protection;
• Personal data protection, protection of privacy and security of network and information systems;
• Tax and social fraud;
• Violations that relate to the EU internal market (including competition and state aid); and
• Violations that affect the financial interests of the EU.

If a Report does not fall within the scope of the above-mentioned list, this Report might not be legally protected. However, we still strongly encourage you to Speak Up about these matters. Melexis commits itself to protect any Partner who Speaks up in good faith from any Reprisal.

Examples of topics that can you can Speak Up about are:

• Safety and health;
• Discrimination or harassment;
• Misuse of computing and information resources;
• Non-compliance with law & fair dealing;
• Environment and human rights concerns;
• Product safety concerns;
• Inadequate financial or non-financial recordkeeping;
• Confidential information and intellectual property; and
• Conflict of interest, gifts, bribes and fraud.

This Speak Up policy should not be used:

• To settle personal disputes;
• To make accusations which you know are false, doing so may lead to disciplinary measures.

Speak-Up Procedure

This policy allows you to raise Speak Up to the Confidential Advisors (you can find more information on who these are at the bottom of this page) through a variety of means. You can Report in writing, by phone or virtual meeting, or in a physical meeting if you wish.

Every Partner is expected to read and understand this policy and abide by it. It is recommended that any Partner who Speaks Up provides adequate facts and data to substantiate the Report and e.g. not make a Report merely based on hearsay or rumor.

Speak Up Tool

In case you suspect Misconduct or have Concerns about any Misconduct and want to Report on the matter you can, in addition to the options mentioned above, also use our Speak Up Tool. This is the preferred way to report any Misconduct and can be accessed through the following link: melexis.integrity.complylog.com.

This Tool gives you the option to Report anonymously. In any case, every Report will be treated with full confidentiality. The Speak Up Tool enables the Confidential Advisors to communicate with you (even in an anonymous way if opted for) to optimally investigate the Report.

The Speak Up Tool is directly and solely managed by our Confidential Advisors. They will treat your Report impartially and diligently follow-up as specified below. They will also coordinate the Report, and if needed, involve other Report managers, when you provide your consent.

For any questions in relation to the Speak Up Tool and the Speak Up procedure you can contact speakup@melexis.com**.

Information to be provided

When you Speak Up, please provide as much detailed information as you can to enable the Confidential Advisors to investigate your Report, such as:

• The background, history and reason for your Report;
• Names of the Persons Concerned, dates, places and other relevant information on the Misconduct;
• Any document that may support your Report.

Reports can only be fully investigated if they contain sufficient information and there is a reasonable possibility of obtaining further information.

Confidentiality

Confidentiality is granted to any Partner who Speaks Up. Your identity, and any information revealing your identity, will only be shared with the Confidential Advisors, insofar you opt for a non-anonymous Report. The Confidential Advisors shall treat the identity and all information that can be deducted from Protected Persons confidentially and shall not disclose this to any other persons without the explicit consent of the Partner that Speaks Up or the Protected Person concerned, unless when permitted by law.

Your identity and the information will only be shared further:

1. To national authorities or courts if necessary under the law. In this case, you will be informed of the sharing unless this would endanger investigations or proceedings.
2. To anyone else, only with your explicit consent.

The same confidentiality shall be respected towards the identity of Person Concerned.

The information in your Report can only be shared with the CEO and CFO on a strict need-to-know basis.

Record Keeping

Melexis will keep a register of each received Report. Records of your Report will be kept as long as relevant. You can also provide your prior consent to record the conversation if you Report through the phone or through a physical or virtual meeting. In any event, you will receive minutes of the conversation and the opportunity to check, correct and sign the minutes for approval.

Follow-up

Melexis takes every Report seriously. The Confidential Advisors will assess the proper use of the policy and the accuracy of the Reported Concerns about any Misconduct. Unless it concerns an anonymous Report, the Confidential Advisors shall ensure the necessary communication with the Partner who Speaks Up and may request additional information as necessary.

The Confidential Advisors will take the appropriate actions and measures in relation to the Report and the Reported Misconduct. Such actions and measures may include, without limitation, internal inquiries, investigations, prosecutions, actions for recovery and the closure of the procedure.

