This Code of Conduct sets out the values and standards that guide how we act as a company and how we expect to work with employees, customers, partners, and suppliers worldwide. It applies to everyone acting on behalf of Roxen and forms part of our customer and partner relationships.

The Code is principles-based by design. It is meant to be read, understood, and used as guidance in everyday decisions, especially when situations are complex or unclear. When in doubt, we expect people to act with integrity, respect for others, and in the long-term interests of both Roxen and society. When faced with a difficult or uncertain situation, the following questions may serve as a practical guide:

1. Is this consistent with applicable laws and regulations?
2. Does it align with our Code of Conduct, policies, and guidelines?
3. Is it the right thing to do from an ethical perspective, taking into account security, sustainability, and the company’s reputation?
4. Is there a reason to raise or report the matter?

If the answer to any of these questions is uncertain, the situation should be discussed with management or raised through the reporting channels described in this Code.

Scope and responsibility
This Code applies to all Roxen employees, board members, contractors, and consultants, as well as to business partners and suppliers acting on our behalf. We seek to work with partners and suppliers who share our commitment to responsible business practices and who aim to use their expertise, influence, and technology in ways that respect fundamental rights and benefit society.

Integrity and lawful conduct
We conduct our business honestly, transparently, and in compliance with applicable laws and regulations in all markets where we operate. We act fairly and responsibly in all business relationships and do not tolerate corruption, bribery, facilitation payments, money laundering, or other forms of improper influence.

Employees and representatives acting on behalf of Roxen must not offer, promise, give, request, or accept gifts, hospitality, or other benefits that could improperly influence – or be perceived to influence – business decisions. Modest and customary business courtesies may be acceptable where lawful and transparent but must never compromise integrity or professional judgment.

Actual or potential conflicts of interest must be disclosed and avoided where possible. Personal interests must never take precedence over professional responsibilities or the integrity of Roxen’s business. Situations that feel unclear, inappropriate, or inconsistent with this Code are expected to be raised with management.

Respect for human rights and working conditions
Roxen respects internationally recognized human and labor rights and expects these standards to be upheld in all business relationships.

We do not accept forced or compulsory labor, child labor, discrimination, harassment, intimidation, or any form of abuse. Everyone involved in our business must be treated with dignity and respect.

We support the right to freedom of association, including trade union membership and collective bargaining. Safe and healthy working conditions are fundamental, and we do not engage in or support business relationships where serious risks to personal safety are not adequately addressed.

Freedom of expression and independent media
Freedom of expression, press freedom, and the safety of journalists are fundamental to our purpose and to how we choose to conduct business.

Roxen uses the World Press Freedom Index[1], published by Reporters Without Borders (RSF), as an independent and internationally recognized reference when assessing media freedom and related risks in different countries.

In countries classified by RSF as presenting very serious restrictions on press freedom (0–40 points), Roxen will as a general rule not enter into or continue customer engagements. Exceptional cases that clearly support independent journalism may be considered following careful assessment. Explicit Board approval is required.

In contrast, in countries classified as problematic (40–55 points) or difficult (55–70 points), potential customer engagements are considered on a case-by-case basis. Assessments take into account press freedom conditions, journalist safety, the nature and independence of the media outlet, and the specific context and use case. For customers in countries classified as problematic, the reasoning for entering into or continuing a collaboration must be documented, and such engagements are reviewed on a regular basis.

Roxen also reserves the right to decline or discontinue business relationships where there are credible indications of systematic incitement to violence, hate, or discrimination, or other conduct that conflicts with the fundamental rights and principles set out in this Code of Conduct or internationally recognized human rights standards.

We expect our partners to understand and respect this position. Where our principles limit participation in certain markets, we view this as a deliberate and responsible choice. Similarly, we expect our partners to recognize these ethical, reputational, and long-term business implications when considering their own market activities and customer engagements.

Information security, privacy, and data protection
We protect confidential information and personal data and handle it responsibly. Information entrusted to us must be safeguarded and used with care, respecting the privacy and rights of individuals.

Roxen complies with applicable data-protection regulations, including GDPR. More detailed requirements related to information security, privacy, and data protection are outlined in separate policies and contractual agreements.

Safe, respectful, and inclusive workplace
Roxen is committed to providing a safe, respectful, and inclusive working environment where people feel trusted, supported, and able to do their best work.

We expect everyone to act responsibly, respectfully, and with integrity – especially in work-related contexts and when representing the company. Harassment, discrimination, intimidation, or abusive behavior are not accepted.

Wellbeing is central to a healthy and sustainable workplace. Reasonable workloads, manageable stress levels, and a healthy physical work environment are essential to long-term performance and personal health. We actively work to promote balance, recovery, and wellbeing, and we take action when work-related pressures or conditions risk becoming harmful.

Excessive use of alcohol, as well as the use of narcotics or non-prescribed medication, is a serious health and safety concern — whether occurring at work or outside of it. We emphasize responsibility, restraint, and care for one another, and we provide support when needed.

Environmental responsibility
At Roxen, we make conscious and responsible choices in how we operate. As a software company, our direct environmental footprint is limited. Our main areas of impact relate to business travel, office operations, and the services we procure. We therefore focus our efforts where they matter most, including travel decisions, office purchases, and the selection and use of key service providers.

More detailed expectations and practical guidance are defined in internal guidelines and contractual agreements.

Reporting concerns and whistleblowing
Roxen encourages openness and expects concerns about unethical, suspected unlawful, or otherwise inappropriate conduct to be raised. Speaking up early helps prevent issues from escalating and is an important part of acting responsibly and protecting our people, partners, and the integrity of our business.

As a first step, concerns should be raised with the immediate manager or another appropriate contact at Roxen. Many issues can be resolved through open dialogue and established management channels.

If a concern cannot be raised locally, if it has not been addressed appropriately, or if the matter is serious in nature, employees and other stakeholders may report concerns openly or anonymously through Roxen’s whistleblowing process.

An independent external whistleblowing service is available for confidential and anonymous reporting of suspected misconduct, irregularities, or violations of this Code. The service is accessible via the company’s website, available around the clock, in multiple languages, and meets high standards for data security and protection of the reporter’s identity.

All reports are handled discreetly and investigated promptly. Matters reported through the whistleblowing channel are escalated as appropriate and reported to the Board of Directors. Retaliation against anyone who raises a concern in good faith will not be tolerated.

To support effective investigation, reporters are encouraged to provide relevant details where possible and may choose to leave contact information to receive follow-up or updates. Proven violations may result in disciplinary or legal action.

Consequences and accountability
Compliance with this Code of Conduct is a shared responsibility. Everyone acting on behalf of Roxen is expected to understand and follow its principles.

Violations of this Code, or of applicable laws and agreements, may result in corrective measures, disciplinary action, or termination of business relationships, depending on the nature and severity of the issue. Serious breaches may also lead to legal consequences.

Roxen is committed to applying this Code consistently and fairly, with the aim of maintaining trust, integrity, and long-term responsibility in all our relationships.

[1]  Reporters Without Borders (RSF) defines press freedom as: “The ability of journalists as individuals and collectives to select, produce, and disseminate news in the public interest independent of political, economic, legal, and social interference and in the absence of threats to their physical and mental safety.” Based on this definition, RSF assesses press freedom in countries and territories across political, legal, economic, sociocultural, and safety dimensions. The Index scores countries on a scale from 0 to 100, combining quantitative data on abuses against journalists with qualitative analysis of media conditions.