TANDBERG Ethical Guidelines

TANDBERG core values shape our corporate culture and are an integral part of our Ethical Guidelines. TANDBERG core values are:

• Speed & Precision
• Integrity & Enthusiasm
• Exceed Expectations
• Fun & Profit
• TANDBERG First

Our values, along with our integrity, are fundamental to our reputation and our success. To safeguard our values and integrity as we grow, we have developed a set of Ethical Guidelines. TANDBERG Ethical Guidelines apply to members of the Board of Directors, TANDBERG employees and others acting on behalf of TANDBERG. These Guidelines are in addition to TANDBERG's policy to comply with all applicable laws and governmental rules.

• Diversity. TANDBERG encourages diversity and believes it is an asset to the Company. People with diverse backgrounds and perspectives are critical to innovation, and innovation is critical to TANDBERG’s success.
• Equal opportunity — no discrimination. All employees shall have equal access to opportunities whatever their gender, race, religion, sexual orientation, nationality, age or disability. TANDBERG will recruit, employ and promote employees on the sole basis of their ability to fulfill the requirements of the job. You shall help create an environment with equal opportunity and without discrimination.
• No harassment. Our workplace must be free from bullying, harassment or similar behavior. We do not tolerate any behavior that can be perceived as degrading or threatening to any person.
• Safety. TANDBERG shall provide all employees with a safe and healthy work environment. You shall play an active role in identifying and rectifying unsafe situations.

Should a conflict of interest arise, you shall on your own initiative evaluate and notify your immediate supervisor to the actual or potential conflict of interest.

• Duty, positions and ownership of external businesses. Engagement in external duties and positions must not affect your working relationship with TANDBERG or come into conflict with TANDBERG's business interests. As an employee of TANDBERG, you shall not hold another paid position or carry out work for yourself or others during working hours without prior express written permission from your superior.
• Political activity. TANDBERG does not make contributions to political parties or participate in election campaigns. This does not restrict the freedom of our employees to participate in political activities as individuals.

• Inside information. As a publicly listed company, TANDBERG is subject to strict rules concerning the handling of non-public information that may affect the market price of TANDBERG shares and other financial instruments that may be issued by TANDBERG. If you have or receive information that may affect the stock price, you shall not trade in the financial instrument/share before the information has been made public or ceases to be sensitive. You must not provide such information to anyone, directly or indirectly, except those who have a real need for the information in order to perform their duties on behalf of TANDBERG. For more information, please see the Insider Trading Policy and the Inside Information Instruction.
• Confidentiality. You shall keep confidential all corporate and other matters that could provide third parties with unauthorized access to confidential information and exercise caution when discussing internal affairs to avoid being overheard by unauthorized persons.
• Information, communication and contact with the media. All of those who, through their work, deal with public information must make sure all information from TANDBERG is reliable and correct.
• Internal reporting. You must make a diligent and good faith effort to ensure the accuracy of internal reporting of any sales results or other transactions for which you have responsibility. Your reporting of such results or transactions constitutes your representation that the figures provided are correct to the best of your knowledge and not the result of any inaccurate or misleading information nor based on any improper sales or fraudulent transactions.
• Financial reporting. Financial reporting shall in all material respects comply with applicable laws and regulations and be full, fair, accurate, timely and understandable. The annual accounts and interim accounts shall be in accordance with the law, IFRS and good accounting practice.

• Competition. TANDBERG wants fair and open competition in all markets. Under no circumstances shall you cause or be part of any breach of competition regulations, such as illegal cooperation on pricing, market sharing arrangements or any other behavior that is in breach of relevant competition laws.
• Suppliers. Suppliers shall be treated impartially, justly and fairly.
• Corruption and bribery. TANDBERG is firmly opposed to all forms of corruption. You shall never offer or accept illegal or inappropriate monetary gifts or other remuneration in order to achieve business or personal advantages for TANDBERG, yourself or others. Nor shall you use agreements with middlemen to channel payment to anyone in such a way that may be interpreted as corruption or money laundering.
• Gifts and business courtesies. You shall always exercise caution in relation to offering or accepting gifts and business courtesies. You shall not accept gifts or other remuneration — either from external or internal parties — if there is reason to believe that its purpose is to influence business decisions. If in doubt, consult your immediate supervisor. Gifts received as a TANDBERG employee that do not violate the guidelines above are to be handled as TANDBERG property and not as your personal belongings.

• Authority. All decisions shall be made at the appropriate level in accordance with the applicable regulations concerning authority. You may only obligate the Company vis-à-vis others if you hold such special authority, and you must at all times keep within the limits of your authority.
• Property and assets. The group's equipment and property may only be used for personal purposes with prior approval from your supervisor.

• Reduce energy consumption, CO₂ emissions and traffic congestion by letting the user avoid unnecessary travel. Improve quality of life for the user.
• Can be recycled or disposed of safely at end of product life.
• Comply with all relevant environmental legislation.

• No reprisals. TANDBERG will not permit reprisals of any kind against those who, in good faith, report an infringement or suspicion of an infringement of these Ethical Guidelines.
• Consequences. If a violation has occurred, TANDBERG will take such disciplinary or preventive action as it deems appropriate.
• Questions. Any questions relating to how these guidelines should be interpreted or applied should be addressed to TANDBERG's General Counsel.
• Exceptions. Any changes to or waivers of these Ethical Guidelines for executive officers or directors or other employees of TANDBERG may only be made by the Board of Directors.

You are responsible for ensuring your own behavior conforms to these Ethical Guidelines. As a member of the TANDBERG team, you are also entrusted with preserving the high level of integrity that is a hallmark of TANDBERG. You are encouraged to go above and beyond these Ethical Guidelines in your daily conduct.