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Code of Conduct

Who are we?

Transforming the video experience for millions of users is our mission at Accedo. We are proud to be a contributing member of the video ecosystem, with our products and services but also with our industry vision, knowing the influence media in general and video specifically have on society today. Our mission statement sets not only the direction for Accedo’s innovation roadmap, it also defines the scale of our impact on the industry and the world. It makes us want to become the most sustainable video technology vendor and to further drive our positive contribution to society.

I am certain that our company values ‘Aspiration, Courage, and Trust’ fully align with this ambition, which I’m looking forward to achieving in the future.

As a global company with 15 offices around the world, we thrive on diversity and are continuously working on enabling a global framework for local entities to leverage and adapt locally while staying true to Accedo’s global culture and strategy. This framework defines our ways of working, from human resources processes to global delivery, as well as our internal policies. In all ways, we seek to act in a fair and honest way towards each other and all our stakeholders, to limit our environmental impact, and to

Michael Lantz, CEO

ensure a safe place for everyone at Accedo to work in. This is of course something we need to improve continuously and we need the support of everyone in the Accedo team to make this program a success.

As part of this global framework, we created the Code of Conduct, to summarise our commitment to the Accedo way of working and to what we stand for as a company. Please read, understand, and follow this Code – and always speak up if you have any concerns.

Thank you for your efforts and contribution!

What do we stand for?

Our core values, Aspiration, Courage, and Trust, are meant to represent who we want to be in this ecosystem.- These are the cornerstones of our identity. They unite us as employees and are our guiding principles in everyday actions, behaviors, and decisions.


ASPIRATION

We dream big while enabling our customers’ long-term success, learning, and innovating along the way. We are driven by growth, our willingness to learn, and by remaining innovative in the way we work. We actively share our knowledge and work together to grow both as individuals and as a company.

COURAGE

Our employees feel empowered to take action and are not afraid to push clients to think outside the We dare to voice our opinions and suggest improvements, always valuing the greater good of the company. We have the courage to always advise customers on the best approach for their business.

TRUST

We rely on each other’s commitment and expertise and use constructive feedback as a vehicle for growth. We are completely honest and transparent in the way we work, and offer our customers 100% commitment. We trust each other to give and receive feedback and use constructive criticism as a vehicle for growth.

Our code of conduct is based on Aspiration, Courage, and Trust

Its sole purpose is to ensure that the way we work is done in a legal, ethical, and respectful manner. It gives us guidance on how to operate, whilst providing clear visibility to all Accedo’s partners, customers, and suppliers on the way we expect them to collaborate with them.

As a global company operating in more than 15 offices worldwide, it is our policy to observe and apply all local rules, laws, and regulations. It is also the personal responsibility of each Accedo staff to adhere to these standards, with the addition of the policies and guidelines described in the Code of Conduct – encompassing Environment, Ethics, Labour & Human Rights, and Sustainable Procurement. Indeed, our responsibility does not end within the border of Accedo, as we also expect our suppliers to follow the same standards and principles within our Code of Conduct.

This Code of Conduct is the foundation of our work, and is to be respected by all Accedo’s staff, to ensure that we are doing our very best – both at an individual and group level – to work in accordance with our values, policies, and customer’s expectation.

Any employee unsure whether their conduct or the conduct of others is in line with this code should reach out to their manager or Human Resources. This code applies to all Accedo’s staff, whether they are permanent or temporarily employed. This code is subject to modifications and may be amended should it be necessary as policies and regulations can evolve over time.

Environment

Public Transport & Company Cars Accedo actively encourages the use of public transport, bicycles, or other environmentally friendly means of transport. To this end, Accedo does not subsidize or provide any company cars anywhere in the world. Offices are placed in locations where public transport (if reasonably available in the office location) can be used for work commute.

Recycling

All offices shall have a recycling process. At a minimum, the following items shall be recycled:

1. Computers, TVs and other electronic or IT equipment

2. Paper, cardboard, or any other similar products

3. Any hazardous material, as applicable (paint, cleaning equipment, etc )

The office admin in each office shall be responsible for executing the recycling process.

