SUPERCELL SUSTAINABILITY CODE OF CONDUCT

Last updated: 1 July, 2022

INTRODUCTION

This Code of Conduct defines the basic requirements for our business relationship towards our stakeholders, social surroundings, and the environment. Supercell views sustainable development as an integral part of its pursuit of value creation and has integrated sustainability principles to its core business processes.

We require commitment to our Code of Conduct from all our partners, licensees and manufacturers as well as their respective licensees, affiliates and subcontractors (which we collectively refer to as Partners). We may amend this Code of Conduct from time to time by posting a new version on supercell.com.

This Sustainability Code of Conduct is based on major international agreements and documents, including the United Nations Sustainable Development Goals (SDGs), United Nations Guiding Principles on Business and Human Rights, the International Labour Organization’s (ILO) Fundamental Principles and Rights at Work, The Organisation for Economic Cooperation and Development’s (OECD) Guidelines for Multinational Enterprises.

1. GENERAL PRINCIPLES


1.1. Supercell is committed to respecting human rights, protecting the planet, and delivering a positive environmental legacy for future generations.
1.2. Partners must comply with the standards set out in this Code of Conduct. Supercell seeks to collaborate with its Partners on a global level to prevent, mitigate, and remedy adverse human rights impacts, as well as reduce the environmental impacts of our operations, products, services, and supply chains.
1.3. Partners must comply with applicable laws, regulations, and standards. In certain jurisdictions, the standards set for Partners by this Code of Conduct may surpass the requirements of the applicable local laws and regulations.

2. SOCIAL SUSTAINABILITY


2.1. Fair Labour Practices and Human Rights

2.1.1. Partners must comply with fair labour practices and human rights, as set out in the United Nations’ Guiding Principles on Business and Human Rights. Each Partner shall exercise due diligence to identify, prevent, mitigate, and account for how they address actual or potential adverse human rights impacts through its own activities, or those directly linked to its operations, products, or services through its business relationships.
2.1.2. Partners must avoid causation of and complicity in any human rights violations. Heightened attention shall be paid to ensuring respect of human rights to specifically vulnerable rights holders or groups of rights holders such as women, children, migrant workers, or (indigenous) communities. Each Partner must comply with general labour rights and maintain an active view on the human rights performance of direct and indirect partners.
2.1.3. Each Partner must pay exceptional attention to topics regarding modern slavery, and how it monitors standards in its own supply chain. Partners must not use or contribute to slavery, servitude, forced or compulsory labour, or human trafficking.
2.1.4. All forms of forced (involuntary) labour must be eliminated. Forced labour includes all work or service exacted from any person under the menace of any penalty and for which that said person has not offered her/himself voluntarily.
2.1.5. All forms of child labour must be eliminated. Partners must not employ workers under the age of 15. In countries subject to the developing country exception (ILO Convention 138), no workers under the age of 14, or younger than the age of compulsory education may be employed. Partners must comply with the local minimum employment ages set by the applicable laws. For hazardous work or work that is likely to jeopardise the health, safety, or morals of young persons (ILO Conventions 182, 138), workers under the age of 18 may not be employed.
2.1.6. Partners must comply with applicable labour laws concerning employment. All employees must have written employment agreements that are executed, binding and enforceable, and that in a transparent manner establish all terms of the employment (no hidden terms, no side letters, and no oral agreements).
2.1.7. Employees must be able to carry out their respective functions in the workplace.
2.1.8. Partners must not tolerate or promote any unacceptable treatment of individuals such as mental cruelty, sexual harassment, or discrimination, including gestures, language, or physical contact, that is sexual, coercive, threatening, abusive or exploitative.
2.1.9. Partners must not restrict the rights of employees to join, associate, organise or participate in workers’ unions or collective bargaining in a lawful and peaceful manner, without penalty, harassment, discrimination, or interference.
2.1.10. All Partners shall take appropriate steps to ensure that the provisions of this Code of Conduct together with employees’ legal rights and responsibilities are communicated and understood by workers and employees.

