At Oben, integrity guides all our decisions and interactions, both internally and globally. We uphold the highest ethical standards as a central part of our identity, ensuring principled conduct in every partnership and engagement while fostering respect and responsibility.
We view business as a force for good through innovation, collaboration, and service, operating transparently and ethically in compliance with all laws and regulations.
Oben’s business practices are guided by the following core principles:
Oben expects its suppliers, contractors, consultants, and other business partners to adhere to these principles when providing goods or services to Oben, or when acting on Oben’s behalf. All third parties conducting business with Oben must comply with the Oben Third Party Code of Conduct. The Business Conduct Policy applies to all full-time and part-time employees of Oben, serving as a standard reference for expected conduct within the organisation. Employees are required to complete annual online training on Business Conduct, and must review and certify their understanding of the Business Conduct Policy. Additionally, employees must complete online trainings on Respect at Oben and Privacy; depending on job responsibilities and geographic location, further mandatory online training may be required. Periodic live training sessions are also organised on Business Conduct and other pertinent topics. If local laws impose requirements on Oben and its employees that differ from those specified in the Business Conduct Policy, any waiver of this Policy for directors, executive officers, or principal accounting officer may only be granted by the Board of Directors, and will be disclosed as mandated by law or relevant listing requirements.
Employee Responsibilities and Code of Conduct
All activities performed represent Oben. Employees are required to:
Reporting Concerns
Concerns regarding the Business Conduct Policy or related inquiries can be directed to management at transparency [@] oben.technology. Information related to concerns will be shared only with individuals who require it for addressing questions or conducting investigations and determining any necessary enforcement or disciplinary actions. The Business Conduct Manager (BCM) is responsible for administration of this policy. The BCM provides support to employees and responds to questions relating to business conduct, policies, regulations, and legal compliance. Oben’s Global Whistleblowing Policy outlines how the company handles reports of possible misconduct and details employee rights to raise concerns in accordance with applicable law.
Non-Retaliation
Oben does not permit retaliation against individuals who make good-faith reports or participate in investigations of reported concerns or complaints, whether internally or externally. Employee Rights Employees may discuss or disclose non-confidential information and working conditions, including matters involving harassment, discrimination, or other conduct believed to be unlawful or inappropriate. This Policy, and any other Oben policy or agreement, does not restrict these rights. Human Rights Commitment Oben aims to uphold internationally recognised human rights, following the United Nations Guiding Principles on Business and Human Rights. For further details, refer to the Human Rights Policy.
Drugs and Alcohol
Employees are required to follow Oben’s policies on alcohol, drugs, and smoking at the workplace, during Oben-sponsored events, or while conducting Oben business. Being under the influence of any substance, whether legal or illegal, that impairs job performance is not permitted. Employees must not manufacture, solicit, distribute, possess, or use illegal drugs or substances in the workplace or while working. Employees are expected to exercise good judgment and maintain consistent work performance.
Environment, Health, and Safety
Oben puts employee, customer, and community health and safety first. The H&S team helps staff meet all requirements—use their guidance to address risks early. For H&S policies or training, contact HR or the H&S team.
Harassment and Discrimination
Oben is committed to a creative, inclusive, and supportive workplace and prohibits discrimination, harassment, and workplace violence in all professional interactions, whether with employees or external partners. If you experience or witness harassment or discrimination, please report it through any channel you prefer, such as our whistle-blower platform or by emailing transprency [@] oben.technology. Respect is key to our culture and essential for effective collaboration, open debate, and achieving excellence in our work. We are committed to a safe, inclusive, and respectful environment where professionalism is expected from all employees.
Respect is everyone's responsibility and should be shown daily in our workplace actions and decisions.
Respect does not mean that we don’t disagree or debate - it means that when we do so, we do it in a way that does not cause a coworker to feel offended, humiliated, or intimidated.
Governments as Customers
Government clients have distinct bidding, pricing, disclosure, and certification requirements. Always consult Legal when bidding for government business, and contact Business Conduct for compliance questions. Hiring Government Employees Legal restrictions may limit what former public sector employees can do at Oben, especially regarding matters they handled in government. Employment discussions with such individuals may require approval and disclosure, particularly if they are involved with Oben-related issues. Always get prior approval before negotiating employment with government employees. Do not hire anyone to gain or keep business or secure an improper advantage, and never offer hiring preferences for special treatment.