Energy Consumption

Being a software company, Accedo’s main use of energy is to power offices and hardware used by employees (TVs, computers, connected devices) – primarily related to office work. The amount of energy consumed in the office follows normal standards for each market, with the following additional constraints:

1. In the nature of Accedo’s business, we produce software for Smart TVs and other big-screen devices. Such devices consume more energy than normal office equipment and should be turned off or put in standby after office hours.

2. All computers should have power save mode enabled, guaranteeing that the computer goes into standby mode if not used.

3. No production servers shall be hosted in any office. Energy-efficient data centers should always be used – Amazon Web Services being the reference cloud provider.


Travel

Travelling can be needed in the context of our business, and the following guidelines are applied:

1. Flights can only be used if corresponding train, bus, or car travel takes longer than 3 hours;

2. We should strive to minimize travel by choosing project attendees from the closest office;

3. Internal meetings that require flight travel should be kept at a minimum. Each larger office shall have at least one video conferencing system to allow for efficient meetings over telecommunications.

Cloud services vs in house hosting

Accedo strives to use Cloud services, as usage of data centers has low climate impact compared to in-house hosting when one considers resource utilization and energy efficiency. It has been researched that Cloud services can use up to 40% less energy than in-house hosting, and such data centers are also able to re-use the heat output as energy, making them more sustainable.

Accedo has chosen Amazon Web Service as our main vendor of cloud services. In order to use other Cloud Service suppliers or vendors, the following rules apply:

● The Cloud vendor must utilize at least 40% of renewable energy

● The Cloud vendor should have energy recycling in place for at least 40% of the data centers used.

Accedo is committed to reviewing its hosting partners on an ongoing basis to ensure constant optimization, which allows us to leverage the right amount of resources needed for our products.

Ethics

We thrive on doing business with ethics. Our commitment to doing what is right is deeply embedded in our DNA for the benefits of our employees and customers. Conflicts of Interest A conflict of interest in the workplace can take many forms, but generally occurs when personal, social, or financial interests are put before the best interests of the company. Conflicts can even arise when Accedo earns a profit from a transaction, for instance when a member of Accedo’s staff or its representatives have a personal, social, or financial interest in the transaction. Actual conflicts must be avoided, but even the appearance of a conflict can be harmful and must therefore be avoided.

Family and other close personal relationships

Conflicts of interest may arise when family or friends are involved. For instance, a conflict of interest can occur if Accedo offers to sell our products or services at a lower price than usual to a family member, a close friend, or a company in which a family member or friend has an >ownership interest. At a minimum, these situations raise serious appearances of conflicts, even when intentions are good.

No business activity related to Accedo should be taken with an employee’s family member or close friend before disclosing this to Accedo’s management. Such business activity will always require written confirmation from CEO or CFO before proceeding. For the avoidance of doubt, this includes all situations when a family member has ownership interest in a supplier, customer, or business intermediary/partner of Accedo, or when Accedo is contemplating awarding business to a family member or a business owned by a family member.

In addition, employees should not supervise a family member, be under the supervision of, or be in a position to influence the salary or conditions of employment, or the expense report, of a family member.

Insider trading

When working for Accedo, its staff and representatives get access to confidential information about our customers, partners, market trends and new technologies. Accedo’s staff and its representatives should avoid any personal investment decisions in companies, public or private, that are influenced by any insider knowledge. Insider trading is forbidden by law, and Accedo will, by law, report any suspicion of insider trading to the proper authorities in each relevant jurisdiction.

Personal relationships with suppliers

Accedo buys many goods and services from others. The selection process for services or goods should be based solely upon quality, delivery, price, service, and need. Additionally, we must take care to ensure that we engage in business with suppliers that carry on their businesses legally and with integrity. Employees involved in the selection or purchase of goods and services from suppliers should avoid situations that could interfere, or appear to interfere, with their ability to make independent decisions regarding purchases on behalf of Accedo. Not only would accepting excessive gifts or entertainment from a supplier create the appearance of a conflict of interest, but it could also constitute accepting a bribe, which is prohibited by international law.

Bribery and Corruption

Anti-corruption Accedo works with customers and partners all over the world and occasionally also with public officials in the territories we are active in. Accedo is following the guidelines of the International Chamber of Commerce regarding anti-bribery and corruption.

