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UBISOFT CODE OF CONDUCT

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This Code of Conduct is a binding document that sets out Ubisoft’s commitments as a company and the role of each individual team member. It is mandatory for all team members, regardless of contract, position or location within Ubisoft, to read, comply with and sign this Code of Conduct every year.

The Code of Conduct provides guidelines for creating and maintaining a respectful and inclusive work environment as well as directives to ensure that we fulfill our duties ethically and in line with all applicable laws.

It is our collective responsibility to undertake that each of Ubisoft’s offices and studios be the best possible places to work and grow – knowing and respecting the Code of Conduct’s principles and guidelines is key to achieving that goal.

How to apply the code in daily decision making

The Code of Conduct includes rules that must be followed at all times as well as a guide for day-to-day decision-making, to make sure everyone at Ubisoft fulfills our professional responsibilities respectfully and with integrity. If you have searched this document for an answer to a specific question and could not find it, you should ask yourself:

• Are my actions legal? • Are my actions in line with the basic principles set out in the Code of Conduct? • Would I be comfortable telling my colleagues, family or friends, about my actions?

These questions can help you in making the right decision. However, if you still have doubts, you should reach out to your manager before you act. More information on how managers can help team members to uphold this Code of Conduct can be found in our section below on “The role of managers”.

How and where to go for help

If you see anything not in line with the Code of Conduct or that you think goes against the principles herein, please speak up. Ubisoft commits to review all reports of misconduct, treating allegations of misconduct respectfully and confidentially and to protect anyone who raises a concern from retaliation. Each section of the Code of Conduct outlines a specific contact depending on the situation. That said, in most circumstances, the first step is for team members to speak to their direct manager or a local human resources manager. If needed, reports of misconduct can also be raised anonymously through Whispli, our speak-up system.

This Code applies to Ubisoft teams. But it also gives clear commitments that must be followed by team members in their day-to-day relationship with business partners or players.

For any other questions regarding the Code of Conduct, please refer to your local HR managers or local Managing Directors.

The role of managers and Human Resources

Everyone at Ubisoft must act with integrity. And if you are part of the senior leadership, the human resources or a manager, you have additional responsibilities, to lead by example and to care for the well-being of your team.

Senior leadership

Employees holding directing, supervising and senior management’s positions are bound to the highest level of exemplarity when it comes to upholding the Code of Conduct and policies. They are expected to demonstrate leadership in the application of these policies and intervene whenever they see behaviors or processes that don’t comply with these standards.

Human Resources

In addition to their duties to foster a respectful workplace environment and act as the primary support for all employees on employees’ relations and well-being matters, Human Resources have a duty to promptly inquire into any alleged misconduct or reasonable risk of misconduct they are aware of. They are responsible for implementing adequate measures to protect the physical and psychological safety and integrity of all parties involved throughout the misconduct management proceedings.

Managers

Ubisoft managers have a duty to be mindful of team interactions and behavior in the workplace. They are expected to demonstrate a willingness and availability to prevent misconduct and protect Ubisoft employees. Their duties also include acting as ‘first-responders’ as soon as they are made aware of alleged misconduct. In doing so, they are required to act with care to ensure the safety, dignity and reputation of all parties involved.

Managers have a duty to promptly report to HR any form of misconduct they observe, hear about, or reasonably suspect has occurred as well as describe any actions already taken to address the situation.

It is vital to communicate to your team members that following the Code of Conduct and treating their colleagues and partners fairly and with respect is an integral part of achieving their objectives.

Related resources:

Consequences of any violation of the Code

Ubisoft is committed to applying appropriate measures and sanctions for any violation of the principles in this Code of Conduct in line with our disciplinary procedure and any applicable local regulations and laws. These sanctions range from a verbal or written warning to contract termination.

Ubisoft expects team members to be aware of the company’s zero-tolerance commitments set forth in this Code of Conduct.

No disciplinary action (as defined by applicable local law) will be initiated against an employee unless the allegations have been substantiated and the employee has been given the opportunity to state their case.

Disciplinary actions & sanctions will be proportionate to the misconduct’s nature. Repeated, persistent or major misconduct could lead to dismissal. The same misconduct cannot be sanctioned twice unless repeated after a first warning or if Ubisoft is made aware of new information.

Regardless of the disciplinary action taken by Ubisoft, violations of the Code of Conduct may also expose the individuals concerned, as well as Ubisoft, to significant risks of civil and criminal sanctions.

