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Compliance and Privacy

At Headwall, compliance is more than a requirement—it’s a commitment. Our policies and practices reflect a dedication to ethical conduct, product quality, responsible sourcing, and safeguarding data and privacy. These principles guide how we operate as a company, how we work with partners and suppliers, and how we deliver trusted solutions for our customers worldwide.

Disclaimer: Documents made available for download are the property of Headwall Photonics, Inc. and may be viewed or downloaded by customers free of charge. They may not be embedded or linked to any third-party location without written permission from an authorized Headwall representative. Headwall makes no warranty or claim to the accuracy of these documents at the time of viewing and reserves the right to make changes without notice.

Code of Business Ethics

Quality and Certifications

Responsible Sourcing

Data Protection and Privacy

Code of Business Ethics

As a private company, we are committed to protecting our assets and managing our business in the best interests of our stakeholders: customers, employees, and suppliers. Contact us for a complete statement as adopted by all employees, officers, and directors of Headwall Photonics, Inc. and subsidiaries.

In particular, we are committed to:

  • Accuracy of Company Records in compliance with U.S. Generally Accepted Accounting Principles, recording and reporting all financial and other business information fully, honestly, and accurately, and in a timely and understandable manner.
  • Acting with honesty and integrity, avoiding actual or apparent conflicts of interest in personal and professional relationships.
  • Promoting full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company provides to government agencies and in other public communications.
  • Complying with applicable governmental laws, rules, and regulations.
  • Acting in good faith, responsibly, with due care, competence, and diligence, without misrepresenting material facts or allowing one’s independent judgment to be compromised.
  • Respecting the confidentiality of information except when authorized or otherwise legally obligated to disclose it.
  • Sharing knowledge and maintaining skills important and relevant to the goals of this Code.
  • Proactively promoting ethical behavior among peers, in the work environment and the community.
  • Using responsibly all Company assets and resources employed by or entrusted to the individual.
  • Promptly reporting under the procedures outlined in this Code any conduct that the individual believes to be a violation of law, business ethics, or this Code.
  • Using appropriate judgment and discretion in emails, memos, notes, and other formal and informal communications relating to our business. Communications relating to our business must avoid inappropriate or derogatory comments about other individuals or companies, unprofessional language, and unauthorized financial, legal, or business statements.
  • Providing high value software and hardware products and related services to our customers and business partners.
  • Striving to achieve satisfied customers who will be repeat buyers of our products and services and to build mutually advantageous alliances with our business partners.
  • Delivering products that perform as documented and as represented to the customer.
  • Building lasting relationships with our customers through superior delivery and execution and honest sales, marketing, and support resources.
  • Compliance with applicable advertising laws and standards, including a commitment that our advertising and marketing will be truthful, non-deceptive, and fair and will be backed up with evidence before advertising claims are made.
  • Recognizing that special legal and contracting rules usually apply to our dealings with domestic and foreign government customers. For purposes of this Code, “government customers” include commercial customers who resell our products or services to government agencies, as well as other prime contractors to government agencies with whom we subcontract.
  • Making the work environment safe, secure, and healthy for its employees and others.
  • Compliance with all applicable laws and regulations relating to safety and health in the workplace.
  • Adhering to all national, state, or other local employment laws. Company policy prohibits discrimination in any aspect of employment based on race, ethnicity, religion, sex, national origin, disability, sexual orientation, gender identification or age or US Veterans status, within the meaning of applicable laws.
  • Prohibiting abusive or harassing conduct toward others, such as unwelcome sexual advances, comments based on ethnicity, religion or race, or other non-business, personal comments or conduct that make others uncomfortable in their employment with us.
  • Encouraging and expecting employees to report harassment or other inappropriate conduct as soon as it occurs. All threats or acts of physical violence or intimidation are prohibited.
  • Maintaining a healthy and safe working environment and to report promptly any unsafe or hazardous conditions or materials, injuries, and accidents connected with our business.
