Compliance

At TOPTICA Photonics, we expect that our business and technological activities always comply with applicable laws, international regulations, and our internal standards. For us, compliance means not only knowing the rules, but actively applying them in our daily work – reliably, transparently, and responsibly.
Consistent compliance builds trust: among our employees, as well as with customers, authorities, and partners worldwide. At the same time, it protects our company, our technologies, and our innovative strength. Violations can have significant consequences – for individuals, for projects, and for TOPTICA as a whole.
This is why we foster a corporate culture in which integrity and responsibility are firmly embedded. Managers and employees alike contribute to ensuring that compliance at TOPTICA is not only an expectation, but a lived standard.

A strong compliance culture is not created by individual rules but by ensuring that it is understood, embraced, and practiced throughout the entire organization. At TOPTICA Photonics, we make sure that compliance topics are communicated in a way that is tailored to their audience and practically applicable. Our Compliance Management System provides the structural framework within which we define and implement clear measures.
Our internal policies support employees in all relevant compliance areas – from responsible business conduct and the handling of sensitive technologies to topics such as integrity, gifts, invitations, and fair competition. These guidelines are a binding part of our daily work.
Through regular training, clear communication, and practical information, we foster risk awareness that goes far beyond the mere formal observance of rules. Our goal is to ensure that compliance is lived naturally at TOPTICA, that potential violations can be addressed openly, and that responsible behavior remains the foundation of our success.

The TOPTICA Photonics Code of Conduct defines the fundamental principles that guide our actions in our daily professional activities. It provides all employees with clear orientation for lawful, fair, and responsible behavior – in our interactions with one another, with business partners, and in our conduct on the market.
The Code applies to all employees of the TOPTICA Group, including managers and leadership. It supports us in making transparent decisions and in acting with integrity, in compliance with legal requirements and our own high standards.

To protect TOPTICA, our employees, and our business partners, it is crucial that potential compliance violations are identified early and reported immediately to the responsible compliance function. Only then can we respond quickly and appropriately, effectively minimizing risks for the company and for any individuals involved.
We therefore ask all TOPTICA employees and external partners to contact the Compliance Organization directly with any questions regarding compliance or with any indications of potential violations.
Using the official reporting channels listed below, you can reach the Compliance Function confidentially and reliably. All reports are handled with the utmost care, and whistleblowers are protected within the framework of applicable legal requirements.

If you have concrete indications of potential compliance violations, you can contact the TOPTICA Compliance Organization directly using the contact options listed below. We recommend submitting reports primarily through the reporting channels provided by TOPTICA to ensure fast and confidential processing.
Alternatively, it is possible – within the framework of applicable legal requirements – to contact the competent national authorities.

Email

For legal violations and other compliance breaches: compliance@toptica.com
For matters related to data protection: datenschutz@toptica.com

Mail

TOPTICA Photonics SE
Corporate Compliance
Lochhamer Schlag 19
82166 Graefelfing
Germany

Through our secure whistleblowing system, confidential reports about potential legal violations or other compliance-relevant matters related to TOPTICA’s business activities can be submitted at any time. This also includes indications of potential misconduct by business partners, particularly when such behavior is connected to their work for TOPTICA – for example, violations of human rights– or environmental-related due diligence obligations within the supply chain.
You can decide whether you wish to remain anonymous when submitting a report or whether we may contact you directly for follow-up questions. Both options are available and handled with the highest level of confidentiality.

Access to the TOPTICA whistleblowing system (german): https://survey.questionstar.com/Meldestelle-HinSchG

Reports may generally be submitted in any language.

Why should I report a compliance violation? 

Violations of applicable laws and internal rules can cause lasting damage to our company and may lead, among other things, to significant fines and reputational harm. This, in turn, can jeopardize the company’s economic stability and ultimately the security of our jobs.

What should I report?

Please confidentially report any concrete indications of suspected violations of applicable laws, the TOPTICA Code of Conduct, or other internal regulations in connection with TOPTICA’s business activities or employees. Particularly relevant are incidents that may indicate criminal behavior (e.g., theft, fraud, embezzlement, bribery, environmental offenses, disclosure of trade secrets) or intentional, systematic violations of applicable standards (e.g., repeated non-compliance with safety or quality requirements).
Suspected misconduct by business partners that is directly connected to their activities for TOPTICA (e.g., violations or risks related to human rights or environmental standards within our supply and value chains) can also be reported through our whistleblowing system.

What happens after I submit a report?

All reports received are handled confidentially by the TOPTICA compliance organization. This includes the Head of Export Control & Corporate Compliance.The process following the submission of a report is as follows. 

1. Acknowledgment of receipt: You will receive confirmation of your report within 7 days at the latest – provided you have shared your contact details or are using the whistleblowing system’s feedback function.
2. Initial assessment: The Compliance Organization conducts an initial assessment of the report and reviews whether additional information is required.
3. Follow-up questions and clarification: If further clarification is needed, we will contact you. – If you have provided contact details, we will reach out to you directly. – For anonymous reports, communication takes place exclusively through the secure, anonymous mailbox of the whistleblowing system, which you should check regularly.
4. Forwarding to the responsible departments: With strict adherence to confidentiality, the matter will – if necessary – be forwarded to the relevant internal department (e.g., HR, Data Protection, Security, Legal, Procurement, or units responsible for statutory due-diligence obligations). These departments will conduct further investigations and initiate appropriate measures where required.
5. Status updates: Depending on the scope and complexity of the case, an investigation may take some time. However, you will receive an update on the results or at least on the current processing status no later than three months after your report was received.

Can I submit a report anonymously?

Through our whistleblowing system, you may submit reports either by providing your identity or completely anonymously. For the initial assessment of a report and for any potential follow-up questions, it is often helpful if we can contact you directly – therefore, providing your identity can facilitate a faster and more precise clarification in many cases.
If you nevertheless choose to submit your report anonymously, it is important that we are able to reach you via the secure mailbox of the whistleblowing system if needed. Please ensure that you check this mailbox regularly. You will automatically receive the access details after submitting your report.

Will my report be treated confidentially?

We assure you that all reports received are treated confidentially – regardless of whether you choose to disclose your identity or remain anonymous. Likewise, we expect whistleblowers to handle the information provided to them responsibly and with the same level of confidentiality.
Individuals who are the subject of a report will be given the opportunity to comment as part of the procedure. Upon request, they may involve a trusted person – for example, an employee representative or legal counsel.
Until a matter is fully clarified, the presumption of innocence naturally applies. Both exculpatory and incriminating information are carefully and fairly considered. We place great importance on fairness – both toward whistleblowers and toward employees or business partners who are the subject of an allegation.
In each individual case, we assess which measures are appropriate, necessary, and proportionate.

What if the suspicion I reported turns out to be unfounded?

TOPTICA protects all individuals who, in good faith, report potential violations of applicable laws or internal regulations. Anyone who submits a report to the best of their knowledge and belief does not have to fear any disadvantages, discrimination, or sanctions. What matters is that, at the time of the report, you believe the information to be accurate and that the report is not made abusively.
You are not required to investigate the matter yourself or to collect evidence – this review is carried out by us as part of our compliance process. Even if the investigation later determines that no violation has occurred, you will not face any negative consequences.
However, there is zero tolerance for deliberately false allegations. Reports that are clearly untrue or submitted with harmful intent may themselves lead to consequences.