Our Code of Conduct

1. We always comply with the law
2. We guarantee safety
3. We do not tolerate any harassment, discrimination or bullying
4. We respect data privacy and company assets
5. We require ethical business conduct from our partners
6. We compete fairly
7. We do not tolerate any corruption or bribery
8. We avoid conflicts of interest
9. We commit to speaking up

The Purpose of Our Code

We all have a responsibility to work sustainably and follow ethical guidelines in our
everyday work. We make ethically sustainable decisions because we want to treat
our employees, customers, partners, and the environment with respect. This Code of
Conduct helps us all to make responsible choices.

Everyone at Verticom are expected to commit to these ethical guidelines. We also
require commitment from our partners. Always take these ethical guidelines into
account when making decisions. If you are not sure whether something is in
alignment with our Code, please seek support from your supervisor.

Everyone at Verticom are expected to commit to transparency, and report suspected
violations of this Code of Conduct. At the end of this document we will go through
when, how and to whom to report about activities that are in conflict with our ethical
guidelines.

1. We always comply with the law

We comply with all international and local applicable laws and regulations. If we
identify any activities in conflict with the law or company guidelines, we immediately
take action to resolve the situation.

2. We guarantee safety

We prioritise safety and require our partners to commit to similar safety standards
as well. We take responsibility in our own and others safety. We comply with
applicable occupational health and safety legislation, and with the company’s safety
instructions. All managers are expected to provide support to their teams on safe
working habits. If we identify any activities, that are in conflict with laws or company
guidelines, we immediately take action to resolve the situation.

We take responsibility for the safety of our products and services. We make sure that
they are used appropriately and that they are in alignment with all legal
requirements. The data centers we work with are in alignment with the requirements
of the ISO 27001 certification.

3. We do not tolerate any harassment, discrimination or bullying

We all have the right to feel safe and respected at work. At Verticom, we commit to
treating others with respect and kindness. We do not tolerate any discrimination
based on the employee’s gender, education, religion, ethnicity, age, nationality,
personality, sexual orientation or any other characteristics.

We have a zero-tolerance policy for all harassment and bullying. In case we identify
any form of discrimination, harrasment, bullying or other inappropriate activities, we
immediately take action to resolve the situation.

4. We respect data privacy and company assets

We are committed to protect and process business related confidential information
and personal information of our employees and job applicants with care and
consideration. We respect everyone’s right to privacy. We process confidential
information cautiously and share it with only those who have the right to process the
information and need it in their work. Information is backed up by industry-leading
solutions and will never be stored outside of Finland.

5. We require ethical business conduct from our partners

We pursue to build productive, ethical and open partnerships with all of our
suppliers and other partners. We expect our partners to comply with all applicable
laws and regulations, and to commit to the ethical guidelines presented in this Code
of Conduct.

6. We compete fairly

We compete fairly and responsibly in accordance with applicable competetion laws.
All of our employees have to comply with competition laws, regulations, and
company guidelines.

7. We do not tolerate corruption or bribery

We work towards growth and good business with our achievements, not with illegal
or unethical means. We do not tolerate any form of corruption or bribery and comply
with all the anti-corruption laws.

We do not give or receive gifts, favours, or benefits that are not in alignment with our
business objectives. Gifts that are given or received are clearly documented, and they
are reasonable in value and appropriate in relation to the nature of the business
relationship. You should decline and report all offers and requests of inappropriate
gifts, payments, hospitaly, or benefits.

8. We avoid conflicts of interest

All our employees are expected to act according to the company’s interests. A
conflict of interest occurs when your personal interest are or may be in conflict with
the interests of the company. Even the possibility of a conflict of interest may be
harmful for the company. We acknowledge and speak up in case we find ourselves in
a situation of conflicting interests, and recuse ourselves from decision making.

9. We commit to speaking up

In case we have a reason to suspect a breach of these ethical guidelines we are
bound to speak up and report it. We also need to listen concerns brought up by
others, especially when working as a manager. Never assume that someone else has
already reported your concern.

All employees are expected to report all concerns immediately to their supervisors.
Managers and executives have the responsibility to evaluate the situation and
possible actions needed. If needed, we will use external experts in possible
investigations.

We process all reports and personal information with care and considerations, and
keep the reports confidential when possible. Violations of our Code, failure to
promptly report a known violation, or making a false report may result in disciplinary
action up to, and including, termination of employment.