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1. Commitment to integrity and business ethics

The reputation and integrity of Swarm64 AS and its direct and indirect affiliates (”Swarm64”) is a valuable asset that is vital to Swarm64’s success. You and each other director, officer, manager or employee (collectively referred to as “employees”), are responsible for conducting Swarm64’s business in a manner that demonstrates a commitment to the highest standards of integrity. This Code of Conduct, which applies to all employees, has been created to help meet these standards. Specifically, the purpose of this Code of Conduct is:

  • to encourage among our employees a culture of honesty, accountability and mutual respect;
  • provide guidance to help you to recognize and deal with ethical issues; and
  • to provide mechanisms to report unethical or inappropriate conduct.

While this Code of Conduct is designed to provide helpful guidelines, it is not intended to address every specific situation. Nevertheless, in every instance, we require that you act honestly, fairly and with a view towards ”doing the right thing”. Therefore, dishonest or unethical conduct or conduct that is illegal violates this Code of Conduct, regardless of whether such conduct is specifically referenced in this Code of Conduct. Such violations may result in disciplinary sanction up to and including dismissal.

Swarm64 has designated an independent Compliance Officer who is responsible for implementing and administering the Code of Conduct. The Compliance Officer will monitor if the Code of Conduct has been implemented effectively and report to the Chief Executive Officer of Swarm64.

If you have any questions regarding this Code of Conduct, our guidelines or policies, feel free to direct your questions to the Compliance Officer.

2. Overview

We as Swarm64

  • Expect and require you at all times to act honestly and ethically when you are performing your responsibilities for Swarm64;
  • Expect and require you to comply with all applicable governmental laws, rules and regulations;
  • Expect you to treat others, including other employees, stockholders, customers and vendors, in a professional manner; and
  • Encourage and support internal disclosure of any violation of this Code of Conduct for appropriate action.

3. Raising concerns and reporting impropriety

Swarm64 encourages you to openly discuss compliance issues. Often, asking a question is the best way to determine whether an action is proper and to ensure that we comply with applicable laws. Any question concerning this Code of Conduct, our guidelines and policies can be addressed to the Compliance Officer.

We expect that all our employees conduct themselves in a manner consistent with our values and commitment to ethical conduct. To this end, if you become aware of, or reasonably suspect that there will be or has been a violation of any laws, rules, regulations applicable to Swarm64’s business, Swarm64’s policies or this Code of Conduct, – as a first step – promptly consult your scrum master, team lead or a member of the Executive Team, best one of these persons who appears not to be involved in the alleged misconduct. He or she is responsible for taking necessary steps to resolve the issue. In case such person does not take the necessary measures or in case he or she may be involved in the alleged misconduct, please contact the Compliance Officer at

4. Conflicts of interest

You are expected to put the interests of Swarm64 ahead of your personal interests or those of any other person or company. You must avoid Conflicts of Interest. A Conflict of Interest exists when your private interests interfere or could reasonably potentially interfere with the business interests of Swarm64. Examples of Conflicts of Interest include:

  • Having outside employment or business or civic affiliations or ventures (including board memberships) that interfere with your ability to perform your duties for Swarm64 in an objective, effective and timely manner;
  • Having a direct or indirect financial interest in a customer, vendor or supplier;
  • Engaging in personal investment or business ventures that compromise or give the appearance of compromising your ability to make decisions in the best interests of Swarm64;
  • Selecting suppliers, contractors or vendors based on a close personal relationship.

If you are uncertain whether you or someone else you are dealing with has a Conflict of Interest please contact your Supervisor or the Compliance Officer.

5. Compliance with laws

We are committed to conduct our affairs in a manner consistent with all applicable laws. Being a Swarm64 employee, you are expected at all times to conduct Swarm64 business in accordance with all applicable national, regional, local and foreign laws, and applicable Swarm64 policies. Swarm64 condemns all acts that violate any applicable law, rule or regulation, even when such action appears to be in Swarm64’s best interest and is motivated by your best intentions. In most cases, simply doing the right thing will avoid any violations of law. However, some legal concepts and areas of regulation are a challenge for all of us. If you are uncertain of whether or not a particular action or transaction violates applicable laws, rules or regulations, please do not hesitate to contact the Compliance Officer.

6. Anti-corruption

Any action you perform and all decisions you make for Swarm64 are subject to a wide range of applicable anti-corruption laws. This is simply a reflection of our international work environment. As a matter of example, anti-corruption legislation such as the U.S. Foreign Corrupt Practices Act (“FCPA”), the UK Bribery Act, and the German Criminal Code has an impact on our daily work-flows and actions taken by Swarm64 employees.

