Represents ICEYE US' culture of acting as one and doing the right thing

We are committed to conducting our business ethically and in accordance with all applicable national and international regulations and laws in the areas where we operated, including:

• Space Laws
• Competition Laws
• Export Controls
• Sanctions
• Anti-Bribery and Anti-Corruptions Laws and Policies
• U.S. Government Ethics and Responsibility Requirements

Ignorance of legal obligations is never an excuse or defense to misconduct, and violations of the laws or regulations may result in harm both to ICEYE US and the employees themselves. These include fines, financial penalties, lawsuits, loss of business privileges, damage to ICEYE US’ business relationships and reputation and, in some cases, civil or criminal prosecution.

Space Laws

ICEYE US’ constellation of satellites operated from the U.S. are governed by space station licenses from the U.S. Federal Communications Commission and by remote sensing licenses from the US National Oceanic and Atmospheric Administration. ICEYE US is committed to ensuring its operations comply with the licenses and their terms.

Competition Laws

Competition laws, also referred to as antitrust laws, hold a central role in regulating the activity of businesses operating in all sectors of our economy and are designed to protect competition.

ICEYE US supports all efforts to promote and protect competition, including protection of intellectual property and marketing rights. Employees who must deal with competition in their work are expected to understand the principles and key rules of competition law and the importance of complying with such laws. If an answer to a specific antitrust question is not clear, employees must seek advice from ICEYE US Legal.

Export Controls

Export control regulation means laws that regulate the distribution of goods, technology, and information to other countries. The U.S. uses export controls for foreign policy and national security reasons, or to protect domestic production and R&D.

ICEYE US is a high-tech space company and some aspects of our technology and products are considered dual-use or otherwise sensitive from an export controls point of view. As a company operating in the U.S., ICEYE US must comply with the U.S. export control laws.

Sanctions

International sanctions refer to the restriction or suspension of economic or commercial relations, or other areas such as transport and communications or diplomatic relations, with a particular State or groups of individuals and entities.

ICEYE US is committed to complying with EU, UN, UK, and US sanctions regimes. Due to the nature of our business, special attention is paid with respect to sales compliance screenings, both product and service. We screen our customers, suppliers and business partners and will not engage in any business with individuals, entities, or use cases that are subject to international sanctions.

Anti-Bribery and Anti-Corruptions Laws and Policies

ICEYE US is committed to following Anti-Bribery and Anti-Corruption laws and policies. Employees should not offer, promise, authorize, make, solicit, or accept, directly or indirectly, any third party, whether a commercial or government, organization, or private individual for anything of value, monetary or otherwise, for the purpose of improperly obtaining business or affecting the performance of a public function.

U.S. Government Ethics and Responsibility Requirements

ICEYE US is committed to implementing the highest standard of Ethics and Responsibility in performing our U.S. Government Contracts. Employees are encouraged to report fraud, waste, and abuse of U.S. government funds or resources. ICEYE US will investigate all claims and will not retaliate against any employee who makes a report in good faith. Employees are also encouraged to be aware of and report any potential organizational conflicts of interest resulting from our business relationships which would give us an unfair competitive advantage, or which would impair our impartial and objective performance under a U.S. Government Contract due to bias or unequal access to nonpublic information.

At ICEYE US we offer an inspiring and safe work environment where our employees feel welcome and where they can thrive at the highest level. All our policies are aligned with ICEYE US’ established culture of equality, openness, friendship, trust, and integrity.

We respect internationally recognized human rights as defined in the United Nations Universal Declaration of Human Rights and comply with all labor regulations and fair employment practices.

How to be a great ICEYE USR:

• Respect each other’s freedom to express thoughts and opinions.
• Interact in a good and polite manner.
• Value each other as individuals
• Follow safety guidelines.

ICEYE US has a zero-tolerance policy for:

• Working under the influence of illegal drugs or alcohol.
• Inappropriate behavior such as workplace harassment or bullying.
• Discrimination based on race, religion, gender or gender identity, political opinion, age, nationality, sexual orientation, civil status, or disability.

We do not under any circumstance compromise our employees’ health and safety and thus, we comply with all occupational health and safety regulations. As our employees’ wellbeing is a priority for us, our occupational health and safety performance is monitored regularly.

Narcotics or illegal drugs are not permitted at the offices, office premises, company apartments or company organized events. Working under the influence of illegal drugs or alcohol, or using company facilities to manufacture, sell or distribute such, is strictly prohibited and may result in termination of employment.

As we have a culture of acting as one, we must always respect each other and interact in a good and polite manner. We do not tolerate any kind of inappropriate behavior or discrimination based on race, religion, gender or gender identity, political opinion, age, nationality, sexual orientation, civil status, or disability. Every employee is seen and valued as an individual, and we promote and respect everyone’s freedom to express their thoughts, opinions, and religion.

We have zero tolerance towards mistreatment, abuse, bullying, sexual harassment, or any kind of personal offensive behavior. Those who violate the code are subject to appropriate disciplinary actions.

