CODE OF CONDUCT PRINCIPLES

1. INTRODUCTION

At Fynd Reality, we hold ourselves – and our partners and suppliers – to high standards. These Code of Conduct Principles are established to ensure that Fynd Reality AS, and our entire value chain, reflects the same commitment to safety, integrity, and responsible innovation that defines our work.

These Code of Conduct Principles ensure that our company, and everyone contributing to Fynd CORE, operates in an environment where:

• working conditions are safe,
• all individuals are treated with dignity, fairness, and respect,
• business practices are ethical and transparent,
• and operations are carried out with care for the environment and society.

We expect from ourselves, and all partners and suppliers, to uphold internationally recognized standards for responsible business conduct, including relevant conventions on human rights, labor practices, environmental protection, and anti-corruption.

1.1 Purpose

These Code of Conduct Principles outline the minimum standards of conduct and professional practice we expect from Fynd Reality employees, and all partners and suppliers working with Fynd Reality. In addition to any commercial terms agreed upon, all suppliers must comply with these Principles to ensure ethical, sustainable, and responsible development across the full Fynd CORE ecosystem.

All Fynd Reality employees, partners and suppliers with Fynd Reality, are required to understand and follow our core values: Focused, Persistent and Reliable and commitment to responsible innovation. Read more about our values are available at www.fyndreality.com.

1.2 Content, scope and applicability

These Principles apply to Fynd Reality AS, and all partners and suppliers delievering products and/or services connected to Fynd Reality contracts or purchase orders.

Partners and suppliers must ensure that these Principles are communicated and upheld throughout their own supply chain, including both direct and indirect contributors. This extends to subcontractors, technology partners, agents, intermediaries, and recruitment or employment agencies.

At Fynd Reality, we believe in building strong and responsible partnerships. We therefore:

Encourage continuous improvement from ourselves and our partners and suppliers within all areas covered by these Principles.

Provide support and guide suppliers in identifying areas for development and implementing improvements.

To safeguard responsible and compliant delivery across Fynd CORE projects, Fynd Reality may evaluate adherence to these Code of Conduct Principles through partner and/ or supplier dialogue, assessments, and audits (see section 6.3 “Access for Verification”).

1.3 National Legislation and International Standards

Fynd Reality, and all partners and suppliers working with Fynd Reality, must operate in full compliance with the laws, regulations, and requirements of the countries in which they conduct business. Compliance must always meet, or exceed, the highest applicable standard.

In addition to national legislation, suppliers are expected to align their practices with internationally recognized principles, including but not limited to:

• The International Bill of Human Rights
• The International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work
• Applicable standards of international humanitarian law
• The UN Guiding Principles on Business and Human Rights
• The OECD Guidelines for Multinational Enterprises

If national law conflicts with these Principles, suppliers shall adhere to the higher standard. Any such discrepancy must be reported to Fynd Reality without delay.

If a partner and supplier cannot meet the higher standard, they must request a written exception from Fynd Reality.

2. HUMAN AND LABOUR RIGHTS

To meet the human and labor rights standards outlined in these Principles, Fynd Reality and all partners and suppliers working with Fynd Reality are required to conduct human rights due diligence in line with the OECD Guidelines for Multinational Enterprises and relevant international guidance.

Human rights due diligence is a recognized framework for ensuring respect for human rights and consists of six essential steps:

1. Embed responsible business conduct into policies and management systems
2. Identify and assess actual or potential adverse impacts across operations, supply chains and business relationships
3. Cease, prevent, or mitigate identified adverse impacts
4. Monitor and track the effectiveness of implemented actions
5. Communicate transparently how impacts are managed
6. Provide or cooperate in remediation when appropriate

Partners and suppliers must take proactive and ongoing steps to identify and address any real or potential human rights impact they cause, contribute to, or are directly linked to through their operations, supply chains, or business relationships.

2.1 Freely Chosen Employment 

Partners and suppliers working with Fynd Reality must not use or benefit from any form of human trafficking, slavery, or forced labor, including involuntary or exploitative prison labor.

