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Code of Ethics and Conduct

Introduction

All directors, officers and employees of Tradedoubler (“the Company”) are expected to be familiar with this Code of Ethics and Conduct (“the Code”) and to adhere to these principles and procedures set forth in the Code.

Tradedoubler has a history of success as a result of fair and ethical business practices. We interact with a variety of stakeholders: advertisers, publishers, suppliers, colleagues, shareholders and regulatory bodies as well as the communities in which we operate. Our relationships and communication shall be honest, fact-based and transparent within the bounds of commercial confidentiality. We value interaction and therefore encourage constructive dialogue with all our stakeholders.

Tradedoubler is committed to establishing mutually beneficial relations with our advertisers, publishers, suppliers and business partners. In our business dealings we expect our partners to adhere to business principles consistent with our own.

Tradedoubler’s Code of Ethics and Conduct contains guidelines on how to act in various situations when representing Tradedoubler in a business context, towards colleagues, conflicts of interest as well as compliance and whistle-blowing.

Core values

Our vision is to be the leading performance marketing partner. We help digital marketers succeed by creating smarter results through traffic, technology and expertise. Our core values –“Collaborative, Analytical, Optimistic, Determined and Daring” form the foundation of our everyday work:

  • Collaborative – we are quick to share learning and best practice and we value open, direct communication. We take personal responsibility for our actions and are proactive in developing solutions; we recognise and celebrate success
  • Analytical – we value analysis and insight because it drives informed decisions and delivers smarter results. Focus is important: we set clear priorities and deliver on them to make a difference to our business
  • Optimistic – we take charge of our own destiny and look for opportunities in the challenges ahead. We are positive: if we apply our collective talents and work hard we will overcome barriers and climb mountains
  • Determined – we are passionate about success. We set objectives, are committed and never settle for mediocrity. We persue our goals and strive to be the best
  • Daring – we are innovative, creative and we take and manage calculated risks. We learn from setbacks: they are a key step on the journey to ultimate success.

Honest and Ethical Conduct

  • Tradedoubler has a zero tolerance policy on bribery and corruption. You are not allowed to accept or offer bribes in any circumstances as set out in Tradedoubler’s Anti-Bribery and Corruption Policy.
  • Tradedoubler has zero tolerance against discrimination or harassments due to gender, ethnicity, nationality, religion, sexual orientation, age, handicap, marital or parental status or political opinion. All employees shall be treated fairly and equally. We will honor and value the abilities and contributions of others, embracing the responsibility and accountability for our actions in this regard.
  • Tradedoubler comply with all applicable laws, rules and regulations. It is the personal responsibility of each employee, officer and director to adhere to the standards and restrictions imposed by those laws, rules and regulations in the performance of their duties for the Company, including those relating to accounting and auditing matters and insider trading.
  • Tradedoubler´s shares are listed on the NASDAQ OMX Stockholm stock exchange. We ensure that information that is provided to the stock market is accurate and reported in accordance with relevant laws, stock exchange rules and corporate governance codes. We are truthful in our financial and non-financial communication and information is given to the best of our knowledge. Our aim is full accountability.
  • In carrying out the Company´s business, employees, officers and directors often learn confidential or proprietary information about the Company and its business partners. Employees, officers and directors must maintain the confidentiality of all information so entrusted to them, except when disclosure is authorised or legally mandated.
  • Our employees are key to our success. We strive to attract, develop and retain qualified and motivated people in a professional, safe and healthy working environment.
  • We treat Tradedoubler´s assets and the equipment we use at work in a responsible manner. Tradedoubler´s assets may not be used for private purposes or personal gain.
  • Based on the risk that you can put yourself and others in dangerous or awkward situations, you must not use or be under the influence of illegal drugs, alcohol or anything similar during working hours.

Conflicts of interest

Conflict of interest may arise if your personal interests compete or conflict with the interests of Tradedoubler. Fidelity or service to the Company should never be subordinated to or dependent on personal gain or advantage. Employees, officers and directors of Tradedoubler are expected to avoid personal activities and financial interests which could conflict with their responsibilities to the Company.

You must not carry on business on behalf of Tradedoubler with relatives and/or other persons that you have a close personal relationship with.

While you are employed or hired as consultant by Tradedoubler you must not take up employment or run your own business outside the Company without the Company´s written approval (from your Manager or HR).

Compliance & Whistle-blowing

The CEO is responsible for implementing these principles and is supported in this by the Group Management of Tradedoubler. Day to day responsibility is delegated to all Managers of the geographies and functions and if necessary through more detailed guidance tailored to local needs. It is your responsibility to make sure that you understand the content of Tradedoubler´s Code of Ethics and Conduct and that you observe these guidelines in your daily work.

Acts that are inconsistent with the Code must be promptly corrected and are subject to disciplinary action up to termination of employment. Employees are encouraged to report violations of the Code by reporting the misconduct by contacting his/her immediate superior, any member of the Group Management or HR at hr.hq@tradedoubler.com.

Regardless of the reporting channel, all allegations of potential violations of the Code that are made in good faith, will receive a swift and fair investigation conducted with the relevant internal and/or external assistance.

Each director, officer or employee must not retaliate against any other director, officer or employee for reports of potential violations. Provision has been made for employees to be able to report in confidence and no employee will suffer as a consequence of doing so.

The Company will inform all concerned whenever there are any major changes or updates in the Code.