Wargaming Group Limited, a company incorporated in Cyprus (company number: HE 290868) with its registered office at: 105 Agion Omologiton Avenue, Nicosia 1080, Cyprus, together with its subsidiaries and affiliates (collectively, “WARGAMING”) are committed to maintain the highest level of compliance, integrity and honesty through all aspects of its business.

WARGAMING believes that the responsibility of its vendors, partners and contractors (the “Business Partner”) is to treat others with honesty and respect and to act in accordance with laws and the highest ethical standards as well.

Thus, WARGAMING expects that any Business Partner, which is doing or is willing to do business with WARGAMING, shall comply with this Code of Conduct.

The Business Partner is also responsible for ensuring its sub-contractors to adhere to the same level of compliance with this Code of Conduct as WARGAMING expects from the Business Partner itself.

1.                  COMPLIANCE WITH LAWS AND REGULATIONS

1.1.            Compliance with laws. The Business Partner shall comply with all laws and regulations applicable to its business and cooperation with WARGAMING. The Business Partner is also responsible for ensuring that its directors, officers and employees are aware of the laws and regulations related to their job activities, so that they can perform their work in accordance with this Code of Conduct.

1.2.            AML/CTF laws. The Business Partner is compliant with all applicable laws, statutes and regulations relating to anti-bribery, anti-corruption (including but not limited to UK Bribery Act 2010 and US Foreign Corrupt Practices Act) and counter-terrorism financing laws, statutes and regulations ("AML/CTF Laws"). Neither Business Partner nor any of its directors have been involved or are currently engaged in any activities connected directly or indirectly with drugs trafficking, terrorism, money laundering, tax evasion, fraud or any activity, practice or conduct which would constitute an offence under sections 1, 2 or 6 of the UK Bribery Act 2010, or under any other applicable AML/CTF Laws.

The Business Partner represents, warrants and is obliged by the following:

a) it complies and will comply with AML/CTF Laws;

b) it is not engaged and will not be engaged in any activity, practice or conduct which would constitute an offence under the UK Bribery Act 2010 or under any other AML/CTF Laws;

c) it will not do, or omit to do, any act that will cause WARGAMING to be in breach of the AML/CTF Laws, and

d) it will promptly report to WARGAMING any request or demand for any undue financial or other advantage of any kind received by it in connection with cooperation with WARGAMING.

1.3.            Trade control. The Business Partner must always respect and comply with all applicable US or EU customs law and trade controls governing the import and export of products and services as well as similar regulation in the countries where Business Partner or WARGAMING is conducted its business. The Business Partner is prohibited from participating, in any manner, in the export/import of any equipment, technology, software, merchandise and other goods or services from one country to another country in order to illegally evade a country’s customs laws.

1.4.            Sanctions. The Business Partner shall strictly comply with economic sanctions, issued by the US/EU authorities, or applicable in any other location where the Business Partner or WARGAMING has an office. The Business Partner should take steps to ensure that it is not interacting, contracting or otherwise engaging with a sanctioned person or entity. This may include screening, risk-based due diligence or other procedures. The Business Partner shall avoid doing anything that would position itself or WARGAMING in violation of economic sanction regulation.

1.5.            Breach consequences. In case any breach of applicable laws or regulations is identified, the Business Partner should take immediate appropriate actions against such illegal acts and violations. The Business Partner should support zero tolerance to unlawful acts, regardless of grounds, motivation or reasons of such acts.

2.                  COMPLIANCE WITH HUMAN RIGHTS

2.1.            Human rights. WARGAMING is deeply committed to respecting human rights and expects its Business Partner to ensure the same level of compliance with applicable human rights laws. The Business Partner must organize fair and ethical workplace where all its employees are treated with respect and dignity.

2.2.            Abusive conduct. Work environment created by the Business Partner should be free of any harassment and abusive conduct. The Business Partner may not threaten or subject employees to harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental coercion, physical coercion or verbal abuse.

2.3.            Equal opportunities. The Business Partner should provide equal opportunities to all employees. No discrimination against any employee in hiring and employment practices such as applications for employment, promotions, rewards, access to training, job assignments, wages, benefits, discipline, termination, and retirement, based on race, religion, sex, sexual orientation, citizenship, national origin or disability should be tolerated.

2.4.            Unethical workplace. The Business Partner shall ensure that its work environment is free of any unethical or illegal conduct, including but not limited to corruption, bribery, money laundering or any other shady behavior.