All workers must have full freedom of movement and the right to resign at any time, in accordance with contractual terms and applicable notice periods.

Partners and suppliers must not require workers to surrender government-issued identification, passports, or work permits as a condition of employment.

No worker may be charged recruitment fees or related costs. If any such fees are identified, suppliers are responsible for ensuring that workers are fully reimbursed.

2.2 Child Labor Avoidance 

Partners and suppliers working with Fynd Reality must not hire, use, or benefit from child labor in any form.

No individual under the age of 15 may be employed, unless the local minimum age is 14 in accordance with the exceptions in ILO Convention 138. If national law sets a higher minimum employment age or mandatory school-leaving age, that higher standard applies.

Children and young people under 18 must not perform hazardous work, defined as any task that could compromise their health, safety, or physical or moral development. Where compulsory education applies, young workers may only work outside school hours.

2.3 Work Hours 

Standard work weeks are not to exceed the maximum set by national laws and regulations.

2.4 Wages and benefits 

Fynd Reality and all partners and suppliers shall, as a minimum, comply fully with all applicable laws and regulations concerning wages, working hours, overtime, and benefits. Wages must always be sufficient to cover basic needs and allow for a reasonable level of discretionary income.

Workers shall be compensated for overtime at rates that exceed the regular hourly rate, in accordance with local legislation.

No deductions may be made from wages as a disciplinary measure under any circumstances.

The basis for all wage payments must be clearly communicated. Employees shall receive timely pay slips, or equivalent documentation, detailing how their compensation has been calculated.

Before entering employment, all workers shall be provided with written, understandable information regarding their terms of employment, including wages and conditions.

2.5 Humane Treatment 

Fynd Reality and all partners and suppliers must have clear, accessible disciplinary policies and procedures that are communicated to all workers.

Any form of abuse or harassment is strictly prohibited—whether it occurs in the workplace or in any work-related setting outside the workplace. This includes, but is not limited to:

• Physical punishment or abuse.
• Sexual harassment or unwanted sexual attention.
• Verbal abuse or degrading language.
• Intimidation, coercion, or threats of any kind.

All workers shall be treated with dignity and respect at all times.

2.6 Non-Discrimination 

Fynd Reality and all partners and suppliers shall ensure a workplace free from discrimination. No worker shall be treated unfairly in hiring, promotion, compensation, access to training, termination, retirement, or any other employment practice based on:

• Gender
• Race or ethnicity
• Religion or belief
• National or social origin
• Caste
• Age
• Disability
• Sexual orientation
• Gender identity or expression
• Pregnancy or parental status
• Political affiliation
• Union membership
• Or any other status protected by applicable law

All employment decisions must be based on qualifications, competence, and performance.

Partners and suppliers shall not require or request medical tests that could be used for discriminatory purposes.

2.7 Freedom of Association  

Fynd Reality and all partners and suppliers shall respect employees’ right to form or join organizations of their own choosing, and to engage in collective bargaining, in line with national laws and regulations.

In countries where these rights are restricted by law, partners and suppliers shall enable, and never obstruct, the establishment of alternative, independent forms of worker representation and dialogue.

Workers shall be free from any intimidation or retaliation related to organizing, joining, or participating in such groups.

2.8 Regular Employment 

Fynd Reality and all partners and suppliers shall not use short-term or ambiguous employment arrangements—such as contract, casual, or day labor, to avoid obligations under national law, international conventions, or regulations relating to regular employment.

All apprenticeship or trainee programs must have clearly defined duration, learning objectives, and terms of engagement, ensuring they are used for genuine skill development and not as a substitute for regular employment.

2.9 Minority Rights and Protection of Vulnerable Communities 

Fynd Reality and all partners and suppliers shall ensure their operations do not cause or contribute to harm against marginalized or vulnerable populations. This includes avoiding actions that negatively affect livelihoods through irresponsible use of land, territories, or natural resources.

