Opera Ethical Code of Conduct Opera Software ASA

Transcription

1 Opera Ethical Code of Conduct Opera Software ASA

2 Dear Opera Software colleagues, Every day, we are faced with ethical challenges and dilemmas. This is a natural part of life and work. What matters at the end of the day is how we conduct ourselves when we relate with or meet our colleagues, our business partners, clients, journalists or users. It is vital that we remember that the conduct we as Opera employees show the world, can be the one interaction that forms the perception of the company as a whole. Our vision, which our employees have been instrumental in creating, describes what should guide us every day: We are shaping an open, connected world We champion an open internet We strive to bring the web to everyone We enable content and commerce We create value through partnerships We shape with love and craftsmanship We bring technology to life We believe that an open, connected world powered by great technology and services is essential to break down barriers that limit access to information, education and fun. Our culture is playful, people-centric and innovation-driven, and our goal is to improve communication for the benefit of everyone. We must always ask ourselves if our way of meeting a customer, a user, a colleague or a journalist matches the content of our vision, and whether we, by our way of acting on behalf of Opera, can bring our vision statement even more to life. In the following pages, you can read our Ethical Code of Conduct, which applies to all staff members, in all Opera offices and departments, all over the world. This code has been put in place to help employees, clients and business partners understand the values and standards of Opera. For more specific and detailed descriptions, employees can check out our even more detailed guidelines in the Opera Employee Handbook. We should all study the Opera Ethical Code of Conduct to ensure that we perform our role and duties in accordance with it. Together, we make up the image and face of Opera, and our conduct is essential to make Opera the great company it is today and the fantastic company it will be tomorrow. Sincerely, Tove Selnes

3 Opera s Ethical Code of Conduct The Ethical Code of Conduct applies to all staff members, in all Opera Group offices and departments. 1 Our vision Everything we do is guided by our vision: We are shaping an open, connected world We champion an open internet We strive to bring the web to everyone We enable content and commerce We create value through partnerships We shape with love and craftsmanship We bring technology to life We believe that an open, connected world powered by great technology and services is essential to break down barriers that limit access to information, education and fun. Our culture is playful, people-centric and innovation-driven, and our goal is to improve communication for the benefit of everyone. 2 Promoting human rights Opera Software ASA respects and observes internationally-proclaimed human rights. Opera ensures that it is not complicit in any human right abuses. Respect for human rights is a core value for our company. Opera helps millions of people across the globe to connect to the Internet. Freedom of expression and privacy are fundamental human rights. Moreover, these rights are fundamental to facilitate the meaningful realizations of other human rights, such as the right to access information. At Opera, we strongly believe in these human rights, and will strive to protect them for our users, employees, partners and other stakeholders. The open internet, including the web, has true potential as an open communication platform that enables users globally to exercise their freedom of speech. Conversely, new technologies can be used to invade citizens privacy. Opera will take the required measures to protect their users basic right to privacy. Opera believes that people should be treated with respect at all times. We strongly condemn discrimination. Instead, we promote tolerance and freedom of expression. Opera recognizes the freedom of association and the right to collective bargaining.

4 Opera is an equal-opportunity employer. We insist on fair, non-discriminative treatment for all employees, in recruitment and in selection for promotion or training opportunities, irrespective of race, color, nationality, age, sex, sexual orientation, gender identity, ethnic origin, marital status, disability or religion. Individuals at every level share responsibility for maintaining a culture that is built on open, supportive and positive relationships, free from prejudice, stereotyping and unfair bias. Opera does not directly or indirectly use child- or compulsory labor. Our employees have the right to a healthy and safe working environment, and it is our goal to foster a positive and motivating environment, where it is a joy to come to work. We greatly value input from our employees to improve the work environment. Opera Software is a proud signatory to the United Nation s Global Compact. 3 Our conduct Employees All employees must adhere to the existing laws and regulations, contractual obligations, internationally acclaimed human rights and the demands that good business conduct and commonly approved personal conduct require. Cases of doubt and cases of principal importance must be settled by the company s CEO. Our work environment Opera Software is committed to a safe and healthy workplace. Employees are expected to comply with safety and health laws and regulations that apply to our business activities. Opera staff members must not be under the influence of drugs or alcohol while carrying out his or her work. Our employees shall not be subjected to harassment or other improper conduct that might be perceived as threatening or demeaning. Discrimination on the basis of gender, age, religion, political views, nationality, ethnicity, sexuality, living arrangements, disabilities or culture shall not occur at Opera. Employees are expected to practice cultural sensitivity in online and offline communication, with co-workers, partners and users alike.

