Code of Conduct

1. Introduction to our code of conduct

1.1. Purpose

The purpose of this Code of Conduct is to provide guidance and set common ethical standards to which all Symphony personnel should adhere consistently. It governs the working relationship between colleagues, our attitude toward work, the company, our clients and our responsibilities and standards. This Code of Conduct promotes the core values that we strive to build and strengthen at Symphony. It provides guidelines and a framework of conduct for all Symphony personnel, covering all aspects of our functional organization. 

• The rights and obligations of personnel
• Employee relations
• Attitude to work
• Attitude toward the company
• Client relations

1.2. Vision and mission statements

Our vision is Unlocking the full potential of humans + technology to inspire growth for our people, our clients, and our communities. For us, seizing opportunities and delivering great results by combining the power of humans and technology generates endless possibilities to impact humans, businesses, and the world in achieving multidimensional growth. Our mission is Passionately creating innovative digital experiences with meaningful value for all. Symphony’s way of working and living is based on a passion for finding ways to break new ground that generates business value and impact while driving results with a tangible purpose for us, our team, our partners, and the society that surrounds us.

1.3. To whom does this code apply

The Code of Conduct applies to all Symphony Group and subsidiaries employees, including directors, permanent and temporary employees, agents and other representatives acting on our behalf (together with our personnel).

2. Expectations of our employees and the leadership team

2.1. What we expect from our employees

• Read, understand, and comply with the Code.Reading, understanding and complying with the Code of Conduct, internal policies and applicable laws are primary responsibilities of all Symphony personnel.
• When uncertain, seek guidance from a superior, management or the Compliance Department.This Code of Conduct cannot describe every situation that may occur. Therefore, we should apply the principles it sets forth when dealing with business situations not covered by the Code. We need to use good judgment and common sense. If unsure how to proceed, we should seek advice from our immediate superior or from the Compliance Department. If in doubt, we need to ask ourselves specific questions before we take action: · Is this action in line with the principles and guidelines of the Code? · Is this action the right thing to do? · Would this action contribute toward cooperation and quality relationships within the team? · Would it reflect poorly on Symphony or on myself?
• Maintain a high level of work ethics.We do our job diligently and responsibly, always oriented toward precision and detail. We always strive to deliver high quality products at all levels. We respect our colleagues and only use company resources in the prescribed manner.
• Complete all required training and certify compliance with the Code.We complete all mandatory compliance training within set deadlines and confirm our compliance with the company rules and procedures, including this Code, in written form.
• Report your concerns.We do not ignore a violation. We prevent harm to our company and its reputation by reporting our concerns immediately.

2.2. What we expect from our leadership team

If you are a member of the leadership team then you have additional responsibilities. We expect our leaders to reinforce and promote ethical behavior and lead by example, as a true leader should.

• Promote a culture of integrity by making ethical decisions and showing honesty and integrity in everything you say and do.
• Never encourage or direct employees to achieve business results at the expense of ethical conduct or considerations.
• Encourage open and ongoing communication between you and your employees.
• Read the Code, understand it and talk about it.
• Make sure that personnel under your supervision understand their responsibilities under the Code and complete their required training.
• Consider the Code when evaluating employees, check for any potential violations.
• Create an environment where employees feel comfortable when raising their concerns.
• Respond to questions or concerns raised by employees by giving advice and guidance or by identifying the correct company resource to do so.
• Recognize that you may not always find the answers that you need in the Code, so know where to go for answers when there are questions.

3. Obtaining guidance and raising concerns

3.1. What to do when in doubt

Our Code of Conduct cannot address all of the rules, policies, regulations or circumstances that you may encounter. We must all use common sense and good judgment when determining the appropriate conduct. If you find yourself in a situation where you are unsure of what the ethical implications of your action might be, use the following questions as guidance:

• Is it consistent with the Code?
• Is it legal?
• Is it ethical?
• Is it fair?
• Is this the right thing to do?
• Would it reflect poorly on the company and myself?
• Would I want to read about it in the newspaper or on the internet?