Partners and suppliers must assess and consider how their activities may impact local communities and take steps to prevent or mitigate any adverse effects.

2.10 Privacy and Data Protection 

Fynd Reality and all partners and suppliers shall respect the privacy of all employees and ensure that personal data is collected, stored, and processed in accordance with applicable laws and regulations.

If surveillance measures are required, for example to support safety, investigate concerns, or maintain cyber security, suppliers shall assess the impact on individuals and take steps to minimize any intrusion on privacy.

Partners and suppliers must also evaluate whether their products, services, or technologies – including any modified versions – may pose risks to the right to privacy. Where such risks are identified, appropriate safeguards must be implemented to prevent or mitigate potential harm.

2.11 Humanitarian Law 

Fynd Reality and all partners and suppliers shall respect and comply with all applicable standards of international humanitarian law.

Partners and suppliers must assess whether their products, services, or technologies, including modified or repurposed versions, could be used in ways that violate humanitarian law, as such misuse may also result in human rights breaches. When such risks are identified, suppliers shall take responsible and proportionate steps to prevent or mitigate potential misuse.

2.12 Responsible Sourcing of Minerals  

Technical suppliers providing hardware, components, devices, or other technology to Fynd Reality must comply with all applicable regulations regarding restricted substances, including hazardous materials and conflict minerals.

To ensure responsible and ethical sourcing, suppliers working with minerals such as cobalt, lithium, tin, tantalum, tungsten, or gold (and their derivatives) from conflict-affected or high-risk areas must:

• conducting a reasonable inquiry into the origin of any conflict minerals used in products supplied to Fynd Reality.
• performing due diligence (based on OECD/RMI guidance or equivalent) to determine whether minerals from high-risk areas may directly or indirectly support unlawful conflict.
• carrying out risk assessments and implementing appropriate mitigation measures.
  

2.13 Occupational Safety 

Fynd Reality and all partners and suppliers shall ensure safe working conditions for all employees by minimizing exposure to potential hazards through proper design, engineering controls, administrative procedures, preventative maintenance, and safe work practices.

When risks cannot be fully eliminated, suppliers must provide workers with appropriate and well-maintained personal protective equipment.

All employees shall receive regular, documented health and safety training, relevant to their role and environment.

No worker shall ever be disciplined or face negative consequences for raising safety concerns or reporting unsafe conditions.

2.14 Emergency Preparedness  

Fynd Reality and all partners and suppliers shall identify and assess potential emergency situations and take proactive steps to minimize their impact. This includes establishing and maintaining effective emergency plans and response procedures covering:

• Emergency reporting and communication
• Timely employee notification and evacuation routines
• Worker training and regular drills
• Adequate fire detection, suppression, and safety equipment
• Clearly marked and accessible emergency exits
• Recovery and business-continuity plans

All procedures must be understood by employees and tested regularly to ensure readiness.

2.15 Occupational Injury and Illness 

Fynd Reality and all partners and suppliers shall establish procedures and systems to prevent, manage, and respond to occupational injuries and illnesses. These systems must include:

• Processes for workers to report, classify, and record incidents without fear of retaliation
• Timely access to appropriate medical care
• Investigation of all cases to identify root causes
• Implementation of corrective actions to prevent recurrence
• Support for employees returning to work, ensuring a safe and sustainable reintegration

Accurate reporting and continuous improvement are essential to maintaining a safe workplace.

2.16 Sanitation, Food and Housing 

Fynd Reality and all partners and suppliers shall provide all workers with safe, clean, and hygienic facilities. This includes:

• Adequate ventilation and air quality
• Readily accessible, clean toilet facilities
• Safe drinking water
• Hygienic areas for preparing, storing, and eating food
• Appropriate emergency exits
• Hot water for bathing or showering
• Adequate heating and ventilation
• Sufficient personal space
• Reasonable freedom of entry and exit

If the supplier or a labour agent provides worker housing, it must be maintained to a high standard of safety and cleanliness. Dormitories shall include:

These conditions are essential to ensuring the wellbeing and dignity of all workers.

