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Code of conduct

Last updated: June 4, 2026

1. Introduction

Catacloud AS (‘Catacloud’) strives to conduct business in a manner, based on the duty to respect human rights, labour rights, protect health, safety and the environment, prevent corruption and apply decent business practices. We endeavour to contribute to a more sustainable world, both for our planet and for its inhabitants. We strive to implement sustainability in all our operations and in our day-to-day business. To achieve this, we need to cooperate with our suppliers, intermediaries and business partners.

This Code of Conduct (the ‘CoC’) sets out the principles for responsible business conduct expected in all operations in which Catacloud are involved, and applies to all suppliers, business partners, intermediaries and other partners directly linked to Catacloud ‘s business (commonly referred to as ‘External Partners’). We expect our External Partners in turn to make their partners aware of this CoC.

This CoC is based on the Universal Declaration of Human Rights, ILO’s core conventions on fundamental principles and rights at work, the UN Sustainable Development Goals, the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. The requirements implemented in this CoC establish minimum standards. Where conventions, national laws and regulations relate to the same subject, the highest standard shall always prevail.

2. Act with integrity and in compliance with applicable rules, regulations and policies

All External Partners undertake to conduct their business operations in an ethical manner by maintaining a culture of integrity, honesty, transparency and compliance.

In addition to adherence to this CoC, all External Partners shall comply with applicable local, national and international laws, rules, regulations and requirements in the provision of goods and/or services manufactured for or provided to Catacloud.

3. Social responsibility

3.1. Respect for human rights and workers' rights

Catacloud commits to protecting and respecting fundamental human rights and labor rights of everyone affected by our operations. Catacloud expects its external partners to be equally committed to respecting internationally recognized human rights and labor rights.

External partners shall ensure that all services, products, and other deliveries to Catacloud are produced under conditions that comply with the requirements in the "Social Responsibility" section. This includes ensuring compliance with this code of conduct within the external partner's supply chain.

In this code of conduct, "human rights and labor rights" are defined as those internationally recognized human rights and labor rights set forth in international treaties, including but not limited to the United Nations Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights of 1966, the International Covenant on Civil and Political Rights of 1966, ILO Conventions No. 29 and 105, ILO Conventions No. 87 and 98, the United Nations Convention on the Rights of the Child No. 32, ILO Conventions No. 138 and 182, ILO Conventions No. 100 and 111, and the United Nations Convention on the Elimination of All Forms of Discrimination against Women.

3.2. Freedom of Association

External partners shall ensure that all employees and workers have the right to join or not to join any group as permitted by and in accordance with all applicable local and national laws and freedom of association and collective bargaining. External partners shall not obstruct or discriminate against employees who choose to participate in such free associations and collective bargaining. Where the right to freedom of association and collective bargaining is restricted under national law, suppliers will facilitate, but not obstruct, alternative avenues for independent and free association and bargaining.

3.2. Freedom of association

3.3. Underage labour

External partners shall ensure that no child labor has been used in the production or distribution of goods and services to Catacloud. A child is any person who is under the minimum age for employment according to the laws of the country where the product (or parts of it) or service originates, or in the absence of law, under the minimum age for completing compulsory education.

3.4. Forced labour

External partners will not use or tolerate in their supply chain any form of slavery, servitude, debt bondage, indentured, military or forced labor, or any form of human trafficking.

All work must be performed voluntarily and without threat of sanction or punishment.

No government-issued identification, passport, or work permit owned by an employee shall be retained by the external partner as a condition of employment.

Suppliers must recognize workers' right to leave their workplace at the end of the workday or to resign from their jobs with reasonable notice and receive outstanding wages. This also applies to local and migrant workers.

3.5. Regular employment

External partners shall ensure that all their employees and workers in their supply chains receive an employment contract which shall be written in a language they understand.

Obligations to employees under international conventions and national social security laws, and regulations resulting from a regular employment relationship, shall not be avoided through the use of short-term contracts (such as contract work, casual work or day labor), subcontractors or other employment relationships.

3.6. Working hours, wages and benefits

External partners shall ensure that weekly working hours do not exceed national legal standards. Workers shall always receive overtime pay, at a minimum in accordance with national legal standards.

Wages and benefits, including statutory insurance, of the external partner's employees and/or workers must meet legal minimums and industry standards without unauthorized deductions.

3.7. Health and safety

External partners must provide safe and clean conditions for workers in workplaces and housing facilities. Clear procedures must be in place to ensure compliance with regular standards on occupational health, safety, and well-being.

3.8. Prohibition of discrimination

Catacloud expects all external partners to treat everyone with courtesy and respect, regardless of race, gender, national or social origin, disability, sexual orientation, religious beliefs, etc. An inclusive and diverse working environment with equal opportunities for all workers is encouraged.

All employees must be treated fairly and not discriminated against, regardless of their form of employment.

External partners must not discriminate against an employee based on age, gender, sexual orientation, race, nationality, disability, religion, political affiliation, union membership, ethnic origin, marital status or pregnancy, or on any other relevant grounds during hiring or in connection with other employment practices.

External partners must commit to a workforce free from any form of harassment or threat of harassment. Any physical, mental, sexual, or verbal harassment or threat thereof must be prohibited and not tolerated.