Bribery and Corruption
Oben strictly prohibits any form of bribery or corruption in its business dealings. Bribes—including cash, gifts, meals, travel, or anything of value—are not allowed, whether involving public officials or private individuals. Kickbacks (exchanging favours or information for value) and facilitating payments to expedite routine government actions are also banned. The only exception is when a payment is necessary to prevent immediate harm to health or safety, which must be promptly reported to BCM. Oben may be held accountable for improper payments made by third parties on its behalf; consult with BCM before engaging third parties who interact with government or officials to determine if further due diligence is needed.
Money Laundering
Money laundering is the illegal act of disguising illicit funds as legitimate. It is strictly prohibited by Oben. If you work with customers or vendors, watch for signs such as: • Large cash payments • Payments from unrelated third parties • Overpayments beyond contract terms • Payments in unapproved currencies • Funds from unusual accounts • Unusual transaction patterns, like bulk purchases, gift cards, or repeated cash payments.
Competition and Trade Practices
Oben is committed to fair competition and does not engage in illegal agreements with competitors. Such agreements, or those with resellers, distributors, and suppliers—especially if Oben holds a strong market position—are closely scrutinised.
Never: •
Always consult Competition Law or seek legal guidance if unsure.
Obtaining and Using Business Intelligence
Always gather customer, competitor, and market information ethically, using public sources, surveys, or competitive research. Never obtain personal data from third parties without Privacy approval, and do not use illegal or unethical methods. Avoid theft, espionage, or violating non-disclosure agreements. If you receive confidential information about a competitor unintentionally or from unknown sources, contact your manager, Legal, or BCM immediately.
Trades, Imports, Exports
Many countries periodically implement regulations on imports, exports, and interactions with specific countries, individuals, or groups. These regulations may affect the trade of goods or technologies, travel to or from countries under sanction, and investments. Certain laws also restrict participation in boycott activities. If your responsibilities involve transactions, technology, or services that cross international borders, you should obtain approval from your manager.
Private Employee Information
Do not share a coworker’s or prospective employee’s personal information unless they make it public or give you permission. As an Oben employee, be aware that, subject to local laws and Oben’s review process, we may monitor and access all data and messages on our systems—including those from personal accounts—as well as conduct surveillance and search workspaces or belongings on company premises. Information found indicating unlawful behaviour may be disclosed to law enforcement without notice. Limited personal use of company equipment is permitted, but there should be no expectation of privacy on any Oben system or network, including VPN.
Human Trafficking
Oben upholds human rights throughout our business and supply chain, treating everyone with dignity and respect. Human trafficking and involuntary labour are strictly forbidden in all operations. Report any suspected human trafficking to BCM immediately or use whistle-blower platform or send an email to transparency [@] oben.technology.
Assets and Confidential Information
Employees are responsible for protecting Oben's assets, including equipment, supplies, product information, and Oben Confidential Information. The Confidentiality and Intellectual Property Agreement signed at the beginning of employment outlines the obligation to safeguard Oben Confidential Information. Oben Confidential Information includes all Third Party Confidential Information as well as any non-public materials or information related to past, current, or future Oben products or services. This may include sales, pricing, operations, sources of material, financials, and marketing plans. Refer to the Confidentiality addendums for more details on the definition and scope of Oben Confidential Information. Third Party Confidential Information refers to confidential information provided to Oben by customers, partners, suppliers, or other third parties during business activities. All employees must maintain the confidentiality of such information, as failure to do so can affect partner relations and may result in legal consequences. Oben only shares Confidential Information with vendors, suppliers, or third parties when a Non-Disclosure Agreement (NDA) is established. Employees should confirm with their manager if there is a legitimate business reason to share Oben Confidential Information with external parties, and limit disclosure to what is necessary for business purposes. Within Oben, Confidential Information should only be shared on a need-to-know basis. Review your Confidentiality Rights to understand the guidelines regarding discussions about wages, hours, working conditions, or other confidential topics. Be aware of conversations and who may be present to maintain the confidentiality of Oben information.
