Code of Conduct

This Code of Conduct encompasses all employees of and consultants to (Employees) companies within the Apply.

1. Fundamental principles
i. All Employees in companies comprising Apply ASA (the “Company”) must practice the utmost integrity and professionalism in their work in the Company’s general running and business activities.

ii. Each Employee in Apply must familiarize themselves with this Code of Conduct and sign to the effect that the Code of Conduct has been read, understood and accepted.

2. Compliance with laws, regulations and internal working practice
i. All Employees must conform to those laws and regulations that apply at any time to the Company. All Employees must also, at all times, abide by the prevailing internal routines that have been determined by The Company, including instructions and authorizations etc. that are connected to the individual’s position.

ii. If an Employee gains knowledge of a situation within the Company that is in breach of this Code of Conduct, then their immediate superior must be notified. The Employee can also choose to notify the board member who has been designated as contact person for such notifications (usually the deputy chairman of the board).

iii. Infringement of laws and regulations applying to the business and the execution of such, or violation of the Company’s instructions and regulations – including the Company’s Code of Conduct - is regarded as a breach of The Code of Working Practice and can impact the Employee’s working relationship to the Company.

3. Duty of professional secrecy
i. All Employees have a duty of professional secrecy in all matters concerning the Company and its customers or other business relations. The duty of professional secrecy also applies after employment by, or board involvement for the Company has been discontinued.
All Employees must sign the Company’s own statement of confidentiality.

ii. Duty of professional secrecy applies primarily to contact with unauthorized persons, including family and friends. Information that the Employee should understand to be especially sensitive should also be treated confidentially in relation to other Employees who have no need of this information in regard to their work. This should not prevent one being able to discuss confidential matters with colleagues when judged to be necessary on grounds of fact.

iii. Duty of professional secrecy has no time limit and must be observed also after any termination of connections with the Company.

iv. Employees must especially observe securities trading law rulings on insider trading, cf. Securities trading law §22-1 - 22-7.

4. Customer and contractor relations. Representation and gifts.
i. Representation on behalf of the Company must be kept within justifiable limits with respect to the Company’s business activities.

ii. Travelling and hotel expenses in connection with work for, or services to the Company must always be covered by the Company.

iii. Gifts or additional benefits which Employees may be offered by Customers, Suppliers or others as a result of their association with the Company, may only be received after written consent has been given by the managing director. The managing director may only receive gifts or additional benefits as a result of his association with the Company after written consent has been given by the chairman of the board.

iv. Each Employee must ensure that gifts or additional benefits received from third parties as a result of their association with the Company, will not lead to the Employee coming under suspicion of acting contrary to the Company’s instructions or laws and regulations stipulated, including taxation provisions.

v. Employees must not receive loans or guarantees from any of the Company’s business connections. Excepted from this are loans and/or guarantees under normal market conditions from business connections who give out loans or guarantees as an ordinary part of their business.

vi. No one is allowed, on behalf of the Company, to give gifts or additional benefits for the purpose of receiving benefits for their own or the Company’s advantage.

5. Corruption, bribes and antitrust.
i. Corruption and bribing shall not occur in the Company.

ii. Employees must exercise particular discretion in all contact with public employees (“governmentals”) so that no undue pressure occurs.

iii. The Company will, as a rule, not utilise agents or middlemen in its business. In those cases where this, nevertheless, is considered necessary and justifiable, such agreements must always be approved jointly by the managing director and the chairman of the board.

iv. If the Company seeks business opportunities in countries and regions which have a high score on the international corruption index, a special approval process (due diligence) for all involved partners and suppliers must be implemented.

v. The Company is committed to free and open competition and will therefore not accept any breaches of the competition and antitrust laws.

6. Legal competency – attestation (Conflict of Interest).
i. An Employee must not take part in decisions or consideration of questions that are of significance to his own part, or to any people close to him in such a way that the staff member is considered to have a special personal, or financial interest in the matter.

ii. Each and every travel expense or other payment to the Company’s Employees must therefore always be documented with receipts and be endorsed by a superior or other authorised person.

7. Human Rights
i. The Company’s Employees shall be characterised by high integrity and ethical business practice, based on a sustainable and socially responsible business philosophy.

ii. The Company has a fundamental respect for all individuals and accepts no discrimination based on sex, race, religion, sexual orientation, age, ethnicity or political opinion.

iii. The Company does not accept child labour and will avoid suppliers who practice this.

8. Publicity and media relations.
All press inquiries of a general nature, which are not affected by confidentiality, will be answered by the board chairman, the managing director or others who, in each particular case, have been designated to speak on behalf of the Company. Each and every statement to the media must be serious and accurate in form and content, thus contributing to an optimally objective image of the Company.

9. Elected representatives
The Company’s Code of Conduct also apply to all board members and other elected representatives in all companies that comprise Apply.

10. Annual revision
The content of the ethical guidelines must be reviewed and assessed at least once annually. In the case of a law or regulation necessitating changes to the ethical guidelines, then this must be carried out as soon as the need arises.