  • Maintaining personal information that relates to employment, including compensation, medical and benefit information and protecting information wherever it is stored or processed, and access.
  • Respecting employees’ involvement in the community, charitable and political activities and causes that may be chosen, so long as these activities do not interfere with job responsibilities to the Company. Employees may not represent that their views or activities represent those of the Company, and must not engage in any unwanted solicitations or pressure toward other employees relating to community, charitable, religious, or political causes.
  • Use of the Company’s tangible and intangible assets only for our lawful, corporate purposes, as approved by management from time to time. Protecting Company assets from misuse, theft, damage, or other loss. Improper or unauthorized use of Company assets is prohibited.
  • Protecting proprietary and other confidential information and trade secrets of the Company, and its customers, suppliers, and other business partners and of employees. Proprietary and other confidential information and trade secrets (“Confidential Information”) includes, but is not limited to, information relating to a party’s technology, source code, schemas, product or marketing plans and strategies, nonpublic financial and business information, product research and development, production plans and strategies, employee lists and information, sales data, and customer or supplier lists and information.
  • Maintaining the value of Company Confidential Information by using care to keep it confidential, and limit access of such information to those authorized to use it in their duties for the Company. The Company has designated receptacles for the disposal of Company confidential information. If customers, suppliers or other third parties provide Confidential Information to employees in their dealings with the Company, employees are expected to protect that information in the same manner as the Company protects Confidential Information.
  • Acting in the best interest of the Company and making every effort to avoid situations where employees’ actual or apparent private interest interferes in any way with the interest of the Company.
  • Applying sound judgment to avoid conflicts of interest that could negatively affect the Company or its business, whether or not we have specific rules for that particular situation.
  • Disclosing any situations that may involve inappropriate or improper conflicts of interests affecting an employee personally, affecting Company business or reputation, affecting other employees or those with whom we do business.
  • Conducting our business affairs with honesty and integrity and in compliance with all applicable laws, rules, and regulations. The Company and its subsidiaries are organized under various U.S. and non-U.S. laws and such laws extend to the operations of the Company and its subsidiaries throughout the world, and wherever our employees live.
  • Complying with the antitrust and unfair competition laws of the countries in which we do business. These laws, which vary by country, can be complex, and were designed to (a) ensure that competition remains vigorous and free from collusion, (b) protect free enterprise, and (c) prevent interference with the functioning of a competitive market system. Employees having roles that may implicate them with antitrust laws are responsible for knowing the laws that apply to their business activities, and should speak to the President and CEO if any questions arise.
  • Not using improper or illegal means of gaining competitive information that is confidential or proprietary information owned by others, or disclose confidential or proprietary information that you may have from past employment with other employers. If such information is offered or becomes available to an employee by any means, employees must not accept it.
  • Compliance with applicable restrictions under domestic and foreign laws relating to importing or exporting technology, products, services, or regulated information. Employees engaged in import or export transactions for the Company are expected to know and abide by applicable import/export and similar restrictions.
  • Conducting our business and use our business systems and facilities in ways that avoid any violations of copyright, trademark, service mark, patent, trade secret or other intellectual property rights held by third parties.
  • Compliance with software licensing agreements, which specify how and where the software is to be used on Company computers. The Company strictly prohibits any unauthorized or illegal copying or distribution of licensed software.

Quality and Certifications

Our Quality Statement

We will develop and deliver high-quality photonics instrumentation and component solutions for our core markets that meet or exceed expectations while providing full product support. Headwall will invest in continuously improving our existing technologies and manufacturing capabilities for the benefit of all our interested parties including customers, employees, suppliers, and our local and global communities.

ISO 9001:2015 Certified by NQA

Download ISO 9001:2015 Certificate (1.45MB, .PDF)

Conformité Européenne (CE) Certification

These documents are provided for the convenience of our customers. To ensure that you have the proper document for your particular need, contact support.

