A Message from the CEO

At Syzygy Plasmonics we have a simple rule: We do not pay bribes. We strive to protect our reputation and integrity which are our most important assets that we have developed through hard work and ethical behavior.

Corruption is a threat to our business and employees and is counter to our culture. We owe it to our customers, our communities, our shareholders, and ourselves to conduct our business pursuant to high ethical standards and to denounce corruption.

We have provided you with a Code of Conduct and Global Anti-Corruption Policy that contain clear guidelines to assist you in making ethical decisions.

I encourage you to come forward by reporting an incident at erx.erelations.com/hotline/Syzygy if you observe potential corrupt behavior as it is our company obligation to speak up! If you come forward, I assure you that your confidentiality will be maintained, and you will never be retaliated against. I encourage you to provide as much detail as possible including your contact information so we can keep you informed as we look into the matter and share information where appropriate. Providing contact information will not compromise your confidentiality. As always, our General Counsel is here to assist you if you have any legal or compliance questions.


Trevor Best
Chief Commercial Officer
Syzygy Plasmonics

Syzygy Code of Conduct and Global Anti-Corruption Policy

Syzygy’s Code of Conduct (the “Code”) and Global Anti-Corruption Policy (the “Anti-Corruption Policy”) build on the strong foundation of Integrity that has served as a Core Value of the company since formation. They serve as guidelines for ensuring our actions and decisions align with our core values and principles. We aim to uphold the highest standards of integrity, contributing to a greener and more sustainable future.

Everything we undertake at Syzygy is driven by our unwavering commitment to clean and sustainable technology, measured against the highest ethical business conduct. We strive for this excellence to continue developing groundbreaking technologies, build trust among our customers, and attract and retain exceptional talent. A deep-rooted respect for our planet, customers, and each other is crucial to our success and is something we are passionate about nurturing daily.

Who Must Follow Our Code and Policy?

All employees and anyone associated with Syzygy are expected to know and adhere to this Code and Anti-Corruption Policy. Non-compliance can lead to disciplinary actions, including termination. Members of our extended workforce and service providers temporarily assigned to perform work for us are also expected to uphold our Code and Anti-Corruption Policy while working with us.

Raising Concerns and Questions

If you encounter any ethical dilemmas or suspect any violations, please do not hesitate to communicate with your manager, Human Resources, or Legal. Concerns can be raised anonymously through our Anonymous Hotline, but we encourage providing contact details for a more direct resolution.

No Retaliation

Syzygy prohibits retaliation against anyone who reports or participates in an investigation of a possible violation of our Code or Anti-Corruption Policy. If you suspect retaliation, please immediately contact Legal.


Syzygy aspires to be a disrupter and leader in our industry. While it is not possible to list every ethical situation we might face, we rely on each other’s judgment to uphold high standards of integrity. We are all responsible for fostering a sustainable and ethical environment, driven by our shared commitment to innovation and respect for the planet. If you’re unsure about the right course of action, seek advice from your manager, Human Resources or Legal.

Let’s continue to innovate responsibly, champion sustainability, and make thoughtful and ethical choices every day. If something doesn’t align with our values, let’s have the courage to speak up. Together, we can make a substantial positive impact on our world.

Code of Conduct: Highlights

Employment Practices

  • Freedom from Discrimination and Harassment.
  • Health, Safety, and the Environment

Business Conduct

  • Competition Laws, Bribery/ Corruption, International Trade
  • Conduct of International Operations.

Protecting Syzygy’s Assets

  • Safeguarding Proprietary Assets, Data Security/ Privacy, Conflict of Interest.

Non-Retaliation Policy

Compliance & Violation of Code of Conducts

Global Anti- Corruption: Highlights

Anti- Corruption and Bribery Laws, penalties for such actions.

Type Prohibited and Restricted Payments.

Due Diligence Process for International Consultants and Agents.