Contract analysis

1. Introduction and Purpose of This Notice Calderwood & Harkness LLP issues this Litigation Hold Notice on behalf of our client, Halcyon Semiconductor Aktiengesellschaft ("Halcyon" or the "Company"), in connection with the civil antitrust complaint filed by the Antitrust Division of the United States Department of Justice ("DOJ") on October 30, 2023. This notice is being issued under the direction of the undersigned,

2. Legal Obligation to Preserve The duty to preserve relevant evidence in civil litigation in the United States is well-established and broadly enforced. The Federal Rules of Civil Procedure, including Rules 26(a), 26(b), 34, and 37(e), together with the case law of the U.S. District Court for the District of Columbia and the D.C. Circuit, impose a clear and affirmative duty to preserve documents and ESI that are rel

3. Scope of the Litigation Hold The scope of this litigation hold is intentionally broad and is designed to encompass all categories of documents and ESI that are or may be potentially relevant to any claim, defense, or issue in United States of America v. Halcyon Semiconductor Aktiengesellschaft and Vectris Photonics, Inc., Case No. 1:23-cv-03187. If there is any doubt as to whether a particular document or category

4. Key Custodians 4.1 Mandatory Custodians The following individuals at Halcyon Semiconductor AG and its subsidiaries have been identified as key custodians whose documents and ESI must be preserved immediately and in their entirety, without exception. These individuals are likely to possess documents and information that are directly relevant to the claims and defenses in the DOJ civil action, and their files — both

1. Dr. Katarina Breuer — Chief Executive Officer (Vorstandsvorsitzende), Halcyon Semiconductor AG

2. Markus Ellinger — Chief Financial Officer, Halcyon Semiconductor AG, and Sole Director, Halcyon Acquisition Sub, Inc.

3. Dr. Luisa Hartmann — General Counsel, Halcyon Semiconductor AG

4. Prof. Dr. Friedrich Wendt — Chair, Supervisory Board (Vorsitzender des Aufsichtsrats), Halcyon Semiconductor AG

5. All members of the Halcyon Vorstand (Management Board) who participated in any deliberations, discussions, or decision-making concerning the proposed Vectris acquisition, including any members who received presentations, memoranda, or other materials relating to the transaction

6. All members of the Halcyon Aufsichtsrat (Supervisory Board) who participated in any deliberations, discussions, or decision-making concerning the proposed Vectris acquisition, including any members who received presentations, memoranda, or other materials relating to the transaction

7. All employees and officers in the silicon photonics business unit, including but not limited to the heads of product management, engineering, sales, and marketing for silicon photonics transceiver modules and co-packaged optics products, who were involved in competitive analyses, pricing decisions, product roadmap development, or customer relationship management for these product lines

8. All employees and officers in the strategy and corporate development functions who were involved in identifying, evaluating, or executing the proposed Vectris acquisition, including any personnel who participated in due diligence, financial modeling, synergy analysis, or integration planning

9. All employees who participated in responding to the DOJ Second Request (Civil Investigative Demand) issued on September 15, 2023, or who provided information, documents, or data for the preparation of the HSR Act premerger notification filing on August 18, 2023, or the EUMR Form CO notification filed with the European Commission on August 25, 2023

10. Any other individuals identified by management as having potentially relevant information relating to the proposed transaction, the silicon photonics market, competitive conditions, or any other subject matter within the scope of this hold 4.2 Notification of Custodians Dr. Hartmann, as General Counsel, is requested to promptly distribute this Litigation Hold Notice — or an appropriately translated and adapted in

5. Immediate Preservation Steps Required The following preservation steps must be implemented immediately upon receipt of this notice. We recognize that certain of these steps may require coordination among the General Counsel's office, the IT department, and business unit management. We are available to assist with implementation planning, but the steps themselves must be initiated without delay. 5.1 Suspension of D

6. Ongoing Obligations This litigation hold constitutes a continuing obligation. It is not a one-time event but an ongoing duty that persists throughout the pendency of the litigation and applies to documents and ESI created or received after the date of this notice as well as to pre-existing materials. All custodians must remain vigilant in identifying and preserving potentially relevant materials on an ongoing basi

7. Coordination with Vectris Photonics Counsel Please be advised that Vectris Photonics, Inc. is also a named defendant in Case No. 1:23-cv-03187. We understand that Vectris is represented by Whitfield, Prager & Loomis LLP, with Catherine Whitfield serving as lead M&A counsel and Douglas Prager serving as lead antitrust counsel. It is essential that Halcyon personnel not communicate directly with Vectris Photonics pe

8. Consequences of Non-Compliance The consequences of failing to comply with this litigation hold are serious and potentially severe. We emphasize the following: • Court-imposed sanctions. The Court presiding over Case No. 1:23-cv-03187 has broad discretion to impose sanctions for the destruction, alteration, or failure to preserve relevant evidence. Under Rule 37(e) of the Federal Rules of Civil Procedure, if ESI th

9. Contact Information All questions, acknowledgments, reports of potentially relevant materials, and any other communications regarding this litigation hold should be directed to: Howard Bellamy Partner, Antitrust & Competition Practice Group Calderwood & Harkness LLP 1333 New Hampshire Avenue NW, Suite 700 Washington, DC 20036 Telephone: (202) 457-6218 Email: h.bellamy@calderwoodharkness.com Derek Okonkwo Associate