Code of Conduct

Last updated: 2022

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

This Rovio Code of Conduct outlines the ethical and responsible behavior standards for Rovio and all Rovio employees and partners.  The Code of Conduct is applicable to all Rovio employees, including the employees of its subsidiaries and the members of 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 is the minimum level Rovio should operate, but the ethical business conduct goes even 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 understands the importance of protecting its end users’ personal data and Rovio has made substantial efforts in reviewing and improving its personal data processing activities. Rovio has spearheaded industry-wide privacy initiatives and is closely following the development of various privacy regulations, including the requirements and evolving interpretations of EU’s General Data Protection Regulation (GDPR). All Rovio employees are expected to process personal data only to the extent necessary and in accordance with the relevant Rovio policies and guidance.  Rovio processes its end users’ personal data in accordance with Rovio’s Privacy Notice: http://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 is a publicly listed company. Rovio must follow securities laws such as Market Abuse Regulation (“MAR”), insider guidelines of Nasdaq Helsinki Ltd and other relevant legislation. Rovio employees must follow securities laws and comply with Rovio insider rules. Rovio has a separate Rovio Insider Guidelines in place that defines the most important rules and restrictions regarding inside information and the use and management thereof. The Insider Guidelines include rules and regulations about prohibited use of inside information, company’s insider lists, disclosure and delayed disclosure of inside information and notifying transactions of company’s management and their closely associated persons and notifying transactions.

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 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. 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.

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 shall respect and promote universal human rights. The United Nations Universal Declaration of Human Rights stands as a benchmark for Rovio. Rovio uses equality and non-discrimination planning to encourage diversity while also preventing discrimination on the basis of gender, age, religious beliefs, nationality, sexual orientation, parenthood or any other reason.

Rovio complies with international ILO agreements and the applicable employment laws in our countries of operation. Rovio shall not use nor tolerate the use of child labor or any working conditions that are not in accordance with international conventions, practices or Rovio’s own ethical standards.

Rovio’s intellectual property (e.g. copyrights, trademarks, utility models, designs, trade secrets, know-how, brands and patents) is one of the most valuable assets 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 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 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 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 internal 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.

Alexandre Pelletier-Normand
Chief Executive Officer