5 Management Managers are responsible for making employees aware of the Ethical Code of Conduct, as well as ensuring that employees adhere to the rules, regulations and principles therein. They should also be able to provide advice on how to understand and interpret the guidelines. Within particularly vulnerable areas of operations, the supervisors in charge must assess the need for further clarification in the shape of more extensive guidelines. Feedback and training Opera view our employees as our most valuable resource. Therefore, we expect and deliver feedback regularly and constructively. All Opera staff members shall receive the proper training, relevant to their position, so they can execute their work in the best way possible. Interaction with other parties Supervisors and employees must act in a confidence-inspiring and respectful manner towards business partners and others they meet in connection with work. The company does not accept harassment or any other conduct that might be perceived as threatening or demeaning. Opera shall ensure that our clients and business partners are familiar with our Ethical Code of Conduct. Complaints and input from our clients and business partners shall be dealt with in an efficient manner, as these people are considered as valuable resources in our continuous work to deliver high quality products. Confidentiality All Opera employees are bound to confidentiality, as stipulated in their non-disclosure agreements. During the working relationship, employees have an obligation to full confidentiality and the protection of company information, which includes technical, administrative and business-related relationships of which he/she will be aware during service for the company. The obligation to full confidentiality will also exist after termination of the contract. It is forbidden to, directly or indirectly, give information regarding this matter to a third party. Other employees within the company will also be considered as third party, if they have no right to know or no need to know the information in question. Opera respects and protects information obtained from or relating to our business partners and clients, as well as personal information about our staff, in accordance with Norwegian law and professional standards. Opera does not use personal information for personal gain. The duty of loyalty Acting or behaving in ways that may be harmful to Opera s interests is considered to be a breach of loyalty. All employees are expected to treat any sensitive information regarding coworkers, customers, job applicants, and other work relations with loyalty. Breach of loyalty may be grounds for termination of employment; for managers or leaders, there are higher demands than subordinate employees.

6 Conflict of interest Opera s employees must neither directly nor indirectly have personal business-related contact with contractors who work within his/her area of responsibility, without approval from the relevant supervisor. No employees must work on or deal with any matter in which they themselves, their spouses, partners, co-habitants, close relatives, or any other persons with whom they have close relations, has a direct or indirect financial interest. Employees must avoid any conflicts between their own interests and those of the company. For that reason, no one should participate in or try to influence matters for which special conditions pertain that could diminish confidence in the person s independence or impartiality. Outside work and activities Opera s employees are knowledgeable, caring and have initiative. No wonder we are attractive for outside work and activities. However, we have to be aware of the risk for conflicts of interest between our personal interests and Opera s interests as a company. We resolve this by transparency. All Opera employees should notify their manager about any outside work or activities that are not personal in nature, such as being member of the board of your building society, your kids school or sports team. Any outside work or activity that might cause a conflict of interest has to be approved by your manager. Examples include; to be on any Board of Directors, an advisory board, industry organization, a committee or any honorary office. Freedom of speech Freedom of speech and blowing the whistle on malpractice, fraud, illegality, breaches of rules, regulations and procedures or raising health and safety issues is encouraged at Opera. Whistleblowing Staff members at Opera may blow the whistle either in person or anonymously to the Work Environment Committee. The person making the report must, as a main rule, state his/her identity to ensure that clarification/follow-up questions are provided to the person making the report. However, the identity of the person making the report will be confidential and known only to the people necessary to ensure that the case is handled properly. If the person making the report does not wish to specify his/her identity, reporting may take place anonymously. Anonymous reporting should take place only in exceptional cases, as it will be difficult for the company to follow the report up properly. Any Opera staff member making a whistleblowing report is protected from any repercussions, such as dismissal and other forms of reprisals. To improve communication and ensure that issues do not escalate to the point where they become a whistleblowing case, Opera focuses on the following aims: 1. Communicate the company s norms, values, and rules and regulations regarding ethical conduct. 2. Create an open atmosphere by making sure that staff members have the opportunity and possibility to meet and discuss issues in formal and informal settings.