After investigating the Report, the Confidential Advisor will submit an assessment to the CEO and CFO (with a detailed description of his/her findings and all supporting documents) indicating whether, in his/her opinion, the Report is either well-founded or unfounded.

You will be informed of the overall findings, the taken or planned actions and measures and the main reasons for such actions and measures. However, for reasons of confidentiality, privacy, and the legal rights of all concerned, you will not be given full details of the outcome.

The receipt of your Report will be confirmed to you within seven days. A substantive response to your Report will be provided within a reasonable timeframe, but in any case, within three months from the confirmation of receipt.

External Reporting

Melexis encourages you to first Speak Up to Melexis directly. However, you are also able to Report to external, competent authorities of the country in which Melexis is situated or to the EU if you prefer this. Please note that this specific option is only open to Melexis-entities of the countries mentioned below. Reports regarding Melexis-entities in other countries can also be done to any appointed external authorities but, in that case, the protection as mentioned in this policy may not apply (depending on the applicable national legislation)..

Below you can find a list of the relevant external authorities. If there is no external authority mentioned yet, it will be listed in this policy when it has been designated by the relevant country.

Protection from Reprisal

You and any Protected Persons will not be subject to Reprisal or any threats and attempts to Reprisal.

Protected Persons may benefit from protection and support measures if the following conditions are met:

• For the Partner who Speaks Up:
  • If he or she had reasonable grounds to believe that the Concern about any Misconduct was true at the time of Reporting and that such Concern fell within the scope of this policy; and
  • Made a Report in accordance with this policy.
• For the Partner who Speaks Up who initially made an anonymous Report on Concerns about any Misconduct, this Partner may also benefit from the protection measures mentioned in this policy if they are identified in a later stage.
• For the Other Protected Persons, if they had reasonable grounds to believe that the protective measures are applicable to the Partner who Speaks Up.

If this protection is not legally guaranteed, then Melexis further undertakes to protect any good faith Reporter from Reprisals.

A Protected Person who believes (s)he is being subjected to Reprisal, may:

• submit a reasoned complaint via the Speak Up Tool upon which the Confidential Advisor will investigate and take appropriate action on the complaint;
• submit a reasoned complaint to the relevant national instance (see title “External Reporting” for contact details), who will follow the extrajudicial protection procedure provided by the applicable national legislation; or
• start legal proceedings.

Furthermore, provided that the Partner who Speaks Up has reasonable grounds to believe that the Report was necessary to reveal Misconduct:

• they will not be subject to any civil, criminal, or administrative legal action or disciplinary sanctions because of the Report;
• they will not be held liable for Reporting Concerns about any Misconduct in accordance this policy; and
• the Report will not be considered a violation of any legal or conventional limitation to the disclosure of information.

The Protected Persons are also entitled to impartial information and advice, technical, psychological, and other assistance, as well as in certain cases legal and financial assistance.

More information on and assistance relating to the protection and support measures can be obtained from the Federal Institute for the protection and promotion of Human Rights.

Website: https://federaalinstituutmensenrechten.be/nl
Address: Leuvenseweg 48, 1000 Brussel
E-mail address: info@firm-ifdh.be

Sanctions

Melexis does not tolerate any form of Reprisal against Partners for Speaking Up.

Partners who do not adhere to this policy and obstruct or try to obstruct anyone from Speaking Up, take Reprisal measures, institute unnecessary or abusive procedures against the Protected Persons or unlawfully disclose the identity of Protected Persons can be subject to criminal and civil proceedings.

Partners who deliberately Report false information can be held liable under civil or criminal law.

Intentionally false Reports will themselves be considered a violation of the Melexis Global Code of Conduct and dealt with accordingly.

Data protection

Submitting, handling and investigating Reports for the purpose of this Speak Up policy involves processing the personal data of those involved. Melexis (Rozendaalstraat 12, 8900 Ieper, Belgium) is the controller for the processing of the personal data that is exchanged for the purpose of this Speak Up policy.