2.2. Working Hours, Wages and Benefits for Employees

2.2.1. Partners must exercise fair and equitable compensation practices (competitive on the market), considering each employee’s individual work experience and performance while being equitable internally. This requires pay equality and at least market standard salaries also in developing countries (similar pay for similar work principle).
2.2.2. Partners must adhere to applicable wage and compensation laws, including those relating to minimum wages, overtime, piece rates, and other elements of remuneration. Salaries to employees must be paid transparently (abolition of grey salaries). All withholdings or deductions from pay must be lawful, clearly communicated to employees, and must not be used as a form of punishment or otherwise to impede employees’ rights.
2.2.3. No unilateral setoffs against the salary payments or other payments can be made to employees unless this is explicitly allowed under applicable laws and the relevant employees have been clearly and timely informed of the consequences of such offsetting.
2.2.4. Partners must adhere to all applicable working-hours regulations. Overtime hours must be compensated at such a premium rate that is legally required. If there is no legally prescribed premium rate, a rate higher than the hourly rate must be applied.
2.2.5. All Cooperation Parties’ employees must be provided with adequate rest days after consecutive days of work in accordance with the applicable laws.
2.2.6. In the event of cross-border personnel employment, Partners must adhere to applicable legal requirements, especially with regards to minimum wages.
2.2.7. Partners must ensure that all employer contributions (i.e., salary taxes, mandatory social security contributions, mandatory unemployment contributions etc.) and legally required benefits (including, but not limited to family leave, illness, healthcare, vacation) are paid fully, accurately, and timely. Employees must be informed of the contributions in an understandable manner.
2.2.8. Partners must provide adequate and periodic free-of-charge professional training to employees to ensure the skills and capabilities needed for carrying out employment tasks successfully.
2.2.9. With regards to sufficient employment terms, the Partners must implement standardised policies on workforce planning, holiday regimes, and remote working.

2.3. Health and Safety

2.3.1. Supercell is committed to protecting the safety and health of people and communities in all its operations, as described in its Safe and Fair Play Policy and other policies as applicable. Supercell expects all its Partners to provide a safe and healthy workplace for their employees and communities.
2.3.2. Partners must have adequate policies and procedures in place to ensure and support physical and mental health of employees at the workplace. All necessary steps to ensure prevention, mitigation of injury or accidents that may arise from the course of the work must be taken.
2.3.3. Partners must act in accordance with the applicable statutory local, national, and international standards regarding occupational health and safety.
2.3.4. The Partners’ working spaces must be secure and allow reasonable freedom of movement of employees, as well as entry and exit to/ from premises. Partners must regularly assess whether buildings, where their employees are performing duties, are structurally safe and sound.
2.3.5. Partners must provide (free-of-charge) adequate training and education for employees regarding health and safety issues, as well as establish an occupational health and safety management system.
2.3.6. Partners must create, maintain, and execute emergency preparedness plans and procedures that are understandable and clearly communicated to all employees. Emergencies include, but are not limited to fires, natural disasters, security, and health and safety related events.

2.4. Diversity, Equality, and Inclusion

2.4.1. All the Partners’ employees must be treated equally, regardless of their race, religion, colour, sex, sexual orientation, gender identification, national, social, or ethnic origin, age marital status, military or veteran status, disability, pregnancy, union membership, political affiliation, or any other basis determined by applicable laws.
2.4.2. Partners must not discriminate in hiring and employment practices, including, but not limited to, salary, benefits, training and development, discipline, termination, or retirement.
2.4.3. Partners are urged to foster inclusive teams and purposefully shape an employee-friendly corporate culture with a sense of belonging to the workforce and community. Learning experiences and tools to enable leaders, managers, and individual contributors to model inclusive leadership are encouraged.
2.4.4. Partners are urged to enforce procedures within their organisation which establish effective whistle-blower channels as well as comprehensive protection and support for reporting person.

3. ENVIRONMENTAL SUSTAINABILITY


3.1. Supercell is committed to ensuring safe and environmentally sound development, manufacturing, transport, use and disposal of its products and services. All Partners are expected to make every effort to protect the environment, minimize adverse environmental impacts and optimize the use of energy and natural resources.
3.2. Partners must comply with all applicable local, national, or international environmental laws and regulations, as well as all applicable health and safety regulations.
3.3. Partners must protect their employees as well as the wider public against environmental hazards inherent in their services and products.
3.4. If the Partner’s activity is subject to local, national, or international environmental permits and/or licenses, the Partner is responsible for always ensuring compliance to the terms of such permits and licenses, including timely renewal/re-application, reporting obligations and other.
3.5. Partners are encouraged to integrate sustainable environmental principles into their work processes and supply chain management (optimization of the use of energy, raw materials, and land management; minimize impact on biodiversity, climate change and water scarcity; reduction of emissions to air, consumption; reduction, reuse, and recycling of waste).
3.6. Partners are encouraged to use energy-efficient and environmentally friendly technologies, where possible. Use of and production of harmful pollutants and chemicals should be limited.
3.7. Partners are encouraged to use sustainable materials and manufacturing methods to support re- and upcycling, conserve of natural resources and reduce waste.
3.8. Partners are encouraged to set targets and implement action plans for reducing environmental impacts in their activities.