Business Records and Fraud
Maintaining accurate, honest business records is essential for legal, financial, and management compliance. All reports—including expenses, timecards, employee and customer information—must be complete, fair, timely, and clear in any format. Altering or misrepresenting Oben business records is fraud. This includes modifying records, misstating facts, or omitting critical data to mislead others. Follow all policies on business expenses, meals, and travel. Records Management All records and information generated or received during business operations are owned by Oben. Employees are required to manage and protect such records and information in line with company policy. A record refers to information created, received, and maintained as evidence or as an asset for the Company to meet legal obligations or conduct business, as identified in Oben’s proprietary cloud. Records must be kept in a way that preserves their accuracy, integrity, and security. Privacy laws may set requirements for information retention periods. In certain situations, records and information may need to be retained longer than standard periods for legal or audit reasons. Records subject to a “legal hold” must not be altered, destroyed, or deleted. The Legal department will inform relevant employees of any applicable legal holds and their associated requirements. Oben documents all agreements formally, specifying rights, obligations, liabilities, and accounting treatments. We do not accept commitments outside approved contracts. Employees may not make side agreements or modify existing ones without upper management approval through the formal process. The Oben Identity and Trademarks Oben’s name, branding elements (including product names, taglines like “Achieve More,” and logos) make up its identity. Always ask your manager before public use of these assets, and check with Legal or management before using any third-party names or logos.
Third-Party Intellectual Property
Oben respects others' intellectual property and prohibits using it without proper rights or permission. Report any suspected infringement of patents, copyrights, trademarks, or trade secrets to management or your legal Administrator.
Copyright-Protected Content
Only use or copy software, music, videos, publications, or other copyrighted materials at work if you or Oben have legal permission. Do not use Oben's facilities or equipment to make or store unauthorized copies.
Inventions, Patents, and Copyrights
Submit your invention disclosure to Oben upper management before discussing it outside the company—even under an NDA—to protect patent rights. You may personally own inventions if they (a) are not created with Oben resources or confidential information; (b) do not result from or relate to your work at Oben; and (c) are unrelated to Oben’s current or future business, products, research, or development. Report any suspected patent infringement to Legal. For original works needing copyright protection, add Oben’s copyright notice and submit a disclosure form to Legal.
Technical Standards
Obtain management and Legal approval before engaging in technical standards activities, such as joining standards groups, contributing technology or code, or using standards in Oben products. For details, consult your management.
Open Source
Open source software typically refers to collaboratively developed software with source code available under an open source license. Prior to using, modifying, or distributing any open source software for Oben infrastructure, or as part of an Oben product or service development effort, management and Legal approval is required.
Public Speaking and Press
All public speaking engagements related to Oben’s products or services, or where you may be seen as representing the company, require prior approval from your manager. If approved, you may not accept personal compensation but can receive reimbursement for relevant expenses. Direct all media, industry, or analyst inquiries about Oben to management. This policy does not restrict your right to discuss wages, hours, working conditions, or report workplace concerns, as long as you do not disclose Oben Confidential Information to third parties.
Publishing Articles
Before submitting articles or other content about Oben’s products, services, or related topics—including potential conflicts of interest—you must get your manager’s approval. Employees wishing to publish research papers as Oben representatives also need management approval.
Endorsements
Do not endorse products or services as an Oben employee unless your manager approves it. This excludes routine comments about third-party products or services sold by Oben.
Avoiding Conflicts of Interest
A conflict of interest arises when an activity could harm Oben’s business interests or suggests divided loyalty. Avoid real or perceived conflicts and consult your manager if uncertain. Significant Personal Relationships Personal relationships—such as with spouses, partners, family, close friends, or external business contacts—can lead to conflicts if they influence employment decisions. Do not conduct Oben business or seek special treatment for yourself or associates with whom you have significant personal ties. This includes all business matters like hiring, promotions, and contracts. Disclose potential conflicts involving personal relationships to your manager. Ensure that no relationship disrupts the workplace or affects your judgment.
Conflicts of Interest and Outside Activities
Participation in external activities—including secondary employment, business ventures, inventions, or board service—is permitted only when such engagements do not pose a conflict of interest and all guidelines outlined below are strictly followed. Oben generally defines a conflict of interest in outside activities as any scenario that: • Involves working for or with an entity that produces or sells products or services in competition with Oben, or that Oben could reasonably be expected to develop. This includes, but is not limited to: consultancy services, cloud applications, B2B offerings, cloud solutions, software, or apps related to Oben’s areas of expertise. • Results in the creation or exposure to intellectual property that competes with or pertains to Oben’s current or foreseeable business interests, products, or services. • Necessitates the disclosure or use of Oben Confidential Information. • Relates directly to Oben’s business interactions or relationships with the external organization. Additionally, engaging in outside activities that mirror or closely resemble your responsibilities or role at Oben may, under certain circumstances, also constitute a conflict of interest. Employees should consult with their manager to assess any potential conflict of interest. If an external activity poses a conflict, written approval is required from your manager, Legal (if relevant), and the highest-ranking individual reporting to the CEO of both your own and any related organizations. All employees, whether full or part-time, who engage in outside activities are required to adhere to the following guidelines: Do not: • Use work hours or any Oben property for external activities, including workspace, phones, computers, internet access, photocopiers, or other Oben assets and services, except for incidental use. • Leverage your role at Oben to request resources or benefits for external activities, seek preferential treatment, or influence others to participate. • Take part in any activity that may negatively affect your performance at Oben. • Disclose or use Oben Confidential Information. This policy does not limit employees’ rights to form, join, or assist unions, or to participate in other protected group activities (or choose not to take part). Such actions are not considered conflicts of interest or outside activities under this policy.
