Piql Code of Conduct

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CODE OF CONDUCT

Our values, principles and standards of professional conduct

| CODE OF CONDUCT

CONTENT

What it is and why we need it

The Piql way - Our mission, vision and values

General employee conduct

Work environment

Piql values diversity

Health and safety standards

Environmental responsibility

We respect the company’s assets

Professional use of information systems

Conflict of interests

Clients, Partners and Suppliers

Standards of openness

Gifts, entertainment and favours

Corruption and secrect comissions

Open and fair competition

Organisation funds and other assets

Dealing with outside people and organisations

Prompt communication

Privacy and confidentiality

Piql records and communications

Breaching the Code of Conduct

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What it is and why we need it

The Piql Code of Conduct is the framework which outlines and explains the behaviour we expect fromof our employees, Partners and anyone who represents Piql world-wide.

tive, in every location, every day. We also expect this of our business partners. It is not what we say we do, it is what we actually do and how we do it that is important. We want everyone involved to feel proud to be associated with Piql. Our unconditional commitment to act profes- sionally and with integrity helps us hire the best and brightest people who develop and provide great products and services, which attracts loyal clients and business partners. Mutual respect and trust amongst Piql employees and Partners is at the core of our success and must be built on a day to day basis. I encourage you to familiarise yourselves with the Code and strive to follow and incorporate this framework to the best of your ability. Remember that you all play an important part in making Piql what it is; you are all Piql Ambassadeurs and you contribute to our success. Thank you for your continuous valuable contribution and effort. It is highly appreciated!

OUR CODE OF CONDUCT IS BASED ON OUR VALUES: innovative trustworthy nimble

Piql employees and Partners must apply this framework to their work on a daily basis when- ever they are representing Piql, always remember- ing that each person has a shared and personal responsibility to live up to the standard the Code of Conduct sets, while encouraging others to to doo the same. At Piql, our focus is on providing our clients out- standing, yet affordable products and services, without compromising our reliability and quality. Our reputation as a reliable company with trust- worthy and top-of-the-line products and ser- vices, is one of our most valuable assets and this reputation must be maintained and protected. The Piql Code of Conduct is very important to the way we develop and protect our reputation. It is not just what we do but also how we do it that will determine our reputation and contribute to continued success. The Piql Code of Conduct reaches beyond com- pliance with laws and regulations, to achieve the highest integrity wherever we run our business in the world. The Code illustrates our commitment to behaving ethically and with integrity in all situations and re- specting people’s rights as individuals. We expect this of every single Piql employee and representa-

Rune Bjerkestrand Managing Director Piql AS

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The Piql Way

PIQL’S VISION IS “to give eternal life to information, through innovation.”

OUR MISSION IS TO “keep authentic information alive, secure and accessible into the futureorganisation.”

Carrying this culture and shared value of integrity becomes a powerful force.

We are an international organisation with a reputation that is built on specific values and qualities.

Our values define our behaviour and are a road-map for helping us build and maintain our reputation. We believe that our corevalues are good for business! Our vision, mission and values are the foundation of “The Piql Way.” We are committed to developing a culture where integrity and ethical behaviour are woven into ev- erything that we do—imbedding it into our DNA as a company. This means acting responsibly as an organisation and as individuals and it happens one dicision and one action at a time.

It is as important as good engineering or business education.

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INNOVATIVE – BY BEING CREATIVE CHALLENGERS Our focus is on quality: we strive to help Partners and clients achieve competitive advantage by adding value through our performance and service, and through the quality of our technology. We always keep in mind the “big picture” because we believe it helps us to forecast future needs. We clearly com- municate our holistic innovative perspective and we do our best to be one step ahead of the game at all times. We are willing to take calculated risks to identify the best solutions, without ever compromis- ing ’ quality or reliability of our products and we pursue new and creative ideas that have the potential to make a difference on a global scale. We are passionate about what we do. TRUSTWORTHY – BY BEING HANDS-ON EXPERTS What we do, we do to the best of our abilities. We always aim to be better than expected and build our Partners’ and clients’ trust through the integrity of our actions and words. We strive toalways keep our word and lead by example. We “walk the talk.” Being trustworthy is also about showing consider- ation and respect. We pride ourselves in always being available to our Partners and clients and in al- ways being professional. Being trustworthy also means being prepared to “walk the extra mile”, keeping our promises and delivering on time. We compete fairly and within the bounds of law wherever we are in the world, always acting honourably and treating each other, and our competitors, with respect. We are accountable for our actions and ethical in all things we do. NIMBLE – BY BEING ATTENTIVE SERVICE-PROVIDERS We prioritise support to our trusted Partners’ and clients’. We are flexible and adjustable towards dif- ferent people and cultures and we demonstrate dedication and commitment in all that we do. We encourage and accept concerns and objections, while responding with speed and precission. We strive to react quickly and analytically, so we can make the best and most suitable decision. We keep seeking and gaining knowledge, always striving improve. Being nimble also means being pro-active, seamless and dynamic. We are hard-working and responsive to change – we adapt well to new demands and situations.