If you encounter discrimination, harassment or bullying, any other form of inappropriate behavior, or have any concerns regarding yours or others health and safety in the workplace, you are encouraged to communicate these concerns through your supervisor or People Operations Lead. Please find more information about raising your concerns in the last section of this Code of Conduct.

We ensure that we present a clear, consistent, and accurate message of our potential capabilities by:

Combining sustainability with the world’s leading radar satellite business. Our SAR satellite imaging helps clients resolve environmental and societal challenges, and we comply with sustainability and environmental laws and regulations.

Quality management. We follow standard industry protocols to ensure that our products and services continue to meet the standards demanded by the organization and expected and valued by our customers.

Sustainable supply chain. We require that our suppliers have a good reputation and do not operate in, or source materials from, any sanctioned countries or conflict areas. It is also required that our suppliers have a healthy financial situation and sufficient technical competences.

Avoiding conflict of interest. We avoid conflicts of interest and make sure that in the working context, our company interests are the priority.

Anti-corruption and anti-bribery. We do not engage in bribery, corruption, or any other improper business arrangements.

Following instructions on how to interact with the media. When posting on personal social media, employees shall clearly state that their opinions are their own. Requests for public statements for the media on behalf of ICEYE US are sent directly to the Executive Leadership Team.

Building and operating the world’s leading radar satellite constellation. ICEYE US provides access to timely and reliable satellite imagery, ICEYE US empowers decision-makers to make better decisions in governmental and commercial matters and industries.

The following is summarizing the key points that ICEYE US wishes to emphasize when dealing with potential clients, investors, and/or the public. It is important for all team members to be familiar with these points to ensure that we present a clear, consistent, and accurate message of our potential and capabilities.

Combining business and sustainability.

Environment, society, and sustainability are a matter of principle for us. We deeply care about the environment and the society of which we are a part. ICEYE US’ radar satellite imaging service and hardware helps clients resolve challenges in sectors such as maritime, disaster management, insurance, finance, security, and intelligence. Our constellation of SAR (synthetic aperture radar) satellites enables a high level of change detection both day and night, and in any weather.

In addition to radar satellite imaging itself, we are building industry-specific information services to address sustainability issues as well as environmental problems and monitoring natural catastrophes. Our constellations’ ability to revisit the same location in space even sub-daily, enables us to provide near real-time data across the globe. We can participate in solving, for example, climate change related or other sustainability issues by providing imagery and solutions to monitor and address illegal fishing, maritime traffic, floods, or wildfires.

We comply with all applicable laws and regulations regarding sustainability and protecting the environment. We are committed to reducing the environmental impact of our operations and keeping space sustainable and consider the goal of mitigating space debris. Most of our direct emissions come from energy consumption, transportation, and launches. We encourage our employees, partners, and customers to utilize the tools we provide to act in ensuring a healthy environment for generations to come.

Quality.

ICEYE US’ mission is to enable everyone to make better decisions based on timely and reliable Earth Observation data. To achieve our mission, we are committed to create value for our customers through high quality products and services by applying seven quality principles:

• Encouraging our employees to take an active role in applying and developing our Quality Management System.
• Promoting the safety of all ICEYE US products, safety to our employees and to other stakeholders.
• Advancing customer satisfaction by fulfilling customer needs.
• Satisfying all legal, regulatory, and other applicable stakeholder requirements.
• Ensuring quality and responsibility within our supply chain.
• Continually improving quality in all business areas.
• Managing risks through controls and processes and tracking process execution with actionable metrics.

Conflict of Interest.

We make our business decisions based on the best interest of ICEYE US and all its shareholders. All transactions must be on an arms’ length basis and for fair market value. We avoid conflicts of interest and make sure that in the working context, our company interests are the priority. Conflict of interest can be any situation where a person’s own direct or indirect interest conflicts with the company’s interest. In such a case, the employee cannot be involved in the decision-making process.

It is important to know the red flags considering conflicts of interest, so you may notice and report them. Potential conflicts of interest that require disclosure include, but are not limited to the following:

• You intend to pursue secondary employment or consulting project(s) outside of ICEYE US for competitors or which conflict with ICEYE US’ interests.
• You intend to serve as a board member of a competitor, supplier, or partner company of ICEYE US.
• You, or your family member, is an employee or owner of, or has a significant interest in, a competitor or a company that could affect ICEYE US.
• You use your own position at ICEYE US or ICEYE US’ confidential information to further your own private interests or the interests of a friend or family member.
• You have a personal or family relationship with a colleague in a direct or an indirect managerial or subordinate position.
• You take part in the hiring decision regarding a family member or friend.
• Any fact or circumstance which would present a threat to, or would appear to threaten, the interests of ICEYE U.S. customers, including any threat to the national security interests of the U.S. arising from (but not limited to) the following: the employee’s relations, personal or financial interests, or access to sensitive, nonpublic information.

