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CODE OF CONDUCT Message from the Founders LeoVegas Mobile Gaming Group was founded in Sweden 2011. This was the year when the mobile and touch screens was about to change the world and become the primary source for digital entertainment. Like no other, LeoVegas merged the intuitive interface and playfulness we learnt to love in smart phones - with the thrill of Vegas in gaming. LeoVegas has grown from an unknown brand with zero customers to one of the leading mobile gaming companies in Europe. Our business idea and vision are as relevant today as when we started out: LeoVegas is to create the greatest mobile gaming experience and be the number one in mobile casino. In leading an industry and spearheading development also comes a great responsibility. LeoVegas has always endeavoured to cultivate a culture with high ethical standards and employees that live and develop according to values we all are to be proud of. It is our strongest believe that this has been and are to be a key part of our continued success and that LeoVegas Value´s will lead the way in the journey that still has just started. LeoVegas Mobile Gaming Groups Code of Conduct is to visualise and guide the ethical standards and serve as a compass for our decisions and actions in our daily work. It is the responsibility of each LeoVegas employee and board member to understand and follow the Code of Conduct. LeoVegas is committed to leading the way into the mobile future. We are to create value for all employees, our customers, and our shareholders - whom all make the LeoVegas journey possible. We are to build positive relations to business partners, media and society at large. We are all to be role models as people and as a company.

By maintaining high ethical standards, staying committed to our values and continually making ourselves deliver upon the trust and respect from our stakeholders, we will be able to stand strong and embrace the future we are shaping. LeoVegas requirements on social responsibility and compliance with ethical principles are based on internationally widely accepted regulations and norms, including relevant ILO conventions1, the UN Universal Declaration of Human Rights2 and UN Global Compact3. We know that we are all defined by our actions, so let’s ensure that our actions speak for us.

Gustaf Hagman Robin Ramm-Ericson Group CEO, co-founder Group Chairman of the Board, co-founder

1 http://www.ilo.org), 2 http://www.un.org 3 The UN Global Compact is a policy initiative for businesses that are committed to aligning their operations and strategies with ten universal principles in the areas of human rights, labour, environment and anti-corruption. http://www.unglobalcompact.org

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2. Purpose and Scope of the Code 2.1 Why do we have a code? The Code of Conduct is a set of standards describing whom LeoVegas mobile gaming group is and how we do business. The LeoVegas mobile gaming group will also be named the Group or LeoVegas throughout the Code Of Conduct. The Code translates LeoVegas core values into practical action and provides guidance for how we are expected to act. It also explains what you as an employee can expect from LeoVegas. All LeoVegas employees and board members should comply with applicable laws and regulations when conducting business on behalf of the Group. In some cases, LeoVegas standards may be higher than existing legislation or regulations, and in those cases we will comply with our own higher standards.

2.2 Target group / Applicability The Code of Conduct applies LeoVegas board members and to all employees, in every country where it operates. We also expect our business partners, including distributors, suppliers, consultants and independent contractors, to adhere to standards similar to those reflected in our Code in the conduct of their own business.

2.3 Violations of the CodeViolations of the Code of Conduct will always be taken seriously and may lead to disciplinary action or criminal prosecution. If an employee observes a behaviour that may represent a violation of the Code of Conduct, the issue needs to be reported promptly.

2.4 Reporting concernsThe first step is to inform its colleague that a certain action might not be in harmony with the code. If it is no affect of information it is mandatory to report any violations of the Code of Conduct. When an employee wishes to report an alleged violation of the Code, his/her immediate manager should be informed as a first step. If the employee finds it difficult to bring up an issue locally or if the

allegation is of a serious or sensitive nature, the reporting shall be made directly to country HR or Group CEO. An employee’s integrity is protected and will always be in good standing when reporting a suspected violation of the Code of Conduct.

3. Administration of the Code 3.1 Governance The Code is approved by LeoVegas’s Board of Directors and shall be reviewed annually. It is the responsibility of each employee to observe and promote the Code.

3.2 MonitoringLeoVegas will ensure that each employee is provided with the Code and informed about its principles. Adherence to LeoVegas’s vision and its Code of Conduct will be monitored as part of the regular employee survey.

4. Business Basics 4.1 Confidentiality LeoVegas will collect and handle personal information of clients, employees and third parties in strict compliance with applicable privacy laws and LeoVegas’ relevant internal policies.

4.2 Protection of Company property Company property and assets, such as physical assets, competitive company information, intellectual property, such as patents, trademarks, know-how and information systems, should be used for business purposes only, and may not be used for personal gain, fraudulent purposes or in any other inappropriate manner.

4.3 Protection of Customers information LeoVegas see the company’s information as the same value as the customer’s information and identity. Therefor it is absolutely forbidden to talk about or share information about our customers with third party. Even internally it is not allowed to speak or share information with staff that is not related to the specific customer case.

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4.4 Conflict of interest LeoVegas’ employees and business partners must always avoid conflicts of interest, which arise when your own private interests, personal relationships or external activities influence, or appear to influence, the performance of job responsibilities.

4.5 Gifts and Rewards Gifts, rewards, benefits and entertainment may only be offered or accepted if they are a reasonable compliment to a sound and legitimate business relationship. It is important to avoid situations where gifts and benefits might diminish your or someone else’s objectivity or influence business transactions and decision-making. LeoVegas and its employees are always obligated to live in accordance with national law where we operate.

4.6 Fraud LeoVegas does not accept fraud in any form, which involves the use of deception, dishonesty and breach of confidence to gain unfair or dishonest advantage. LeoVegas run checks daily to prevent any kind of internal or external type of fraud. All internal actions in the LeoVegas back office system is being tracked and are followed up regularly. LeoVegas is running daily checks for online partners to LeoVegas such as affiliates and other connected networks.