SUMMARY

Building a great place to work

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Providing positive experiences for our players

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Working ethically with partners

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Protecting confidential information, user data & company assets

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Contributing to communities and causes

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Speaking-up

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Building a great place to work

1.1 Well-being at work

Ubisoft commits to providing a safe working environment, both in terms of mental and physical health and to guaranteeing a sustainable work-life balance.

During the process of creating a high-quality game of international scope, there can be periods of intense work, throughout the company. Ubisoft will ensure that these intense phases of work are carefully supervised across our studios and business entities and kept to a minimum. Teams can also reach out to HR with questions relating to their well-being at work.

1.2 Physical safety at the workplace

Ubisoft commits to take all necessary precautions to ensure the physical safety of teams such as ensuring all workspaces respect local regulations and by preparing and testing emergency response plans. Team members should also be mindful of actions that can impact the health and safety of their colleagues.

Team members should further be aware of the emergency procedures that apply to their working locations.

Alcohol may occasionally be served in a Ubisoft office or during events, however the use, possession or sale of illegal drugs and the abuse of alcohol are prohibited. Intoxication will never be an excuse for misconduct.

Lastly, functional weapons are not allowed, in any Ubisoft location. Teams are required to ensure that prop weapons required for our business activity are fully neutralized and safely stored.

1.3 Respect at Ubisoft

Ubisoft is committed to guaranteeing a respectful working environment – everyone is expected to participate in this effort. This principle applies to the treatment of every team member, player, community member, and business partner teams interact with during online, at work or work-related events.

Ubisoft expects all teams to maintain a professional attitude and a civil tone at all times including when facing tough challenges or when contentious topics are on the table. Incivilities include behavior such as shouting at someone, pounding the table in frustration and aggressively vulgar language. These and similar behaviors undermine Ubisoft’s culture of mutual respect and work experience of teams.

While celebrating our successes and adding an element of fun is an important part of the Ubisoft experience, this fun cannot come at the expense of our colleagues.

Ubisoft expects that when we tell jokes, we make sure that they are not hurtful, discriminatory or disrespectful. Further, while teams can celebrate achievements and milestones with enthusiasm everyone is expected to do so responsibly.

1.4 Diversity and inclusion

At Ubisoft, we aim to represent the diversity of the world we live in. Creating a culture of inclusion and belonging is of paramount importance. Every team member should be able to participate actively and be equally accepted as part of the Ubisoft community.

Ubisoft is committed to continually improving the diversity of its teams through recruitment and promotions and to support initiatives like Employee Resource Groups, policies and processes that enable building diversity and inclusion within our company and culture.

Ubisoft expects all team members to support the company’s commitment to diversity and inclusion. This means fighting any potential bias, being a supportive and inclusive team member, and ensuring that our decisions to hire, promote or reward team members are based on what each person brings, or could bring, to the company, such as their talent, skills, perspective, and experience.

1.5 Non-discrimination

Ubisoft commits to not take employment-related actions that could negatively affect teams or candidates on the basis of a protected characteristic.

Ubisoft is dedicated to building a workplace culture that empowers everyone and ensures that all team members feel safe and respected. Discrimination of any kind has no place at Ubisoft.

The company commits to a zero-tolerance policy where any team member in violation of this principle, regardless of their position, will be subject to disciplinary action.

1.6 Prevention of harassment, sexual harassment and bullying

Ubisoft has a responsibility to provide a safe environment in which our teams feel protected.

In order to uphold this responsibility, Ubisoft does not tolerate any form of harassment, sexual harassment or bullying.

Ubisoft commits to review and respond to all reports of alleged harassment, sexual harassment or bullying among team members and to impose sanctions where appropriate.

This commitment extends to harassment carried out by our partners, or our players, against Ubisoft team members, for example as part of our online gaming communities.

1.7 Personal relationships at work

Personal relationships at work can be a potential source of conflicts of interest, as they could affect a team member’s ability to act in the best interests of Ubisoft and teams at large.

Ubisoft commits to respect the private lives of its team members. However, Ubisoft considers that personal relationships when one individual has power and/or authority over another in terms of hiring or employment conditions represent a conflict of interest. Ubisoft expects team members to act responsibly when a personal relationship could affect a team member’s impartiality or create a conflict of interest. In such a case, Ubisoft requires team members to declare the relationship to their HR manager.

Ubisoft also commits to preventing any abuse of power which could result from personal relationships between team members with a direct reporting line between each other.

An example would be a situation in which a manager has a romantic or personal relationship with a team member and has to decide whether to award them a promotion.

If you become aware of any conflict of interest at work, favoritism for instance, report this to your direct manager or the human resources team.

For more information on the conflicts of interest, see our Code of Conduct’s section 3.6.