7 3. Discuss and put questions regarding freedom of speech and whistleblowing on the agenda in internal communications. 4. Ensure that there is a Work Environment Committee in place that meets regularly to discuss issues. 4 Anti-corruption Opera Software abstains from and works actively to combat corruption and bribery. Corruption distorts economic decisionmaking, deters investment, undermines competitiveness and, ultimately, weakens economic growth. There is no single, comprehensive, universally accepted definition of corruption. Therefore, each Opera employee must adhere to the existing laws and regulations in their country of operation. As a minimum, the following rules apply to all Opera employees. Controls will be made to ensure that these rules are followed. Bribery No person acting on behalf of Opera shall attempt to influence someone in the conduct of their post, office or commission by offering an improper advantage. Nor shall improper advantage be offered to anyone for the purpose of influencing third parties in the conduct of their post, office, or commission. This includes all forms of facilitation payments. Correspondingly, no person acting on behalf of Opera shall request, accept or receive improper advantage in connection with his/her position or assignment or for the purpose of influencing a third party. Improper advantage can take different forms, including but not limited to money, objects, credits, discounts, travel, accommodation and other services. The use of middlemen Opera Software could be held responsible for corrupt and fraudulent activities carried out by our middlemen. For this reason, we need to ensure that our middlemen do not commit corrupt or fraudulent acts on our behalf. In cases where it is necessary for Opera Software to be represented locally by an independent sponsor, consultant, broker, agent or any other middleman it shall be done in accordance with the Internal Authority Guidelines for Opera Software ASA. These rules include among other things: The demand for a written agreement, with two signatures from Opera Software ASA The middleman must be credible, reputable and reliable Kickbacks are prohibited A transparent conduct is demanded throughout

8 The middleman must act according to Opera Software s anti-corruption guidelines. We must further be aware of the following red flags: The lack of transparency in the middleman s conduct The middleman may not be willing to confirm that he/she will not take unlawful steps Irregular payment patterns Irregular size of payments Fees are not proportionate to the services provided His/her business reputation and record Insider trading Opera employees are prohibited from trading in Opera securities based on information that is material, nonpublic information; that is, the public does not yet have access to this information, and this information may be deemed interesting for an investor to use when deciding whether to buy or sell securities. This rule also applies to other companies, where Opera employees may have access to such nonpublic information. Please note that even a tip to family and friends is considered illegal, if this should be used as a basis for buying or selling securities. Money laundering Money laundering is the process of concealing illicit sources of money. Opera employees are forbidden to engage knowingly in transactions that facilitate money laundering or result in unlawful diversion. Gifts It is a normal part of business life to exchange business courtesies, such as meals, transportation, recreation, facilities or small gifts. Such an exchange of business courtesies must always follow local laws and regulations and not put any Opera employee in the position of a sense of obligation to return the favor, compromise professional judgment or create the appearance of compromise or corruption. Opera employees should always check with their manager or the HR department, if in doubt, and consider whether the exchange of business courtesy would be acceptable if it should become publicly known. No person acting on behalf of Opera is allowed to accept any amount of cash or cash equivalents (such as gift certificates or market securities and similar), regardless of sum. Correspondingly, cash or cash equivalents may never be offered by Opera employees as a business courtesy, regardless of sum.

9 Political contributions The company must, as a main rule, not make any contributions in support of political parties. Exceptions to this rule may be made only by the company s CEO. If such a contribution is made, it will be done in a transparent way. 5 Protecting the environment Opera Software understands the importance of supporting the environment. For this reason, Opera has adopted an environmental policy to indicate the company s mission of preventing any negative environmental impact of its activities. Opera shall: Act according to environmental laws to limit the environmental burden on earth, air, water and ecosystem. Commit to using environmentally safe products in the workplace. Educate staff about company environmental regulations. Evaluate the consumption of energy and other resources to determine means of control. Ensure the development of environmentally protective procedures. 6 Breaches Concerns about possible breaches should be discussed with a supervisor or the Human Resources department directly. Management and HR are obligated to handle suspected breaches with discretion and respect for the privacy of those involved. A violation of these guidelines will result in disciplinary action up to and including termination of employment. Note that several of the guidelines concern actions that are also punishable offenses, such as the harassment of co-workers and corruption. In the event of such a breach, the relevant authorities may also be notified. Changes to the Ethical Code of Conduct will be presented in writing by the Human Resources department, as amendments or corrections to this document. 7 Questions or suggestions? If you have any questions regarding the proper conduct in a certain situation, or if you need assistance to take the appropriate action, please feel free to talk to your manager or call or send a request to the HR department at hr@opera.com. If you have suggestions for improvements of this Ethical Code of Conduct, you may direct your suggestions to internal-comms@opera.com