02 Compliance with regulations inside the company

1. All employees must safeguard information that is considered to be personal or confidential;
2. Caution and discretion are required in the discussion. Personal and/or confidential information within the company should not be discussed with anyone other than those who need to be involved for valid business reasons;
3. Requests for information regarding current or former employees should be referred to the HR department;
4. All employees should avoid any discussion in public places that contains stakeholder information or confidential information about HZPC.

Business secrets and other information that is not publicly known are to be treated strictly as confidential and may not be communicated to third parties, including family members.

The foregoing also applies once a business relationship has ended. All employees are responsible for the security of confidential data. Financial information about HZPC is not to be discussed with or released to any person or entity, unless it has been published in reports to our shareholders or otherwise made generally available by or on behalf of the Executive Board. 

New employees are asked to sign a ‘confidentiality clause’ and/or (depending on the position they will hold within HZPC) a ‘non-competition clause’. This will be an integral part of the agreed employment contract. Sometimes, existing employees accept another position within HZPC. In this case, it will be reconsidered whether or not a ‘confidentiality clause’ and/or a ‘non-competition clause’ needs to be (re-)installed or updated.

HZPC wants to ensure careful practices regarding insider information and the (presumption of) personal benefit that can be derived from it. All employees contribute actively to secure these practices. Therefore, anyone who has access to, or holds inside (unpublished) company information, is summoned not to derive any personal benefit from it. Neither will he/she assist (directly or indirectly) others to benefit from the access to insider information. Everyone who possesses or has access to unpublished price sensitive information, is summoned not to trade “Certificates of Shares” of HZPC Holland B.V. Neither shall this person communicate (directly or indirectly) any information of this kind towards others. 

Although this act applies to everybody, there are some groups or persons who are more likely to be in possession of inside information than others. This regulation is an internal requirement in HZPC. It aims to promote careful handling by the undersigned of inside information towards third parties in general and in particular while conducting transactions in HZPC Holland B.V. certificates. 

a. The Members of the Board of the Vereniging HZPC (Association HZPC)
b. The Members of the Supervisory Board of HZPC
c. The members of the Senior Management of HZPC, i.e.:

• Members of the Executive Committee
• Members MT Strategic Business Areas (Europe, Research and Stet)
• Project Managers Strategic Business Development Areas
• Directors of 100% subsidiaries.

d. The Members of the HZPC Monitoring Committee
e. HZPC employees designated by or on behalf of the Supervisory Board. 

The regulation has been approved by the Board of the Vereniging (Association) and the Supervisory Board of HZPC Holland on 18 May 2016.

Handle personal data responsibly and in compliance with all applicable privacy laws;
act in accordance with any relevant contractual obligations.
a. Be aware of and act in accordance with applicable law and relevant contractual obligations;
b. Collect, use and process such information only for legitimate business purposes;
c. Limit access to such information to those who have a legitimate business purpose to see it;
d. Take care to prevent unauthorised disclosure to those who do not have a legitimate business purpose for the information.

Only authorised spokespeople may respond to media inquiries and/or actively seek communication with the media as well as make use of (mass) communication channels such as web pages or social media on behalf of HZPC. Employees are strongly advised to refer all inquiries from the media to the attention of the general manager of every subsidiary of HZPC.

Every employee should handle company property responsibly and protect it against loss, abuse and theft. Without the express permission of a supervisor, company equipment and other property may not be used for private purposes or removed from company premises.
Employees must be aware that any product or writing developed or produced by HZPC employees during work time (by using HZPC facilities and knowledge) or as a result of performing their responsibilities, is the property of HZPC.

Employees should take appropriate steps to protect all HZPC proprietary interests, including the access to work-related information. Therefore, copying any records for any purpose other than a necessary job-related activity is strictly prohibited. No HZPC records, information or copies thereof may be retained by an employee following termination of employment.

In order to safeguard information, the following arrangements need to be observed:

• Personal passwords or log-in codes are not to be shared with third parties;
• To prevent theft, loss or unauthorised use of ICT-systems and facilities, a user must take measures to safeguard the provided hardware such as laptops, phones, USB sticks, etc. This can be done by setting passwords and access controls.

Employees are responsible for using the patented, copyrighted, or other proprietary material or information of a third party in compliance with applicable provisions of any contract between HZPC and the third party.

Within HZPC the use of IT systems and facilities is widespread. Virtually all business processes are supported by (and depend on) those systems and facilities. A number of rules are described to protect the availability, integrity and confidentiality of the information and the provision of information. The purpose of this policy is to set up and monitor a balanced system of security, focusing on risk management. Check our internal manual for detailed information.

Check our internal manual regarding provided tangible goods, such as:

• Laptop/tablet
• Mobile phone
• Company car
• Credit card

The goods named above and others are provided with the goal of supporting you while carrying out your profession.