The personal data involves the data mentioned under title “Information to be provided”. It concerns identification of the persons involved, such as the name and position of the Partner who Speaks Up, written Reports, records and voice recordings and the description of the facts, nature, period and proof of the Misconduct and other relevant facts. The personal data can also contain criminal convictions and offences.

Personal data that is exchanged for the purposes of receiving and following up on Reports and public disclosures of Misconduct in order to verify the accuracy of the allegations made and to follow-up on the Reported Misconduct if necessary, including through measures such as internal preliminary investigations, inquiries, complaints, recovery of funds, and alike proceedings with a view of legally protecting the interests of Melexis, its Colleagues or third parties, etc.).

The legal basis of personal data processing for the purpose of this Speak Up policy is based on:

• Melexis’ legal obligation: to provide appropriate internal Reporting procedures in light of the Act and Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who Report breaches of Union law;
• Melexis’ obligation to carry out and exercise specific rights of persons involved in the field of employment, social security, and social protection law: this is in line with the obligation set out in the Act;
• Explicit consent: the consent can be expressed by e.g. explicitly consenting to the recording of a voice by the Partner who Speaks Up. Persons have the right to always withdraw their consent for the future.

Melexis may forward personal data to processors (e.g. the provider of our Speak Up Tool), external advisers, auditors and investigators, competent authorities and supervisory bodies and insurers.

Personal data that is clearly irrelevant for the handling of a Report will not be collected or, if accidently collected, deleted immediately. If a Report appears to be unfounded, Melexis will delete the personal data within a reasonable period (e.g. taking into account potential sanctions against the Partner who Speaks Up of a manifestly unfounded Report). If a Report appears to be founded, Melexis will retain the personal data for as long as necessary with a view to taking measures or imposing sanctions or with a view to its defence in court. The storage period will not exceed the expiry of the limitation period for the Reported Misconduct.

Persons whose data are processed for the purposes of Reporting a Misconduct are entitled to access their personal data. They may arrange for the personal data to be corrected, ask for it to be deleted, or limit its processing.

They can even oppose the processing of their personal data on the basis of justified mandatory grounds. They can request the portability of their personal data.

The exercise of the above rights may be subject to conditions. However, these rights do not imply any entitlement to access the personal data of other people.

People whose data is processed for the purposes of Reporting a Misconduct are also entitled to file a complaint with the supervisory authority (in Belgium: the Data Protection Authority (contact@apd-gba.be)).

This policy is governed by the applicable law of the relevant entities.

Definitions

• Colleagues: present, future and former employees, freelancers, our shareholders, management contractors, volunteers, interim workers and paid or unpaid trainees.
• Concern(s) about any Misconduct: reasonably suspected Misconduct, including actual or potential Misconduct, which occurred or are very likely to occur, and any attempt to conceal such Misconduct in a work-related context
• Confidential Advisors: the impartial persons within Melexis designated to manage, coordinate (and investigate) any Report, being our General Counsel and Internal Auditor. In addition, for Bulgaria, the local Legal Counsel is also appointed as Confidential Advisor.
• Misconduct: any act or omission that (i) violates the law in the areas defined above in the section “Scope of this Policy”, the Melexis values, the Melexis Code of Conduct or other policies, all issues related to internal controls and audit matters or, (ii) that defeat the object or purpose of the rules under point (i).
• Other Protected Persons: any facilitators (employees, family members and/or persons supporting you when you Speak Up), connected third persons who could suffer Reprisal in a work-related context and legal entities owned by the Partner that Speaks Up.
• Partner: (employees of) present, future and former suppliers, customers, contractors, or any other natural person or entity which has dealings with Melexis and is not a Colleague.
• Partner who Speaks Up: Partner who Reports Concerns about any Misconduct.
• Person Concerned: the person to whom the Concerns about any Misconduct can be attributed or with whom that person is associated.
• Reprisal: any direct or indirect act or omission that is prompted by the Reporting or by public disclosure, and that causes or may cause unjustified detriment to the Partner who Speaks Up or Other Protected Persons (e.g. intimidation, harassment, etc.).
• Speak Up, or Report, to Report or Reporting: to communicate the Concerns about any Misconduct

** Only the General Counsel and the Internal Auditor have access to this mailbox