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| CODE OF CONDUCT

All employees, managers, clients and partners deserve to work in safe and healthy environment, where they feel supported and valued.

GENERAL EMPLOYEE CONDUCT

Piql works to create and maintain a work- environment free og harassment of any kind.

Employees will notfeel welcome or comfort- able at Piql if they, their colleagues or anyone who has any business dealings with Piql endure harassment or bullying. All representatives of Piql must not engage in such behaviour, or con- duct themselves in a manner that could be con- strued as such. Harassment or bullying may come in different shapes and sizes. People may feel harassed by aggressive or intimidating acts or words, by derogatory jokes or gestures or by unwanted verbal or physical conduct. Harassment may also manifest itself through communication or display of offensive material connected to for example gender, race, religion, sexual orienta- tion, nationality or physical ability. An example would be using inappropriate language, keep- ing or posting inappropriate materials in the work-area, or accessing inappropriate materials on the computer. Harassment in any way, shape or form (verbal, written, physical or electronic) will not be tolerated under any circumstances. Anyone who believes they have experienced any form of harassment should report it as soon as possible, without fear of being further mis- treated.

WORK ENVIRONMENT

It is the joint responsibility of each Piql Em- ployee to contribute to a healthy, nurturing and flourishing work-environment. Piql expects its employees to show respect for one anoth- er at all times, regardless of differing opinions. Piql values fruitful discussions where different opinions are expressed and heard and views it as aneffective tool to make the best decisions so that we can move forward in the desired di- rection. Furthermore, it is expected that Piql employees use the tools and resources available to them always with the best intention in mind. We must all show respect for each others’ time and competencies. For example; only call for meet- ings when it is necessary and only include the

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people who are necessary. Piql also expects its employees to be on time. For example; if you are delayed or prevented from attending a meeting, always inform the organiser at the earliest conve- nience. Piql encourages open and regular communication through meetings, briefings, newsletters, web- sites, presentations and training. Communication between employees and their manager should include making clear how employees are contrib- uting to Piql’s business goals. All employees have the right to receive a review of their performance by their manager, which is expected to ascertain progress and to include proposed plans for further development.

Piql as an organisation is focused on individual and professional development and the well-be- ing of each employee. It is therefore important to ensure that employees receive the required and necessary training and are able to use their skills and talents in the appropriate way. Piql expects all its employees to conduct them- selves in a business-like manner. Gambling, fight- ing/aggressive behaviour, swearing or drinking/ illcit drug use and similar unprofessional activities are prohibited while on the job. We are all members of the Piql Family. It is expect- ed that we all support and respect our colleagues and their aspirations through caring for the envi- ronment in which we work.

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Helping each other to succeed depends, amongst other things, on how we handle positions of authority, have access to privileged information and handling potential conflicts of interest.

It is imperative to report dangerous conditions and other unacceptable health, safety or environ- mental conditions immediately, so that corrective actions can be taken and workplace accidents are minimiszed. Work safely and protect yourselves, your co-workers, the community and environ- ment.

ENVIRONMENTAL RESPONSIBILITY

All Piql employees have the responsibility to com- ply with the letter and the spirit of environmental regulations and laws, especting the environment, wherever in the world they work.

PIQL VALUES DIVERSITY

Piql views diversity as an asset and people are wel- come regardless of gender, nationality, age, reli- gion or physical ability – or any other aspect of diversity. Piql employees and Partners must con- duct business activities with co-workers, clients, stakeholders and business partners with respect for all people without regard to differences or similarities. The organiszation promotes and hires people solely on the basis of their abilities and skills. Piql employees and Partners should not engage in or support discrimination when hiring, compensat- ing, training, promoting, terminating or retiring based on gender, age, ethnic and national origin, caste, religion, disability, sexual orientation, politi- cal affiliation or union membership. It is important to recognise the value each person brings and treat them with respect at all times.

