Code of Corporate Responsibility

1.0 INTRODUCTION

Jigsaw School Apps is committed to operating in accordance with responsible, ethical and sound corporate and business principles and in compliance with all applicable laws and public regulations. This requires the collective effort of all employees.

This Code of Conduct applies to all Jigsaw School Apps employees and board members in entities owned by Jigsaw School Apps throughout the world. By agreement it may also apply to independent consultants, intermediaries or others acting on behalf of Jigsaw School Apps. The document provides a framework for what Jigsaw School Apps considers to be responsible conduct, and defines the individual responsibilities of employees through a combination of broad principles and specific requirements.

This Code of Conduct does not provide an exhaustive overview of what is responsible behaviour. The ultimate responsibility to act in accordance with law and ethics will always remain an individual responsibility.

2.0 GENERAL PRINCIPLES

2.1 Comply with laws and regulations

All employees and board members shall comply with public laws and binding internal requirements in all their activities for Jigsaw School Apps

The Jigsaw School Apps Group, the individual companies, employees and board members shall always respect applicable local laws and regulations. In addition, all employees shall comply with internal company policies.

2.2 Act in the best interest of Jigsaw School Apps

All employees and board members shall be loyal to and serve the best interest of Jigsaw School Apps.

Loyalty means to work for the best of Jigsaw School Apps, and, within the framework of public law and Jigsaw School Apps’s policies, give Jigsaw School Apps’s interests priority over other interests. We should always use our best judgement to enhance Jigsaw School Apps’s value creation, protect the company’s interests and contribute to continuous improvement.

2.3 Act with integrity

All employees and board members shall act with integrity in their activities for Jigsaw School Apps.

Personal integrity means “doing the right thing”, even when nobody is watching. We shall always be honest, truthful and reliable. We should act responsibly towards colleagues, business associates and society at large.

2.4 Act with respect and care for others and for the environment

All employees and board members shall treat other human beings and the environment with respect and due care.

Jigsaw School Apps shall foster a corporate culture characterised by respect and care for other people, their property and the environment. We should behave in a way that inspires trust both when collaborating with colleagues and interacting with suppliers, customers, other business partners or authorities.

3.0 SPECIFIC PRINCIPLES

3.1 Protect Jigsaw School Apps’s property and reputation

All employees and board members shall protect Jigsaw School Apps’s property, assets and reputation.

The reputation of Jigsaw School Apps is important for our ability to succeed. Employees and board members shall avoid activities or behaviour which could damage Jigsaw School Apps’s reputation.

All employees shall act responsibly and with caution to protect buildings, machinery, equipment and other property from misuse, theft, damage or destruction. Intellectual property such as patents, designs, trademarks, recipes, know how, ideas and information shall also be protected. Jigsaw School Apps’s property and assets shall not be used for the employee’s own purposes, unless this is agreed with authorised personnel.

3.2 Contribute to Jigsaw School Apps’s environment, health and safety vision

All employees shall contribute to achieving Jigsaw School Apps’s vision of zero harm to people, the environment and society.

Employees shall contribute to the vision by cooperating with the management and by exercising sound judgement. Employees shall notify their immediate superior of important issues related to health and safety in the workplace, consumer health or the company’s impact on the environment.

3.3 Avoid discrimination and harassment

All employees shall avoid behaviour which may be seen as discrimination or harassment.

Jigsaw School Apps aims for a workplace characterised by diversity and anti-discrimination. To reach this goal, all employees shall treat colleagues, customers, business partners and others with respect. Employees shall avoid any form of harassment or other behaviour towards colleagues or business associates which may be regarded as threatening or humanly degrading. No discrimination (due to gender, sexual orientation, age, ethnicity, or religious belief) which violates applicable law shall take place. Employees should also be sensitive to and respectful of cultural differences.

3.4 Handle business information with care

All employees and board members shall treat information about Jigsaw School Apps with due care, and treat non-public information confidentially.

A trustful relationship with customers, business partners, colleagues and society is built by engaging in dialogue and sharing perspectives. At the same time, disclosure of confidential information may harm Jigsaw School Apps’s business or reputation. By confidential information we generally mean information which is not, or should not be, known to the public. Examples of such information include business plans, budgets, marketing and sales programmes, design specifications, customer records and the like. Employees and board members shall never disclose confidential information to people outside of the company, unless such disclosure is explicitly permitted by an authorised superior or required by law.

Information about Jigsaw School Apps which has not become public shall be regarded as Jigsaw School Apps’s property. Consequently, the non-disclosure obligation continues without time limit after the termination of employment or the term of service as a board member.

3.5 Avoid conflict of interest

All employees and board members shall be loyal to Jigsaw School Apps by avoiding any conflict of interest.

Employees and board members shall not seek to obtain advantages for themselves or others that are improper or may harm Jigsaw School Apps’s interests. No one should take part in, or seek to influence, a decision if this may give rise to an actual or perceived conflict of interest. Particular attention should be given to situations where the employee or board member has a personal interest in the matter, economic or otherwise, directly or through someone closely related.

Employees or board members shall not accept assignments outside Jigsaw School Apps without notifying their immediate superior. Assignments shall not conflict with Jigsaw School Apps’s interests. Careful consideration should be applied to avoid activities which may be perceived to advance the interests of a competitor, a supplier or other stakeholders at the expense of Jigsaw School Apps. Employees or board members are not allowed to market products or services that are in direct competition with Jigsaw School Apps’s business activities or interests.

Employees or board members who become aware of a potential and unacceptable conflict of interest shall, without delay, notify their immediate superior.

