Code of Conduct

VALUES

1. LONG-TERM COMMITMENT

We are committed to sustainable development and it is the objective for our business. At the same time, it is a stance for how we develop our own company. We act in a way that we believe will render us long-term success, rather than cashing in short-term simply by copying others and doing what is politically correct or the current trend. We have the courage to take the lead, review and challenge prevalent opinions. With our long experience we have a unique opportunity to be in the front line, and thus we shall, in order to promote and contribute to sustainable development in the best possible way. Our own history is a living proof of this: When we started our business 15 years ago, responsible investment was almost considered a contradiction in itself. Today “the impossible” has become reality, embraced by the world wide organizations and an important part of the institutional communities around the world.

2. INTEGRITY

We strive to objectively assess companies in all markets around the world. For this, our independence is absolutely vital. We are politically, religiously and financially independent and have no strings to organisations with a political agenda. Since we have no owner interests or other third party interests that can influence our analysis or advice, we can limit the risk of being prejudiced and favoring special interests. We apply international guidelines which constitute a common frame of reference since they are widely recognized and have gained approval during a long time period. Decisions are based on facts, and we put every effort possible into collecting information from and consulting with a wide range of sources in order to avoid “condemning anyone without being heard”.

3. RESPECT

We are aware that life is not “black and white” and therefore we are humble when facing the complexity of the issues we deal with and the business reality of the companies. We show respect towards different viewpoints, and never condemn anyone. We do more listening than talking and believe this is an essential part of learning and building competence, which is crucial for our professionalism and credibility. We assess and give advice in a constructive manner, focusing on both positive and negative information.

4. RESPONSIBILITY

We take responsibility for both large and small duties and execute them thoroughly and completely. We assist each others when needed and possible. We take initiative to get things done. We deliver high quality to clients which ensures that we can be proud of our products and services both today and tomorrow. We are loyal to our company and support decisions made, thereby increasing the value of our work and enhancing opportunity for success.

PRINCIPLES

1. LEGAL COMPLIANCE

In every country in which we operate, we shall abide by the laws and regulations of that country. In situations where the law does not give guidance, we apply our own company standards based on our values and culture.

2. RELATIONS WITH BUSINESS PARTNERS

Our dealings with business partners are characterized by fairness and honesty. We market our company and services by demonstrating our strengths and advantage S3Tel, never by slandering competitors or nor acting in any other distrustful way. Our employees must not accept payments, gifts, or other kinds of reimbursement from a third party that could affect or appear to affect their objectivity in their business decisions. All information on clients and their operations, obtained as a result of an agreement with S3Tel. Inc. shall be kept secret and confidential in accordance with S3Tel. Inc.’ Confidentiality Policy and each employee shall annually be updated on the policy and undersign a confidentiality agreement.

3. TRANSPARENCY

We encourage an ongoing dialogue with clients, employees and other stakeholders and will strive to actively provide them with relevant, accurate and timely information, with due consideration to business interest.

4. CONFLICTS OF INTEREST

Our employees and board members shall conduct their private, financial and other external activities in a manner that does not conflict or appear to conflict with the interests of the company. Should such a conflict of interest arise, it must be reported immediately by the person subject to the conflict to his/her immediate supervisor or the Managing Director or a board member. Each employee shall annually be updated on S3Tel Inc. Policy on Transactions with Personally Owned Stocks and declare their ownership and transactions. Clear guidelines on the abuse of privileged or confidential information, on any form of bribery, on the handling of gifts, shall be worked out and signed of by all collaborators.

5. ENVIRONMENT

We strive to continuously reduce our climate impact by focusing on our two most significant impact areas: travelling and energy consumption. We practice the precautionary principle by avoiding materials and methods posing environmental and health risks when suitable alternatives are available.

6. HUMAN RIGHTS

Within our sphere of influence, we support and respect the protection of internationally proclaimed human rights including labour rights. We hire and treat our employees in a manner that does not discriminate with regard to gender, race, religion, age, disability, sexual orientation, nationality, political opinion, union affiliation, social or ethnic origin. Freedom of association and the right to collective bargaining and agreements are respected. We provide all employees the necessary conditions for a safe and healthy work environment. We encourage our employees to maintain a healthy work-life balance. To reach this goal our employees have the opportunity to work part time, work from home and/or plan their work days in a way that best suits their family and private life.