If the answer to any of these questions is ‘No’ or ‘Maybe’ then this is a signal to stop and seek advice from your supervisor or the Compliance Officer. Think about the Compliance Officer as a keeper of the company and the person who will help you with your questions and concerns relating to integrity.

3.2. When do you need to ask for approval from your compliance officer (CO) or to inform your CO

In some situations, you will need to obtain written approval from the Compliance Officer before you take action or to inform your hub Compliance Officer about certain events. Here are a few examples of situations where written approval from or notification of the Compliance Officer may be required:

• gifts, meals and entertainment;
• conflict of Interest (actual or perceived);
• due diligence (employees or third parties);
• publishing information on company projects or clients.

3.3. Raising concerns

We do our job with integrity and we treat each other with respect. Any behavior that does not support this concept disrupts our culture and prevents our development and success. We must report any activity that seems unfair, unlawful, fraudulent or unethical and therefore represents a potential breach of this Code as soon as possible. Failing to raise a concern quickly could deprive our company of the opportunity to investigate the matter and to take appropriate action before it becomes a violation of a law and therefore a risk to the security and the reputation of the company. Symphony takes all reports of violations seriously and will investigate all of these reports promptly. We will to the greatest extent possible treat all of these reports as confidential and make every effort to protect the anonymity of anyone who reports a potential violation in good faith. We will not tolerate any form of retaliation against anyone who reports in good faith. You should report a problem to your immediate superior as soon as possible after becoming aware of an irregularity. In situations where your superior is not currently available or you are not satisfied with the response or reaction of your immediate superior or when you for any reason do not feel comfortable expressing your concerns or doubts to your immediate superior you can report suspected irregularities to the Compliance Department. You can contact the Compliance Department directly at ethics-line@symphony.is.

3.4. Prohibition of retaliation

Symphony prohibits retaliation, even if a reported irregularity remains unconfirmed after the investigation. Managers at all levels are responsible for protecting a person who, in good faith, reports irregularities and shall take all lawful measures to prevent or avert retaliation or the whistleblower being placed, in any way, in an unfavorable position. Personnel involved in any form of retaliation will be sanctioned through appropriate disciplinary measures, including the possibility of termination of engagement. Similarly, personnel who report any suspicious irregularity in ‘bad faith’ or provide evidence that they know to be false or without reasonable justification or belief in the truthfulness and accuracy of the information will not be protected. They may also be subject to disciplinary measures, including the possibility of termination of engagement.

4. Our values

Our values are principles that guide our behavior. Humans + Technology Using the power of technology would not be possible without the endless potential of human intelligence. The incredible results we achieve are a joint product of outstanding talent, human intellectual property, and latest technology, all combined toward a common goal of creating meaningful value. We > I Collaboration is in our DNA. It guides our workspace design, the way we put together lean, flat teams, and how we think about the best talent. The toughest problems won’t be solved alone, so we take pride in working together. (It’s also why we always give back to our communities and each other.) Excellence = Growth When the bar is set to world-class - every detail matters. We take pride in delivering our best work through dedication, drive, and thoughtfulness. We work hard so we can bring the big picture to life on time, every time. Long term > Short term This isn’t about sprinting towards the end of a contract. This is about driving technology forward and building the foundation of long-term partnerships so we can do work that matters. Flexible > Fixed We are lifelong learners. Our growth mindset means that we are always looking for ways to be better. We track things like happiness and motivation so we can adapt. We learn from working with each other, new teams, new technology or in new cities. Our values have created a space for us to define broader commitments that will support our actions and behaviors in three impact areas - each other, integrity, and company and clients.

5. Our commitment to each other

Commitment to mutual respect, diversity and inclusion

In our community, we have great respect for our colleagues and our differences and values. We are all here because of our qualities. It is essential to keep in mind that every one of us has broad knowledge, respected experience and contributes to the overall success of Symphony. This is why it is so crucial that we share our experiences, ask for feedback and opinion, and listen to and respect the advice of our colleagues. We promote an atmosphere of tolerance and trust, both within the company and toward our customers and society in general. Each of us is expected to respect our colleagues’ private lives. Discrimination, abuse and violence are strictly prohibited. We accept our differences in a tolerant way. Symphony respects the individuality and the dignity of every employee. All of our employees have equal opportunity.

