Codeof conduct
2023

Contents
Understanding the Code....................................................................................................................... pg. 3
Purpose........................................................................................................................................... pg. 3
Scope ............................................................................................................................................ pg. 3		Our vision................................................................................................................................. pg. 3		Our mission.............................................................................................................................. pg. 3		Our values................................................................................................................................ pg. 3
Compliance with laws and regulations.......................................................................................... pg. 3
Responsibility and Implementation............................................................................................... pg. 4		Personal responsibility............................................................................................................ pg. 4		Managers’ responsibility......................................................................................................... pg. 4		
Board of Directors and CEOs’ responsibility........................................................................... pg. 4		
Cognite commercial partners, customers and suppliers ...................................................... pg.4
Caring about People.............................................................................................................................. pg. 5
Personal data and privacy.............................................................................................................. pg. 5
Working environment (human rights and workers’ rights?)......................................................... pg. 5
Acting with Integrity.............................................................................................................................. pg. 6
Conﬂict of interest......................................................................................................................... pg. 6
Corruption and bribery................................................................................................................... pg. 6
Gifts and hospitality....................................................................................................................... pg. 6
Export controls and sanctions....................................................................................................... pg. 7
Fair competition............................................................................................................................. pg. 7
Insider trading................................................................................................................................ pg. 7
Money laundering........................................................................................................................... pg. 7
Safeguarding of IP and assets....................................................................................................... pg. 7
Sensitive information and conﬁdentiality..................................................................................... pg. 8
Protecting the Environment................................................................................................................. pg. 9
Retaliation ............................................................................................................................................ pg. 9
Promoting Transparency....................................................................................................................... pg. 9
Accurate and timely information and ﬁnancial reporting............................................................. pg. 9
Political contributions and activities............................................................................................. pg. 9
Relations to business partners...................................................................................................... pg. 9
Sponsorships.................................................................................................................................. pg. 9
Where to seek guidance and report breaches..................................................................................... pg. 10Revisions............................................................................................................................................... pg. 10

Understanding the code

PurposeThis Code of Conduct describes
the ethical commitments ofCognite AS, including its affiliatedcompanies and subsidiaries(“Cognite”). In order to develop acompany culture that meets ourvision, mission and core values,
the Code of Conduct sets out
expectations to the personal
conduct and business practice ofour employees.

Scope
This Code of Conduct applies toall employees (including officers/directors and hired-in personnel),commercial partners, customers
and suppliers (together referred
to as “we”). Anyone acting on
behalf of Cognite are expectedto adhere to standards that areconsistent with this Code of
Conduct and applicable laws andregulations.

creativity to shape a safer, more
efficient, more sustainableindustrial future.

Our mission
Our mission is to provide a digital
representation of industrial
reality, and make it accessible
and meaningful for humans andmachines.

Our values
We are a vibrant, diverse
company and our commitment
to shape the industrial futurewith our customers brings us
together. Together, we havedefined a set of common values
to inspire our work life.

mission keeps us alignedand motivated. Execution iseverything.
Openness — Data must be open
to create value. That’s how
we work with our customers,
partners, and teammates alike.
Within our company, we share as
much as possible by default. And
we hold each other accountable.
Curiosity — We love learning. We
seek out what we don’t know
yet by asking good questions,challenging assumptions, andlistening to one another. We’rewilling to challenge each otheron the way.
Togetherness — We innovate
through building on our ideas
and strengths. This means
supporting and challenging oneanother. On good days and bad,we stand shoulder-to-shoulder,
and we have fun… together!

Our vision

Impact — Go big or go home.
We fundamentally change theindustrial world and make it moresustainable. What we do matters
to our customers, changing theway they work and showing up on
their bottom lines.

Compliance with laws
and regulations

Our vision is to create anindustrial world powered by data
and algorithms, freeing human

Velocity — We move fast and try
new things, and we don’t stopmoving forward. Our exciting

We shall all comply with allapplicable laws and regulations,and respect cultures and rights

of individuals everywhere weoperate. If there are differences
between laws/regulations andthe standards set out in thisCode of Conduct, we shall follow
the highest standards that areconsistent with applicable local
laws.
This Code of Conduct is the main
governing document in Cognite.
We also have other, moredetailed policies for expectedbusiness conduct. If you thinksomeone is violating any of ourgovernance policies or applicablelaws or regulations, don’t bebashful - let your manager orother appropriate authority knowabout it.

