Code of conduct
2024

Contents
Understanding the code ................................................................................................................................................................. pg. 2
Purpose ......................................................................................................................................................................................... pg. 2
Scope ............................................................................................................................................................................................. pg. 2
Our vision .......................................................................................................................................................... pg. 2
Our mission ....................................................................................................................................................... pg. 2
Our values ......................................................................................................................................................... pg. 2
Compliance with laws and regulations................................................................................................................................... pg. 3
Responsibility and Implementation ........................................................................................................................................ pg. 3
Personal responsibility ...................................................................................................................................... pg. 3
Managers’ responsibility ................................................................................................................................... pg. 3
Board of Directors and CEOs’ responsibility ...................................................................................................... pg. 3
Cognite commercial partners, customers and suppliers.................................................................................... pg. 3
Caring about people ........................................................................................................................................................................ pg. 3
Personal data and privacy ........................................................................................................................................................ pg. 4
Working environment (human rights and workers’ rights) ............................................................................................... pg. 4
Acting with integrity........................................................................................................................................................................ pg. 4
Conflict of interest ...................................................................................................................................................................... pg. 4
Corruption and bribery .............................................................................................................................................................. pg. 5
Gifts and hospitality ................................................................................................................................................................... pg. 5
Export controls and sanctions.................................................................................................................................................. pg. 5
Fair competition .......................................................................................................................................................................... pg. 6
Insider trading ............................................................................................................................................................................. pg. 6
Money laundering....................................................................................................................................................................... pg. 6
Safeguarding of IP and assets .................................................................................................................................................. pg. 6
Sensitive information and confidentiality ............................................................................................................................. pg. 7
Protecting the environment .......................................................................................................................................................... pg. 7
Retaliation......................................................................................................................................................................................... pg. 7
Promoting transparency ................................................................................................................................................................. pg. 7
Accurate and timely information and financial reporting.................................................................................................. pg. 7
Political contributions and activities ...................................................................................................................................... pg. 8
Relations to business partners................................................................................................................................................. pg. 8
Sponsorships ................................................................................................................................................................................ pg. 8
Where to seek guidance and report breaches ............................................................................................................................ pg. 8
Where to seek guidance and report breaches ..................................................................................................................... pg. 8

Understanding the code

PurposeOur visionThis Code of Conduct describes
the ethical commitments of
Cognite AS, including its affiliatedcompanies
andsubsidiaries(“Cognite”). In order to develop a
company culture that meets our
vision, mission and core values,
the Code of Conduct sets out
expectations to the personal
conduct and business practice of
our employees.

Our vision is to create an industrial
world powered by data andalgorithms,
freeing
humancreativity to shape a safer, more
efficient,moresustainableindustrial future.

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

Our mission
Our mission is to provide a digital
representationofindustrial
reality, and make it accessible andmeaningful for humans andmachines.

Our values
We are a vibrant, diverse company
and our commitment to shape theindustrial future with ourcustomers brings us together.
Together, we have defined a set ofcommon values to inspire our work
life.
Impact - Go big or go home. As aresult oriented company, we
fundamentallychangetheindustrial world and make it moresustainable. We strive to make an
impact in all that we do. What we
do matters to our customers,changing the way they work andshowing up on their bottom lines.
Ownership - We embrace a cultureof ownership. We go beyond our
comfort zone to contribute to thegreater good, foster inclusivity andsharedresponsibility
forchallenges and success. We thriveon taking initiative and driving
projects to fruition. Our work is not
merely a duty but a reflection of
our ethos. Therefore, we takepride in our work, with eachendeavor imbued with a sense ofownership. This is a testament of
our unwavering determination anddedication to our customers andpartners.
Relentless - We are relentless inthe pursuit of innovation and wepush boundaries to achieve
excellence. We are determinedand deliberate (never ruthless or
reckless), facing challenges headon and viewing setbacks asopportunities for growth.

