1. The purpose of this Code of Conduct is to communicate our common set of ethical values and business principles to our stakeholders and to give internal guidance in our daily pursuit of Building the Information Society. Neoxen encourages the suppliers and other business partners within its sphere of influence to adopt the principles in this Code of Conduct.
2. Neoxen Systems’ business operations worldwide are based on high ethical standards. Neoxen Systems promotes fair competition in accordance with applicable laws. It is expected that employees compete vigorously and fairly in the conduct of business.
3. In every country in which it operates Neoxen Systems shall abide by the laws and regulations of that country. In situations where the law does not give guidance, Neoxen Systems applies its own standards based on its corporate values and culture. In cases of conflict between mandatory law and the principles contained in this Code of Conduct, the law shall prevail. It is the responsibility of all employees to be aware of relevant laws or to seek legal advice to ensure compliance.

Business Practices

1. Safeguarding Corporate Assets
2. Safeguarding Neoxen Systems assets – both tangible and intangible (such as intellectual property rights) – is vital to Neoxen Systems’ business success. Employees have a duty to use Neoxen Systems assets only for legitimate business purposes and to protect them from loss or unauthorized use. In no event may Neoxen Systems’ assets be used for unlawful or improper purposes.

1. Conflict of Interest
2. In order to operate in a fair and open manner, it is important that every employee and the members of the Boards of Directors avoid any situation or interest which might interfere with their judgement regarding their responsibilities to Neoxen Systems, other employees, customers, suppliers and other partners. Should such a conflict of interest arise, it must be reported immediately by the person subject to the conflict to his/her immediate superior.

1. Gifts and Bribes
2. No gifts or similar benefits may be offered by an employee of Neoxen Systems nor accepted if it is considered as a contravention of any applicable law or code of local business practice. Gifts or similar benefits may only be offered to a third party if modest in value and if they are consistent with reasonable hospitality given in the ordinary course of business. No bribes or kickbacks may be offered to any third party.

1. Political Involvement
2. Neoxen Systems observes neutrality with regard to political parties and candidates. Neither the Neoxen Systems name, nor any resources controlled by Neoxen Systems, shall be used to promote the interests of political parties or candidates.

1. Insider Trading
2. Neoxen Systems expects its employees to act in the way required of insiders, even if they are not in fact registered as insiders. Employees must keep all information and secrets that relate to Neoxen Systems’ present and future business operations strictly confidential. It is prohibited to misuse or disclose to any third party any information about Neoxen Systems’ business operations or information about specific projects.

1. Accounting and Reporting
2. All accounting and reporting by Neoxen Systems must be reported in accordance with generally accepted financial accounting practices and accounting records must give a true and fair view of the financial position. Neoxen Systems shall strive to provide disclosure that is open, fair, relevant, timely and understandable.

Human Rights and Workplace Practice

1. Human rights
2. Neoxen Systems supports and respects the principles set out in the Universal Declaration of Human Rights.

1. Non-discrimination and Equal Opportunities
2. Neoxen Systems hires and treats its employees in a manner that does not discriminate with regard to gender, nationality, religion, race, age, disability, sexual orientation, political opinion, union membership, or social or ethnic origin. Neoxen Systems promotes the idea that all employees shall be treated with equal respect and dignity. Furthermore, we promote a culture of equal opportunities and diversity where appointments to jobs, rewarding and personal success depend on individual ability and performance.

1. Labour
2. Neoxen Systems does not accept child labour nor other forms of compulsory and forced labour. Neoxen Systems supports the freedom of association and all employees have the right to be a member of a trade union and to bargain collectively.

1. Work Environment
2. A safe and healthy working environment shall be provided for all employees.

1. Environmental Practice
2. Neoxen Systems supports a precautionary approach to environmental challenges and a responsible way of conducting our own business operations.

1. Responsibility of Managers and Employees
2. It is the responsibility of Neoxen Systems managers to make sure that both the content and the spirit of this document are communicated, understood and acted upon within their organizations and to encourage employees to reveal behaviour that may be non-compliant with this Code of Conduct. Explicit or implicit approval of questionable actions will not be tolerated. Reports of violations of this Code of Conduct may be made anonymously and in confidence to the General Counsel of Neoxen Systems. Persons reporting violations in good faith will not be subject to retaliation. Failure to act in compliance with the Code of Conduct can result in appropriate disciplinary actions.
3. Neoxen Systems seeks continuous improvement in the way we conduct our business and encourages all managers and employees to take part in this process. This Code of Conduct is a part of the Corporate Responsibility Framework and covers Neoxen Systems’ business operations in all countries. Our Code of Conduct will be regularly reviewed.

1. This Code of Conduct has been adopted by the President and Chief Executive Officer.