2.5.            Anti-slavery policy. The Business Partner must not arrange, conduct, be connected to, involved with or associated in any way with the organization, arrangement or administration of any form of slavery and comply with any applicable law, including but not limited to UK Modern Slavery Act.

2.6.            Child labour protection. The Business Partner must always respect children’s rights and comply with any applicable law on child labour, including but not limited to UK Children and Young Persons Act.

3.                  HEALTH AND SAFETY, ENVIRONMENT

3.1.            Health and safety. WARGAMING is committed to ensuring healthy and safe working environment for the employees in line with internationally declared human rights. WARGAMING expects that the Business Partner to provide and maintain a safe work environment, integrate effective health and safety management practices into its business and comply with applicable laws and regulations relating to these issues.

3.2.            Trainings. All employees shall be given necessary and adequate health and safety trainings.

3.3.            Reporting. Any employee should be able to report unhealthy working conditions. Corrective actions shall be documented and completed on a timely basis.

3.4.            Environment. WARGAMING cares about the environment and supports environmental activities such as recycling, reducing the use of printing, using recycled paper, and other local initiatives. WARGAMING expects its Business Partner to demonstrate the same commitment and manage environmental impacts of their organization.

4.                  ASSET USE AND MANAGEMENT

4.1.            WARGAMING’s assets. The Business Partner, who has access to WARGAMING’s assets (intellectual property, technology, data, information, etc.), is required to protect them and safeguard from loss, damage, theft, waste, improper or unauthorized use.

4.2.            Intellectual property. WARGAMING expects the Business Partner to respect the intellectual property rights of WARGAMING. The Business Partner shall not use WARGAMING’s intellectual property in a manner that is not authorized by WARGAMING nor other parties’ unlicensed software or technology in support of or in connection with work for or with WARGAMING.

5.                  PRIVACY AND CONFIDENTIALITY

5.1.            Personal information. WARGAMING respects the privacy of its customers, players, employees and contractors. The Business Partner is also required to comply with all privacy laws and regulations while they collect, process any personal data or transfer it across international borders. Personal information should be collected only for legitimate business purposes, shared only with those who are allowed to access it, protected in accordance with security policies and retained only for as long as it is necessary. The Business Partner also should contractually oblige any of its contractors with access to personal information to protect it in accordance with data protection law. The Business Partner must take appropriate precautions (administrative, technical and physical measure) to safeguard any personal information against loss, theft, misuse as well as unauthorized access, disclosure, alteration and destruction.

5.2.            Confidential information. The Business Partner shall protect the confidential information that it has access to and strictly abide by all non-disclosure agreements and other agreements regarding confidential information as well as abide third parties with the same confidentiality obligations which it has. Confidential information includes but not limited to new product information, sales information, business plans, contract terms, financial information, work methods and processes, customers lists, databases, acquisition and product strategies and any other information which is not public and provides competitive privilege to WARGAMING in the market. If the Business Partner needs to share confidential information with its own employees, it can do that only on a need-to-know basis and ensure the employees do not share this information with anyone else and treat it as confidential.

6.                  RELATIONS INFLUENCE

6.1.            Conflict of Interest. The Business Partner must conduct business objectively, openly and transparently. If the Business Partner becomes aware of an actual or potential conflict of interest or a sensitive situation that may impact its or someone’s work for or with WARGAMING, the Business Partner should notify WARGAMING immediately. Many conflicts can be easily handled or avoided completely if they are promptly disclosed and properly managed.

6.2.            Gifts and entertainment. No gifts, meals, hospitality or entertainment is allowed if they may influence a decision or compromise WARGAMING’s professional judgement. It is possible to give or accept gifts or entertainment of value less than 250$ for a reasonable business purpose, providing that it is permitted by law and policies of WARGAMING and the Business Partner.

7.                  REPORT

7.1.            Violation Reporting. If the Business Partner is aware of any actual or potential violation this Code of Conduct, it should report this to WARGAMING immediately by e-mail compliance@wargaming.net. When a conflict with this Code of Conduct is reported, it will be dealt on a confidential basis. This means that reporter’s identity will be protected. The Business Partner should inform its employees that they will not be subject to retaliation as a result of raising a concern in good faith.

8.                  CODE OF CONDUCT BREACH

8.1.            If WARGAMING determines that the Business Partner has breached any of this Code of Conduct’s clauses, it may require the Business Partner to implement a remediation plan, or, in certain circumstances, may suspend or terminate the relationship with this Business Partner.