1.0 Code of Conduct

mnemonic is a market leader and expert of information security. mnemonic’s business requires trust from customers, authorities, business partners, shareholders and the society at large. Furthermore, it is important for our customers' view of mnemonic as a serious and reliable company, that we follow relevant laws, regulations and principles for good business practice.

In order to gain confidence and trust, we are dependent on professionalism, high standard for quality and skill, as well as high ethical standards at all levels. This applies both to mnemonic’s business operations and to the way everyone at mnemonic acts.

Our Code of Conduct describes our ethical guidelines and applies to all employees in mnemonic. In addition, suppliers and business partners who do business with mnemonic are expected to comply with our Code of Conduct.

1.1 Ethical standards

mnemonic shall be an organisation with a high ethical standard. We will act in an ethical, fair and professional manner in all contact with our customers and business partners. To ensure that mnemonic and our employees have the same ethical standards, we have established a Code of Conduct and a set of ethical principles. The ethical principles are a part of mnemonic's governing documents, and is the framework for how we behave and what mnemonic stands for. In addition to this document, employees must also be aware of and follow internal rules, guidelines and routines, as well as the laws and regulations that set limits for our business.

It is expected that employees at mnemonic shall adapt to and follow ethical guidelines in other companies when providing services there.

Managers at all levels have a responsibility to ensure that their and their employees’ behaviour is in accordance with mnemonic's ethical rules, and are responsible for reporting violations of ethical rules to the CEO.

1.2 Whistleblowing

mnemonic has routines that safeguard our employees' rights if they report having experienced or witnessed unacceptable conditions and wrongdoings. Whistleblowing is an important principle for mnemonic and society as a whole, in order to stop and correct these circumstances. Employees are therefore encouraged to disclose any circumstances that may violate our internal rules, guidelines and ethical standards, and are obliged to report criminal matters and conditions in which life and health are at risk.

Principles for handling whistleblowing cases:

• All inquiries shall be taken seriously
• All inquiries shall be responded to immediately
• Anonymity is possible - anonymous sources can be just as valuable as open sources
• The different methods of notification must be valued equally
• Confidential treatment
• The warning system must be able to be used without fear of consequences
• Alerts must be received within a reasonable time

Examples of situations where notification is necessary are violations of legal provisions, internal rules and guidelines or ethical norms such as bullying, harassment, discrimination, substance abuse, poor working environments, conditions that threaten human life and health, dangerous products, malnutrition, corruption, theft, fraud and financial infidelity in the service, etc.

1.3 Combating economic crime and corruption

Economic crime is detrimental both to those affected and to society. mnemonic strives to protect customers, owners and the society from economic crime and corruption.

mnemonic shall comply with applicable laws and regulations on bribery, corruption, fraud and other prohibited business practices. We shall not offer or provide a disproportionate benefit or service to a government official or other third parties, directly or through an intermediary. We will not offer customer representatives bribes, entertainment or gifts to influence how they do their job. We shall also not demand or accept bribes or other erroneous payment to act ourselves or refrain from performing our duties.

mnemonic strongly oppose all forms of money laundering, and have implemented controls to prevent our financial transactions from being used by others for money laundering. Employees (especially employees who work with banking activities or similar assignments) are expected to be familiar with Norway's law on measures against money laundering and terrorist financing (the Money Laundering Act).

1.4 Discrimination and anti-harassment

Competent and motivated employees are vital to mnemonics’ success. In order to ensure that everyone can make full use of their talents we shall welcome, listen to and respect the ideas of people from different backgrounds.

At mnemonic, everyone shall be treated with fairness, respect and dignity. We do not tolerate any form of abuse, harassment, intimidation, bullying, degrading treatment or sexually offensive behaviour by or towards employees or others affected by our operations. Comments or any other forms of offensive messages, derogatory remarks or inappropriate jokes are unacceptable.

