ROVIO CODE OF CONDUCT 

Introduction and Applicability

At Rovio Entertainment Oy (“Rovio”) our aspiration is to delight the world. Rovio brings delightful cross-media family entertainment, memorable stories, and long-lasting brands to the world by combining world-class creative talent with technological excellence. 

One of the most important means is to ensure that our creative and innovative business is conducted in an ethical manner and all our fans have fun and entertaining experiences. 

Thus, Rovio is fully committed to the highest standards of ethical behavior and shall conduct business ethically, transparently, and in full compliance with all applicable laws and regulations.

Rovio’s principles of doing business are:

  • Delight
  • Trust
  • Respect 
  • Quality
  • Compliance

This Code is applicable to Rovio and all of its subsidiaries. All Rovio’s employees including directors and officers shall follow this Code without exception. Further, Rovio’s expectation is that all independent consultants, suppliers, licensees, and other third parties who do business with Rovio comply with this Code. If a non-compliance of the Code is discovered, Rovio reserves the right to take disciplinary action. 

Ethics and Legal Compliance

Rovio’s objective is to pursue a long-term profitable and sustainable business in an ethical and responsible manner. The applicable laws and regulations are the foundation of this Code including, for example, prevention of bribery and corruption, antitrust and promotion of fair competition, labor conditions, privacy, processing of personal data, and good corporate governance. 

However, at Rovio the ethical business conduct goes even beyond the applicable laws and regulations. Our behavior is our business card and wherever we go or are seen we want to show a deep sense of responsibility and demonstrate the highest integrity. This is everyone’s duty at Rovio and an integral part of managing our business operations and brands.

Anti-bribery policy

Rovio has a separate anti-bribery policy in place that covers also gifts, hospitality and conflict of interest. Rovio has a zero-tolerance approach to bribery and other corrupt practices. 

Employees shall not give or receive gifts or hospitality to/from current or potential suppliers, customers, or other Rovio stakeholders unless a gift or hospitality is given or received during the ordinary course of business and, in all circumstances, is of moderate value. Cash gifts are never acceptable. Local laws and national regulations take precedent if these are stricter than Rovio’s own anti-bribery policy. 

Rovio’s employees must avoid any activity that may lead to a conflict of interest, i.e. in a situation where personal interest is or may be inconsistent with or opposed to Rovio’s best interest. Additionally, Rovio’s employees shall not use his/her position to obtain personal gain or a gain for others with whom the employee has a significant relationship. The best interests of Rovio shall always be observed. 

Any kind of bribery and corruption is prohibited in Rovio’s business operations. Rovio and its employees shall not pay nor offer to pay bribes or any other illicit payments to government officials or other parties to obtain or retain business. 

Antitrust

Rovio shall in all its business dealings comply with applicable antitrust legislation. Antitrust legislation is designed to ensure existence of competition in the market. For example, the following acts are always prohibited: price fixing among competitors, licensees and/or resellers, market/customer allocation, and sharing of sensitive information (e.g. roadmaps, prices, R&D projects, and contract terms). 

Respecting and Promoting Human Rights

Rovio shall respect and promote universal human rights. The United Nations Universal Declaration of Human Rights stands as a benchmark for Rovio. Rovio views, among many others, the following human rights as fundamental: freedom of thought, opinion, expression, religion and peaceful assembly; freedom from discrimination on any grounds; and freedom from arbitrary detention, execution or torture. 

Rovio shall not use nor tolerate the use of child labor or any working conditions that are not in accordance with international conventions, practices, and Rovio’s own ethical standards. 

Employee Health & Safety 

Rovio employees shall respect the Rovio values and ways of working and always comply with this Code at work. 

Rovio is committed to providing equal opportunity for each employee and treat employees fairly and impartially. Rovio promotes and expects each of its employees to promote teamwork, diversity, and open communication. 

Rovio strives to provide a safe, inspiring, and fun workplace for its employees. Accordingly, it is every employee’s responsibility to conduct his/her duties in a manner that does not endanger health and safety in the workplace.

Suppliers, Licensees and other Business Partners 

Rovio requires its suppliers, licensees, and other business partners to comply with all applicable laws and regulations. Furthermore, Rovio encourages and expects each business partner to act ethically and in a socially and environmentally sustainable way. Rovio shall make every effort to ensure that all business partners fulfill Rovio’s expectations. Rovio reviews business partners’ compliance prior to any business engagement, and it always incorporates the criteria into its agreements and continuously reviews the partners’ performance and compliance.

Environment

Rovio complies with all applicable environmental and health and safety legislation. Rovio is committed to using environmentally friendly means to conduct business and operate in a manner that enhances sustainable development. 

Protecting Rovio’s Assets and Information

The assets include both proprietary information (e.g. intellectual property, roadmaps, and other sensitive business information) and physical assets (e.g. cash, computers, and other equipment). Each employee is required to ensure that in his/her daily work Rovio’s assets are safeguarded in a proper manner and are used only for legitimate business purposes. 

Rovio’s employees create and have access to sensitive business information, including information on its business partners. It is every employee’s responsibility to keep such information confidential and ensure that information shall be properly protected and not be disclosed in an unauthorized manner. 

Accuracy of Records and Reports

Rovio keeps accurate and transparent records and reports. Each employee must ensure that all records and reports are prepared honestly, timely, and accurately. Any attempt to create misleading records or reports is strictly prohibited.  

Implementation

To ensure the full implementation of this Code, each employee must promote and comply with every aspect of it. Any questions or clarifications relating to this Code should be directed at an employee’s superiors or the Legal Department.

Employees who encounter a potential violation of this Code have an obligation to report it to his/her superior or to the General Counsel. All potential violations shall be investigated in a fair manner. An employee who has violated this Code is subject to disciplinary action including, but not limited to, termination of employment. Rovio will make sure that there will be no consequences for employees who bring attention to any violation of this Code.

Kati Levoranta
CEO