We should pay special attention to:

• Treating others with dignity and respect at all times;
• Address and report inappropriate behavior and comments that are discriminatory, harassing, abusive, offensive or unwelcome;
• Foster teamwork and employee participation, encouraging the representation of different employee perspectives;
• Seek out insights from employees with different experiences, perspectives and backgrounds;
• Avoid slang or idioms that might not translate across cultures;
• Support flexible work arrangements for co-workers with different needs, abilities and/or obligations;

Commitment to privacy and protection of information

Symphony takes the security of the personal data of our employees, associates, clients, vendors, candidates, partners, and individuals very seriously. Personal data is defined as any information relating to an identified or identifiable natural person (data subject). An identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Our Privacy Policy describes the types of personal information we collect, how we use the information, with whom we share it and the rights of individuals regarding our use of their information. We have created a set of privacy policies and procedures in order to protect the information belonging to our employees or individuals outside our company. This constitutes part of our Compliance Program, which defines how we collect, process and keep personal data, what kind of data we hold and for how long, how we perform risk assessment, what the data owner’s rights are and how they can contact us.For what purpose and on which legal basis do we process your personal data? We process basic, performance and usage data in order to understand your engagement relationship with us based on the Law (for more information please visit this link). We may also process basic, performance and usage data in order to ensure compliance with legal obligations. Legal obligations can include the mandatory disclosure of personal data to social insurance bodies and (tax) authorities. When necessary, we process personal data (in addition to processing for the engagement relationship or to comply with legal obligations) for our justifiable interests. Justified interest can include maintaining the security of our information technology systems and our premises and infrastructure, and the management and further development of our business operations, including risk management. Suppose, for example, during the recruitment process or in the course of the engagement that we provide the option for you to declare your consent to the processing of your personal data. In this case, we process the personal data covered by your consent for the purposes specified in relation to such consent. Please note:

• Your declaration of consent is always voluntarily and neither the declaration of consent nor a later withdrawal of consent will have negative consequences in terms of your performance engagement relationship.
• Failure to declare consent or the withdrawal of consent may, nevertheless, have consequences. We will inform you about any potential consequences before you are given the option to declare your consent.
• You can withdraw your consent at any time with effect for the future.

Are you obliged to provide data? The provision of basic data is necessary for entering into and maintaining an engagement relationship with us. We are not able to enter into and maintain an engagement with you without the provision of this type of data. If we collect additional data from you then we will inform you if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement (in particular, your engagement agreement).

Commitment to ethical communication

The way we communicate and relate to each other is one of the most crucial factors of the Symphony culture. Yet communication is closely linked to our personality, temperament, experience and knowledge. Thus, sometimes it is not easy to decide what is best to say and when to say it: is it appropriate for the situation and participants, is it ethical, etc. The integrity of ethical communication is fostered through truthfulness, accuracy and honesty.

Commitment to ideation

At Symphony, we value and appreciate good ideas that will bring benefit to us all. We will always aim to be innovative and enthusiastic and we will promote and implement such ideas in order to create a more interesting environment, learn, develop and have fun. We always feel free to propose mutual activities and ideas at Symphony and are happy to contribute to their implementation.

Commitment to health, safety and security

All Symphony employees have an important role to play in ensuring that we maintain safe and secure premises for our colleagues to work in and for our visitors. Everyone must comply fully with all safety and health regulations, policies and procedures. We must report unsafe working conditions or practices immediately so timely action can be taken. We must ensure that our identification cards and those issued to our visitors are visible at all times whenever we are on company premises.

Commitment to prevent harassment and workplace violence

We will not tolerate verbal, non-verbal or physical abuse by anyone associated with our business (including suppliers and clients) that harasses or creates an intimidating, offensive, abusive or hostile work environment, including workplace violence and sexual harassment. Workplace violence includes robbery and other commercial crimes, violence directed at the employer, past or current employees and/or family members, clients, suppliers or other third parties. Sexual harassment constitutes unacceptable behavior of a sexual nature that offends, intimidates or violates a person's integrity or dignity.

