Telio Corporate Values

• Innovative: - In Telio we strive to build a culture that inspires innovation and continuous improvement through all fields of our business
• Respectful: - In Telio we respect our customers, shareholders, colleagues and partners by being accountable and committed to deliver results and quality. We emphasize being honest, showing empathy and always being service minded
• Simplistic: - In Telio we strive for simplicity in our communication, operations, product portfolio and development process
• Courageous: -In Telio we dare to think different, dare to do the impossible, dare to challenge the existing, dare to prioritize
• Fun: - In Telio we celebrate the success, achievements and challenges!

Telio Ethical Guidelines

The Telio Group’s reputation and the public’s trust in the company depend on the professionalism and skill of its staff and on maintaining a high ethical standard. This applies with regard to the Group’s business operations as well as the conduct of every individual employee.
All employees are therefore expected to act with due care, integrity and objectivity, and to refrain from actions that might diminish the public’s confidence in the Group. The Telio Group has drawn up a corporate code of ethics in the form of normative principles and guidelines with respect to the conduct of Telio staff.

Scope of application

• The code applies to all employees. This includes, as appropriate, members of steering groups and controlling bodies in connection with the performance of their duties to the Telio Group.

• Within these guidelines, the term “close relation” refers to the spouse or cohabiting partner of an employee, and the parents, siblings and children of an employee or his/her spouse/cohabiting partner. “Close relation” also refers to businesses in which the employee or any of his above-mentioned relatives hold a controlling interest. Additionally, and subject to special assessment, there may be other affiliations which according to their nature may be deemed a “close relation”.

Relationship to other regulations

• The requirements set out in Telio’s corporate code of ethics are minimum requirements. The Telio Group shall comply with all applicable laws and regulations, such as competition legislation and laws/regulations concerning corruption and money laundering. It is the responsibility of each employee to ensure that they comply with statutory requirements.

Competence and authority

• All decisions must be taken at the correct level and by the correct person within the organization in accordance with the applicable rules relating to the award of authority. An employee can only commit the company vis-à-vis another party if he/she has been specially authorized to do so. Employees must always act within the limits of their powers.

Confidentiality

• All staff employed by the Telio Group are subject to a confidentiality pledge not to disclose any business-related or private information they receive in the due course of their work for the Group, unless they have a statutory right or obligation to disclose such information. The confidentiality pledge also covers information concerning the Group’s business operations and other matters of a proprietary and confidential nature. Confidential or classified information received in the course of employment must never be disclosed to a third party or used for personal gain.

• The obligation of confidentiality covers the disclosure of information not only to external companies, but also to affiliated companies within the same group if they have no need for such information in the course of their work. The obligation of confidentiality remains in force after the employment or contract has been terminated and for as long as the information is considered to be competition sensitive or confidential in any other way.

Loyalty and conflict of interests

• Telio staff must refrain from conduct that might diminish the trust in their impartiality, and never take part in discussions or decision-making processes concerning issues that involve a conflict of interest, or other matters that might affect the faith in their objectivity. In such cases no pressure must be brought to bear on other parties within the Group.

• If there is potential for personal interests to influence decisions in a matter for which an employee carries professional responsibility, the employee’s superior officer must be asked to discharge the employee of this particular duty.

Relationship with business associates, competitors and public authorities

• While in the company of Telio Group’s customers, contractors or other associates, Telio’s employees must never put themselves in a position which might preclude objective conduct.

• Contractors must be treated impartially and fairly. All contracts must be awarded according to the Group’s established guidelines and procedures. Telio’s employees must never abuse their position in order to achieve special benefits from Telio’s contractors. Employees must distance themselves from and combat any unethical business practices.

• The Group’s competitors must always be treated fairly and professionally. Telio’s employees must never cause or contribute to a breach of general and special competition regulations, such as illegal price fixing, illegal market division, or other offences against the current competition legislation.

• Support for sports clubs, cultural and voluntary associations must be treated in accordance with these ethical guidelines as far as appropriate.

• Telio expect contractors and partners to follow ethical guidelines of a standard similar to Telio’s code of ethics.

• Public bodies must be treated correctly and openly.