Compliance with laws
and regulations
We shall comply with allapplicable laws and regulations,and respect cultures and rights ofindividuals
everywherewe
operate. If there are differences
between laws/regulations and thestandards set out in this Code of
Conduct, we shall follow thehighest standards that areconsistent with applicable local
laws.
This Code of Conduct is the main
governing document in Cognite.
We also have other, more detailed
policies for expected businessconduct. If you think someone isviolating any of our governancepolicies or applicable laws or
regulations, don’t be bashful - letyour manager or other appropriate
authority know about it.

Responsibility and
Implementation

Board of Directors andCEOs’ responsibility

Personal responsibility

Cognite’s Board of Directors is
responsible for implementing theCode of Conduct. The CEO shallensure that employees are awareof and comply with this Code of
Conduct, that annual Code of
Conduct training is mandatory for
employees and that all employees
sign off to confirm they have readand understood the Code of
Conduct on an annual basis.

We shall all strive to exercise good
judgment, care and consideration.
Get familiar with and perform yourduties in line with the principles ofthis Code of Conduct. If you need
advice in handling a specific or
possible ethical dilemma, or havequestions about the Code of
Conduct, consult withyourmanager or Cognite’s Compliance
Officer.

Managers’
responsibility
Managers are responsible forcommunicating the requirementsin the Code of Conduct to all theirdirect reports, and for promoting
and monitoring compliance with
the Code of Conduct within theirrespective area of responsibility.

Cognite commercial
partners, customers
and suppliers
Cogniteexpects
alltheircommercial partners, customers
and suppliers to follow Cognite’s
Code of Conduct or have their own
equivalent policy in place. If you
have any questions about theCode of Conduct or any of ourother Policies, you may direct yourinquiries to ourCompliance
Officer. You can also report any
concernsorsuspicions
anonymouslytoourwhistleblower channel →Caring about people
Cognite prides itself in having an
inclusive work culture that values
diversity and equality. We want
ouremployees,
customers,
suppliers,
andcommercial
partners to be proud to be
associated with us and to promote
our values by behaving ethicallyand in accordance with this policy.

Personal data andprivacy
Cognite is committed to protecting
all individuals’ personal data while
performing our businessanddelivering our services. We only
collect, process and store personal
data in line with applicable dataprotection laws and regulations.
To learn more about this, read ourPrivacy Notice or GDPR Policy.

Working environment(humanrightsandworkers’ rights)
Cognite respects, supports andacknowledges the fundamental
principles of human rights as
defined in the United Nations
Guiding Principles for Business andHuman Rights, the ILO Declaration
on Fundamental Principles andRights at Work (including the ILO
core conventions), and the OECD
Guidelinesfor
Multinational
Enterprises, as well as the new
Norwegian Transparency Act 2022(Åpenhetsloven).
Cognite acknowledges employees’right to form and join tradeunions. We involve employees indecision-making processes andbelieve this improves the grounds
for decision-making.
Cognite values diversity and wants
every employee to be able todevelop individual skills andtalents. We oppose harassment,
discrimination based on age,gender,sexualorientation,
disability,
race,
nationality,
political
opinions,
religion,
philosophical belief or any otherbasis prohibited by law, and otherdegrading treatments in any form,
by or towards employees.
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■ respect the personal dignity,
privacy and right of all people weinteract with and those affected by
Cognite’s business.
Cognite expects the same highstandard of respect for humanrights and working conditions
from all our commercial partners,
customers
andthird-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 inwriting, if you become aware of
breach of Cognite’s human andlabor rights standards. You canalso report any concerns or
suspicions 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 of
Conduct.