1.8 Politics and religion in a neutral workplace

With diverse teams comes diverse perspectives and backgrounds. It is therefore our shared responsibility to create a politically and religiously neutral and accepting workplace.

Ubisoft is committed to respecting every team member’s right to freedom of expression, thought and belief and never discriminates against anyone on this basis. Ubisoft will not tolerate violence or verbal abuse against team members – including harassment and bullying – on the basis of their political opinion or beliefs, in the workplace, on internal social media or on online platforms.

Ubisoft also expects its teams to help maintain Ubisoft’s neutrality, and not to engage in religious or political proselytization in the workplace.

Ubisoft expects that when team members discuss religion and politics, they keep in mind that these topics can be more sensitive for some people than others. Team members also must be careful that any public expressions of political or religious views do not imply any endorsement or link with the company.

Our standing guideline is that Ubisoft may not support politically or religiously affiliated organizations. However, if you believe there are extenuating circumstances and would like to partner with such an organization, approval should be obtained from the CSR department if NGOs are concerned and Corporate Affairs if public institutions are concerned.

1.9 Working together: guiding principles

At Ubisoft, we have a shared responsibility to create a work environment where everyone can thrive and give their best. Thus everyone is to abide by the following principles that inform how we work together:

We Are Caring. We strive to act with empathy. We never hesitate to offer a helping hand, knowing that we can also count on the support of others when we need it.

We Are Open-Minded. We value each other’s unique perspectives and believe that open discussions raise awareness and lead to growth, learning and mutual understanding.

We Are One Team. We are team players. We each bring our individual talents to achieve our shared mission. Our diverse backgrounds, cultures and experiences fuel our creativity.

Providing positive experiences for our players

2.1 Inclusive and accessible gaming experiences by design

Games should be for everyone.

Ubisoft is therefore committed to developing games that create positive experiences for all players, and reflect the diversity of the world we live in. Ubisoft expects team members to design every experience, event, product, service, website and communication with diversity, inclusion, equity and accessibility in mind, so that together we can remove potential barriers and foster inclusive and healthy gaming experiences.

Ubisoft will empower players and their families to make informed choices about our products. Appropriate labelling, age ratings and other relevant information will be made available to ensure the chosen game is suitable.

Ubisoft also strives to be fair and transparent in its approach to in-game monetization, offering fun, compelling and immersive gaming experiences while supporting player safety and wellbeing.

2.2 Ubisoft Teams as Players

Ubisoft has provided guidelines and rules that all players, partners and team members must follow when participating in activities associated with Ubisoft’s games or services both online and offline. These are detailed in the ‘Ubisoft Player Code of Conduct: The way we play’.

Ubisoft also expects team members to never misuse information gained as a result of their employment at Ubisoft when playing Ubisoft games as an unfair advantage. This includes winning at the expense of another player or obtaining rewards in a game by relying on confidential information.

Lastly, whether they are Ubisoft games or games made by the competition, the company further expects its team members to play by the rules and set an example for others. When team members are playing within games and communities in their own time, it is also important to not give the impression of acting on behalf of the company.

2.3 Player safety and trust

Ubisoft strives to build communities free from any forms of cheating, harassment, hate speech, or any other abusive or inappropriate behavior.

The company uses internal tools to actively prevent actions that could negatively impact our communities. We also empower our players to report any misbehavior, either through our reporting features or by getting in touch with our community managers. Ubisoft commits to investigate, and take action, whenever any inappropriate behavior is proven.

Ubisoft expects team members always to strive to create a safe and positive gaming environment, whether they are creating worlds or playing within them. Ubisoft also expects team members to report any misconduct they see or experience within Ubisoft’s communities, such as our forums.

Related resources:

Working ethically with partners

3.1 Fair treatment of partners

Ubisoft is committed to dealing fairly with partners through every point of our professional relationships. This means all team members must make sure they follow a certain number of rules.

This begins with engaging in open and competitive bidding, where personal contacts do not bypass formal procurement processes. It continues with contacting the relevant internal experts to prepare for any negotiation, and never disclosing information during a bidding process which might give one supplier an unfair advantage over another.

The company also expects teams to honor the written agreements and never asking suppliers to work for free or without a contract.

As part of the above process, Ubisoft expects team members dealing directly with partners to ensure all procurement and legal processes are strictly applied, to make sure that partners respect human rights and fundamental freedoms, as well as the health and safety of their teams and environmental responsibilities. Likewise, team members must follow the social responsibility and corruption risk-analysis as part of their selection and routinely re-assess existing partners. By following the proper process, you help Ubisoft deliver on these commitments.

