Code of Conduct

Rovio Entertainment Corporation (“Rovio”) is a global, mobile -first games company that creates, develops and publishes mobile games. Rovio is best known for its global Angry Birds brand, which started as a popular mobile game and has since evolved from games to various entertainment and consumer products in brand licensing.

Rovio is incorporated and registered in Finland and is the parent entity of the Rovio group companies ( “Rovio Group”). Rovio is directly owned subsidiary of Sega Europe Limited (“SOE”) a private limited company that is directly and wholly owned by Sega Corporation (”Sega Corporation” or “SOJ”), that, in turn, is directly and wholly owned by Sega Sammy Holdings Inc. (“SSHD”). SSDH and its group companies are referred to as the “Sega Group” in this document.

This Rovio Code of Conduct outlines the general principles of ethical and responsible behavior standards for Rovio and all Rovio employees and partners. There are additional sub-policies defining specific areas in more detail as set out in this document. The Code of Conduct and sub-policies are applicable to all Rovio employees, including the employees of its subsidiaries and the members of the Board of Directors. Each person to whom this Code of Conduct applies is expected to know and follow this Code of Conduct. Rovio also expects that its consultants, freelancers, suppliers, licensees, and other partners comply with this Code of Conduct or similar guidelines.

Rovio culture is a sum of Rovio’s shared beliefs, purpose, values and behaviors. When conducting our business, all Rovio employees are expected to commit to our values:

Rovio conducts its business ethically, transparently and in compliance with all applicable laws and regulations. Compliance with laws and regulations is the minimum level Rovio should operate, but the ethical business conduct goes beyond the applicable laws. Our behavior is our business card and wherever we go or are seen we want to show a deep sense of responsibility and to demonstrate the highest integrity.

Rovio appreciates the importance of protecting its end users’ personal data and invests in continuously reviewing and improving its data processing practices. As part of its privacy governance, Rovio has designated a Data Protection Officer to oversee matters related to data protection and instructs all Rovio personnel to process its end users’ personal data in accordance with applicable laws and regulations as well as relevant Rovio policies and guidance. To maintain a progressive stance on privacy, Rovio has spearheaded industry-wide privacy initiatives and closely follows regulatory developments in the privacy landscape, including the evolving interpretation of the EU General Data Protection Regulation (GDPR). Rovio processes its end users’ personal data in accordance with its Privacy Notice, which is available at https://www.rovio.com/privacy.

Rovio shall in all its business dealings comply with applicable antitrust legislation and promote fair competition. Sharing or communicating sensitive or confidential information (e.g. roadmaps, prices, development projects, products, financial analyses, business models or contract terms) or otherwise aligning with competitors without solid business grounds is prohibited. When sharing such information with solid business grounds, a written confidentiality undertaking (an NDA) is to be concluded. Rovio employees are expected to follow the Rovio Fair Competition Guidelines when discussing with industry peers.

Rovio shall maintain good corporate image and communicate openly, directly and with integrity. All media relations are handled by appointed individuals at the Communications department.

Rovio has a separate Anti-Bribery Policy which covers matters such as bribery, gifts, hospitality and potential conflict of interest situations. The Anti-Bribery Policy is applicable to all Rovio employees, including the employees of its subsidiaries and the members of the Board of Directors.

Rovio has a zero-tolerance approach to bribery and other corruptive practices. When it comes to gifts and hospitality, Rovio 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.

Rovio encourages and expects each of its business partners to act ethically and in a socially and environmentally sustainable and responsible way. Rovio has zero tolerance towards bribery and other corruptive behaviors also from its partners. Rovio is carrying assessments of its partners and contractually require the partners to act in accordance with this Code of Conduct or similar guidelines. Rovio also has specific Partner Code of Conduct for licensing partners requiring Rovio branded goods to be produced in an ethical and responsible manner, respecting the human and labor rights as well as the environment. Rovio is also auditing the compliance of its partners.

Social responsibility and personnel

Satisfied employees are essential for successful business. Rovio wants to be an employer that adapts to employee’s life circumstances and supports their individual growth and career development. Rovio has a Nordic workplace culture; the work is done within normal working hours and employees are encouraged to build a healthy work-life balance, which also helps to maintain their work ability. Rovio supports e.g. the reconciliation of work and family life by providing remote work opportunities and flexible hours.

Rovio places a high priority on making work rewarding and ensuring inclusivity in the workplace. 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. Employees are expected to respect each other and Rovio has zero-tolerance on bullying or other disrespectful behavior.

Rovio’s intellectual property (e.g. copyrights, trademarks, utility models, designs, trade secrets, know-how, brands and patents) is the most valuable asset for Rovio. Rovio is actively protecting its intellectual property and it is also every Rovio employee’s responsibility to protect Rovio’s intellectual property and physical assets (e.g. cash, computers, and other equipment) and ensure that sensitive information shall be properly protected. Licensing, giving rights or access to Rovio’s intellectual property to third parties always requires an applicable written agreement approved by the legal department. When commissioning creative work from contractors, suppliers, freelancers or other partners, a written agreement must be concluded to ensure the assignment of the work results to Rovio.

Rovio is committed to safeguarding the confidentiality of its own and its partner’s business information. All Rovio employees are expected to be aware that all confidential documentation and business-related information disclosed to third parties without proper business purpose and confidentiality undertaking may cause serious harm and have an adverse effect on Rovio’s business and competitive position.

Rovio also respects the intellectual property and confidential information of others. All Rovio employees should avoid using any unlicensed or unauthorized assets of third parties and ensure that we always have a valid license for the usage.

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

The most significant environmental impacts of the gaming industry are related to energy consumption, both in the game development stage and while gaming. Compared to other forms of digital gaming, gaming on mobile devices consumes approximately one tenth (a typical smartphone) or half (a tablet device) of the electricity consumed by a laptop computer during gaming. Rovio actively monitors the environmental impacts of the suppliers of the server capacity required by mobile games as well as the measures they take to mitigate these impacts. Rovio strives to pay increasing attention to the environmental impact of its operations, such as the energy efficiency of business premises and the reduction of air travel.

Rovio has high quality systems and infrastructure to ensure information security and cybersecurity to protect confidential business information from any modification, disruption, destruction or other unlawful access by third parties. All Rovio employees are expected to follow the internal guidelines and policies regarding the information security and to protect Rovio, its employees, customers, partners and other stakeholders from information security risks. Rovio business is dependent on information systems and with proper information security we can ensure confidentiality, integrity and availability of Rovio’s data.

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. Rovio has implemented appropriate controls to represent its financial data accurately and consistently. Rovio is committed in complying with applicable laws and regulations that cover its financial reporting.

Anyone who encounters or suspects a potential violation of this Code of Conduct has an obligation to report it without any undue delay to his/her supervisor, Rovio’s General Counsel, legal or human resources department or issue an anonymous report via Rovio’s Whistleblower tool or report by sending an email to whistleblowing@rovio.com (the email is automatically forwarded to the General Counsel).

All potential violations shall be investigated in a fair manner. An employee who has violated this Code of Conduct may be subject to disciplinary action including, but not limited to, termination of employment. Rovio shall ensure that no retaliatory action, discrimination or other unfair treatment will follow from reporting in good faith of suspected breaches or to persons who are suspected of alleged breaches. Rovio encourages openness and will support anyone who raises concerns in good faith under this Code of Conduct, even if they turn out to be mistaken.

To ensure the full implementation of this Code of Conduct, each employee must promote and comply with it. Any questions or clarifications relating to this Code of Conduct should be directed at an employee’s supervisor or the legal department of Rovio.