Page 15 - Hexagon Code of Business Conduct & Ethics

5. 4. 3 Due diligence 5. 5 Trade compliance
Hexagon may be held responsible for corrupt conduct by third parties acting Hexagon provides products and services around the world. As such, we
on Hexagon’s behalf. Before engaging a third party that will be representing must comply with all applicable trade laws and regulations, including those
Hexagon or interacting with government agencies or other third parties that relate to export controls, trade sanctions programmes, and customs
on Hexagon’s behalf, Hexagon must perform appropriate due diligence to procedures, and we expect our trading partners to do the same.
determine whether the third-party is suitable to represent Hexagon.

It depends. Many laws
What if impose several restrictions What if Notify your export

You are considering on Hexagon’s ability to hire I learned that our customer officer, as export
US government employees.
hiring a former Before speaking with any prospect intends to use our of our products
for military use in
government engineer government employee product for manufacturing certain countries,
to work at Hexagon. about employment military items, while e.g., Russia, may be
They are very qualified opportunities at Hexagon, formally declaring the use prohibited or require
consult with the Hexagon
for the position. May compliance team to for civil purposes. What an authorisation of
you hire this engineer? ensure compliance with should I do? export authorities.
applicable laws.

5. 5. 1 Export control and trade
sanctions programmes
5. 4. 4 Public contracting/doing business with government customers
Hexagon sells to national, state and local governments government officials, and payment of commissions or If our products are found in sanctioned
and their agencies around the world. Strict rules apply contingent fees to third parties for assisting Hexagon to countries or in the possession of unauthorised
to business relations with government agencies and win government contracts. end-users, government regulators may
their officials. These rules may sometimes differ from question the integrity of our internal controls,
those that apply when dealing with commercial or Hexagon funds may not be used for political activity. even if a third party is solely responsible for
private customers. Notwithstanding the foregoing, lobbying activities may be an unauthorised shipment. Export laws and
undertaken with the advance approval of the CEO. regulations also may apply to third-party
Hexagon conducts its business with government agencies products that incorporate Hexagon products or
in compliance with these rules, including those related to For further guidance, see the Hexagon Public that are made using technology or services from
procurement, lobbying, gifts and entertainment, making Contracting Compliance Programme Summary. Hexagon.
false claims or statements, recruiting current or former
Prior to the export or in-country transfer
of goods, software, technology or services,
Hexagon confirms that the export is lawful and
does not violate an applicable economic or
trade sanctions programme.

Hexagon will not export any item or provide
services to any party if Hexagon knows or has
reason to believe the Hexagon item will be
used or retransferred in a manner contrary to
applicable export control or trade sanction
laws and regulations or if the party, or any other
party to the transaction, is prohibited under an
applicable trade sanctions programme or other
list of proscribed individuals or entities.

For further guidance, see the Hexagon Trade Export
Compliance Programme Summary.

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