3. QUALITY AND CONTINUOUS IMPROVEMENT

Fynd Reality is committed to delivering world-class quality in everything we do, from the development of Fynd CORE to the partnerships that support our technology and customers.

We expect our partners and suppliers, to work with Fynd Reality in an open, collaborative way to continually improve the quality, reliability, and safety of the products and services they deliver. Continuous improvement is a shared responsibility, and we rely on suppliers to actively look for ways to strengthen processes, reduce risk, and enhance performance throughout the value chain.

Where applicable, suppliers are expected to comply with relevant international standards such as ISO 14001 (environmental management) and ISO 45001 (occupational health and safety).

4. THE ENVIRONMENT

ynd Reality and all partners and suppliers shall take a precautionary and proactive approach to environmental and climate-related challenges. All operations must be carried out in a way that minimizes negative impact on local communities, the environment, and natural resources, while ensuring the health and safety of the public.

This includes responsible management of materials, emissions, waste, and energy use, as well as continuous efforts to reduce the environmental footprint of manufacturing and delivery processes.

4.1 Pollution Prevention and Resource Reduction

Fynd Reality and all partners and suppliers shall work actively to prevent pollution and reduce resource consumption. Waste of all kinds, including materials, water, and energy, should be minimized at the source through responsible practices such as:

• Improving production, maintenance, and facility processes
• Substituting materials with safer or more sustainable alternatives
• Conserving resources wherever possible
• Recycling and reusing materials to reduce overall footprint

A continuous focus on reducing environmental impact is essential to supporting a sustainable and responsible supply chain.

4.2 Hazardous Substances

Fynd Reality and all partners and suppliers shall identify all chemicals and materials that may pose a risk to people or the environment. These substances must be managed responsibly to ensure safe handling, transport, storage, use, recycling or reuse, and disposal.

Processes and controls shall be in place to prevent leaks, accidental releases, or unsafe exposure, protecting both workers and the surrounding environment.

4.3 Wastewater and Solid Waste

Fynd Reality and all partners and suppliers shall ensure that all wastewater and solid waste generated from operations, industrial processes, or sanitation facilities are properly identified, monitored, and controlled.

All waste must be treated and handled in accordance with relevant legislation, permits, and environmental standards before discharge or disposal.

These practices must protect workers, local communities, and the environment from harmful exposure or contamination.

4.4 Air Emissions

Fynd Reality and all partners and suppliers shall identify, monitor, and control all air emissions generated from their operations, including volatile organic compounds, aerosols, corrosives, particulates, ozone-depleting substances, and combustion by-products.

All emissions must be treated in accordance with relevant laws, permits, and environmental standards before release, ensuring they do not harm workers, communities, or the environment.

4.5 Greenhouse Gases (GHG)

Fynd Reality and all partners and suppliers shall identify, measure, and report all greenhouse gas emissions resulting from their operations.

Partners and suppliers are expected to set clear targets and develop actionable plans for reducing their GHG footprint over time, contributing to a more sustainable and climate-responsible supply chain.

4.6 Water Use

In regions where freshwater is limited or vulnerable, Fynd Reality and all partners and suppliers shall measure and disclose their freshwater consumption.

Partners and suppliers are also expected to establish plans for reducing freshwater usage in their operations, supporting responsible and sustainable resource management.

4.7 Sustainable Technologies

Fynd Reality and all partners and suppliers shall actively promote and adopt sustainable technologies in their operations. This includes selecting efficient, environmentally responsible components and production methods, and striving to increase the use of technologies that reduce overall environmental impact.

Partners and suppliers are encouraged to continuously explore and implement innovations that support a lower environmental footprint across their products, processes, and supply chains.

4.8 Environmental Permits and Reporting

Fynd Reality and all partners and suppliers shall obtain and maintain all required environmental permits, approvals, and registrations. All operational, monitoring, and reporting obligations associated with these permits must be followed accurately and on time.