These laws share a common denominator which you need to bear in mind at all times: In the broadest sense, these laws prohibit Swarm64 and its employees, agents, affiliates or any other partners from directly, or indirectly offering, promising, authorizing or giving anything of value to any government official or private party, anywhere in the world, for purposes of improperly obtaining or retaining business, gaining influence, favourable treatment or any other advantage for Swarm64 or another party (active corruption). Under many of these laws, it is equally prohibited to request, agree to receive or accept such an improper advantage personally or for any other person or entity
(passive corruption). Anywhere in the world you are expected never to engage in any kind of corrupt conduct. Never let your actions be driven by the goal to improperly obtain or retain business, to gain influence, favourable treatment or any other advantage for Swarm64 or another party. You are furthermore expected never to request, never to agree to receive, and never to accept any such improper advantage for you personally or for another person or entity.

You may only accept personal benefits (e.g. invitations in restaurants or to sports events or gifts) if the impression is not created that a consideration is expected from them. The benefit must be within the framework of the generally normal business customs and must not violate the law.

For more information, consult Swarm64´s Gifts and Hospitality Policy. For questions and additional guidance, consult the Compliance Officer.

7. Government officials

In the course of conducting business affairs you may need to interact with government agencies, ministries or offices, e.g. in order to obtain permits, licenses or other approvals. If conducted improperly, interacting with governments and government officials can result in significant legal risks to Swarm64 and even to you personally. When engaging in such interactions, it is therefore important to obey the following simple rules:

  • Do not make any payments to a government official (including indirectly through third parties). Refrain from even creating the appearance that such a payment could be made for the purpose of improperly influencing their opinions or actions.
  • Be attentive where gifts, hospitality or entertainment are/is being provided to a government official. In particular granting a donation or charitable or political contribution at the request or suggestion of a government official should capture your attention.
  • Remind yourself that all interactions with or connected to government officials conducted by you as Swarm64 employee must be consistent with any applicable law and this Code of Conduct.

You must always receive pre-approval from the Compliance Officer before giving or accepting any advantage to or from a government official.

8. Money laundering

Swarm64 is committed to complying with all applicable anti-money laundering laws, rules and regulations. Our values require that we take steps to ensure that we will only conduct business with reputable vendors, suppliers, contractors and customers involved in legitimate business activities with funds derived from legitimate sources. Money laundering is broadly defined as engaging in a transaction with criminally derived property, structuring a transaction in order to avoid detection of criminal conduct or engaging in a transaction in furtherance of criminal conduct. Be alert, in particular, to the following:

  • Requests for cash payments.
  • Country where business partner is located deviates from country where its bank is located.
  • Unreasonable splitting of transactions.
  • A business partner uses multiple accounts or suddenly changes its accounts.

Swarm64’s Compliance Officers can provide you with further guidance on red flags of money laundering and requirements to prevent Swarm64 from being involved in any money laundering conduct. If you have any questions about whether a vendor, supplier, contractor or customer may be involved in money laundering, please contact the Compliance Officer. In case you recognize any suspicious facts, consult immediately with the Compliance Officer.

9. Customer and supplier relations

Our success depends upon deep and trusting relationships with our customers and suppliers. When dealing with customers and suppliers, you must act ethically, fairly, courteously, competently and timely. In furtherance of these objectives:

  • You must act in a professional and courteous manner at all times and avoid misleading customers and suppliers.
  • You must only make claims about our services that you know to be true or have adequate information to support.
  • You must not misuse or disclose confidential or proprietary customer or supplier information.
  • You must truthfully represent the nature and quality of our services, prices, contractual terms and other information.
  • When dealing with suppliers, vendors or customers, you must ensure full compliance with this Code of Conduct.

For questions and additional guidance, consult the Compliance Officer.

10. Business Partners

“Business Partner” means persons or entities engaged by Swarm64 to sell, market or provide goods or services for Swarm64, including suppliers, contractors, distributors, sales agents and others.

Any Business Partner we hire must meet our ethical standards and be capable of sufficiently performing their assigned duties. All arrangements with Business Partners must be in writing. Contracts with agents and similar distribution agreements should be aligned with the Compliance Officer. You may not retain any Business Partner or make any payments to a Business Partner unless authorized by the appropriate Swarm64 manager.

For more information, consult Swarm64´s Business Partner Policy. For questions and additional guidance, consult the Compliance Officer.

11. Books, records, and disclosures

The effective operation of Swarm64’s business, and the integrity of Swarm64’s public disclosures, is dependent on accurate business records. You must prepare and maintain all company records accurately and honestly.
No false or misleading entries may be made in any books, records or accounts of Swarm64 and no Swarm64 funds may be used for any purpose other than as described in the documents supporting the disbursement.

Swarm64 personnel engaged in the preparation of these filings, submissions and communications must endeavour to ensure that Swarm64’s filings, submissions, and communications accurately and fairly reflect Swarm64’s transactions and provide full, fair, timely, accurate and understandable disclosure.

12. Fair competition and antitrust

Swarm64’s mission is to become a global market and technology leader for high performance big data analysis solutions through ethical and legal conduct, and not resort to anti-competitive behaviour. Although we recognize the importance of identifying Swarm64’s strengths and our competitors’ weaknesses, you may not seek a competitive advantage for Swarm64 through fraud, concealment, misrepresentation of material facts, or illegal means. Swarm64 also does not condone theft of trade secrets and non-public information and you must avoid unauthorized use of any patented, copyrighted, privileged or confidential information.