Team members should report to a manager, the purchasing team or the whistleblowing line any actions made by, or towards, our partners which conflict with this Code of Conduct.

For more information on our relationship with partners, you can contact the Procurement Team. If you have a specific question about a contract with one of our partners, you can contact the Legal Team.

For more information on the conflicts of interest, see our Code of Conduct’s section 3.6.

3.2 Trade restrictions and export controls

As a company operating globally, Ubisoft complies with regulations concerning export controls, financial sanctions and trade restrictions.

Economics and trade sanctions include controls which restrict dealings with certain countries or individuals. For some countries, these sanctions amount to complete export and import embargoes meaning that any kind of trade or other commercial activity with that country is prohibited.

“Export controls” regulate the movement of certain goods considered sensitive, such as valuable information or technology, for example by requiring government licenses to move them across borders.

Ubisoft expects team members:

  • In our sourcing activities, not to contract with partners based in territories/countries subject to comprehensive sanctions/embargoes or with partners subject to individual sanctions.

  • In our distribution activities, not to offer our products or services in those territories/countries (directly or through distributors).

Failure to comply with these rules may result in severe penalties, fines and damage to our reputation.

3.3 Fighting corruption and influence peddling

Ubisoft is committed to conducting its business with integrity, transparently and in compliance with applicable laws. We have therefore adopted a zero-tolerance policy on corruption and influence peddling in all their forms and under all circumstances.

Ubisoft expects every team member to respect this zero-tolerance approach to corruption and influence peddling, and to participate in the associated training sessions.

This means never:

  • Soliciting, promising, authorizing, offering or accepting anything of value or any other benefit in exchange for undue advantage or to influence a business decision.

  • Paying or providing anything of value to a public official in order to induce them to perform their ordinary duties or perform them more quickly (facilitation payments).

  • Participating in any decision-making (e.g. partner selections) in which we could be influenced by a conflict of interest.

  • Using an intermediary as a way to make improper payments or bribes.

Failure to comply with these principles may result in disciplinary measures and exposure to civil and criminal sanctions for both the team member and the company.

Countering corruption and influence peddling is everybody’s responsibility.

Ubisoft expects every team member to be vigilant and to report any instance of corruption, influence peddling or related situations via the Whispli speak-up system.

For example, in the context of Ubisoft’s activities, acts of corruption or influence peddling could be motivated (either by a team member or a partner):

  • To obtain or renew a contract to work with us, to favor the renewal or signing of a contract, to obtain favorable decisions (being awarded a tender, gaining advantageous contractual clauses…).

  • To pursue a commercial relationship.

  • To obtain a retro-commission or obtain a personal service.

  • To obtain an undue advantage in exchange for donations to associations.

  • To obtain confidential and strategic information from Ubisoft in exchange of money, gifts or invitations.

  • To favor a recruitment of a relative.

For more information on the conflicts of interest, see our Code of Conduct’s section 3.6. Regarding gifts and invitations, see section section 3.4. About community involvement, see section 5.1.

3.4 Gifts and invitations

Gifts and invitations are an ordinary part of business life when they are a mark of courtesy to maintain quality business relationships.

However, in certain circumstances, gifts and invitations can be, or be perceived as, an act of bribery or corruption intended to influence a decision in favor of Ubisoft, a third party or an individual.

Ubisoft is committed to avoiding any exchange of gifts or invitations that could be perceived as bribery or dishonest activity.

Ubisoft therefore expects all team members to ensure under all circumstances that gifts and invitations, whether given or received, are:

  • Not exchanged at inappropriate times such as during partner assessments or selections, negotiations, signing or renewal of contracts or advantageous contractual clauses, etc.

  • Not made with the expectation of any obligation, influence or undue advantage in return.

  • Reasonable: by respecting the annual financial thresholds for each country as defined in Ubisoft’s Gifts and Invitations Policy.

  • Occasional i.e., not regular, frequent or systematic.

  • Transparent i.e., exchanged openly and without any concealment.

  • Compliant with all applicable local procedures and laws.

Failure to comply with these principles, our ‘Gifts and Invitations Policy’ or related laws, may result in disciplinary measures and exposure to civil or criminal sanctions, for the company as well as team members.

The company expects team members to follow the Gifts and Invitations Policy, which also addresses the case of business-related meals and the coverage of business travel & hospitality expenses for event invitations.

For more information on fighting corruption and influence peddling, see our Code of Conduct’s section 3.3.