Any potential or actual conflicts of interest must be reported immediately, or in advance if practicable, to your supervisor.

Corruption and bribery.

Corruption means the misuse of entrusted power for personal gain. It can be, but is not limited to an excessive gift, sponsorship, bribery, or any form of improper business arrangement with any third party.

Bribery is offering, promising, giving, or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage. An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.

We at ICEYE US conduct all our business in an honest and ethical manner.

We do not engage in bribery, corruption, or any improper business arrangements. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. We are also committed to implementing and enforcing effective systems to counter bribery and corruption.

Any gifts and hospitality provided or accepted by ICEYE US employees from third parties are modest, appropriate and comply with applicable laws and regulations as well as ICEYE US values and policies.

We will uphold all laws and regulations relevant to countering bribery and corruption in all the jurisdictions in which we operate, including U.S. Criminal Law and the US Foreign Corrupt Practices Act. As the industry gold standard, we have opted for complying with the UK Bribery Act 2010 on a voluntary basis in respect of all our conduct.

Interacting with the media.

We communicate in an open, honest, and transparent way and aim to meet the needs of our stakeholders. We respect the confidentiality of our contracting parties and apply laws and regulations governing business and government secrecy. As a private company, we are not under obligation to publish detailed business, or financial, information. However, we share selected information and updates on ICEYE US’ official social media, and on press and events.

WE EXPECT AND TRUST EVERYONE AT ICEYE US TO ALWAYS ACT AS AMBASSADORS OF OUR COMPANY.

We are all responsible for communicating in the media with the terms that do not harm ICEYE US’ reputation. When posting on personal social media, employees shall clearly state that their opinions are their own. Employees do not make public statements for the media on behalf of ICEYE US and if a comment is asked, the request shall always be forwarded to our Executive Leadership Team, who will assign the appropriate ICEYE US spokesperson based on the topic.

Any breaches or suspected breaches of information security must be reported immediately to the ICEYE US security team.

Intellectual Property and Confidentiality.

Protection of confidential information within ICEYE US and all our business endeavors is a vital business priority. In principle, everything we do is strictly confidential, and we share confidential information on a need-to-know basis only. We also respect the intellectual property rights and non-public information of any third parties and handle such information with appropriate care.

Generally, any content that is not contained in the ICEYE US website is strictly confidential, until it is explicitly shared in our website or ICEYE US controlled mediums. If you have any questions or concerns regarding whether something can be discussed, please always refer to ICEYE US’ communication guidelines, your manager, or reach out to Legal.

Sharing of proprietary information with any third party, without an acceptable non-disclosure agreement (NDA) in place, is prohibited.

Innovations.

The making of new inventions and their patenting are important for the competitiveness and success of ICEYE US. We may file patent applications each year for inventions made by our employees.

ICEYE US has the intellectual property rights to all inventions (whether patentable or not), creations, documents or other results made or obtained by its employees during the employment period.

All ICEYE US employees are required to execute a Confidential and Proprietary Information Agreement as part of employment with ICEYE US.

ICEYE US Property and Information Security.

ICEYE US is subject to various information security requirements from its U.S. Government Customer and regulations, including the National Industrial Security Program Operating Manual and U.S. Export Control Restrictions. To comply with these requires and protect ICEYE US assets, ICEYE US will implement security controls under the NIST 800-171 standards (and additional requirements as appropriate). These include implementing requirements in the following Information Security families:

• Access Control
• Awareness and Training
• Audit and Accountability
• Configuration Management
• Identification and Authentication
• Incident Response
• Maintenance
• Media Protection
• Personnel Security
• Physical Protection
• Risk Assessment
• Security Assessment
• System and Communications Protection
• Systems and Information Integrity

Implementing these requirements helps reduce the likelihood of a data breach occurring, ways to limit our liability, and to protect both ours and our customers’ confidential information and assets.

Our information security policies are separate from this Code of Conduct. However, all employees will be expected to become familiar with and follow these policies.

Company property provided to employees by ICEYE US (smart phones, laptops etc.) should be treated with care against theft, misuse, or other damage. Company property must not be used for unauthorized purposes as well. 

We encourage our employees to voice their concerns in case they have noticed any kind of misconduct at any level. Together we are making sure that everyone at ICEYE US has a healthy and safe atmosphere to work. It is everyone’s responsibility to promote our values and policies at the workplace and thus, report any suspected misconduct of this Code of Conduct.

For action to be taken in a timely manner, it is important to report any incidents at your earliest convenience. All reports of misconduct will be handled confidentially and will not cause any harm or retaliation to the person who reported the suspected misconduct. People Operations will review and evaluate all the reports for further investigation.  Compliance is an obligation to all ICEYE US employees and concerns everyone. If you have questions about any legal obligation, don’t hesitate to contact the Legal team or People Operations.

How to Raise a Concern

• Contact your manager.
• Contact People or Legal Operations.