Conflict of interest
Conflict of interest is when you
have a personal or outside interest

that conflicts with the best interestof Cognite. A personal interest canbe a financial interest in anothercompany or a transaction, a
relationship, 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 that in fact orappearance can give rise to aconflict of interest, and ensurethat transactions with relatedparties adhere to relevant
principles for such transactions;■ if a conflict of interest arises orsomething appears to be a conflictof interest, notify your manager or
the Compliance Officer;■ seek pre-approval from yourmanager for directorships orassignments held/carried out inother companies; and■ never let engagement in duties
or assignments outside Cognite
negatively impact our working
relationship with Cognite andalways ensure that such activities
do not conflict with Cognite’sbusiness 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 business activities.
Corruption, as defined in Cognite’s
Anti-Corruption and Appointmentof Third Party Representatives
Policy, is when a person ororganization
offers, gives,
receives, or solicits something ofvalue forthe purpose of
influencing - directly or indirectly officials or private parties for an
improper purpose, including toobtain or retain business or any
business advantage.
When engaging with public
officials, we must be extra
cautious of the corruption risk andact in a transparent manner.
We are all committed to thefollowing:■ never, directly or indirectly,
offer anything of value to influence
the actions or decisions of, orotherwise obtain any improper
advantage from:— any official person, including any
person in public or legal duty,— any person acting on behalf ofcustomers or subcontractors/
suppliers, or— any other third party; in selling
goods and services, conducting
financial transactions or
representing the company’s
interests;■ 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;■
never give nor encourage
facilitation payments unless anemployee is a victim of extortionand his or her health and safety isin danger (such incidents shallimmediately be reported to yourmanager and Cognite’s CEO orCompliance Officer); and■ never, directly or indirectly,
accept gifts or other remuneration
if there is reason to believe its
purpose is to influence businessdecisions; and■ensure that all paymentscomply with Cognite’s accounting
and financial procedures for theapproval and recording of
payments, 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
Officer

Gifts and hospitality
Cognite does not accept the offer
or acceptance of businesscourtesies where they could
constitute, or appear to constitute,an undue influence. Hospitality,
such as social events, meals or
entertainment, may be acceptable
for a clear businessreason,provided that the costisreasonable. Local laws may restrictor prohibit offering of gifts andentertainment to public officials.
For more information about gifts
and hospitality, see the Gifts andHospitality Policy.
We are all committed to thefollowing:■ 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 of
information, 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 electronically transfer,through discussions orvisualinspections.
We are all committed to thefollowing:■
carefully consider potential
impact of export control laws andsanctions before transfer of goods,
technology, software or services
across national borders; and■ be cautious if dealing withparties from sanctioned countries
or otherwise designated forfinancial sanctions.

Fair competition
Cognite shall protect fair and open
competition and comply withantitrust and competition laws andregulations.
We are all committed to thefollowing:■ meet competition in a
professional and transparent
manner;■ never take part in or support
illegal cooperation on pricing,illegal market sharing or any otheractivity that constitute breach of
applicable competition laws; and■ consult the Compliance Officer
in all matters involving risk ofantitrust 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 definedas trading, either
directly or
indirectly, in publicly traded sharesor other securities
while inpossession of specific information
capable of affecting the price ofthe shares or securities and that is
not publicly available or generally
known in the market, or disclosureof such 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’sshareholders
orcustomers that are publicly listed(this applies to our close family
members as well); and■seek advice from theCompliance Officer in all matters
involving risk of insider trading.

Money laundering
Money laundering occurs when
the criminal origin or nature ofmoney or assets is hidden in
legitimate business dealings orwhen legitimate funds are used tosupport criminal activities. Cognite
is firmly opposed to all forms ofmoney laundering.
We are all committed to thefollowing:■ seek to prevent that Cognite’s
financial transactions and businessactivities are used to laundermoney;■ ensure that all business activities
are legitimate andinvolvelegitimate funds deriving fromlegitimate sources;■ consult the finance department
or the Compliance Officer if there
are irregularities
relating to
payments, such as offshore bankaccounts or accounts not normallyused by the party in question; and■ consult the finance department
or the Compliance Officer if in
doubt about the origin
anddestination of money andproperty.