4. FAIR OPERATING PRACTICES


4.1. Partners must abide by all applicable national and international laws and regulations including, but not limited to antitrust, trade controls, and sanction regimes, as well as applicable export controls and customs regulations.
4.2. Partners must consider business integrity as the basis of business relationships with Supercell and prohibit all types of bribery and corruption. This includes not offering gifts to private or public parties to influence official action, business decisions or obtain any improper advantage. The aforesaid also includes giving or accepting improper facilitation payments
4.3. Partners must not directly or indirectly facilitate money laundering or terrorism-related financing. Monitoring transactions for suspicious activity in accordance with the applicable anti-money laundering regulations is mandatory, as well as carrying out customer identification and screening procedures required by applicable know-your-customer regulations.
4.4. Partners must act in accordance with national and international competition laws and must not participate in price fixing, market or customer allocation, market sharing or bid rigging with any market participants.
4.5. Partners must respect the intellectual property rights of others and use intellectual property rights of others in a manner that does not infringe the rights of any third party. Partners are urged to take all legal steps to protect their own proprietary intellectual properties against the misuse of any third party.
4.6. Partners must be compliant with excise and other taxation obligations, and file with relevant tax authorities all tax returns, tax reports, and other tax-related documents that they are obliged to file with relevant tax authorities in a timely manner. Partners shall not implement aggressive tax schemes aimed to avoid lawful tax obligations.

5. PRIVACY, SECURITY AND DATA PROTECTION


5.1. Partners must be compliant with the GDPR and any other applicable data protection laws and requirements. Should the Partner process personal data in the course of working with Supercell, Supercell’s Data Processor Terms shall apply.
5.2. Partners must at all times process personal data in a confidential and responsible manner, respect everyone’s privacy and ensure that personal data is effectively protected and used only for legitimate purposes.
5.3. Partners must pay attention to information technology security and comply with relevant standards on IT security (e.g., ISO/IEC 27000). In the event of remote working, the Partners must, according to the best market practice, safeguard the security of communication and data transfers to and from the location the relevant employees carry out their employment duties.
5.4. Partners shall have adequate back-up, disaster recovery and other systems and procedures in place to enable their business and operations to continue without material adverse change in the event of a failure of any of the Partners’ ICT systems.

6. GOVERNANCE AND COMPLIANCE


6.1. Partners are required to implement an appropriate compliance management system, which facilitates compliance with applicable laws, regulations, and standards.
6.2. Partners must avoid and disclose internally and to Supercell all conflicts of interest that may influence business relationships.
6.3. When working with Supercell, Partners must require their suppliers, sub-contractors, and business partners to follow the same or similar provisions as set forth by this Code of Conduct.
6.4. Supercell must be provided with continuous visibility on the Partners’ employment, social, corporate, and environmental policies, practices, and certifications.
6.5. To monitor compliance with this Code of Conduct, Partners are, upon request, required to provide Supercell with yearly sustainability reports (the form of which will be communicated separately by Supercell).
6.6. Each Partner must allow Supercell to carry out yearly sustainability compliance audits on it. To that end, the Partner shall authorise Supercell and/or its designated agents to engage in necessary monitoring activities to confirm the Partner’s compliance with this Code of Conduct. All the details and timing of the above-mentioned sustainability compliance audits shall be primarily discussed and coordinated between Supercell and the relevant Partner well in advance to minimise disturbance on the Partner’s daily operations, but Supercell may also cause an audit to take place unannounced in case Supercell deems such measures to be necessary.
6.7. Partners must provide access to a protected mechanism for their employees to report possible violations of the principles of this Code of Conduct.
6.8. Partners shall facilitate active employee engagement in issue identification and resolution process. The Partners shall establish mechanisms to address grievances and track resolution of raised concerns. At a minimum, the Partners must not interfere with employees’ efforts to identify workplace concerns.