Responsible Sourcing

Conflict Minerals Policy

Download Conflict Minerals Policy (78.4KB, .PDF)

Supplier Code of Conduct

Introduction

Headwall Photonics is committed to conducting business ethically, sustainably, and responsibly. We expect the same from our suppliers, who play a crucial role in ensuring that our products and services meet the high standards of quality and integrity that our customers expect from us.

This Supplier Code of Conduct Policy outlines the standards and expectations that we have of our suppliers with respect to their conduct, including labor practices, environmental management, ethics and compliance, and supply chain responsibility. It applies to all suppliers who provide goods and/or services to Headwall Photonics.

Compliance with Laws and Regulations

Suppliers shall comply with all applicable laws and regulations in the jurisdictions in which they operate, including but not limited to labor laws, health and safety regulations, environmental protection laws, and anti-corruption laws. Suppliers shall also comply with international human rights standards and respect the rights of their employees, including the right to freedom of association, the right to collective bargaining, the prohibition of forced labor, and the prohibition of child labor.

Labor and Human Rights

Suppliers shall respect the human rights of their employees and provide a safe, healthy, and non-discriminatory work environment. Suppliers shall ensure that their employees work voluntarily and are paid fairly for their work, and that working hours and conditions are in compliance with local laws and industry standards. Suppliers shall not engage in any form of forced labor, including bonded labor, indentured labor, or any other form of involuntary labor. Suppliers shall also prohibit child labor and ensure that no one under the legal age of employment is employed, as defined by applicable laws and regulations.

Environmental Protection

Suppliers shall demonstrate a commitment to environmental sustainability and minimize their environmental impact by implementing and adhering to environmentally responsible practices. Suppliers shall comply with all applicable environmental laws and regulations and strive to minimize the use of natural resources, reduce emissions and waste, and prevent pollution. Suppliers shall also take measures to reduce their carbon footprint and promote sustainable practices in their operations.

Ethics and Anti-Corruption

Suppliers shall conduct their business ethically, transparently, and in compliance with applicable laws and regulations. Suppliers shall not offer, give, or receive any bribes or kickbacks, or engage in any other form of corruption or unethical behavior. Suppliers shall maintain accurate and complete records of all transactions and comply with all applicable laws and regulations related to accounting, reporting, and disclosure.

Data Privacy and Information Security

Suppliers shall protect the confidentiality, integrity, and availability of any data or information they receive from or transmit to Headwall Photonics and shall comply with all applicable data protection and privacy laws. Suppliers shall take appropriate measures to safeguard information against unauthorized access, disclosure, or use, and shall notify Headwall Photonics promptly in the event of any suspected or actual security breach.

Supply Chain Responsibility

Suppliers shall ensure that their own suppliers and subcontractors also adhere to the standards set out in this code of conduct policy. Suppliers shall implement due diligence processes to identify and manage risks in their supply chains, including risks related to labor practices, environmental sustainability, ethics and compliance, and data privacy and security. Suppliers shall ensure their purchasing policies mitigate the risk of the purchase, acceptance, and distribution of counterfeit parts.

Reporting and Remediation

Suppliers shall promptly report any suspected or actual violations of this code of conduct policy to Headwall Photonics and cooperate with any investigations. Suppliers shall also take appropriate corrective action to remedy any violations. Failure to comply with this policy may result in termination of the supplier relationship.

Conclusion

At Headwall Photonics we are committed to working with suppliers who share our values and our commitment to ethical, sustainable, and responsible business practices. We expect our suppliers to comply with this code of conduct policy and to continually strive to improve their environmental and social performance. Together, we can build a sustainable and ethical supply chain.

Download Supplier Code of Conduct Policy (61.21KB, .PDF)

Data Protection and Privacy

Cybersecurity Commitment

At Headwall Photonics we are deeply committed to protecting our systems, data, and customers by adhering to the principles of the NIST Cybersecurity Framework. Our cybersecurity strategy is built on a foundation of prevention, detection, and response, ensuring that we remain resilient against emerging threats and vulnerabilities.