WE RESPECT THE COMPANY’S ASSETS

We are respectful of the organisation’s assets. Piql attempts to provide its employees with the necessary tools and information they need to be effective. It is expected that Piql’s physical assets, intellectual property rights and information are to be handled with care at all times to avoid loss, damage or theft. Information assets are technol- ogies and processes, manufacturing methods, as well as marketing, advertising and business devel- opment studies and plans. Company assets are intended to be used for business purposes. Limited personal use is only acceptable if it does not conflict with the organi- sation’s interests and policies. WE HANDLE INFORMATION SYSTEMS IN A PROFESSIONAL MANNER The organisation’s information systems have the purpose of helping us work more professionally and effectively. In general, such systems should only be used for business purposes and in a way that does not compromise the rights and inter-

HEALTH AND SAFETY STANDARDS

Piql strives to safeguard the health and safety of every employee at work. Piql provides profession- al, clean working environments and equipment, while regularly monitoring conditions.

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ests of Piql. Keep in mind that communication through e-mail could be regarded as a statement of Piql. , Employees must take care not to release information that is commercially sensitive or that could have unwanted contractual or legal implica- tions for the organisation. All laws governing defamation, discrimination or copyright also apply to online and e-mail com- munication. Unauthorised or unlicensed software must not be placed onto Piql’s infrastructure fa- cilities. Information which is stored and produced on Piql’s information system facilities, is regarded as company property and Piql reserves the right to access all such information – except where limit- ed by agreement or law. Furthermore, all employ- ees are responsible for storing and keeping their electronic files and archives in a tidy and orderly fashion. Piql’s information system facilities must not be used to compromise the integrity of the organ- isation or third partys’ networks or data. This includes forwarding or creating chain-letters or spam.

ees must not use their positions or their gained knowledge for private or personal advantage. No matter the circumstances, if an employee be- lieves that a course of action they have pursued, is about to pursue or is contemplating pursuing, might present a conflict of interest with Piql, they should immediately communicate all facts to their supervisor/line-manager. In general, we should avoid situations where personal interests, financial interests, outside activities or relationships pose a conflict with the organisation’s interests.

It is imperative that that we at all times safeguard our business

dealings on behalf of the organisation from being

influenced by personal relation- ships or considerations or any of the situations mentioned above.

CONFLICTS OF INTEREST

Piql expects all employees to perform their du- ties honestly, conscientiously and always with the best interest of the organisation in mind. Employ-

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| CODE OF CONDUCT

RELATIONSHIPS WITH CLIENTS, PARTNERS AND SUPPLIERS

GIFTS, ENTERTAINMENT AND FAVOURS

Employees must not offer or accept entertain- ment, gifts, paymements or personal favors that could, in any way influence, or appear to influ- ence business decisions in favour of any person or organisation that Piql has, or is likely to have, business dealings with (which are not within the bounds of customary business hospitality or which are prohibited by applicable law). Piql will not condone activities of employees who achieve results by breaching the law or any other uneth- ical business dealings. For example: payments for illegal acts, indirect contributions, rebates and bribery. Piql does not allow any activity which fails to stand up against the closest possible pub- lic scrutiny.

Employees should refrain from investing in or ac- quiring a financial interest for their personal ac- counts in any business organisation which has a contractual relationship with Piql, or that provides goods or services, or both, to Piql if such invest- ments or interests could potentially influence or create the impression of influencing their perfor- mance of their duties on behalf of Piql. When you choose or deal with suppliers, you should refrain from showing any preference or fa- vour to any business or person based on anything other than the best interest of Piql. You must pre- vent business dealings on behalf of the company from being influenced by personal or family in- terests. Similarly, all purchased goods and services for the organisation must be made in accordance with organisational policies. WE TEAM UP WITH LIKE-MINDED PARTNERS FOR JOINT ALLIANCES Our success and strength also depend on creating and nurturing long-lasting relationships with busi- ness-partners that share our commitment to ethi- cal principles and that can identify with and incor- porate our values and mission. The standards of any joint venture should align with Piql’s standards and framework outlined in the Code of Conduct. WE EXTEND STANDARDS OF OPENNESS TO LENDERS AND EXPORT CREDIT AGENCIES Piql will disclose all relevant material facts nec- essary for obtaining financing from government lenders or export credit agencies. Piql will dis- close all material facts which would be responsive to critical analysis carried out by any prospective lenders. Any certificate or supporting documents issued by Piql as an export credit agency supplier or exporter, must be signed in accordance with Piql’s compliance regulations and standards.