6. Our commitment to integrity

Our reputation depends on our ability to cherish our people and be outstanding professionals. We act with honesty, integrity and transparency in our daily operations. Our commitment is to always perform our business unreservedly pursuant to all applicable laws, rules and regulations and to the highest standards of business integrity. We adopted a Compliance Program in order to define the conduct that we expect from each of our personnel and those third parties with whom we choose to do business. Everybody is personally responsible for compliance with the laws, policies and procedures. Any violation will be considered a disciplinary matter and may result in disciplinary action, including termination of employment.

6.1. Commitment to comply with anti-corruption laws and rules

Corruption, in all its forms, is contrary to everything for which Symphony stands. As a company that does business with clients from the US and Europe, Symphony is committed to full compliance with the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and all local anti-corruption laws and regulations that prohibit corrupt actions aimed at obtaining or retaining business or any other improper advantage.

6.2. Commitment to ban prohibited activities

Symphony strictly prohibits corruption, fraud or facilitation payments, improper relationships with public officials or the engagement of third parties in order to induce or secure any improper advantage for the company. The company believes that facilitation payments, no matter how small the value of the paid amount, constitute bribes or bribery. Symphony has zero tolerance of violating this standard. Always keep in mind that Symphony can be liable for the conduct of third parties acting on its behalf. All our personnel must never engage in bribery and must not use intermediaries, such as agents, consultants, advisers, distributors or any other business partners, in order to commit acts of bribery. Symphony does not distinguish between public officials and private persons as far as bribery is concerned: bribery is not tolerated, regardless of the status of the recipient.

6.3. Commitment to proper usage of gifts, hospitality, and entertainment

Symphony’s business should always be won or lost based on merit. Symphony personnel can only offer or approve business courtesies that are legal, proper and in full compliance with Symphony policies and instructions. They must not engage in any activity that could give rise to the reasonable perception that they are offering inducements in order to gain an unfair business advantage. Symphony personnel must never use personal funds or resources in order to avoid reporting or seeking approval for a business courtesy that Symphony could not provide. Gifts Symphony allows the giving or accepting of adequate presents provided that they correspond to our rules. Yet it is important that these gifts do not affect the business assessment of our personnel (actual conflict of interest) and that they do not create the impression that they could affect the business assessment of our personnel (perceived conflict of interest). Please refer to the Symphony ABC policy for more information on gifts.Special caution: Personnel must be cautious and careful when offering gifts to a public employee, taking into account that gifts to these individuals can be seen as a bribe. Furthermore, public employees are often prohibited by law and/or other internal documents from accepting gifts. Therefore, offering a gift could place them in a prohibited situation. Symphony personnel are obliged to get acquainted with client rules on gifts. The following gifts are strictly prohibited and never and under no circumstances are to be deemed appropriate, whether giving or receiving:

• gifts in cash or cash equivalent (such as gift cards or gift certificates);
• gifts prohibited by the applicable law;
• gifts given as a bribe or form of corruption (e.g., to obtain or to maintain business contacts or to provide an improper advantage such as the provision of preferential treatment);
• gifts that the recipient knows are prohibited by the gift giver's organization;
• gifts that the giver knows are prohibited by the gift recipient's organization;
• gifts given in the form of services or other non-cash benefits (e.g., a promise of engagement);
• gifts to family members of a third party.

Symphony personnel must never ask for gifts, premiums or other things that would bring them personal benefit, regardless of the value. Hospitality and entertainment Third parties with whom Symphony operates in order to strengthen business relationships can provide hospitality and entertainment to Symphony personnel. Personnel may accept such an offer if it is moderate and in keeping with local custom for business related meals or entertainment when the supplier or customer is in attendance. Special caution: Personnel must exercise caution and care when inviting public employees to organized parties or offering them hospitality, because it can be seen as a form of bribery. Symphony personnel are obliged to get acquainted with the client's rules on hospitality and entertainment. The following hospitality and entertainment is strictly prohibited and never and under no circumstances should be deemed appropriate, whether giving or receiving:

• entertainment that in the context of business opportunities can be deemed excessive;
• ‘adult entertainment’ or any sort of event involving dissipated behavior, nudity or vices;
• entertainment that the recipient knows the giver is not permitted to offer;
• entertainment that the giver knows the recipient is not permitted to receive;
• entertainment offered as a form of bribery or kickback (e.g., to obtain or maintain business contacts or to provide an improper advantage);
• actions that could create the impression that Symphony receives preferential treatment;
• actions that take place at a venue deemed unacceptable for business purposes.

