Environmental Policy.

Hale-X Luxembourg SA (“Hale-X”) builds clinical artificial-intelligence software designed to make care safer, earlier, and more accurate. We believe that responsibility for human health is inseparable from responsibility for the environment on which human health depends.

As an early-stage technology company, we commit to running our operations and developing our products with a clear, proportionate, and continuously improving environmental conscience.

This Policy applies to all Hale-X operations : corporate, research, and commercial : and to all employees, contractors, interns, and officers acting on behalf of Hale-X. We also expect our suppliers and partners to share the principles set out below.

3.1 Legal compliance

We comply with applicable Luxembourg and European Union environmental law and regulation, and with any sector-specific requirements that apply to our activities.

3.2 Digital-first, low-footprint operations

Hale-X is built as a remote-friendly, cloud-native company. We avoid unnecessary physical infrastructure and prioritise efficient digital workflows over paper-based processes.

3.3 Responsible cloud and computing partners

We work with cloud and high-performance-computing providers : including AWS and LuxProvide / MeluXina : that publish credible climate commitments such as renewable-energy targets and water-positive operations, and we monitor the environmental performance of our infrastructure choices.

3.4 Computational efficiency

Training and inference for clinical AI is energy-intensive. We design our models, pipelines, and experiments to use compute proportionate to the clinical value created : favouring efficient architectures, reusable components, and avoiding redundant training runs.

3.5 Travel

We default to virtual meetings. Where travel is necessary, we prefer rail over short-haul flights for journeys within continental Europe, and we consolidate trips where possible.

3.6 Low-waste office and equipment

We operate paperless wherever practical, recycle, use energy-efficient equipment, and switch off devices when not in use. We extend the useful life of IT hardware through repair and reuse, and dispose of end-of-life electronic equipment through certified channels in line with applicable WEEE rules.

3.7 Responsible procurement

We give preference to suppliers and service providers who can demonstrate environmental commitments, recognised certifications, or transparent reporting.

3.8 Engagement of our people

We make this Policy available to all employees, encourage suggestions for improvement, and integrate environmental awareness into onboarding.

3.9 No greenwashing

We do not overclaim. We describe our environmental performance and commitments honestly and proportionately to our size and stage of development.

The Chief Executive Officer is ultimately accountable for this Policy. Day-to-day implementation is delegated across the leadership team:

• Operational practices (office, travel, procurement): Operations lead.
• Cloud and compute footprint: Chief Technology Officer.
• Supplier and partner engagement: as relevant per function.

The Policy is reviewed at least once per year and updated whenever our activities, scale, or applicable regulation change materially.

As Hale-X grows, we will progressively build out our environmental data collection : including measurement of cloud-related emissions : and align with relevant European reporting frameworks (such as CSRD-aligned disclosures) once they apply to us. We will share environmental progress with investors, clients, partners, and our team in a way that is proportionate, accurate, and verifiable.

Questions, suggestions, or concerns about this Policy can be addressed to:

• Email: contact@hale-x.com
• Postal: Hale-X Luxembourg SA, [Insert registered office address]