We implement a comprehensive cybersecurity program that includes continuous monitoring of all network activity, systems, and devices. This ensures that any unusual behavior or potential threats are immediately identified and addressed. Our real-time threat detection capabilities, combined with multi-layered defense mechanisms, allow us to respond swiftly to incidents, minimizing any potential impact on our operations or customer data.

In collaboration with trusted IT service and security providers, we regularly review and update our cybersecurity practices to stay ahead of industry standards and best practices. We employ a rigorous improvement program that involves periodic audits, vulnerability assessments, and penetration testing to identify and mitigate risks proactively.

Data protection and compliance are at the core of our operations. We adhere to strict access control policies, encryption standards, and data integrity measures to safeguard sensitive information. Our commitment to cybersecurity also extends to the ongoing education and training of our employees, ensuring they remain vigilant and informed about the latest security threats.

As part of our continuous improvement efforts, we actively monitor advancements in cybersecurity technologies and practices, incorporating new tools and methodologies as needed. This approach allows us to evolve alongside the changing threat landscape and maintain a secure, reliable environment for our customers.

Privacy Policy

General

This Site is controlled and operated by Headwall Photonics, Inc. (“Headwall”) and contains “cookies”. Headwall makes no representations about information or materials available on this Site. If you choose to access this Site, you do so of your own volition and you are solely responsible for compliance with all applicable laws. Headwall may change the terms and conditions contained on this page at any time and you should periodically visit this page to determine the then-current terms governing your use of the Site and of the information and materials presented there.

Consent

Headwall respects your privacy. We also request your consent. By clicking the SUBMIT button on any of our forms, you consent to receive information from Headwall as well as possible further correspondence from us pursuant only to our respective business interests. We only collect information relevant to this, and nothing more. Most importantly, we do not share your information with any third parties, unless you have given express permission for us to do so.

About Cookies

Cookies are small pieces of data sent from a website and stored on a website user’s web browser while a user is browsing a website. When the user browses the same website in the future, the data stored in the cookie can be retrieved by the website to notify the website of the user’s previous activity. Cookies do not harm your computer in any way, and are usually automatically deleted after a certain period of time, such as six months.

Does Headwall use cookies on its website?

Yes. Like virtually all websites, Headwall uses certain types of cookies on its site. This allows us to collect non-personal information through a variety of technologies. This helps us identify visitors who return to our site and tells us such things as how many users visited our site, the pages that were accessed, and whether there were any technical problems in loading pages or navigating through our site. By collecting this information, we learn what parts of our sites are the most interesting or valuable to our users, and can monitor overall interest in our website. It also lets us spot technical problems with our site so we can correct them right away. This, in turn, helps us upgrade our website and improve our offerings for our visitors.

Am I required to accept cookies to use the Headwall website?

No. You can disable the use of cookies by websites (including ours) by turning off the cookie function on your browser.

What information do you receive about me through cookies?

We use essential cookies to allow users to be authenticated through our site. We also may use Browser and Flash cookies to tell us, for example, whether you’ve visited us before, and to help us identify site features in which you may have the greatest interest. Browser and Flash cookies may enhance your online experience by saving your preferences while you are visiting a particular site so that you do not need to reset or re-enter them each time you visit the website. Neither Browser nor Flash cookies can identify you as an individual. You can decline any Browser cookie through your browser. However, without Browser cookies you may not be able to take full advantage of all our website features. Similar to Browser cookies, you may not be able to take full advantage of all website features once you have disabled Flash cookies.

What happens if I choose not to disable cookies on my computer?

Unless you disable such technologies, by using our website and online services, you agree that we can place these types of cookies and related technologies on your device.