Please refer to the Symphony ABC policy for more information on hospitality and entertainment.

6.4. Commitment to proper donations and sponsorships

Donations or sponsorships should not under any circumstances be associated with any offer of the company, tenders, the renewal of a contract or prospective business relationship. Symphony will never use donations or any sponsorship contract to obtain more favorable conditions from the recipient of the grant or sponsorship or its affiliates or related parties. Donations and sponsorships should not under any circumstances be implemented in cash and are only implemented through instruments of cashless payment transactions. When allocating funds for this purpose, it is a must to ensure that any donations or sponsorships comply with our values and the Compliance Program. Symphony does not approve grants for organizations/groups that promote and advocate intolerance and/or violence, for political parties, party officials or political candidates or any person representing them, or for organizations and/or individuals that do not meet the provisions of this policy.

6.5. Commitment to follow political contributions laws

Symphony abides by the laws and refrains from any interference in politics and respects the final decision of the legal and political system. Symphony does not financially support any political party, party officials or political candidates or any person who represents them.

6.6. Commitment to keep business and financial records

We always maintain accurate business and financial records. We ensure that records, ranging from engineering logs to inventory records, quality reports, expense accounts, timesheets or other records, are kept accurately and reliably and in the true state of affairs. We are honest, accurate and complete in what we record. This is the responsibility of all Symphony employees and reflects on the reputation and credibility of the company. It also ensures that we meet our legal and regulatory obligations.

• We make sure that we record and classify transactions in the proper accounting period.
• Reports issued to regulatory bodies must be full, fair, accurate and timely.
• We never falsify a document.
• We ensure that payments are made only to the person or firm providing the services.
• We ensure that actual receipts and valid business purposes accompany all travel and entertainment expense reports.
• We know and follow the policies that relate to the maintenance, storage and disposal of records. We never destroy or dispose of information that might be needed for an investigation, an audit or a legal proceeding.

7. Our commitment to the company and our business partners and clients

7.1. Commitment to avoid conflict of interest

Conflict of interest occurs when a member of personnel places his/her personal interests ahead of the interests of Symphony and where such personal interest influences business decisions and/or actions. All decisions and actions that represent a conflict of interest can hinder the fair, effective and efficient operations and/or legal operations of the company and have regulatory consequences. Typical examples of conflict of interest include personal relations at work (e.g., engagement or supervision of related persons), an external engagement (e.g., personnel who are engaged on a third party board of directors and/or client, or boards of political parties), external engagement/outsourcing (e.g., personnel having a business engagement with customers, suppliers or competitors), promotion of improper personal financial interest (e.g., a member of personnel with a stake in ownership of a vendor company who is in a position to manage and/or influence decision-making in that company) and the receipt of fees, commissions, discounts, gifts, entertainment or services. Outside employment You should not engage in outside employment in any business or in any capacity that could conflict with your ability to discharge your duties objectively and in the best interests of Symphony. Outside employment includes all employment that could lead to any of the following: 

• direct or indirect competition with Symphony;
• benefit to a third party with whom Symphony cooperates;
• prevents you from carrying out your duties objectively and in the best interests of the company;
• conflicts with your scheduled working hours (including overtime) or the performance of company assignments. 