4.7 Anti Money laundering LeoVegas is committed to full compliance with anti-money laundering laws and regulations, and takes appropriate actions to assess the integrity of our business counterparts to ensure that no illegitimate funds are concealed. LeoVegas internal and external Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) procedures are in accordance with Malta and UK license conditions and are also based upon the upcoming 4th AML EU Directive.

4.8 Bribery and corruption LeoVegas does not tolerate bribery (the offering, giving, receiving or soliciting of something of value for the purpose of influencing the actions of the recipient) or corruption (the abuse of entrusted power for personal gain, and can take the forms of

bribery, embezzlement, fraud and extortion) in its business practices. LeoVegas act according to relevant anti-corruption laws in the countries where we have presence.

4.9 Fair competition LeoVegas is committed to complying with applicable competition laws, which prohibit agreements or understandings between competitors that undermine competition, including price fixing, allocation of customers or geographic markets, bid rigging or abuse of a dominant position.

4.9.1 Equality, Diversity and Discrimination At LeoVegas Group, employment and development opportunities must always be based on competence, experience and ability to perform according to our high standards and the expectations of our customers, and in accordance with regulation. Being a company with customers from all over the world, LeoVegas Group views diversity as a source of competitive advantage. LeoVegas Group is committed to ensure a working environment free from discrimination and harassment based on gender, ethnicity, religion or other belief, sexual orientation, gender identity or expression, disability or age. In the event of discrimination or harassment, it is the responsibility of management to take measures for further investigation and to ensure appropriate disciplinary action in accordance with local policy. When recruiting, hiring, developing and promoting employees, LeoVegas is committed to make decisions without taking gender, race, color, national origin, ancestry, citizenship, religion, age, physical disability, sexual orientation, transgender expression, or marital status into consideration.

4.9.2 Harassment LeoVegas does not tolerate any discrimination, harassment or other inappropriate behaviour. This includes comments in general as well as comments based on racial or ethnic characteristics and sexual harassment.

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5. Health and Safety LeoVegas is committed to provide a safe and healthy working environment for all employees, which comply with national standards for occupational health and safety. LeoVegas give the employees opportunity to maintain a good health. For example common training sessions and health care contribution. In addition, and first and foremost, the employee has a responsibility to maintain a healthy lifestyle.

6. Human Rights LeoVegas recognizes its responsibility to promote and respect internationally proclaimed human rights when conducting its business. LeoVegas requirements on social responsibility and compliance with ethical principles are based on internationally widely accepted regulations and norms, including relevant ILO conventions (http://www.ilo.org), the UN Universal Declaration of Human Rights (http://www.un.org) and UN Global Compact (http://www.unglobalcompact.org).

7. Environmental Responsibility LeoVegas is committed to good environmental management by fulfilling the environmental requirements set out in laws and regulations that affect its markets. In this context, LeoVegas is committed to reducing our environmental footprint by making efficient use of energy and natural resources. For more information, kindly see LeoVegas’ Sustainability Policy.

8. Stock Market Information As a listed company LeoVegas will provide accurate and up-to-date information about the company’s business, results and financial condition to all shareholders in accordance with the stock market regulations. LeoVegas accounts to give a true and fair view of the company’s financial performance in line with International Financial Reporting Standards (IFRS). External auditors review LeoVegas accounts and based on this, the auditors annually write a report about the fulfilment of a true image.

8.1 Inside information and Insider trading LeoVegas’ employees is not allowed to use inside information, i.e. information that is not

available publically and could affect some one’s decision to buy or sell stocks or shares, for insider trading. Insider trading not only violates this Code, it violates the law. For additional information and regulations with respect to insider trading, kindly see LeoVegas Insider Policy.

9. Responsible Gaming Mobile gaming is fun – and gaming should be fun for everyone. However, some people risk encounter problems related to their gaming. LeoVegas looks on problem gambling very seriously and the commitment to responsible gaming is the starting point of our operations. We emphasize respect for our customers and with that we have a responsibility to act and do what we can in order to guide the customers. LeoVegas offers a set of consumer tools for automatic gaming control, example of that is self excluding and the ability to set limits for your gambling. In addition to tools for the customer, LeoVegas works internally with responsible gaming as part of the corporate culture and offer training to the entire workforce regardless of role within the Group. An employee whose work involves interacting with customer’s gets additional and specialized training. Participation in these programs is mandatory. Customer Service has a “go to” person during all shifts meaning that the area is covered 24/7 by the department who interact the most with our customers. Further, in order to avoid any type of conflict no employee bonuses are based on customers gaming volumes. In the subject of responsible gaming confidentiality is very important for LeoVegas and it is strictly forbidden to share or pass on customer identity or similar information externally. Our respect for our customer is absolutely critical in how we just like a bank needs to treat the customers identity and protect their integrity both internally and externally. LeoVegas also follow all the rules and regulations regarding Responsible Gaming as required by the Maltese Lotteries and Gaming Authority (MGA), as well as the Gambling Commission in UK. To ensure legal compliance and that all operational aspects are in line with these standards and regulations, as well as established good responsible gaming practices, we have a dedicated Responsible Gaming Resource.

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LeoVegas is committed to constantly work with engagement and responsibility for a

positive and safe gaming experience for everybody.

10. Final remarks As described in the code this is our ethical guidelines within the LeoVegas Mobile Gaming Group and something to use as a guideline for our employees. LeoVegas is a growth company and acts and operate in a fast paced industry. This combination means that there is a need to highlight business ethics, and for LeoVegas it is important to show, both internal and external, that it is our values that guide our decisions.

”LEOVEGAS IS LEADING THE WAY INTO THE MOBILE FUTURE”