UBISOFT CODE OF CONDUCT

This Code of Conduct is a binding document that sets out Ubisoft’s commitments as a company and the role of each individual team member. It is mandatory for all team members, regardless of contract, position or location within Ubisoft, to read, comply with and sign this Code of Conduct every year.

The Code of Conduct provides guidelines for creating and maintaining a respectful and inclusive work environment as well as directives to ensure that we fulfill our duties ethically and in line with all applicable laws.

It is our collective responsibility to undertake that each of Ubisoft’s offices and studios be the best possible places to work and grow – knowing and respecting the Code of Conduct’s principles and guidelines is key to achieving that goal.

How to apply the code in daily decision making

The Code of Conduct includes rules that must be followed at all times as well as a guide for day-to-day decision-making, to make sure everyone at Ubisoft fulfills our professional responsibilities respectfully and with integrity. If you have searched this document for an answer to a specific question and could not find it, you should ask yourself:

• Are my actions legal? • Are my actions in line with the basic principles set out in the Code of Conduct? • Would I be comfortable telling my colleagues, family or friends, about my actions?

These questions can help you in making the right decision. However, if you still have doubts, you should reach out to your manager before you act. More information on how managers can help team members to uphold this Code of Conduct can be found in our section below on “The role of managers”.

How and where to go for help

If you see anything not in line with the Code of Conduct or that you think goes against the principles herein, please speak up. Ubisoft commits to review all reports of misconduct, treating allegations of misconduct respectfully and confidentially and to protect anyone who raises a concern from retaliation. Each section of the Code of Conduct outlines a specific contact depending on the situation. That said, in most circumstances, the first step is for team members to speak to their direct manager or a local human resources manager. If needed, reports of misconduct can also be raised anonymously through Whispli, our speak-up system.

This Code applies to Ubisoft teams. But it also gives clear commitments that must be followed by team members in their day-to-day relationship with business partners or players.

For any other questions regarding the Code of Conduct, please refer to your local HR managers or local Managing Directors.

The role of managers and Human Resources

Everyone at Ubisoft must act with integrity. And if you are part of the senior leadership, the human resources or a manager, you have additional responsibilities, to lead by example and to care for the well-being of your team.

Senior leadership

Employees holding directing, supervising and senior management’s positions are bound to the highest level of exemplarity when it comes to upholding the Code of Conduct and policies. They are expected to demonstrate leadership in the application of these policies and intervene whenever they see behaviors or processes that don’t comply with these standards.

Human Resources

In addition to their duties to foster a respectful workplace environment and act as the primary support for all employees on employees’ relations and well-being matters, Human Resources have a duty to promptly inquire into any alleged misconduct or reasonable risk of misconduct they are aware of. They are responsible for implementing adequate measures to protect the physical and psychological safety and integrity of all parties involved throughout the misconduct management proceedings.

Managers

Ubisoft managers have a duty to be mindful of team interactions and behavior in the workplace. They are expected to demonstrate a willingness and availability to prevent misconduct and protect Ubisoft employees. Their duties also include acting as ‘first-responders’ as soon as they are made aware of alleged misconduct. In doing so, they are required to act with care to ensure the safety, dignity and reputation of all parties involved.

Managers have a duty to promptly report to HR any form of misconduct they observe, hear about, or reasonably suspect has occurred as well as describe any actions already taken to address the situation.

It is vital to communicate to your team members that following the Code of Conduct and treating their colleagues and partners fairly and with respect is an integral part of achieving their objectives.

Related resources:

Consequences of any violation of the Code

Ubisoft is committed to applying appropriate measures and sanctions for any violation of the principles in this Code of Conduct in line with our disciplinary procedure and any applicable local regulations and laws. These sanctions range from a verbal or written warning to contract termination.

Ubisoft expects team members to be aware of the company’s zero-tolerance commitments set forth in this Code of Conduct.

No disciplinary action (as defined by applicable local law) will be initiated against an employee unless the allegations have been substantiated and the employee has been given the opportunity to state their case.

Disciplinary actions & sanctions will be proportionate to the misconduct’s nature. Repeated, persistent or major misconduct could lead to dismissal. The same misconduct cannot be sanctioned twice unless repeated after a first warning or if Ubisoft is made aware of new information.

Regardless of the disciplinary action taken by Ubisoft, violations of the Code of Conduct may also expose the individuals concerned, as well as Ubisoft, to significant risks of civil and criminal sanctions.

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