Restrictions on Use

The materials presented on this Site are copyrighted works of Headwall or others. Except for software covered by a separate license agreement (see below) or for materials bearing the copyright notice of a party other than Headwall, you are permitted to download and use these materials solely for personal, noncommercial purposes. You must retain and not remove any copyright notices or other proprietary notices contained in the materials. You may not copy, modify, republish or distribute these materials or post them on any network computer or broadcast them without the express written permission of Headwall. For materials bearing the copyright notice of a party other than Headwall, you are responsible for obtaining the permission of the copyright owner before making any use of such materials. Because of the open and public nature of this Site, you should not have any expectations of privacy or confidentiality regarding any information or materials that you transmit to this Site. Furthermore, by transmitting any information or materials, you will be deemed to have granted Headwall the unrestricted right to use such information or materials, and any ideas or concepts that they contain, for any purpose as determined by Headwall.

Software Licenses

Any software which Headwall makes available for downloading via the Site may be subject to the terms and conditions of a specific license agreement governing its use, reproduction and distribution. Before being permitted to download such software, you may be required to access a copy of such license and to acknowledge your familiarity with and acceptance of the terms of such license. To the extent that the terms of a particular license conflict with the terms listed on this page, such license agreement terms shall prevail with respect to such software.

US Government Restricted Rights

Except where subject to a specific license agreement, with respect to software made available on this Site, Headwall’s commercial software and commercial computer software documentation is provided to United States Government agencies in accordance with these terms and per subparagraph “(c)” of the “Commercial Computer Software – Restricted Rights” clause at FAR 52.227-19 (June 1987) and for DOD agencies, the restrictions set forth in the “Technical Data-Commercial Items” clause at DFARS 252.227-7015 (Nov 1995) shall also apply.

Export Control

You may not download or otherwise export or re-export any information, materials or software except in full compliance with all United States and other applicable laws and regulations. By downloading the information, materials or software, you are agreeing to the foregoing and you are warranting that you are in compliance with the foregoing.

Disclaimer of Warranty

All information and materials provided on this site are “as-is” without warranty of any kind, either expressed or implied. Headwall and its suppliers disclaim all warranties, expressed or implied, including, without limitation, those of merchantability, fitness for a particular purpose, and non-infringement or arising from a course of dealing, usage, or trade practice.

Limitation of Liability

In no event shall Headwall or its suppliers be liable for any direct, special, incidental, indirect, or consequential damages or any damages arising out of the use or inability to use the information or materials on this site. This includes, without limitation, lost profits or revenues, costs of replacement goods, loss or damage to data arising out of the use or inability to use this site or any Headwall product, or damages resulting from use of or reliance on the information presented, even if Headwall or its suppliers have been advised of the possibility of such damages.

Links to Third-Party Sites

The Headwall site contains links to other Web sites. Headwall is not responsible for the content of such sites. Headwall is providing these links to you only as a convenience and the inclusion of any link does not imply endorsement by Headwall of the site. Access to any other Web site via the Headwall site is at your own, sole risk.

Information Sharing and Disclosure

Headwall Photonics, Inc. does not rent, sell, or share information about you with other people or non-affiliated companies except to provide information or services you’ve requested in writing, by e-mail, in person, or via telephone, and then only when we have your permission.

