Code of Conduct

Last Revised: September 16, 2017

The purpose of this Code of Conduct is to communicate our common set of ethical values and business principles to our stakeholders and to give internal guidance in our daily pursuit of building the Information Society. We encourage the associates and other business partners within its sphere of influence to adopt the principles in this Code of Conduct.

Our business operations are based on high ethical standards. We promote fair competition in accordance with applicable laws. It is expected that employees compete vigorously and fairly in the conduct of business.

In every country in which we operate shall abide by the laws and regulations of that country. In situations where the law does not give guidance, we apply our own standards based on our corporate values and culture. In cases of conflict between mandatory law and the principles contained in this Code of Conduct, the law shall prevail. It is the responsibility of all employees to be aware of relevant laws or to seek legal advice to ensure compliance.

Business Practises

Safeguarding Corporate Assets

Safeguarding our assets - both tangible and intangible (such as intellectual property rights) - is vital to our business success. Employees have a duty to use our assets only for legitimate business purposes and to protect them from loss or unauthorized use. In no event may our assets be used for unlawful or improper purposes.

Conflict of Interest

In order to operate in a fair and open manner, it is important that every employee and the members of the Boards of Directors avoid any situation or interest which might interfere with their judgment regarding their responsibilities to the company, other employees, customers, suppliers and other partners. Should such a conflict of interest arise, it must be reported immediately by the person subject to the conflict to his/her immediate superior.

Gifts and Bribes

No gifts or similar benefits may be offered by an employee of our company nor accepted if it is considered as a contravention of any applicable law or code of local business practice. Gifts or similar benefits may only be offered to a third party if modest in value and if they are consistent with reasonable hospitality given in the ordinary course of business. No bribes or kickbacks may be offered to any third party.

Political Involvement

We observe neutrality with regard to political parties and candidates. Neither our name, nor any resources controlled by us, shall be used to promote the interests of political parties or candidates without a prior written consent.

Insider Trading

We expect our employees to act in the way required of insiders, even if they are not in fact registered as insiders. Employees must keep all information and secrets that relate to our present and future business operations strictly confidential. It is prohibited to misuse or disclose to any third party any information about our business operations or information about specific projects.

Accounting and Reporting

All accounting and reporting by us must be reported in accordance with generally accepted financial accounting practices and accounting records must give a true and fair view of the financial position. We shall strive to provide disclosure that is open, fair, relevant, timely and understandable.

Human Rights and Workplace Practice

Human rights

We support and respect the principles set out in the Universal Declaration of Human Rights.

Non-discrimination and Equal Opportunities

We hire and treat our employees in a manner that does not discriminate with regard to gender, nationality, religion, race, age, disability, sexual orientation, political opinion, union membership, or social or ethnic origin. We promote the idea that all employees shall be treated with equal respect and dignity. Furthermore, we promote a culture of equal opportunities and diversity where appointments to jobs, rewarding and personal success depend on individual ability and performance.

Labor

We do not accept child labor nor other forms of compulsory and forced labor. We support the freedom of association and all employees have the right to be a member of a trade union and to bargain collectively.

Work Environment

A safe and healthy working environment shall be provided for all employees.

Environmental Practice

We support a precautionary approach to environmental challenges and a responsible way of conducting our own business operations.

Responsibility of Managers and Employees

It is the responsibility of our managers to make sure that both the content and the spirit of this document are communicated, understood and acted upon within their organizations and to encourage employees to reveal behavior that may be non-compliant with this Code of Conduct. Explicit or implicit approval of questionable actions will not be tolerated. Reports of violations of this Code of Conduct may be made anonymously and in confidence to the Board of Directors. Persons reporting violations in good faith will not be subject to retaliation. Failure to act in compliance with the Code of Conduct can result in appropriate disciplinary actions.

We seek continuous improvement in the way we conduct our business and encourages all managers and employees to take part in this process. This Code of Conduct is a part of the Corporate Responsibility Framework and covers our business operations in all countries. Our Code of Conduct will be regularly reviewed.

This Code of Conduct has been adopted by the Board of Directors.

Contacting us

We welcome your comments regarding this Code of Conduct. If you have questions about this statement, please contact us.