Exceptions to this rule must be obtained in writing from the Compliance Department and renewed annually. Acting as an officer or Board Member of another company or organization Through the annual Declaration on Conflict of Interest, you should notify the Managing Director and the Compliance Department if you intend to act as an officer or board member of another company or organization. This applies even if it is not a supplier, competitor or customer of Symphony. Any change to the provided information requires a renewal of the declaration. Speaking at seminars, conferences or other events, including the media We recognize the need and benefit of speaking arrangements for our employees and/or Symphony. However, we have to be careful and avoid potential conflicts of interest when accepting these arrangements. When the speaking arrangement formally identifies us as an employee of the company or describes some aspect of the work that we do for Symphony we must obtain written approval from the Managing Director before accepting the engagement. When we want to speak to the media or prepare texts or articles in response to media inquiries or intended for publication we have to ask the Managing Director for approval. All texts should be reviewed in advance by the Compliance Department and Head of Communications and approved by the Managing Director prior to being released to the media. Dealing with close relatives and friends Where a relative or close friend of ours works for a supplier or customer and is responsible for dealing with Symphony we must disclose this fact to the Managing Director and the Compliance Department in order to ensure that all dealings are conducted at arm’s length. We have to be careful not to allow our relationship to affect our ability to do our work impartially or create the appearance of doing so. You should consult the Compliance Department if you are uncertain whether an existing relationship could create an issue. Who are our close relatives Spouses, relatives in direct line, adoptive parent and adoptees, relatives in the collateral line up to the third degree, and relatives-in-law up to the second degree. We have to remember that particular care should also be taken when dealing with close friends, even though they are not relatives. Ask for guidance You must contact your supervisor immediately to report any situation or circumstance that could bring you into a situation where a conflict of interest could occur. Issues involving an actual or potential conflict of interest can only be resolved through a review of the particular circumstances within the context of our activities at Symphony. Therefore, we must follow the disclosure and resolution process. 

7.2. Commitment of confidentiality

Confidential Symphony information is information or material that is commercially valuable to the company and that is not generally known to the public or is not commonly known in the industry. This includes, but is not limited to the following:

• Technical information relating to the company's products and services, including knowledge of products, formulas, drawings, devices, diagrams, software code, test results, processes, research projects and product development, technical memoranda, and correspondence.
• Information relating to the company's operations, including information on cost, profit, sales information, accounting and undisclosed financial information, business plans, markets and marketing methods, customer lists and customer data, procurement techniques, supplier lists and supplier information and advertising strategies.
• Information about the company's personnel, including salaries, strengths, weaknesses and skills.
• Any additional information not known to the general public that could reasonably be expected to adversely affect the company’s business operations if misused or disclosed.

Symphony pays special attention to protecting confidential information provided by partners, customers, suppliers, employees and consultants in the course of doing business with us. Confidential information includes any non-public information about a third party concerning their property, products, services, intellectual property and technology. Important - We keep confidential information for ourselves. Certain aspects of our business and financial performance are confidential. We do not discuss Symphony or a third party’s confidential information. - Particular circumstances may require the disclosure of confidential information to an outside party yet disclosure of such information should only occur on a ‘need to know’ basis and only under a non-disclosure agreement. - We do not tell our significant other or family members anything confidential and we do not solicit confidential information from them about their company. - We do not disclose, directly or indirectly, records, any proprietary information or confidential information of the company or any confidential information of any third party that has disclosed such information to Symphony. - We do not publish confidential information. - We always consider confidentiality obligations stemming from binding NDAs. We avoid the following situations in order to avoid violating client confidentiality: - Sharing customer information with a third party or other staff without permission or authorization to do so. - Using confidential information for personal benefit (or someone else’s). Personal promotion is also included here. - Leaving personal or sensitive information accessible to others (e.g., on an unsecure computer or mobile device). - Sharing confidential information about a client with a family member or friend. - Talking about confidential information somewhere where we can be overheard. - When permission to share information is given but is not specific, this can create confusion and result in a potential breach (e.g., a client may permit their information to be shared with personnel inside a project team but not with all Symphony personnel).

7.3. Commitment to the Symphony property

We act appropriately and cautiously with the property of Symphony. All of the resources that Symphony provides for its employees have to be used efficiently and in accordance with the standards of Symphony for legitimate and legal purposes. We do not use company assets for personal purposes or for activities of which the company does not approve. We do not use company assets for personal purposes unless this is allowed through an appropriate regulation or approved by the relevant instance. Intellectual property is a valuable asset that needs to be protected from unauthorized use. This includes copyright, trademark and patent rights.