CORRUPTION AND SECRET COMMISSIONS

Corruption includes a variety of activities, all with the aim to obtain unlawful benefits. Corruption takes on many forms and disguises, one example is favouritism. The most common form of cor- ruption is bribery, and bribery manifests itself in a variety of ways. When defining corruption, we want to use the definition as it is presented in the Norwegian Penal Code:

To request or receive an improper advantage or accept an offer thereof in connection with a position, office or assignment” or “to give or offer an improper advantage in connection with a position, office or assignment.

Corruption undermines democracy, human rights and the proper functioning of an open market economy and corruption imposes heavy costs on societies. The consequences of corruption are potentially very serious and damaging: it can dam- age companies, individuals, societies and it can have damaging effects across borders. Corruption

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can interfere with economic development as well as with efforts to fight poverty to name but a few examples. Piql is committed to avoid and fight corruption in any form, including bribery, and comply with the anti-corruption laws of every country in which we operate at all times. We all share a joint responsi- bility for enforcing our zero tolerance policy to- wards corruption and for continuing to establish Piql as a responsible and open organisation glob- ally.

Clarity, transparency and trustworthiness are important elements of our reputation.

parties or any private sector worker, Piql repre- sentatives must neither promise, offer nor give any undue financial or other advantage (wheth- er directly or indirectly) to obtain or retain busi- ness or any improper advantage in the conduct of business. We always cooperate fully with officials. Nation- al and local governments around the world have specific and varied procurement laws which pro- tect public interests. Such laws generally prohibit offering benefits to individual officials. Any be- haviour that may be interpreted as improperly in- fluencing objective decision making is forbidden. Piql employees and representatives must be truthful and conscientious in their interactions with government officials, as well as adhering to the highest ethical standards whenever business is conducted with government representatives. Whenever dealing with a government, employees and Piql representatives are responsible for know- ing and complying with applicable laws and regu- lations and must not contact government officials on behalf of the organisation unless it is their job.

All business related dealings should be well above the minimum standards required by law. In effect, all employees must make sure that their actions cannot be interpreted as being, in any way, in breach of the laws and regulations governing Piql’s operations worldwide. Employees and represen- tatives must not receive payment or compensa- tion of any kind, except as authorised under Piql’s business and payroll regulations. Piql in particular strictly prohibits acceptance of kickbacks and se- cret commissions from suppliers or others. Piql complies with anti-money laundering rules, which means that we comply fully with all mon- ey-laundering laws worldwide. Employees and representatives must safeguard the intergrity and reputation of Piql by assisting in detecting possi- ble money laundering activities. They should learn to watch out for warning signs (clients reluctant to provide complete information or wish to make paymets in cash).

We do not accept or make improper payments. When dealing with public officials, political

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OPEN AND FAIR COMPETITION

ORGANISATION FUNDS AND OTHER ASSETS

Piql competes fairly and believes in a competitive, free enterprise system because it ensures that our efforts and innovation will be rewarded. Our ac- tions must at all times comply with all applicable laws regulating competition. These laws differs from country to country. However, there is a min- imum standard that can may defined as follows: We compete openly and independently in every market. We do not make any agree- ments (formal or otherwise) with compet- itors to fix or set prices or allocate prod- ucts, markets, territories or clients. We do not obtain or share with compet- itors current or future information about price, profit margins or costs, bids, mar- ket share, distribution practices, terms of sales, specific clients or vendors. We do not act in a manner that unfairly favors or benefits one client over another competing client. 1 2 3

When an employee’s position requires spending organisational funds or incurring any reimbursable personal expenses, that individual must use good judgement on Piql’s behalf to make sure that good value is received for any expenditure. Piql funds and all other assets are purposed for Piql only and not for personal benefits. This in- cludes the use of Piql assets, i.e computers etc. Employees who have access to Piql funds in any form, must follow prescribed procedures for re- cording, handling and safeguarding funds. Piql imposes strict standards to prevent fraud and dishonesty. If employees become aware of any evidence that supports dishonesty and fraud, they should immediately follow the guidelines outlined in the Piql Code of Conduct, so that Piql can promptly make further investigations.

