Contract analysis

I. INTRODUCTION AND PURPOSE A. Statement of Purpose Halcyon Semiconductor Aktiengesellschaft ("Halcyon," the "Company," "we," "us," or "our"), a German stock corporation (Aktiengesellschaft) registered in Munich, Bavaria (Commercial Register HRB 217458, Amtsgericht München) and headquartered at Maximilianstraße 72, 80539 Munich, Germany, has adopted this Code of Business Conduct and Ethics (this "Code") in connection

1. Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;

2. Full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, the SEC and other regulatory authorities, and in other public communications made by the Company;

3. Compliance with applicable laws, rules, and regulations, including applicable governmental laws, rules, and regulations in all jurisdictions in which the Company operates;

4. The prompt internal reporting of violations of this Code to an appropriate person or persons identified in this Code; and

5. Accountability for adherence to this Code. Each Covered Person is expected to read this Code carefully, understand its provisions, and comply with both the letter and the spirit of the standards set forth herein. Failure to comply with this Code may result in disciplinary action, up to and including termination of employment or removal from office, as described more fully in Section XIV below. B. Regulatory Basis

II. COMPLIANCE WITH LAWS, RULES, AND REGULATIONS A. General Obligation Obeying the law, both in letter and in spirit, is the foundation on which this Company's ethical standards are built. All Covered Persons must comply with applicable laws, rules, and regulations of every jurisdiction in which the Company operates. Given the multinational scope of the Company's operations, this obligation encompasses, without limit

III. CONFLICTS OF INTEREST A. Definition A conflict of interest arises when a Covered Person's private interest interferes, or reasonably appears to interfere, with the interests of the Company as a whole. A conflict of interest can arise whenever a Covered Person takes action or has an interest that may make it difficult to perform his or her Company duties and responsibilities objectively and effectively. Conflicts

IV. INSIDER TRADING AND SECURITIES TRADING POLICY A. Prohibition on Insider Trading It is a violation of U.S. federal securities law — specifically Section 10(b) of the Exchange Act and Rule 10b-5 promulgated thereunder — and of European regulation — specifically the Market Abuse Regulation (EU) No. 596/2014 ("MAR") — for any Covered Person who possesses material, non-public information ("MNPI") about the Company to:

V. ANTI-CORRUPTION AND ANTI-BRIBERY A. General Prohibition Halcyon has zero tolerance for bribery and corruption in all their forms. The Company's reputation for integrity is one of its most valuable assets, and the Company is committed to conducting its business in compliance with all applicable anti-corruption laws worldwide. All Covered Persons are prohibited from directly or indirectly offering, paying, promising

VI. CONFIDENTIAL INFORMATION AND DATA PROTECTION A. Duty of Confidentiality Covered Persons must protect all confidential, proprietary, and trade secret information of the Company and its subsidiaries. The Company's success depends in significant part on its ability to maintain the confidentiality of its proprietary information, and each Covered Person has a duty to safeguard such information against unauthorized dis

VII. PROTECTION AND PROPER USE OF COMPANY ASSETS A. General Obligation All Covered Persons have a duty to protect the Company's assets and to ensure their efficient use for legitimate business purposes. Theft, carelessness, and waste of Company assets have a direct impact on the Company's profitability and financial performance. Any suspected incident of fraud, theft, or misuse of Company assets must be immediately r

VIII. FAIR DEALING A. Standard of Conduct Each Covered Person must endeavor to deal fairly with the Company's customers, suppliers, competitors, and fellow employees. No Covered Person shall take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing practice. The Company's reputation for honest and fair dealing i

IX. EXPORT CONTROLS, SANCTIONS, AND TRADE COMPLIANCE A. Export Control Compliance As a designer and manufacturer of advanced semiconductor devices, including SiC and GaN power semiconductor products, the Company's products, technology, and software are subject to export control regulations in multiple jurisdictions. Compliance with export control laws is both a legal obligation and a critical component of the Company

X. ACCURATE BOOKS, RECORDS, AND PUBLIC DISCLOSURES A. Financial Reporting Standards The Company prepares its consolidated financial statements in accordance with International Financial Reporting Standards (IFRS) as adopted by the European Union. All financial records of the Company and its subsidiaries must be maintained accurately and in compliance with IFRS, the German HGB (to the extent applicable to the Company'

XI. WORKPLACE STANDARDS A. Equal Opportunity and Non-Discrimination The Company is committed to maintaining a workplace free from unlawful discrimination. All employment decisions — including decisions regarding hiring, promotion, compensation, training, discipline, and termination — shall be based on merit, qualifications, and job-related criteria, without regard to race, color, religion, sex, national origin, age,