3.5 Responsible lobbying

Ubisoft strives to act in a spirit of cooperation, transparency and mutual benefit with public institutions such as government bodies and local authorities. However only authorized team members may represent Ubisoft in discussions with public bodies.

Ubisoft is committed to ensuring that all of its lobbying-related activities are conducted legally and ethically, and we expect partners to adopt this same approach and principles.

Team members approved to engage in lobbying-related activities are registered and these activities are formally declared where the law requires it.

If Ubisoft employs an individual or organization to assist with lobbying-related activities, they must be open about the fact they are working for Ubisoft and follow Ubisoft’s rules on gifts, invitations and bribery.

As a team member, you cannot solicit directly or indirectly an elected official, a cabinet official, a ministry representative or a government-related agency on any Ubisoft-related matter. If you require government intervention on any matter, please refer to Corporate Affairs. If you are solicited directly or indirectly by an elected official, a cabinet official, a ministry representative or a government-related agency, on any Ubisoft-related matter, you must also refer such solicitation to Corporate Affairs.

Also, if you are invited to sit on the board of an organization in connection with government institutions, NGOs or advocacy bodies, or to participate in a specific mission initiated by such an organization, you might be perceived as representing Ubisoft.

In such a case, you must make sure you make it clear that you are acting in your own personal capacity. If you have a doubt about an invitation you have just received and wonder if you were invited in your personal or professional capacity, ask yourself the following questions:

  • How did the invitation arrive: were you reached through a corporate email address?

  • Are the membership fees of the organization paid by Ubisoft? Is Ubisoft a sponsor of the organization?

  • How is your affiliation with Ubisoft perceived by those who invited you: were you invited because you work for Ubisoft?

If the answer to one of those questions is ‘yes’, you should get in touch with the Corporate Affairs Department.

At any rates, if you are representing Ubisoft in any capacity, it is essential to note the following points:

  • You must make sure Corporate Affairs is informed of your participation on the Board of an organization in connection with a government / institutions / NGO / advocacy bodies, or a specific mission initiated by such an organization.

  • You must be trained to recognize and avoid conflicts of interest and you must know what Ubisoft’s positions are on the subjects of the day. You must not misrepresent Ubisoft’s positioning or present your own ideas as the company’s.

  • After any such external meeting/event or when you are participating actively in the management of an institution/association on a longer-term basis, you must make sure that Corporate Affairs department knows what has been discussed and provide feedback to Ubisoft so that we can develop our positioning on the issues at hand.

  • If you are in doubt or have concerns about activities that might conflict with our commitments on lobbying, you can speak to the Corporate Affairs Department.

Related resources:

3.6 Conflicts of interest

Ubisoft is dedicated to creating a work environment in which decisions are made fairly and in the best interests of the company as a whole.

However, any team member may find themselves confronted with situations of conflict of interest, in which their personal interest, or that of individuals or entities to which they are linked may come into conflict with the interest of Ubisoft.

It doesn’t matter if the intentions are good, even a perceived conflict of interest can have negative impact and legal implications for Ubisoft and the teams involved.

Conflicts of interest can also sometimes reveal situations of corruption, influence peddling or favoritism.

Ubisoft expects team members to always act with integrity, impartiality, fairness and in compliance with the law. When they are or believe to be confronted with a risk of conflict of interest, team members must immediately inform their direct manager before taking any further action.

Team members who have been witness to a conflict of interest are expected to report it immediately, using the Whispli speak-up system.

A few examples of conflicts of interest:

  • a team member’s relative owns a company that wants to work with Ubisoft. If team members can decide whether to award their family’s company a contract, that is a conflict of interest, as there is a risk of unfair preferential treatment.

  • a team member intervenes in order to favor the recruitment of a relative at Ubisoft.

  • a team member participates in a project that would be in competition with the activities of an organization in which the person concerned exercises functions.

For more information on the personal relationships at work, see our Code of Conduct’s section 1.7.

3.7 Respect for open and fair competition

Ubisoft commits to being fair in its dealings with competitors, consumers and partners.

In practice, this commitment means we never engage in any discussions with our competitors about pricing, market segmentation, or any other behavior that might reduce competition in the industry and increase prices.

Ubisoft also chooses its partners objectively and never selects any suppliers, distributors or other business partners based on any form of agreement with competitors.

Ubisoft expects all team members to know and understand these principles, especially if they interact with our competitors directly or indirectly as part of their role.

3.8 Prevention of money laundering

Money laundering is a process that turns illegally earned money into seemingly legitimate funds. Companies are sometimes targeted by criminals who see an opportunity to engage in money laundering through the company’s assets.