3.9. Safeguards to ensure respect for human rights and workers' rights

External partners shall implement effective measures to ensure that their performance in their contractual relationship with Catacloud respects human rights and labor rights in accordance with the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. To this end, external partners shall take all reasonable steps to avoid, or otherwise appropriately address or mitigate, including by establishing appropriate grievance mechanisms, adverse impacts on human rights and labor rights that they or any of their affiliates, or any officer, director, agent, representative, or employee of the external partner or such affiliates may cause or contribute to.

External partners shall identify the risk of violations of human rights and labor rights in their supply chain and shall, using a risk-based approach, actively seek to protect human rights and labor rights in the supply chain. External partners shall make every effort to ensure that contracts with suppliers contain the same requirements and obligations as this Code of Conduct.

External partners shall promptly and in writing respond to any inquiries from Catacloud regarding compliance with the obligations set forth in this section.

External partners agree to promptly notify Catacloud in writing as soon as non-compliance with this section is discovered. In such cases, the external partner shall promptly take adequate mitigating measures to minimize adverse impacts on Catacloud and any potential violations of human rights and labor rights resulting therefrom.

4. Environment

4.1. Environmental responsibility

External partners are committed to operating in an environmentally responsible and efficient manner, complying with national and international laws and resolutions on environmental protection. External partners are committed to minimizing pollution, promoting the efficient and sustainable use of resources, including energy and water, and minimizing greenhouse gas emissions in production and transport.

4.2. Environmental Management System

External partners must have established an environmental management system that, at a minimum, consists of the following components:

– A system for the company's environmental goals and environmental policy

– A policy regarding competence in the environmental field

– Procedures for executing the contract in an environmentally friendly manner

External partners may submit the company's quality or environmental management system in accordance with ISO 14000, EMAS, or other comparable systems certified by a third party.

Norwegian suppliers (manufacturers or importers) who use packaging must submit a certificate of membership from Grønt Punkt Norge or another recycling company approved by the Norwegian Environment Agency (in accordance with Chapter 7 of the Waste Regulation).

5. Ethical Business Practices

5.1. Anti-corruption measures

External partners shall comply with all laws regarding bribery, corruption, fraud, and other prohibited business practices.

No agent, affiliate, employee, or other individual acting on behalf of an external partner shall, directly or indirectly, give or receive any contribution, bribe, kickback, payment, influence payment, fee, or other payment to or from any person, private or public, regardless of form, whether in the form of money, property, or services (i) to obtain or provide favorable treatment in securing business, (ii) to pay or receive payment for favorable treatment on secured business, (iii) to obtain or provide special benefits or for special benefits already obtained or provided, or (iv) for any other illegal or improper purpose.

External partners shall have implemented systems for internal control and shall organize their operations in a manner to prevent and detect financial misconduct, including corruption, theft, embezzlement, fraud, financial breach of trust, favoritism, and nepotism.

5.2. Gifts and entertainment

External partners shall not, directly or indirectly, accept or offer gifts, including to Catacloud employees or individuals acting on behalf of Catacloud or their close associates, unless the gift is of negligible value. Under no circumstances shall money be accepted or offered as a gift. Hospitality, such as social events, meals, or entertainment, may be accepted or offered if there is a legitimate business purpose and costs are kept within reasonable limits. Travel expenses for an individual acting on behalf of an external partner shall be paid by the external partner. Hospitality, expenses, or gifts shall not be offered or accepted in situations of tenders, negotiations, or the awarding of contracts.

5.3. Conflicts of Interest

A conflict of interest occurs when an individual's personal relations or interests could affect, or could be seen as affecting, the individual's decision-making when acting on behalf of the supplier.

External partners shall ensure that neither the company nor its board members or employees have any external positions or obligations that could involve a conflict of interest in connection with the external partner's work for Catacloud.

6. Sanctions and Export Control

External partners shall comply with national and international laws on the control of foreign trade relating to trade with countries, companies and individuals (sanctions), and the movement of goods and services, software or technology between countries (export control). External partners shall require the same conduct from their sub-suppliers.

External partners shall not import, export, re-export or transfer, directly or indirectly, any goods, services, software or technology contrary to the export control restrictions that have been or may be imposed by any country or institution, including Norway, the United Nations and the European Union, nor perform or fail to perform any act that would cause a violation of such control or restrictions, and will ensure that appropriate measures for marking and handling such goods, services and technology are put in place and maintained.

7. Reporting concerns

External partners are encouraged to report any concerns to Catacloud. If external partners identify serious negative impacts that they either cause, contribute to, or are linked to, suppliers must immediately inform Catacloud and submit a plan to mitigate the impacts.

8. Scope and compliance with the code of ethics

These code of conduct rules apply to all external partners of Catacloud.

External partners must be able to demonstrate compliance with this code of conduct. This includes documented evidence and the right of Catacloud, or a third party designated by Catacloud, to conduct audits. Audits may include inspections of facilities, reviews of the supplier's records and business practices, and interviews with employees.

In the event of a breach of this code of conduct, Catacloud may suspend or terminate the contract with the external partner.