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DEALING WITH OUTSIDE PEOPLE AND ORGANISATIONS

use, store, handle and disclose individual personal information according to Piql’s privacy policies as well as applicable laws. Subject to local legislation, Piql is authorised to supervise the use of e-mail and internet if it is deemed necessary. Employees should not be using the company e-mail account for private matters. All e-mail and internet communications made through Piql facilities are handled as Piql corporate information and may be accessed, retrieved, monitored and disclosed by Piql. Piql always keeps accurate and complete financial records. Integrity of our accounts depends on the accuracy, timeliness and completeness of the entries. All Piql transactions must consequently be fairly and fully recorded in accordance with local authorities and laws governing accounting prin- cipes. Improper or fraudulent documentation/ reporting is illegal and is not accepted by Piql. Piql’s books and records must reflect in an accurate and timely manner all business transac- tions. Employees responsible for financial state- ments must disclose fully and record all assets, liabilities (or both) and must also exercise diligence in enforcing these requirements. Employees must not engage in or make any false record or communication of any kind, whether internal or external, including but not limited to: • False expenses, attendance, production, financial or similar reports or statements • False advertising, deceptive marketing practices, or other misleading representations PIQL RECORDS AND COMMUNICATIONS

Employees must separate their personal roles from their positions and roles in Piql when- ever communicating on matters not involving Piql business. Employees must not use Piql iden- tification, supplies, stationary and equipment for personal or political matters/purposes. When communicating publicly on matters that involve Piql business, employees/represenatives must not presume to speak on behalf of Piql on any topic, unless they are certain that the views they express are those of Piql and it is Piql’s desire that such views be publicly disseminated. Whenever dealing with anyone outside Piql, including public officials, employees/represen- tatives must take care not to compromise the integrity or damage the reputation of either Piql, or any outside individual, business or government body.

PROMPT COMMUNICATIONS

In all matters relevant to clients, suppliers, gov- ernment authorities, the public and others in the organisation, all employees must make every effort to achieve accurate, timely and complete communications – responding promptly and courteously to all proper requests for information and to all complaints.

PRIVACY AND CONFIDENTIALITY

Piql shall be in compliance with laws and regula- tions governing these matters.

The privacy and personal information (be it from employees, contractors, vendors or clients) is to be respected at all times. Employees must collect,

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WHEN IN BREACH OF THE CODE OF CONDUCT

Piql employees and representatives are expected to live by a “zero tolerance” principle. Failure to follow the company policies, will result in a dis- ciplinary action and may as a last resort lead to termination of employment or dissolving of the business relationship with Piql.

Piql expects all employees and Partners to read, acknowledge and follow the Piql Code of Con- duct. In addition, it is expected that Piql third parties, consultants, contractors or anyone assigned to provide temporary work or services for Piql, fol- low the Piql Code of Conduct whenever they rep- resent the organisation. All employees and Partners are required to report any suspected or observed violations of this Code of Conduct or of the law – or if they have been asked to do something that may be a breach of the Code. Reports can be made to your HR-rep- resentative. You may also report possible violations anon- ymously by sending an e-mail to hr@piql.com. Please be aware that anonymous reports may prove more difficult to investigate. However, confidentiality will be upheld and maintained to the fullest extent possible. Retaliation against any employee or Piql representative who in good faith reports a concern regarding illegal or uneth- ical conduct, will not be tolerated. The same ap- plies to any intentional abuse of these reporting processes. It is also a breach of the Code if one does not report a violation or suspected violation that em- ployees and representatives are aware of, or if one refuses to cooperate where an investigation of a possible violation has been initiated. Those who have questions concerning a particular situation, should ask for help by talking to their line-manager or HR-representative. The aim is to voice your concerns early enough in order to re- solve a potentially harmful situation before it es- calates.

For further questions, please contact:

Julie Zetterstrøm HR-Manager, Piql AS E-mail: julie.zetterstrom@piql.com Tel: +47 90 53 34 32

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