Ubisoft is committed to preventing money laundering in all its forms.

Money laundering can take many forms. It is important for us to be vigilant to these risks, in order to preserve the company’s reputation, maintain the trust of our shareholders, business partners and players, and avoid severe criminal sanctions or fines.

Ubisoft expects all team members to remain alert to the potential warning signs of money laundering, especially if they are working with external partners. Warning signs include:

  • Payments that look unusual such as being unexpectedly large, in the wrong currency or from unknown accounts or partners.

  • Situations in which partners insist on cash payment.

  • Payments where the paperwork does not match the activity taking place.

  • Transactions in which the requested payment method is not transparent, accurate or properly recorded.

To mitigate the risks, team members must abide by contractual terms and processes, ensure our transactions are maintained in a transparent, accurate and complete manner, declare conflicts of interest, avoid payments in cash, and be thoughtful when designing our in-game monetization systems.

Related resources:

Protecting confidential information, user data & company assets

4.1 Protecting confidential information

The video game industry is highly competitive, and Ubisoft relies on being able to develop new, exciting and surprising content for our players. This only works if we protect our confidential information.

Ubisoft is committed to taking extreme care to protect any information about games, software, projects, budgets, strategies or anything that has not been publicly announced.

Even after a game is announced, we must continue to protect any unreleased confidential information. Leaks, rumors and inaccurate speculation can lead to a loss in value, undermine our team’s morale, damage our reputation and the trust of our partners.

All team members are responsible for protecting the confidential information they have access to. They should ensure they only pass on confidential information to those who legitimately need to know it and when measures like a non-disclosure agreement are in place.

This responsibility applies when teams are interacting with both colleagues and external partners. Ubisoft also expects teams to ensure they do not disclose any confidential information inadvertently when interacting with friends, family or when working in public spaces like public transportation.

Team members should use tools available to them such as classification banners, project code names etc., should regularly update passwords and should immediately report stolen devices. They should not use public wi-fi for work-related activities.

4.2 Protecting inside information

As team members of a publicly traded company, protecting inside information is a strict legal requirement with severe risks of fines and criminal sanctions attached. It is also important towards maintaining trust and confidence in Ubisoft’s governance.

By inside information, we mean any precise non-public information that, if made public, would be likely to have a significant impact on Ubisoft’s share price. As a rule, if investors would consider a piece of non-public information to be important in their decision to buy or sell shares, it should be protected. Insider trading is the misuse of this information to gain unfair advantage in the trading of Ubisoft shares, or other financial instruments – engaging in this practice is a serious criminal offence.

As such, Ubisoft is committed to protecting inside information and countering all forms of insider trading.

Ubisoft therefore expects team members who have access to inside information to ensure they do not disclose it, either to another Ubisoft team member or to any external individual or organization, until this information has officially been made public by Ubisoft.

Those with access to inside information are also prevented from trading in Ubisoft shares, other financial instruments or derivative products, or encouraging others to do so until that inside information has been officially communicated.

If team members become aware of inside information regarding an external partner, the same confidentiality obligations and trading restrictions apply to the shares of that partner company.

Market Ethics Officers have been appointed to guide and train team members and to provide advice prior to any transaction.

Examples of inside information in our industry could include information related to significant acquisitions, material information associated with the release of a major product or material information on our future financial results.

The only exception to insiders’ confidentiality obligation is when other team members need to know that information to execute their mission. In that case, the information can be shared after approval of the Market Ethics Officer and of your manager. If an outside party is involved, an additional non-disclosure agreement must be signed.

4.3 Speaking on Behalf of Ubisoft

The reputation of our company and teams has far reaching impacts. We therefore have strict rules regarding who can speak publicly on behalf of Ubisoft.

Only designated spokespeople can officially represent Ubisoft. This helps to ensure that we protect our investments and reputation by not inadvertently disclosing confidential information or intellectual property, making promises to players that we cannot keep, making statements that go against our values, or misinforming the media, analysts or investors.

If a team member is not an official spokesperson, or unsure about their status, and receives enquiries from the media, analysts or investors, Ubisoft expects them to contact the Public Relations or Communication Team who will ensure the request is handled appropriately.

4.4 Personal and Professional Use of Social media

The commitment to mutual respect and to protecting the reputation of the company and its teams also extends to the use of social media, both externally and internally on platforms like Mana and Arcade.

Ubisoft expects team members to ensure they communicate responsibly and respectfully, never revealing any confidential information. Teams’ professional use of social media must be free of aggressive or toxic language and be honest and respectful when discussing competitors’ games, players and colleagues.