Full compliance is essential to ensuring responsible and transparent environmental management throughout the supply chain.

5. BUSINESS INTEGRITY

5.1 Ethical Business Conduct

Fynd Reality and all partners and suppliers shall comply with all applicable laws and regulations relating to bribery, corruption, fraud, and any other illegal business practices.

Partners and suppliers shall not offer, request, accept, or receive any improper benefit, service, or incentive from government officials, international organizations, or any third party for the purpose of securing business, gaining an advantage, or receiving personal benefits. This includes a strict prohibition on facilitation or “grease” payments, unless such payments are part of an official, legally established government fee schedule and accompanied by formal receipts.

Payments made solely to protect personal safety in situations involving imminent threat are permitted but must be documented and reported to Fynd Reality without delay.

Partners and suppliers may not sponsor political parties or political candidates in connection with their contract or collaboration with Fynd Reality. Any lobbying activities must comply fully with applicable laws and regulations.

Partners and suppliers must not intentionally or negligently attempt to access confidential information that could provide an undue competitive advantage.

Fynd Reality and all partners and suppliers shall not, directly or indirectly, offer or accept gifts, hospitality, or expense coverage that could give, or appear to give, an improper advantage based on a person’s position, responsibilities, or influence. This applies especially during tender processes or contract negotiations.

Exceptions may be made for modest, clearly appropriate hospitality or representation when there is a legitimate business purpose and costs are reasonable. Under no circumstances may cash or cash equivalents be offered or accepted.

5.2 Disclosure of Information  

Partners and suppliers shall disclose information about their business activities, organizational structure, financial position, and performance in line with applicable laws, regulations, and recognized industry standards.

All reporting must be accurate, transparent, and timely, ensuring the integrity of information shared across the supply chain.

5.3 Intellectual Property

Partners and suppliers shall respect all intellectual property rights and ensure that technology, proprietary information, and know-how are properly protected.

Partners and suppliers must maintain secure systems and processes for the handling, transmission, storage, and disposal of confidential or sensitive information, ensuring it is safeguarded against unauthorized access, misuse, or disclosure.

5.4 Fair Competition

Fynd Reality and all partners and suppliers shall engage with competitors in an honest, transparent, and professional manner at all times.

Partners and suppliers must not participate in—or enable—any practices that violate competition laws or regulations. This includes, but is not limited to:

• Illegal price-fixing
• Bid-rigging
• Market or customer allocation
• Any form of collusive or anti-competitive behavior

We are expected to uphold fair and open competition in every market where we operate.

5.5 Data Privacy

Fynd Reality and all partners and suppliers shall respect the privacy of employees, customers, and all third parties. Any collection, recording, storage, or monitoring of personal data must comply fully with applicable data protection laws and regulations.

Personal data shall only be processed for legitimate business purposes, handled securely, and protected against unauthorized access or misuse at all times.

If a partner or supplier processes personal data on behalf of Fynd Reality, the supplier must sign a Data Processing Agreement (DPA).
This agreement outlines the supplier’s obligations to handle, protect, and process personal data in full compliance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

For more information about how Fynd Reality manages personal data, please refer to our Privacy Statement and applicable data protection guidelines at fyndreality.com.

5.6 Money Laundering and Tax obligations

Fynd Reality and all partners and suppliers shall actively oppose all forms of money laundering and take necessary measures to ensure their financial transactions cannot be used, directly or indirectly, for laundering or other illicit financial activities.

Partners and suppliers must also meet all tax obligations by accurately reporting and paying all required taxes, duties, and fees in accordance with applicable laws and regulations.

5.7 Defence Industry Disclosure 

Partners and suppliers delivering components, technology, or services for defence-related products must maintain full transparency and understand that they form part of a wider defence industry value chain.

If a partner or supplier is granted access to classified or sensitive information, all required security agreements, clearances, and authorizations must be established and maintained in accordance with applicable laws and regulations.