7.4. Commitment to behavior and appearances at Symphony

We do not have a dress code or specific rules because it is more valuable for us to be fit and healthy than to all dress the same. We are a relaxed fit company, but we will always have in mind the boundaries and the impression we create through our appearance. We want to be perceived as intellectuals, out-of-the-box thinkers, professionals, and innovative and creative minds. We do not want to be seen as unprofessional and lacking a sense of respect in terms of professional appearance. We need to pay special attention to our appearance when in contact with our clients or any other capacity when representing Symphony.

7.5. Commitment as Symphony ambassadors

The reputation of Symphony is built on the quality of our work and the promotion of our core values. We want to be perceived as pioneers creating new cutting-edge solutions worldwide. Our aim is to be recognized globally for our products, innovations and high-tech solutions. The ambassadors and messengers of our good reputation will be our products and our employees. This is why we will always strive to promote our reputation and the quality of our work. Remember, we want to impress the world with everything we do. Symphony Ambassadors have the following responsibilities:

• spread the news, build awareness about Symphony and promote our organizational culture and values;
• present an image of high quality, responsibility and integrity through our work;
• increase our networking activities and relationships in the communities where we operate (connect with colleagues, universities and clients);
• be active on social networks, contributing and sharing content from Symphony profiles and the website;
• promote our own credibility through the presentation of Symphony.

When promoting Symphony in public, we must always have in mind that we want to encourage excellence. This is why we pay special attention to the quality of the content we share. We prefer the English language and content that is understandable to the public yet professional enough for the clients who follow us. We should also pay attention to the content we share through our private social network profiles, which are not related to the company. Sensitive attitudes, values and views should be presented as personal and not related to Symphony. Under no circumstances should we present Symphony in a negative context. If we have a problem or sensitive issue then we should discuss it internally with our team leader, HR manager and colleagues.

7.6. Commitment to relations with our clients and business partners

We act ethically and fairly in our dealings with our business partners. We treat one another professionally and fairly. We require the same behavior from our business partners As we can be legally responsible for the conduct of business partners when it occurs during the course of their work for Symphony, we believe in doing business with business partners who demonstrate high standards of ethical business conduct. We expect that our agents, vendors, suppliers, independent contractors, consultants and joint venture partners or any other third party acting on our behalf (business partner) adhere to the ethical and professional standards of conduct as described in the Code for Third Parties. Selection Our selection of business partners will be made on the basis of objective criteria, including quality, technical excellence, cost/price, schedule/delivery. No business partner should be asked to perform services for our company without proper due diligence and an agreement detailing the services and payment terms. We will do our best to make sure that our purchasing decisions will never be compromised by personal relationships or influenced by the acceptance of inappropriate gifts, favors or excessive entertainment. Antitrust/competition laws Symphony complies fully with the relevant competition laws around the world. The rules governing this area are quite complex and differ from one country to another, while penalties can be severe. It is for this reason that we must be careful not to engage in any form of behavior that prevents, restricts or distorts competition. It is not permitted for anyone in our company to direct, participate in, approve or tolerate any violation of antitrust or competition laws. Managers are responsible for the conduct of their teams. If you have questions about applying antitrust or competition laws, consult with our Legal Department or the Compliance Department. Competitive intelligence We compete openly and fairly. We have a responsibility and the right to obtain information about other business organizations, including our competitors, through appropriate ethical and legal means. Such information can include analyst reports, non-proprietary marketing material, advertisements, public journals, magazine articles and other published or spoken information. However, we should only obtain this information from open sources and not through espionage, theft or any other unfair or unlawful means. We respect the legal obligations that an employee may have to a prior employer, such as confidentiality and restrictions on soliciting employees and clients of the prior employer. Anyone who has that type of agreement must make it known in order to ensure compliance with the terms of the agreement. We will always think about possible ways to improve the outcome of our work. Here at Symphony, our final target is not just to deliver a solution that works to the client. Functionality is a must for all of our products and our work yet we aim to deliver more. We will deliver high quality output with a minimum of mistakes, bugs and errors. This is why, as a developer, we try to see things through the perspective of the client and the end-user. We try to envisage all of the difficulties they could encounter and then prevent them from happening.