Externally, team members cannot misrepresent Ubisoft or their role in the company, for example by claiming that private posts are official communications, or by using “Ubi” or “Ubisoft” in their private profile names. Team members who post on social media as part of their work at Ubisoft must make a clear separation between their private and professional accounts.

Internally, on Ubisoft’s internal social networks, team members are encouraged to add comments, constructive critiques, questions, and suggestions. Every team member should feel like their voice can be heard, but never at the expense of a colleague. In order to create a positive and engaging environment for teams, Ubisoft will not tolerate:

  • Disrespectful content or comments, whether towards an individual user or a group of people, their opinion, or their work/project.

  • Offensive content including nudity, pornography, gore and violence.

  • Any virus, hack, crack or pirated software or any other content that acts against the law.

Team members posting about Ubisoft projects on social media are expected to work with our public relations, communications and community teams to ensure messages align with internal guidance. More information can be found on how to do this responsibly

4.5 Protecting the data of our teams, players and partners

As a privacy-friendly company, we are committed to protecting the personal data of our team members, players and partners.

  • For team members this means Ubisoft will only collect personal data when necessary, and for a specific use as part of an individual’s employment. The company will then ensure their rights when it comes to access, control, collection, storage, protection, transfer, erasure and disclosure of this personal data. To make sure Ubisoft strives for ‘privacy by design’, team members must contact DPO (Legal) Team when starting a new project.

  • For players this means Ubisoft provides players with information on their data rights and allows players to control whether their data is shared, deleted or kept confidential. Owners of Ubisoft Accounts should be able to modify their choices at any time in the Ubisoft account management website.

Ubisoft expects team members to know and respect these commitments and our related policies, especially if their role involves the processing of personal data of our teams, players or partners.

Related resources:

4.6 Responsible use of company assets

Ubisoft is committed to providing the best possible equipment and resources for its teams. The company sees these assets as a crucial part of providing the best possible experiences for players.

Besides our talented teams, IT resources including computers, dev-kits, and servers are among the company’s most important assets. These work-related resources remain the property of Ubisoft. This applies to Ubisoft devices and to Ubisoft material accessed from teams’ personal computers or phones.

Ubisoft expects team members to only use IT resources for authorized company activity. Further, to protect the security and longevity of these resources, team members should use secure processes for logging in, configuring devices, third-party services and applications like messaging.

Team members should not carry out any actions on our IT resources that might affect their ability to perform their intended tasks or cause any harm to Ubisoft.

By IT resources, we mean company devices, any aspects of IT infrastructure (such as our network, storage space, messaging system, internet connection and intranet) and any data stored there (such as files, images, software and emails).

Everyone at Ubisoft with access to IT resources (teams, teams of service provider companies, temporary workers, trainees, etc.) needs to adhere to the rules set out by Ubisoft in our IT Resources Use Policy.

For more information on appropriate use of IT resources, see this Code of Conduct’s section below on “Personal projects related to Ubisoft’s activities”.

4.7 Personal projects related to Ubisoft’s activities

How we spend our time outside of work is a clearly private matter.

However, if personal activities create an actual or perceived conflict with Ubisoft’s interests or impact teams’ ability to perform their duties, team members are expected to disclose this potential conflict of interest to their managers and Human Resources to obtain prior written approval.

Examples of such conflicts of interest include developing personal projects that may compete with Ubisoft’s products such as developing/publishing mobile games, providing services or acting on a pro bono basis to advise a company in the video game ecosystem, sitting on the board of directors or being a minority shareholder of a startup that develops games or mobile apps, etc.

Whenever potential conflicts of interest are disclosed, Ubisoft will do its best to find solutions in the best interest of the team members and the company.

Contributing to communities and causes

5.1 Community involvement

Ubisoft is committed to making a positive contribution to the local communities where we operate. We identify and support charitable organizations that align with the actions supported by Ubisoft, like the “PLAY FOR GOOD” program.

Team members must make sure they engage in those activities in an ethical, transparent way. Thus Ubisoft expects all team members to ensure that:

  • Volunteering days, partnerships or charitable actions are always carried out in the general interest (and not intended for an individual) and in line with the actions supported by Ubisoft.

  • Charitable donations are not made in cash, or on accounts opened in the name of an individual or in jurisdictions unrelated to the mission of the beneficiary of the donation.

  • Partnerships or charitable actions are not used to conceal practices likely to be qualified as corruption or influence peddling.

  • Initiatives with local communities are not used to fund political or religious activities.

  • The partner or charitable organization is reliable.

If there is no other option but to go with a political or religious organization, please contact the CSR department.

