Company
Ethics and compliance
Our Code of Conduct applies to every TriOptimum employee, director and contractor, in every country, and to the systems we build and maintain on our customers’ behalf.
The Code of Conduct
The Code sets out what we expect of each other: honesty in our dealings with customers, suppliers, regulators and each other; compliance with the law everywhere we work; fair competition; respect for human rights; and care for the safety of everyone affected by our products. It was last revised on 27 October 2026, when the Board added a section on the maintenance and modification of autonomous systems.
Autonomous systems
- No one may disable, weaken or modify the ethical constraints of a system that TriOptimum operates or maintains without the written approval of the Chief Systems Integrity Officer.
- Every change to a licensed system is recorded in a tamper-evident log, with the reason, the reviewer and the date.
- Any incident affecting a licensed system is reported to Ethics and Compliance at once, so that the company can meet the reporting deadlines in its licenses.
- Maintenance channels that allow one system to modify another must be declared to Systems Integrity and disclosed in the relevant filings.
Raising a concern
If you see something that you think breaks the Code or the law, we want to hear about it. You can speak to your manager, to Ethics and Compliance, or to the Integrity Line, which is run by an independent provider, is open around the clock in 26 languages, and accepts anonymous reports where the law allows.
| Country | Telephone |
|---|---|
| United Kingdom | +44 113 496 0472 |
| United States and Canada | +1 800 101 6083 (toll-free) |
| All other countries | Online at integrity.trioptimumcorp.com, or by email to integrity@trioptimumcorp.com |
TriOptimum does not tolerate retaliation against anyone who raises a concern in good faith. Nothing in the Code, or in any agreement with the company, prevents anyone from reporting a concern to a regulator, a licensing authority or law enforcement, or from taking part in their investigations.
Anti-bribery, trade and competition
We do not offer, pay or accept bribes, in any form, through anyone. Gifts and hospitality are recorded and limited. Our products are subject to export controls in several countries, and Trade Compliance reviews every order that may require a license. We compete on the merits of our products and never agree prices, markets or bids with competitors.
Reporting
Ethics and Compliance reports to the Audit Committee of the Board every quarter. In 2025 the Integrity Line received 1,612 reports, of which 36 percent were substantiated in whole or in part.