Voluntary Adherence to EU-US Privacy Shield Framework

While Headwall has not self-certified with the US Department of Commerce, we voluntarily comply with as many of the principles of the framework for protection of personal data of EU individuals as possible, in support of transatlantic commerce. As a convenience for interested individuals, we provide a link to the US Department of Commerce Privacy Shield website and an e-mail address (information@headwallphotonics.com) to send any inquiries or complaints related to individual privacy to Headwall. We also can receive telephone calls to our company headquarters at +1-978-224-8786. As an individual that has interacted with Headwall, you have the right to access your personal data. Headwall is required to disclose personal information in response to a lawful request by public authorities. Public authorities that could request personal information include US federal, state, or local law enforcement or EU authorities if it is determined that the jurisdiction involved and circumstances require Headwall compliance. Headwall does not transfer individual personal data to third-parties without the express consent of the individual. As an individual that has interacted with Headwall, you may bring a complaint directly to Headwall via a number of means, including the aforementioned e-mail address or telephone number, as well as direct personal discourse at our company headquarters at 580 Main Street, Bolton, MA 01740, United States of America during normal business hours. Headwall commits to responding as promptly as possible to inquiries and requests by the US Department of Commerce for information relating to an individual’s inquiry or complaint. Headwall limits the gathering of personal information to the information relevant for order processing or the fulfillment of a request for company, product, or service information and complies with the latest data-retention principles. If transferring personal information to a third party acting as processor, Headwall complies with applicable notice and choice principles and enters into a contract with the third-party wherein such data may only be processed for limited and specific purposes consistent with the consent provided by the individual and the recipient will provide the same level of protection, and that the third-party will notify Headwall if it can no longer meet this obligation. If that determination is made, then the third-party will cease processing or take other reasonable and appropriate steps to remediate. If personal data is transferred to a third-party processor, such data is used only for limited and specified purposes. Unless otherwise agreed upon, the third-party processor is typically obligated by Headwall to provide at least the same level or privacy protection as required by the principles. Reasonable and appropriate steps will be taken to ensure that the third-party processor effectively processes the personal information transferred in a manner consistent with Headwall’s obligations under the principles. If the third-party processor determines that it can no longer meet its obligation, the third-party will notify Headwall and stop and remediate unauthorized processing. Headwall will provide upon request a summary or representative copy of its contract with the third party. Headwall commits to periodic review and publication of its privacy and data retention principles.

California Online Privacy Protection Act (CalOPPA)

  • Headwall collects the following personally identifiable information from online or other customer-submitted forms: name, affiliation, e-mail address, telephone number (optional), city, state or province, country and region, purchase timeframe, application interest, desire for a sales quote (optional), and information about the spectral application (optional).
  • Unless consent is expressly given, Headwall does not share personally identified information with third parties.
  • Consumers can review and request changes to his or her personally identifiable information as collected by Headwall or third-party processors by means of written correspondence, e-mail, telephone call or in-person discourse with Headwall.
  • Headwall notifies consumers of material changes to the operator’s privacy policy by means of publication to the company website.
  • The effective date of the privacy policy can be seen on the Headwall Privacy Policy / Privacy Statement page.
  • Headwall’s website or other online services respond to Do Not Track signals from Web browsers by respecting such browsers’ Do Not Track requests.
  • Headwall does not grant third-party collection of personally identifiable information on our website or other online services.

EU General Data Protection Regulation (GDPR)

Headwall utilizes GDPR-compliant services for data protection and database opt-in campaigns in order to remain in compliance with current regulations. Subscribers may confirm or re-confirm their desire to be part of our mailing list, or unsubscribe from our mailing list via clickable link, telephone call, written or e-mail correspondence, or in-person discourse. Consent to be added to our mailing list must be freely given, specific, informed, and unambiguous. Individuals may request access to their contact-record data by e-mail, telephone call, written or e-mail correspondence, or in-person discourse. Headwall will respond with reasonable and appropriate speed to deliver that data by e-mail, telephone call, written or e-mail correspondence, or in-person discourse.

Children’s Online Privacy Protection Rule (COPPA)

Headwall’s website, printed and electronic collateral, advertising, and products are not directed towards children under the age of 13 years old. Headwall does not knowingly allow access or collect any personal information from children.

Trademark Notice

Headwall®, Hyperspec®, HSInsight®, SpectralView®, and the Headwall logo are registered trademarks of Headwall Photonics, Inc. All Headwall, other company, product, or service names mentioned herein may be the trademarks of their respective owners.

Effective Date

The effective date of this latest revision of the Headwall Privacy Policy is March 6, 2020.