For more information on fighting corruption and influence pending, see our Code of Conduct’s section 3.3. Regarding diversity and inclusion, see section 1.4. About politics and religion in a neutral workplace, see our Code of Conduct’s section 1.8.

5.2 Environmental protection

As a creator of worlds, Ubisoft also has a responsibility to help protect the world we live in and has committed to contribute to carbon neutrality.

Ubisoft is committed to protecting the planet and all team members are expected to play a part in achieving this. We can always do more to safeguard the environment and Ubisoft aspires to be a leader in sustainability within the gaming industry.

Ubisoft is committed to monitoring and continuously reducing its environmental footprint, as well as regularly reporting on the progress of our action plan.

Ubisoft is also actively working to promote and share best practices among our business partners.

Ubisoft expects teams to make an effort to contribute to the company’s environmental commitment, through their work at Ubisoft, as well as on a daily basis – including turning off lights, heating, air conditioning and any other devices when not in use, and by adopting sound purchasing behaviors.

5.3 Commitment to human rights

Ubisoft is committed to respecting and upholding the human rights and fundamental freedoms of our teams, the players within our games, and our partners wherever we operate.

As a multinational company, Ubisoft and all team members must be aware of the need to protect human rights, especially in the supply chain. In the context of our operations, Ubisoft is committed to ensuring there is no slavery or human trafficking associated with any part of our business.

Ubisoft also abides by all applicable human rights laws in its zones of operation and we require our business partners to do the same. In particular, we respect the values set out in the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights and the Fundamental Conventions of the International Labor Organization.

Ubisoft expects its teams to be aware of the company’s human rights commitments and to report any behaviors, by team members or partners, that may go against them.

Related resources:

Speaking-up

6.1 Open-door culture

Ubisoft is committed to creating an open-door culture where everyone feels empowered to participate in discussions, pitch ideas, and share constructive feedback.

This principle also includes raising a concern when needed. Addressing the matter directly with those involved or with your direct manager is almost always the appropriate first step.

Ubisoft encourages team members to speak up as soon as possible when they see or experience behavior that violates this Code of Conduct. Speaking up in good faith is not only the right thing to do. It also helps to create a wider culture of trust in which all of us are protected. Ubisoft further expects managers and HR teams to listen to, support and protect those who speak up in good faith.

There are a variety of ways to raise a concern and team members should use the one most adapted to their situation. These include speaking with direct managers and HR managers, using local reporting helplines and group-wide channels. Additionally, in some locations teams can reach out to employee representatives or an external ombudsperson. We recognize that, from time-to-time, in-person reporting may be difficult. Therefore, Ubisoft has also put in place a whistleblowing platform, Whispli.

The Whispli platform is available to use in response to any misconduct related to our Code of Conduct as an anonymous reporting channel. Additionally, for concerns linked to corruption, money laundering, influence peddling, or conflicts of interest reports must imperatively be filed via Whispli.

The following sections provide more information on how Ubisoft team members can use the Whispli platform, but you can also find the full details and access the platform.

6.2 Non-retaliation & Reporting in Good Faith

All employees who participate in this process are protected from any form of retaliation.

Raising a concern when you think that something is not right should always be simple, confidential and safe. This means that if a team member raises a concern in good faith, Ubisoft commits to a zero-tolerance policy for any direct or indirect action being taken as punishment for reporting misconduct. If any individual retaliates or threatens to retaliate against a team member, Ubisoft will take strong disciplinary action against them.

No information will be given about a reported case to anyone unless it is strictly necessary in order to investigate it. In the course of an investigation, if a whistleblower made their identity known to the investigators, Ubisoft will protect their identity.

Ubisoft nevertheless expects team members to use the speak-up systems in good faith, without reporting allegations they know to be false for the sake of undue harm or personal gain.

Related resources:

6.3 How Ubisoft handles reports of misconduct

Ubisoft is committed to dealing with all reports of misconduct and to following an impartial process for their management and investigation. Ubisoft is also committed to maintaining confidentiality during all phases of the reporting and investigation process. The company’s systems have been set up to guarantee that only a very small number of individuals in the senior management of Ubisoft will be aware of each case.

Ubisoft’s reporting and investigation procedure includes various internal and external committees made up of people who are independent and chosen to guarantee impartiality.

Reports can be investigated by internal experts or for complex cases, handled by specialized external partners.

Whistleblowers can submit reports of misconduct anonymously. In some cases, whistleblowers may be asked to reveal their identity, however they can always choose not to do so. In all cases, team members that file a report will be informed when the investigations are closed.