Safeguarding of IP and
assetsOnly authorized employees canuse our property and assets, andonly for legitimate businesspurposes. This goes for bothtangible property (such as
equipment),
andintangible
property (such as intellectual
property
andconfidential
information).
Information produced and storedon our IT systems is the propertyof Cognite. We shall never process
or download information that may
be illegal or inappropriate.
Our intellectual property, such as
logos, copyrights, trade secrets,“know-how” and patents are
Cognite’s most valuable assets.
Unauthorized use can lead to lossof value. Inappropriate use ofothers’ intellectual property,
including violation of license
requirements under which open
source software is distributed,
may expose Cognite and you tocriminal and civil fines andpenalties.
We are all committed to thefollowing:■ only use Cognite’s logos andmarks for necessary businesspurposes;■ prevent unauthorized use of
Cognite’s intellectual property;■
respect others’ intellectual
property;■ report suspected misuse of
trademarks, logos, or otherCognite intellectual property to
the legal department;■
consult withdepartment before

the

legal

■ authorizing access to or use ofCognite proprietary information,— soliciting, acceptance or use of
proprietary information
fromoutside Cognite, and— incorporating open source codeor other content not belonging to
Cognite into a product, service, orinternal project;■ use IT systems and particularlyinternet services carefully, andonly for business purposes, notpersonal interests.

Sensitive informationand confidentiality
We shall protect sensitive or
confidential information, and not
misuse information belonging to
Cognite or a partner. We are allcommitted to the following:■
comply with statutory andcontractual
confidentiality
obligations, which may apply as
long as the informationisconsideredsensitiveor
confidential, and after conclusionof the employment or contractual
relationships with Cognite; and■ always carefully consider how,where and with whom Cognite
related 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 external
environment. We shall follow

relevant international and local
laws and standards, and seek tominimize ourenvironmental
impact. For more information

please see Cognites sustainability
report.

result of their reported complaint.
Cognite will not tolerate any
retaliation
againstanother
employee who speaks up in goodfaith. If you are experiencing or
have witnessed retaliation, please
report the incident
to theCompliance officer or Cognite’s
Whistleblower Channel.

Retaliation
Retaliation is not tolerated by
Cognite. Retaliation is any kind of
intentional negative action against
a current or former employee thattakes the form of athreat,retribution,
antagonism
oruncomfortable environment as a

Retaliation of any kind will be
subject to disciplinary action andmay be grounds for termination.

Promoting transparency
Accurate and timely
information andfinancial reporting
Cognite is committed to providing

our stakeholders with quality
information that enables them tomaintain a correct picture of our
financial standing.
We arecommitted to the following:■ communicate relevant businessinformation on a timely basis to
our stakeholders; and■ accurately register and present
accounting
andfinancialinformation, and other disclosureinformation in accordance withlaws, regulations and relevant
accounting standards.

Political contributions
and activities
Cognite maintains a neutral
position on party politics and does
not in any way support any
political party or their candidates.
Cognite may participate in publicdebates if this is in the company’s

interest.

Relations to business
partners
We are dependent on our partners
and shall deal honestly, ethically,
impartially and fairly with our
stakeholders. Cognite expects thesame high standard of businessethic from all
our partners,
customers and suppliers.

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

Where to seek guidance and reportbreaches
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 of
Conduct or any of our otherpolicies.
If you are aware or havesuspicions
concerning
unprofessional
conductorbreaches of this Code of Conduct,
report this to your manager or ourCompliance Officer immediately.
Alternatively, you can report yourconcern through Cognite’s online
whistleblowing channel →.

To learn more about this, read ourWhistleblower Procedure. You
may remain anonymous if sodesired. 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
Version

Date

Revision madereleased
1.0

September 21, 2017

Published

2.0

November 18, 2020

Revision to adjust the code to Cognite’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.

6.0

April 11, 2024

Updated with new values

Preparer: Compliance Officer
Owner: Chief Executive Officer
Approver: Board of Directors
Valid from: April 11, 2024

COGNITE.COM →CONTACT@COGNITE.COM →