Information and reporting

• Unless otherwise agreed, corporate information should be divulged to the public only by corporate management or designated public relations officers. All information from the Telio Group must be accountable and correct, and maintain a high ethical standard.

• Telio’s corporate reporting practices must comply with current laws and regulations and provide full, reliable and correct information.

Gifts and other benefits

• Gifts or other gratuities of a personal character must never be accepted if they may diminish the recipient’s integrity or may be perceived to do so, to his/her or Telio’s detriment.

• This applies similarly to the employees’ close relations if the gratuity is based onTelio’s employment. If in doubt, employees must raise the matter with their immediate superior. Gratuities are acceptable only if won by the company for the benefit of all employees in all or parts of the country.

• Travel, accommodation and/or courses attended on contractor’s invitation, and paid for by contractor, are subject to approval by the immediately superior director. Stringent requirements apply with respect to professional content and benefit. Journeys and events at which Telio’s staff are the only guests, should generally be paid for by Telio. The character of any such travel, accommodation and/or course arrangements must never diminish the integrity of the recipient, or be perceived to do so, to the detriment of the employee or Telio.

• Activities that may be referred to as customary entertainment, must never influence a decision making process.

• The employee’s superior officer must be informed in advance of any entertainment/ gift offered by contractor. While involved with an enquiry or negotiation process, employees must refrain from any such attention afforded by affected bidders.

• Gifts presented on the Group’s behalf must keep a sober level, never giving cause for concern about the Group’s motivation and the recipient’s integrity. No gifts may be presented on behalf of the Group for the purpose of gaining reciprocal personal benefit.

• Gifts of considerable value must never be presented/received. Gifts valued above the minimum threshold for taxable income, currently NOK 1,000, must be approved in writing by the head of the business unit or the Group’s chief executive.

Corporate affairs

• Employees must never enrich themselves from the company’s material or immaterial values, such as property or other assets, special knowledge, methods, concepts and ideas. Employees must never make unreasonable use of the company’s IT equipment, materials or other assets for private purposes or for activities of no relevance to the work. The Group’s rules and guidelines for maintaining data safety must be observed at all times.

• Telio should be a good and professional employer offering an inclusive working environment. Employees must therefore treat everyone with respect and integrity during the course of their work. Employees must never demonstrate improper conduct towards colleagues.

Personal affairs

• The scope and character of external offices and positions held must never have a negative bearing on the employment or conflict with the Group’s business interests. Group staff require their employer’s consent to be able to work for, hold directorships in, run, or hold a considerable stake in businesses that operate within the same sector as a Group company or which is a business associate of any such affiliated company.

• Office bearers for political groups, trade unions etc., to carry out their duties in accordance with laws and agreements, and organize their work to restrict the inconvenience caused to the Group.

Human worth, reputation and trust

• Group staff must never at any time act in a manner which debases human worth or which may harm the company’s reputation and trust.

• Consequently, any employee who travels on company business in Norway or abroad must refrain from buying or receiving sexual services. This ban extends to the employee’s own time whilst traveling on business.

Notification of non-compliance

• Telio has drawn up a procedure in accordance with the Norwegian Working Environment Act for the notification of non-compliance within the business. Such notification should be submitted in case of non-compliance with:

• • Criminal law

• • Other statutory requirements or exclusions

• • Instructions and guidelines, including the corporate code of ethics

• Notification should also be submitted if conditions fail to comply with standards that are generally considered to be reasonable or ethically acceptable. Notification is chiefly to be submitted through the official channels. Alternatively, notification may be submitted in writing to the main safety delegate. Notification of non-compliance involving the Group’s chief executive or other corporate managers must be submitted in writing to the Chairman of Telio’s Board of Directors.

Follow-up and sanctions

• Managers at all levels have a special responsibility to ensure that they and their staff behave in accordance with the code. Every employee must at all times consider their own actions in relation to the rules. If there is doubt whether an action is ethically sound, the employee must refrain from such action or raise the issue with his/her immediate superior.

• The Head of Human Resources (CFO) is responsible for making these ethical guidelines available and for facilitating training and updating.

• Employees in breach of Telio’s corporate code or guidelines must be prepared for sanctions that reflect the nature and extent of their breach, and in a worst-case scenario for their contract of employment to be terminated by a notice to quit or immediate dismissal.