Partners and suppliers shall ensure that both management and employees uphold the highest standards of confidentiality, security, and professional conduct when handling defence-related information or materials.

5.8 Sanctions, Denied Parties Lists or Embargo Compliance

Fynd Reality and all partners and suppliers shall ensure that neither they nor any part of their supply chain engage in business with individuals, organizations, or countries listed on applicable sanctions lists, denied-party lists, or subject to trade embargoes.

Partners and suppliers must have processes in place to screen partners and transactions against relevant international and national sanctions regimes.

Any nonconformity, including suspected or potential violations, must be reported to Fynd Reality immediately.

5.9 Conflict of interest

Partners and suppliers shall avoid any personal, financial, or professional interests that could conflict with their responsibilities to Fynd Reality.

Any actual, potential, or perceived conflict of interest must be reported to Fynd Reality immediately, along with notification to all affected parties. Partners and suppliers are expected to manage such situations transparently and take appropriate steps to prevent compromised judgement or decision-making.

6. IMPLEMENTATION AND ADMINISTRATION 

6.1 Compliance Management System

Partners and suppliers shall establish and maintain a compliance management system that supports full alignment with these Code of Conduct Principles. The system must be designed to:

• Ensure compliance with all applicable laws and regulations
• Secure adherence to the expectations outlined in these Principles
• Identify, assess, and mitigate operational risks related to ethical, environmental, safety, and human rights standards
• Support continuous improvement across relevant processes and practices

A robust compliance management system is essential to maintaining a responsible, transparent, and sustainable partnership with Fynd Reality.

6.2 Responsibilities

Partners and suppliers shall appoint a senior management representative with clear responsibility for ensuring compliance with these Code of Conduct Principles. This person must have the authority and oversight needed to monitor implementation, address risks, and drive continuous improvement.  

6.3 Access for verification  

To ensure adherence to these Code of Conduct Principles, partners and suppliers shall allow Fynd Reality, or approved representatives acting on our behalf, to conduct both announced and unannounced assessments or audits.

Partners and suppliers must provide full access to all relevant documentation, facilities, systems, and personnel involved in delivering products or services to Fynd Reality. This requirement also applies to any subcontractors engaged in work connected to Fynd Reality or Fynd CORE.

Partners and suppliers are expected to cooperate transparently and proactively throughout the verification process.

6.4 Records  

Partners and suppliers shall maintain accurate, complete, and up-to-date records of all business activities relevant to their work with Fynd Reality. These records must be sufficient to demonstrate compliance with these Code of Conduct Principles and with any contractual obligations connected to Fynd CORE or related services.

All documentation must be stored securely, be readily accessible upon request, and retained in accordance with applicable laws and industry standards.

6.5 Communication of the Principles

Fynd Reality and all partners and suppliers shall ensure that the requirements set out in these Principles are clearly communicated to all employees, subcontractors, and other partners involved in delivering products or services to Fynd Reality. Suppliers are responsible for taking active steps to ensure that their own supply chain also complies with these Principles.

Partners and suppliers must provide their employees and subcontractors with safe, accessible, and confidential channels for raising concerns or reporting potential non-compliance. Such matters must be handled responsibly, without retaliation, and addressed in a timely and transparent manner.

6.6 Asking questions and raising concerns  

Fynd Reality and all partners and suppliers shall maintain a clear and accessible system for reporting and managing concerns, including potential breaches of these Code of Conduct Principles within their own organization or among subcontractors. Any concerns that may affect business with Fynd Reality must be reported to us in writing without delay. We expect full transparency and cooperation when such matters are investigated.

Retaliation of any kind against individuals who report genuine concerns or support an investigation is strictly prohibited. Partners and suppliers must ensure that mechanisms are in place to safeguard confidentiality and protect whistle-blowers.

Questions or concerns related to responsible business conduct can be raised directly with Fynd Reality at: post@fyndreality.com

7. EFFECTIVE DATE

 These Code of Conduct Principles become effective from the date they are formally signed and approved by Fynd Reality.