Responsibility andImplementation

with and perform your duties inline with the principles of thisCode of Conduct. If you need
advice in handling a specificor possible ethical dilemma,or have questions about theCode of Conduct, consult withyour manager or Cognite’sCompliance Officer.

ensure that employees are awareof and comply with this Code ofConduct, that annual Code ofConduct training is mandatoryfor employees and that all
employees sign off to confirm
they have read and understood
the Code of Conduct on anannual basis.

Managers’
responsibility

Cognite commercial
partners, customers
and suppliers

Managers are responsible
for communicating therequirements in the Code ofConduct to all their direct
reports, and for promoting andmonitoring compliance with theCode of Conduct within theirrespective area of responsibility.

Personal responsibility

Board of Directors andCEOs’ responsibility

We shall all strive to exercise
good judgment, care andconsideration. Get familiar

Cognite’s Board of Directors isresponsible for implementing theCode of Conduct. The CEO shall

Cognite expects all theircommercial partners, customers
and suppliers to follow Cognite’s
Code of Conduct or have theirown equivalent policy in place.
If you have any questions about
the Code of Conduct or anyof our other Policies, you may
direct your inquiries to ourCompliance Officer. You canalso report any concerns orsuspicions anonymously to ourwhistleblower channel →.

Caring about people
To learn more about this, read
our Anti-Harassment Policy.
We are all committed to thefollowing:■ providing minimum wage,
decent standard for working
condition and workers health andsafety■ we have a zero tolerance formodern slavery, child labour andhuman rights violations

Cognite prides itself in having
an inclusive work culture thatvalues diversity and equality.
We want our employees,
customers, suppliers, andcommercial partners to be proud
to be associated with us and topromote our values by behaving
ethically and in accordance withthis policy.

Personal data andprivacy
Cognite is committed to protect
all individuals’ personal data
while performing our businessand delivering our services.
We only collect, process andstore personal data in line withapplicable data protection laws
and regulations. To learn more
about this, read our Privacy
Notice or GDPR Policy.

Working environment(human rights andworkers’ rights)
Cognite respects, supports andacknowledges the fundamental

principles of human rights as
defined in the United Nations
Guiding Principles for Businessand Human Rights, the ILO
Declaration on Fundamental
Principles and Rights atWork (including the ILO core
conventions), and the OECD
Guidelines for Multinational
Enterprises, as well as the new
Norwegian Transparency Act
2022 (Åpenhetsloven).
Cognite acknowledges
employees’ right to form andjoin trade unions. We involve
employees in decision-making
processes and believe thisimproves the grounds for
decision-making.
Cognite values diversity andwants every employee to be able
to develop individual skills andtalents. We oppose harassment,
discrimination based on age,gender, sexual orientation,

disability, race, nationality,
political opinions, religion,

philosophical belief or any otherbasis prohibited by law, and otherdegrading treatments in any
form, by or towards employees.

■ respect the personal dignity,
privacy and rights of all people
we interact with and thoseaffected by Cognite’s business

Cognite expects the same highstandard of respect for humanrights and working conditions
from all our commercial partners,
customers and third-party
suppliers.
For more detailed information
about how to behave at work,
read the Employee Handbook.
Cognite takes all human rights
concerns seriously. Please reachout to our Compliance Officer
in writing, if you become awareof breach of Cognite’s humanand labor rights standards. You
can also report any concerns orsuspicions anonymously to ourwhistleblower channel →.

Acting with integrity
Act with integrity in the course ofyour work – follow your moral andethical convictions, do the rightthing even if no one is watching
you, be true to yourself and theCode of Conduct, and don’t
dishonor yourself or the Code ofConduct.

Conﬂict of interest
Conflict of interest is when
you have a personal or outside
interest that conflicts withthe best interest of Cognite.
A personal interest can be afinancial interest in anothercompany or a transaction, arelationship, including but notlimited to immediate family, or any
interest or relationship that may
improperly affect our judgment
and decision-making.
We are all committed to thefollowing:■ never take action or get
involved in relationships thatin fact or appearance can giverise to a conflict of interest, andensure that transactions withrelated parties adhere to relevant
principles for such transactions;■ if a conflict of interest arises
or something appears to be a
conflict of interest, notify yourmanager or the Compliance
Officer;■ seek pre-approval from yourmanager for directorships orassignments held/carried out inother companies; and■ never let engagement induties or assignments outside
Cognite negatively impact ourworking relationship with Cognite
and always ensure that suchactivities do not conflict with
Cognite’s business interests.