Accedo strictly prohibits the following practices (“Corrupt Practices” or “Corruption”) at all times and in any form, in relation with a public official at the international, national or local level, a political party, party official or candidate to political office, and a director, officer or employee of any company or organization, whether these practices are engaged in directly or indirectly, including through third parties:

a) Bribery is the offering, promising, giving, authorizing or accepting of any undue pecuniary or other advantages to, by or for any of the persons listed above or for anyone else in order to obtain or retain a business or other improper advantage, e.g. in connection with public or private procurement contract awards, regulatory permits, taxation, customs, judicial and legislative proceedings.

Bribery often includes:

1. kicking back a portion of a contract payment to government or party officials or to employees of the other contracting Party, their close relatives, friends or business partners or

2. using intermediaries such as agents, subcontractors, consultants, or other third parties, to channel payments to government or party officials, or to employees of the other contracting Party, their relatives, friends, or business partners.

b) Extortion or Solicitation is the demanding of a bribe, whether or not coupled with a threat if the demand is refused. Accedo will oppose any attempt of Extortion or Solicitation and is encouraged to report such attempts through available formal or informal reporting mechanisms unless such reporting is deemed to be counterproductive under the circumstances.

c) Trading in Influence is the offering or Solicitation of an undue advantage in order to exert an improper, real, or supposed influence with a view of obtaining from a public official an undue advantage for the original instigator of the act or for any other person.

d) Laundering the proceeds of the Corrupt Practices mentioned above is the concealing or disguising the illicit origin, source, location, disposition, movement or ownership of property, knowing that such property is the proceeds of crime.

Whistle-blowing

It is the responsibility of all employees to immediately report any suspected corruption directly to the CEO, CFO and VP of HR&O. If either CEO, CFO or VP of HR&O are suspected of corrupt practices, the board of the company shall be alerted.

Sub-contractors and vendors

If a sub-contractor or a vendor of Accedo engages in corrupt practices, with Accedo staff or other entities, Accedo’s CEO, CFO, and VP of HR&O shall be notified and they shall immediately notify the subcontractor/vendor’s top management. If the practice is not actively discouraged and immediately stopped, Accedo shall terminate its relationship with said vendor.

Customers

If a Customer of Accedo engages in corrupt practices, in any shape or form, Accedo’s CEO, CFO and VP of HR&O shall be notified and they shall immediately notify the Customer’s top management or HR/CSR departments. The Customer shall be warned that Accedo does not accept such behavior and an expectation of immediate remedy shall be taken. In most cases, Accedo’s customers are fairly large companies, but Accedo shall still make reasonable efforts at alerting the right individuals in that company. If that Customer has an official whistle-blower policy, such policy shall be followed.

Signals of bribery and corruption

Bribery and corruption can be hard to identify. It is impossible to list an all-inclusive listing of bribery and corruption attempts, however, Accedo’s staff and its representatives should generally be on alert if any of the following occur:

1. A request that a commission or invoice to be paid in cash, in another name, or to an address or bank account in another country;

2. A request from a customer or third party to make donations to a special fund;

3. Requests for unusual business trips, potentially including family members;

4. An unexplained large expense on a travel and entertainment expense report;

5. An agent or third party demanding a higher than normal commission for a transaction; 6. Any agent or salesperson who says he or she is working with a government official to give our company the contract.

Gifts & entertainment

Accedo understands that modest and customary business entertainment and gifts can be a legitimate part of conducting business in appropriate circumstances by, for example, promoting successful working relationships and goodwill. Examples of modest and customary business entertainment and gifts include a reasonable celebratory dinner following the closing of a deal or delivering a project. Excessive business entertainment may be interpreted under various laws as an attempt to “buy” business illegitimately, and should always be avoided.

Gifts

Any gift offered or accepted in a business relationship with employees of a commercial company (not owned or controlled by a government entity) must be infrequent and valued at no more than US $100. If applicable local law sets stricter gift limits than the monetary limits provided here, for example, a RMB 200 or less limit applies to certain gifts in China, the local law must be followed.