Our employees shall expect a workplace free from discrimination and we shall demonstrate tolerance for employees' and other stakeholders' attitudes and opinions. We do not tolerate discrimination against any employee, partners, customers or other stakeholders on the basis of age, gender, sexual orientation, disability, race, nationality, political opinions, religion or ethnic background, or any other basis prohibited by law.
All those who feel discriminated or harassed shall be taken seriously.

1.5 Confidentiality of information

mnemonic is committed to protecting confidential information. This is at the very core of our business and fundamental for the trust we seek and are given by our customers and business partners dealing with information security. We will not misuse information belonging to ourselves or any of our business partners.

All employees and others who act on behalf of mnemonic have a statutory duty of confidentiality concerning customers, employees and other business or private matters that they become acquainted with in connection with their work. This applies unless they are obliged or encouraged to disclose information by law or internal guidelines. The duty of confidentiality also applies between the individual companies in mnemonic, and to others in the same company who do not need to familiarise themselves with the information in their work.

It is the individual's responsibility to process information correctly.

1.6 Conflicts of interest

At mnemonic, we work actively to identify and handle actual or potential conflicts of interest. We are open and transparent about possible conflicts of interest and have processes to identify and manage them.

We expect our employees to be concerned about discovering circumstances that may create conflicts of interest, either for you or for your colleagues. A conflict of interest may occur when personal relationships, participation in external activities or interest in another venture can influence or could be perceived to influence a person’s decision making when acting for mnemonic. They may result from personal ambition, financial or business commitments, membership of an organisation, family members or personal relationships. We therefore encourage employees to follow our guidelines, and not let personal or financial interests get in the way. If an employee experiences an ethical dilemma, he or she is encouraged to talk to their immediate supervisor.

1.7 Antitrust/anti-competitive practices

mnemonic competes in the market with respect for, and in accordance with, current competition and marketing legislation. We shall at all times operate in accordance with general and/or special competition regulations, such as illegal cooperation on pricing, illegal market sharing or other behaviour that violates competition laws. Employees are expected to be familiar with Norway's law on competition between companies and control between business associations (the Norwegian Competition Act).

Employees also expect to be familiar with Norway's law on copyright in intellectual property, etc. (Copyright Act), to prevent re-use of documents or images that have copyright, as well as to prevent violations of license and patent rules.

1.8 Health, safety and environment

mnemonic shall be a safe and great workplace. Work with health, safety and environment (HSE) shall be visible and involve everyone, and at the same time make it clear where to turn for assistance when necessary. The general manager and other managers must be clear and concise when they communicate their expectations on how each individual will contribute to a great working environment. In addition to being an attractive workplace for all employees, mnemonic must be an industry leader in low sickness absence and achieve a high score in employee satisfaction surveys.

mnemonic wants to work actively to protect the environment. We want to be perceived as an environmentally conscious organisation, and will demonstrate this to our customers, suppliers and other stakeholders by the way we operate our business. mnemonic follows the standard given in the Eco-Lighthouse, and has been certified since 2010. Our work with Eco-Lighthouse shall inspire employees to have a conscious attitude to energy consumption and waste management at work and home as well.

2.0 Human rights and labour

mnemonic is committed to conducting its business with respect for internationally recognised human rights. We support and respect internationally proclaimed human and labour rights, including the UN Declaration and International Conventions on Human Rights, the OECD Guidelines for Multinational Enterprises, the ILO Declaration on Fundamental Principles and Rights at Work, ILO’s core conventions and the UK Modern Slavery Act.

mnemonic will not use child or forced labour and will not tolerate working conditions or treatment that is in conflict with local and international laws and practices. We have a zero-tolerance approach towards modern slavery and human trafficking.

mnemonic shall ensure that the company, through its operations, does not cause any infringement of human and labour rights. The company has implemented effective systems to minimise risks of human and labour rights infringements in our own operations, in our supply chain and among our business partners.