Corruption and bribery
Cognite has zero tolerance for all
forms of corruption, and we makeactive efforts to ensure that it
does not occur in our businessactivities. Corruption, as definedin Cognite’s Anti-Corruption
and Appointment of Third
Party Representatives Policy, iswhen a person or organization
offers, gives, receives, orsolicits something of value forthe purpose of influencing directly or indirectly - officials or
private parties for an improper
purpose, including to obtain or
retain business or any businessadvantage.
When engaging with public
officials, we must be extra
cautious of the corruption risk
and act in a transparent manner.
We are all committed to thefollowing:■ never, directly or indirectly,
offer anything of value toinfluence the actions or decisionsof, or otherwise obtain any
improper advantage from:— any official person,including any person in public
or legal duty,— any person acting
on behalf of customers orsubcontractors/suppliers, or— any other third party;
in selling goods and services,conducting financialtransactions or representing
the company’s interests;■ never give nor encourage
facilitation payments unless anemployee is a victim of extortionand his or her health and safety
is in danger (such incidents shallimmediately be reported to yourmanager and Cognite’s CEO orCompliance Officer); and■ ensure that all paymentscomply with Cognite’s accounting
and financial procedures forthe approval and recording ofpayments, and that they aresubmitted to the appropriate levelof management.
■ if you or your colleague end
up in a serious situation, report
immediately to your manager andCognite’s CEO or Compliance
OfficerGifts and hospitality
Cognite does not accept theoffer or acceptance of businesscourtesies where they could
constitute, or appear toconstitute, an undue influence.
Hospitality, such as social events,
meals or entertainment, may beacceptable for a clear businessreason, provided that the costis reasonable. Local laws may
restrict or prohibit offering ofgifts and entertainment to publicofficials. For more information
about gifts and hospitality, see
the Gifts and Hospitality Policy.
We are all committed to thefollowing:■ never offer, promise, give orreceive gifts, hospitality or otheradvantage to or from a public
official without specific, written
pre-approval from Cognite’sCompliance Officer;

with antitrust and competition
laws and regulations.

Compliance Officer in all matters
involving risk of insider trading.

We are all committed to thefollowing:

Money laundering■ never, directly or indirectly,
accept gifts or other
remuneration if there is reason tobelieve its purpose is to influencebusiness decisions; and■ meet competition in aprofessional and transparent
manner;■ never solicit a gift or favor
for personal benefit from any of
Cognite’s stakeholders.

Export controls andsanctions
Export controls and economic
sanctions laws restrict the sale,shipment, electronic transfer,provision and disclosure ofinformation, software, goods,
assets, funds and services acrossnational borders or involving
parties subject to economic
sanctions. Exports are not limited
to traditional shipping methods
and include electronicallytransfer, through discussions orvisual inspections.
We are all committed to thefollowing:■ carefully consider potentialimpact of export control laws
and sanctions before transfer ofgoods, technology, software orservices across national borders;and■ be cautious if dealing withparties from sanctioned countries
or otherwise designated forfinancial sanctions.

Fair competition
Cognite shall protect fair andopen competition and comply■ never take part in or support
illegal cooperation on pricing,illegal market sharing or any otheractivity that constitute breach ofapplicable competition laws; and■ consult the Compliance
Officer in all matters involving riskof antitrust exposure for Cognite,
yourself, or any of your reports.

Insider trading
With a main shareholder that is a
publicly listed company, Cognite
is subject to laws concerning
insider trading. Insider trading
is defined as trading, either
directly or indirectly, in publicly
traded shares or other securities
while in possession of specificinformation capable of affecting
the price of the shares orsecurities and that is not publicly
available or generally known
in the market, or disclosure ofsuch information to someone
or influence someone who thentrades in those shares or othersecurities.
We are all committed to thefollowing:■ refrain from trading securities
while in possession of material,
non-public information relating
to Cognite’s shareholders or
customers that are publicly listed(this applies to our close family
members as well); and■seek advice from theMoney laundering occurs when
the criminal origin or nature ofmoney or assets is hidden in
legitimate business dealings orwhen legitimate funds are used
to support criminal activities.
Cognite is firmly opposed to all
forms of money laundering.
We are all committed to thefollowing:■ seek to prevent that Cognite’s
financial transactions andbusiness activities are used tolaunder money;■ ensure that all businessactivities are legitimate andinvolve legitimate funds derivingfrom legitimate sources;■ consult the financedepartment or the Compliance
Officer if there are irregularities
relating to payments, suchas offshore bank accounts oraccounts not normally used by
the party in question; and■ consult the financedepartment or the Compliance
Officer if in doubt about the origin
and destination of money andproperty.