8. Code of conduct and compliance program

This Code of Conduct is a part of the overall Compliance Program that Symphony is implementing. The Code contains several references to other Symphony policies and procedures where you may find a more detailed explanation of the rules and processes described here.

8.1. Administration of the code

Responsibility for administering this Code lies with the Compliance Department. Oversight responsibility rests with the Chief Executive Officer and the Compliance Board. The Compliance Board comprises the Chief Executive Officer, the Vice President of Internal Operations, Director of Engineering, Managing Directors and the Compliance Officer. Senior personnel from other departments, such as Finance and Security, may also be requested to attend when required.

8.2. Legal proceedings and internal investigations

In the event that our company is subject to any legal or administrative proceeding or government investigation or inquiry, only senior management, the Legal Department and persons who are authorized by senior management can communicate with representatives of regulatory bodies. Investigations often involve complex legal and business issues. Do not attempt to investigate legal matters yourself because this could compromise the investigation. It is the responsibility of our company’s senior management to determine whether to conduct an internal investigation and determine the methods to be employed in any investigation. Personnel must cooperate fully with any internal investigation conducted by our company. Subject to advice provided by our company’s legal department or an outside attorney, everyone must cooperate fully when requested to do so in connection with any law enforcement investigation.

8.3. Investigations and decisions

We take breaches of this Code seriously and are committed to conducting thorough but confidential investigations into all allegations. The Compliance Department is responsible for receiving reports on breaches and coordinating investigations. Depending on the nature of the investigation, the decision on the department best placed to conduct or provide assistance during the investigation will be made. According to the disciplinary process, employees who are being investigated will be allowed to be heard before a final decision is made on their case. After an investigation, the CEO/Managing Director will decide on the appropriate disciplinary action to be taken (if any) for Code violations. Disciplinary action linked to the final outcome of an investigation will be governed by the procedures prescribed by the law of the country where the employee is situated. Action taken may include prosecution, termination of employment, suspension, demotion or loss of benefits and will depend on the circumstances of each case.

8.4. Reporting of investigation results

The Compliance Department reports periodically on the results of all Code investigations and disciplinary action taken to the Chief Executive Officer/managing directors and the Compliance Board. A representative samples of actual breaches of the Code, with personal identifying details removed, will be part of future training aimed at raising awareness amongst all employees about the ethical issues encountered within the company.

8.5. Training, communication and certification

Our training activities are designed to provide general training for all personnel on the rules set out in this Code and internal policies and procedures. They are also designed to meet the specific needs of different working positions and to provide additional detailed knowledge in relation to adherence to the applicable internal and external regulations. All new personnel must within 30 days of engagement be familiar with the provisions of this Code, the Symphony Compliance Program and other policies and procedures relevant to a particular position. Obligatory compliance training is conducted at least annually, as online or on-site training, workshops or through other suitable ways. Training sessions are conducted in accordance with the Annual Training Plan, covering our key procedures and specific training based on risk. Additional educational activities include continuous communication with all Symphony personnel on the topic covered by this Code and the Compliance Program and the provision of advice and answering queries raised by personnel. Because we want to help ensure compliance with this Code, all employees must complete and return a compliance report and complete annually certification.

8.6. Acknowledgment

All personnel must acknowledge that they have read and understood this Code and other relevant internal regulations and abide by their provisions. Similar certifications will be required of all employees periodically. Remember that failure to complete this acknowledgment does not absolve any employee of any breach of the Code.

8.7. Compliance Department

The Compliance Department is available to answer any questions you may have on the Code of Conduct or company policies and procedures and to discuss any concerns you may have about potential code violations. Contact the Compliance Department:

• Email: ethics-line@symphony.is
• You should also feel free to contact the Compliance Officer directly via internal communications tools.