3.6 Use written agreements

Jigsaw School Apps’s agreements with employees, suppliers, customers and business partners shall, as a general rule, be entered into in writing and be properly filed.

All Jigsaw School Apps companies enter into agreements on a regular basis, and these business agreements are vital to the company’s success. Oral agreements can be difficult to verify and may sometimes lead to suspicions that something illegal or unethical has taken place. Therefore, all agreements entered into by any Jigsaw School Apps company shall, as a general rule, be in writing, and the agreements shall be properly filed.

3.7 Be accurate in accounting

Jigsaw School Apps’s financial records shall always be accurate.

Jigsaw School Apps’s financial records are crucial for the management of the business and for the fulfilment of the company’s obligations towards stakeholders. Therefore, Jigsaw School Apps is committed to complete accuracy in all financial records. Employees involved in financial transactions or accounting shall ensure that all transactions are fully and accurately documented and recorded in accordance with applicable law, good accounting practice and internal requirements. False or misleading entries are under no circumstance acceptable.

3.8 Never engage in corruption or bribery

All employees and board members shall refrain from corruption and bribery in all forms.

Jigsaw School Apps employees and board members are not allowed to engage in any form of bribery or corruption. This requirement is based on anti-corruption legislation which all Jigsaw School Apps companies must adhere to, and applies to all of Jigsaw School Apps’s activities world-wide. Individuals involved in acts of corruption may be exposed to civil and criminal liability. Corrupt activities are punished severely by the court, and individuals who are found guilty of violating the law may become subject to imprisonment. If a challenging situation occurs as part of the work for Jigsaw School Apps, employees should seek immediate advice from their superior about how to handle it in a legal manner. Such discussions are an important part of the company’s efforts to prevent corruption and bribery.

Offering and accepting personal courtesy gifts may be allowed provided they have a minimal economic value, are infrequent and clearly appropriate under the circumstances. It is not allowed to give or receive cash or gifts which are given in return for a favour. Gifts shall not be given in a context or a way where there are reasons to suspect that the recipient will keep such gift or benefit hidden from his or her superior. For example, gifts should be addressed to the recipient’s working address at the relevant legal or public entity.

Events for customers shall always have a specific and relevant business purpose and can only be accepted if they are reasonable and appropriate with respect to both value and frequency. Participation in such events organised by others shall comply with the same principle, and transportation and accommodation should be paid by Jigsaw School Apps. Employees or board members who have been offered, or who have received gifts or favours, shall, without delay, notify their immediate superior, who will determine whether or not the gift needs to be returned.

3.9 Act fair in competition

Employees shall contribute to fair competition in compliance with competition laws.

Jigsaw School Apps shall always compete in the market place with respect for and in compliance with applicable competition law, antitrust law and marketing control laws. Employees who are involved in marketing, sales, purchasing or logistics activities shall ensure that they are familiar with applicable laws and internal rules and guidelines related to marketing and sales.

3.10 Never engage in money laundering

Employees and board members shall not in any way become involved in money laundering.

By money laundering we mean arrangements conducted in order to make money which is acquired through criminal activities look like it has been lawfully earned. Money laundering is prohibited under law, and will not be tolerated by Jigsaw School Apps. Should an employee observe activities which may indicate that money laundering takes place, or has been taking place, in connection with company activities, the employee shall without delay report his or her concern to Jigsaw School Apps.

The same rules apply to arrangements with the intent to speculate in non detection of illegal or disloyal avoidance of taxes, customs or other duties.

4.0 COMPLIANCE AND IMPLEMENTATION

4.1 The duty to comply

Each Jigsaw School Apps employee and board member has a personal responsibility for complying with all the requirements specified in this Code of Conduct. Employees and board members shall not act (or encourage others to act) contrary to the Code of Conduct. This requirement applies even when violation of a principle may appear to be in the interest of Jigsaw School Apps.

Any uncertainty as to whether a particular activity is in accordance with the principles of this Code of Conduct, should, in so far as is practicable, be discussed in advance, primarily with the immediate superior. Jigsaw School Apps believes in discussions about responsible conduct in an improvement-oriented and informal manner. Nevertheless, breaches of the requirements set out in this Code of Conduct may lead to internal disciplinary action, and in serious cases dismissal or even criminal prosecution.

4.2 Whistle blowing

Observations of conduct which is illegal or represents a breach of the principles in this Code of Conduct should be reported either orally or in writing to the employee’s immediate superior.

If the employee so wishes, a report may be given on a confidential, or even anonymous basis. All persons who have received such confidential report, or information about such report, shall keep the information strictly confidential in order to protect the employee concerned. Any report concerning illegal activities or breach of this Code of Conduct shall be taken seriously, and be appropriately investigated. Jigsaw School Apps will not accept any retaliation against employees or board members who, in good faith, have reported a violation (or suspected violation) of applicable law or of the principles in this Code of Conduct. An employee or board member who feels that a report has in any way been used against him or her by anyone in Jigsaw School Apps, may report this to their immediate superior.

4.3 Implementation and monitoring

The responsibility for implementing this Code of Conduct with the company Directors. The Code of Conduct shall be distributed to all employees.

All employees shall carefully read this Code of Conduct.

Jigsaw School Apps is responsible for updating this Code of Conduct.

This Code of Conduct is a statement of certain fundamental principles that apply to the conduct of employees and board members. It does not create any legal rights for any customer, supplier, competitor, shareholder or any other third party.

5.0 Approval

The Code of Conduct was approved by the Board of Directors of Jigsaw School Apps ASA on 15th September 2014.

Approved by the Board of Directors of Jigsaw School Apps on 15th September 2014.