Antitrust and competition laws seek to protect competition by prohibiting anti-competitive behaviour that results in decreased competition, unjustified price discrimination or produces other artificial forces in the market. Antitrust laws exist in virtually all countries and apply to conduct at all levels of an organization. In general terms, antitrust laws require companies to compete on an individual basis rather than join with other companies in agreements to restrict individual competition.

The consequences of violating antitrust laws are severe. You must not misuse or disclose confidential or proprietary customer or supplier information. You must truthfully represent the nature and quality of our services, prices, contractual terms and other information. For more information, consult Swarm64´s Fair Competition Policy. For questions and additional guidance, consult the Compliance Officer.

13. Data privacy

Swarm64 complies with all applicable data protection laws and treats personal data of employees, customers, suppliers and other affected individuals confidential and protects their personal data. Personal data can be any information relating to an employee, customer, supplier and other affected individual making it possible to identify such individual in particular by an identification number or one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. Swarm64 only collects, processes or uses personal data if Swarm64 is required to do so by law or if necessary for business or employment purposes. Swarm64 treats such personal data as confidential and protects it.

14. Environmental protection

Swarm64 complies with all applicable environmental laws, standards and requirements and takes a proactive and long-term view on environmental matters to prevent pollution and continuously improve environmental performance. Environmental protection and product safety are of great importance, not only for Swarm64’s reputation but also for our customer’s safety and future generations. Swarm64 is conscious of the great importance of environmental protection in developing its products and solutions. It is everyone’s responsibility to take care that environmental laws are properly observed and resources are used efficiently.

15. Employment

It is the policy of Swarm64 to comply with all applicable environmental health and safety laws and regulations. Swarm64 is committed to creating and maintaining a safe working environment and preventing workplace injuries. You are responsible for recognizing hazards, taking steps to correct them, making certain that safe working conditions exist and that safe operating practices are observed. If you observe an unsafe condition, you should warn others, if possible, and immediately report the condition to your manager or local workplace safety contact.

Swarm64 is committed to complying with all laws relating to freedom of association, working time, wages and hours, as well as laws prohibiting forced, compulsory and child labour, and employment discrimination. Beyond legal compliance, Swarm64 strives to create a positive environment that is free of improper harassment and bullying and considerate of all employees wherever they may be located. All employment decisions should be based upon the qualifications and performance of the individual, the particular job requirements, and business needs.

16. Non-retaliation

Do not harass or retaliate against an employee or other person who, in good faith, reports a violation or suspected violation of the law or Swarm64 policies. If you believe you have been retaliated against for reporting an actual or potential violation in good faith, report this matter to the Compliance Officer or your supervisor.

17. Swarm64 assets

Swarm64 property and assets may only be used for legitimate Swarm64-related business purposes. You are responsible for ensuring that Swarm64’s property is not misused, wasted or damaged. Unless authorized to do so, you are also prohibited from using or taking Swarm64 property for your personal benefit or gain. You may not provide third parties with any Swarm64 property, unless you are authorized to do so in a legitimate business transaction.

Confidential and proprietary information is one of a company’s most valuable assets. Without prejudice to any obligation contained in your employment contract or any other document, you may not disclose Swarm64’s confidential and proprietary information without authorization. Similarly, you may not disclose the confidential information of Swarm64’s customers, vendors or suppliers without authorization. You must safeguard Swarm64’s and any competitor’s, vendor’s, supplier’s, contractor’s, customer’s, representative’s confidential and proprietary information. You may not use or allow anyone else to use any such confidential and proprietary information, except as required by your job responsibilities.

These obligations apply during working and nonworking hours, whether or not the information is specifically designated as “Confidential” or “Restricted” and extend beyond your employment with Swarm64.

Intellectual property forms an important part of our economic success and the success of our business partners and customers. You are expected to protect our intellectual property, including any patents, trademarks, trade secrets, technical and scientific knowledge, and expertise developed in the course of our business. You are required to respect the intellectual property of others. Unauthorized duplication or misappropriation of another’s intellectual property may subject you and Swarm64 to significant fines and criminal penalties.

18. Social media

Social media forms an important part of today’s business and is becoming more and more important. Social media include social networks (e.g., Twitter, Facebook, LinkedIn), blogs, wikis and video streaming websites (e.g. Youtube). Swarm64 manages the contents of the official company pages on social media in a centralized manner. Therefore, do not create any Swarm64 pages on any social media platform. When you are active on social media, you must make it clear that you are expressing your own views and not those of Swarm64.

19. IT security

Confidentiality of postal correspondence and telecommunications must be maintained at all times. Therefore, pay particular attention to IT aspects of confidentiality such as data protection and data security and protect your computer from unauthorized access by necessary appropriate measures (e.g. changes of password). Do not make any transcripts or copies of data for other than operational purposes and do not access information that is unrelated to your own activities. Do not save confidential business information in public clouds. Have a healthy distrust especially when it comes to business-related topics in social networks or other public portals.