Safeguarding of IP andassets
Only authorized employees canuse our property and assets,
and only for legitimate businesspurposes. This goes for bothtangible property (such asequipment), and intangible
property (such as intellectual
property and confidentialinformation). Information
produced and stored on ourIT systems is the property of
Cognite. We shall never process
or download information that may
be illegal or inappropriate.
Our intellectual property, such aslogos, copyrights, trade secrets,“know-how” and patents areCognite’s most valuable assets.
Unauthorized use can lead toloss of value. Inappropriate useof others’ intellectual property,
including violation of license
requirements under which open
source software is distributed,
may expose Cognite and you
to criminal and civil fines andpenalties.
We are all committed to thefollowing:■ only use Cognite’s logos andmarks for necessary businesspurposes;■ prevent unauthorized use ofCognite’s intellectual property;■ respect others’ intellectualproperty;

Sensitive informationand conﬁdentiality■ report suspected misuseof trademarks, logos, or otherCognite intellectual property to
the legal department;

We shall protect sensitive orconfidential information, and not
misuse information belonging to
Cognite or a partner.

■ consult with the legal
department before

We are all committed to thefollowing:■ authorizing access to or
use of Cognite proprietary
information,■ comply with statutory andcontractual confidentiality
obligations, which may apply
as long as the informationis considered sensitive or
confidential, and after conclusionof the employment or contractual
relationships with Cognite; and— soliciting, acceptance or
use of proprietary informationfrom outside Cognite, and— incorporating open
source code or other content
not belonging to Cognite into
a product, service, or internalproject;■ use IT systems and particularlyinternet services carefully, andonly for business purposes, notpersonal interests.

■ always carefully consider how,where and with whom Cogniterelated matters are discussed.
To learn more about this, read ourInformation Classification Policy.

Protecting the environment
We shall act responsibly and aim to reduce direct and indirect negative influences on the externalenvironment. We shall follow relevant international and local laws and standards, and seek to minimize ourenvironmental impact. For more information please see Cognites sustainability report.

Retaliation
Retaliation is not tolerated byCognite. Retaliation is any kindof intentional negative action
against a current or former
employee that takes the form of athreat, retribution, antagonism or
uncomfortable environment as aresult of their reported complaint.
Cognite will not tolerate any
retaliation against another
employee who speaks up in goodfaith.If you are experiencing
or have witnessed retaliation,please report the incident

to the Compliance officer or
Cognite’s Whistleblower Channel.
Retaliation of any kind will be
subject to disciplinary action andmay be grounds for termination.

Promoting transparency
Accurate and timely
information andfinancial reporting

laws, regulations and relevant
accounting standards.

Cognite is committed to providing
our stakeholders with quality
information that enables them tomaintain a correct picture of our
financial standing.

Political contributions
and activities

We are committed to thefollowing:■ communicate relevantbusiness information on a timely
basis to our stakeholders; and■ accurately register andpresent accounting and financial
information, and other disclosure
information in accordance withCognite maintains a neutral
position on party politics anddoes not in any way support any
political party or their candidates.
Cognite may participate in publicdebates if this is in the company’sinterest.

Relations to business
partners
We are dependent on ourpartners and shall deal honestly,ethically, impartially and fairly
with our stakeholders. Cognite
expects the same high standardof business ethic from all
our partners, customers andsuppliers.

Sponsorships
Cognite may promote its businessthrough sponsors that reflect
Cognite’s values, quality andprofile. No religious or politicalgroups or organizations may
be sponsored. All sponsorships
shall be structured as ‘win - winsituations’. Charitable donations
to organizations must not be
mutually beneficial.

Where to seek guidance
and report breaches
Where to seek
guidance and reportbreaches
Violation of the Code of Conduct
or any of Cognite’s Governing
Policies will not be tolerated andmay lead to internal disciplinary
action, dismissal, criminal
prosecution or termination ofcontract. Please contact ourCompliance Officer if you havequestions about the Code ofConduct or any of our otherpolicies.
If you are aware or havesuspicions concerning
unprofessional conduct or
breaches of this Code ofConduct, report this to yourmanager or our Compliance
Officer immediately. Alternatively,
you can report your concern
through Cognite’s online
whistleblowing channel →.

To learn more about this, read
our Whistleblower Procedure.
You may remain anonymous
if so desired. There will be no
retaliations nor any impact on
your professional career forreporting violations in good faith.
Failure to report is considered abreach of this Code of Conduct.

Contact Details:
compliance@cognite.com →Revisions
VersionDate released

Revisions made1.0

September 21, 2017

Published

2.0

November 18, 2020

Revision to adjust the code toCognite’s profile

3.0

August 31, 2021

Updated Cognite’s values

4.0

April 26, 2022

Updated for the Transparency
Act

5.0

December 15,2022

Added section on retaliation

Preparer: Compliance Officer
Owner: Chief Executive Officer
Approver: Board of Directors
Valid from: December 15, 2022

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