Funcom Corporate Code of Ethics

Funcom's Corporate Code of Ethics is discussed and reviewed by the Supervisory Board ("The Board") on an annual basis.


1. Introduction

Our attitude to ethics

Funcom's corporate Code of Ethics emphasises that all co-workers and the Group's Board of Directors shall maintain high ethical standards when performing their duties. The Code of Ethics has been distributed to all our partners and agents. We expect them to live up to the same ethical standards as we expect of ourselves. The efforts to generate enthusiasm and an open discussion about ethics and ethical dilemmas have a natural place on the agenda at Funcom. Considerable focus is being placed on our international activities.

Ethics Council

The Board has appointed an Ethics Council to ensure a high level of ethical awareness, good behaviour and a good reputation in and for Funcom. The Ethics Council shall maintain and further develop the corporate Code of Ethics, and give recommendations and advice on dealing with ethical dilemmas. The Council has the following composition:

  • CEO, who also chairs the Ethics Council
  • Managing Director, Funcom SE


2. Corporate Code of Ethics

The corporate code of ethics is primarily a tool to govern Funcom's corporate conduct and culture. Our fundamental values are based on integrity, honesty and reliability within Funcom and in relation to all our stakeholders. These values shall be the very essence of all our conduct. A good reputation for reliability is of the utmost importance for our business activities. Both within and outside the Group, our relationships shall be characterised by candour and confidence. Funcom shall conduct its business activities in an ethical and socially responsible manner. Funcom’s reputation shall secure support for our views, ensure new recruitment and help us retain employees, while safeguarding our credibility with stakeholders. Funcom's corporate code of ethics applies to the directors, management, regular employees and all personnel hired on project basis. All of them are to be familiar with the code. The code will be distributed to all employees and attached to all future employment and consultancy contracts. Our corporate code of ethics will also be attached to agreements associated with the signing of any agent contracts.

Each individual manager is responsible for ensuring the code is reviewed and communicated throughout his/her own unit and to new employees.

Funcom is subject to Dutch, Norwegian, US, Chinese, Canadian and Luxembourgian legislation, regulations and conventions. An attempt has been made to take that into account in the following. Funcoms corporate code of ethics document is divided in three:

  • Internal relations
  • Stakeholder relations
  • Follow up and treatment of non-conformance


2.1 Internal relations

Human value: For those who work for Funcom, all people are equal. We will not accept discrimination of any kind, e.g. due to gender, race, religion or sexual orientation.

Working environment - Personnel policy:  Funcom is to be a good, stimulating place to work and is to have an inclusive working environment. We are to conduct ourselves with integrity, showing respect for colleagues and others we meet in the course of our work. Discrimination, bullying, harassment or similar behaviour will not be tolerated.

Health, Environment and Safety (HES): Funcom devotes attention to health, safety and the environment to ensure a healthy working environment and the greatest possible well-being for our employees. Relationships between employees Funcom has a large number of employees, and it is possible that employees will enter into relationships with each other. Such relationships shall be brought to the attention of an immediate superior if one party has a supervisory function for the other, or if other circumstances entail that the relationship could affect their work.

Conflict of interest: Funcom shall respect individual employees' right to a private life and private interests. All employees are expected to be loyal to the Group and the Group's interests. Employees shall not participate in financial or business-related activities that could potentially involve a conflict of interest between the Group's interests and his or her own or a close third-party's interests.

Professional secrecy: We have an obligation of professional secrecy in respect of all business matters and other situations that could give outsiders access to confidential information. Basically, all business matters not made public are to be considered confidential. Caution shall also be exercised when discussing the Group's internal affairs in front of outsiders.

Price-sensitive information: As Funcom is a listed enterprise, we are subject to stringent regulations regarding information that could affect share prices. Here, too, the rule is that all information not made public is confidential. If you are in any doubt about how to behave, please contact your immediate superior or Corporate Communications.

Whistleblowing: All employees shall have the possibility of reporting alleged irregularities of a general, operational and financial nature in the Company to the chairman of the management board or to an official designated by him, without jeopardising his/her legal position. Alleged irregularities concerning the functioning of management board members shall be reported to the chairman of the supervisory board. Funcom has implemented a whistleblowing policy.

Intangible values: Funcom's intangible values are important to us. They include our knowledge, ideas, structures and working methods. These values shall be safeguarded and managed in the best interest of the Group. By the same token, we will show respect for the corresponding values of others.

Political activity: Funcom maintains a neutral position on party politics and supports no political parties or their candidates. However, we reserve the right to participate in the public debate when doing so is of commercial significance for the enterprise.


2.2 Stakeholders relations

Customers: All our customers shall be treated with respect, integrity and understanding. We shall deal with customers' needs in the best possible manner within the business and ethical parameters that apply to Funcom.

Suppliers: Suppliers shall be treated impartially and fairly. They can rest assured that they compete for Funcom contracts on an equal footing with other providers.

Society-at-large: Funcom aspires to be a responsible corporation in terms of its employees and the communities in which it operates. Funcom shall show respect for cultures and religions in the countries in which it operates.

Corruption: Corruption undermines all sorts of business activities and free competition. Corruption would erode our reputation and expose the Company and the individual to risk. Funcom is opposed to all forms of corruption.

Gifts: Caution shall be exercised in giving and accepting gifts or other enticements that could affect business decisions. However, the rules of common courtesy are to be followed.


2.3 Follow up and treatment of non-conformance

Some of the topics mentioned in these guidelines may involve formidable dilemmas.

If you are in doubt, or uncover circumstances not in accordance with these guidelines, notify your immediate superior. If the situation cannot be discussed with your immediate superior, report it to the Group's Ethics Council.

If you wish to discuss a matter anonymously, you can so by sending a letter directly to the Ethics Council at the Company office address. Mark the envelope "Ethics Council".

Funcom will tolerate no form of reprisals against anyone who, in good faith, reports a violation or suspected violation of this code.