During a tender or competitive bidding process in which Accedo is selecting suppliers, Accedo staff and their representatives will not request or accept gifts and entertainment from any bidder or prospective bidder. Similarly, if Accedo is attempting to win a tender or bid, Accedo staff and its representatives will not offer or provide gifts and entertainment to any representative of the company running the bid.

Gifts can include anything of value, including meals or entertainment if the person providing the meal or entertainment is not in attendance. Examples of things that can be considered gifts include bottles of wine, products, tickets to entertainment or sporting events, lodging, discounts on products or services, services, equipment, prizes, transportation or reimbursement of travel expenses, use of vehicles or vacation homes, home improvements, tickets, and favorable terms on a product or service.

As we believe in a diverse and respectful work environment, and sexually explicit, racial, political, and morally offensive gifts and entertainment are prohibited.

Meals and entertainment

Accedo staff may infrequently offer or accept meals and entertainment in connection with a business relationship, as long as they are reasonable and within customary industry practices and if the person paying for the meal or entertainment is in attendance.

Government officials

Stricter and more specific laws and regulations apply when we do business with employees, officials, or representatives of government entities. These stricter and more specific laws also apply to the family members of employees, officials, or representatives of government entities. In many countries, such as China and the United States, government officials are prohibited from accepting anything of value or nothing more than an inexpensive meal or a nominal gift (e.g., valued at less than U.S. $25).

Note that broadcasters can be considered governmental organizations if a government has a majority share in the business.

Violations of how not to act

Violations of these Ethics Policies will be subject to disciplinary action up to and including termination.

Social Ethics & Human Rights

Diversity @ Accedo

At Accedo, we are transforming the video experience for millions of people around the globe. We believe a diverse workforce is critical to do this successfully. At Accedo a “diverse workforce” includes individuals of diverse genders, ethnicities, sexual orientations, religious beliefs, ages, learning and physical abilities, socioeconomic backgrounds, cultural backgrounds, and marital status.

Non discrimination & harassment

Accedo’s workplace is inherently diverse. Our offices employ people from different nationalities, different cultures, and different beliefs. We actively facilitate employees in cross border assignments and relocations, as we believe there is no better way to understand the true benefits of diversity than by experiencing it. It challenges Accedo’s staff and representatives’ own beliefs, which makes us grow as human beings and as a company.

We strive to create a culture of inclusion where all individuals feel respected, are treated fairly, have a reasonable work-life balance, and are offered suitable career opportunities. We strongly value the broad spectrum of perspectives arising from interactions between our diverse workforce and our diverse client base around the world. We expect everyone to treat their colleagues with respect by listening to different viewpoints, opinions, thoughts, and ideas and embracing a culture of inclusion, and do not tolerate any form of discrimination and harassment.

Freedom of Association, Work Environment, and Compensation

Everyone at Accedo has the right to individually decide to join or to refrain from joining any lawful employee organization. We are committed to complying with laws pertaining to freedom of association, consultation, and collective bargaining, and to promoting a work environment that fosters communication, openness, and employee engagement.

Accedo provides employees with compensation and benefits that are fair and equitable for the type of work performed and the local business market where the work is performed. Under no circumstances will employees receive less than the minimum wage required by law. Any local laws providing particular benefits and overtime compensation to employees will be respected. Employees receive full details regarding their pay and deductions for taxes, benefits, etc.

Employee privacy

Being in the industry we are in, we understand the importance of privacy in the digital era. We are committed to providing privacy protection of employee data maintained by Accedo. Every employee has direct access to his/her personal data and can add, correct, or delete data at any time. Employee data will be used only for supporting our company operations and providing employee benefits.

Forced labor and child labor

The employment relationship with Accedo is voluntary, and the terms of employment are mutually agreed on in the employment contract. We prohibit any employment of forced labor or child labor.

Safety, health, and environment

Accedo is committed to providing employees with a safe and healthy work environment. We strive for continuous improvement in our products, services, and processes to minimize waste and protect the environment.

Doing business globally

As a global company, Accedo’s business transactions cross many borders. We understand the risks this may involve and are committed to conduct reasonable due diligence and screening of customers and suppliers to ensure compliance with laws that regulate international trade.

Violations of human rights @ Accedo

Violations of this policy will be subject to disciplinary action up to and including termination.