App Creation
Apps may only be created for personal or educational use, unless needed for Oben business. Selling or distributing apps, stickers, or media for any operating system is not allowed, except for certain pre-existing apps by employees or short-term hires. If you think an exception applies, check with your manager.
Rotations (Operations Only)
Operations managers must ensure employees making key supplier decisions are rotated every three years to work with different suppliers. Annual exceptions require VP approval. “Suppliers” refers to anyone with any direct or indirect business link to Oben or its supply chain.
Personal Investments
Avoid investing in Oben competitors or business partners if it creates a conflict of interest, especially if you can influence transactions. Do not invest in any company—public or private—if you have non-public information about a current or potential Oben partner. Even if insider trading rules are not violated, an investment may still pose a conflict. Disclose any real or apparent conflicts to your manager, who will help assess and address the issue.
Insider Trading
Providing information to others, including friends and family, regarding when to buy or sell securities based on material nonpublic information about that security is prohibited by law and Oben policy. This applies to transactions involving stock of any Oben supplier, manufacturer, vendor, or customer. Information is considered material if it would likely influence an investor's decision to buy or sell a security or if it could significantly impact the market price of the security. Both positive and negative developments may be classified as material. Examples of potential material information include financial results, details about new products or significant features, the timing of major product announcements or launches, news of pending or proposed acquisitions or other corporate transactions, notable changes in sources or availability of supplies, changes in dividend policy, significant product defects or modifications, and major cybersecurity or other data protection or privacy incidents.
Donations
Employees may support charitable causes of their choice, provided Oben assets (including work time, premises, equipment, or funds) are not used or provided. Charitable donations involving Oben assets require approval from upper management. Any donation equal to or exceeding 500 Euro requires approval from the Legal Administrator.
Political Contributions
Oben does not contribute to candidates or political parties. Employees cannot use company resources—such as time, premises, equipment, or funds—for personal political support. Oben also cannot legally reimburse employees for political contributions.
Personal Political Activities
You may take part in political activities, including running for office or supporting candidates, if you:
Gifts
Accepting or giving gifts to current or potential vendors, suppliers, customers, or business associates may create conflicts of interest or perceptions of favoritism and is regulated by this policy. Gifts between employees are not covered. A gift includes anything of value (e.g., meals, travel, entertainment, branded items, equipment, or discounts). Gifts must be legal and never intended to influence decisions. Cash or cash equivalents like gift cards are always prohibited. Paying for gifts personally does not exempt you from following this policy. Oben employees follow either a zero gift rule (no gifts allowed, unless exceptions apply) or a 100 EURO gift rule (gifts permitted only if worth 100 EURO or less, unless exceptions apply).
Key Exceptions
The following exceptions outline circumstances under which most employees may accept gifts, subject to any noted approval requirements:
Refusing and Returning Gifts
Gifts that do not comply with established limits should be declined or returned whenever feasible. If refusing or returning a gift is not possible or appropriate, notify your manager after accepting the gift and seek additional guidance from Business Conduct. Perishable, non-alcoholic gifts may be placed in a shared area for employees.
Samples
Vendors and suppliers may provide product samples to Oben for business evaluation only. Samples are not gifts and must not be used personally. Document receipt per internal policies and return samples to the vendor or supplier after evaluation when appropriate.
Gifts to Public Officials
Oben allows gifts to public officials only if permitted by relevant laws and policies. A public official is anyone paid with government funds or performing a public function, including elected or appointed officials and employees of government entities, international organizations, public schools, and state-owned enterprises. All employees at these organizations are considered public officials, regardless of their title or position. Oben does NOT allow gifts to public officials unless explicitly permitted.