Integrity, transparency and responsibility characterize the way we conduct business. Operating with a strong sense of integrity is critical to maintaining trust and credibility with our customers, partners, employees, shareholders, society and other stakeholders. Such trust and credibility requires transparency in how we conduct business and confidentiality when we conduct business to protect business assets and the privacy of individuals.

Creating an environment of transparency in the conduct of business is a high priority for all of us. Our Code of Business Ethics reflects our commitment to operate with candor and truthfulness in our dealings and communications to the marketplace. We expect that the company will be operated in accordance with the principles set forth in this Code. Everyone, from the members of the Board of Directors and the executive management to each individual working for Ericsson, will be held accountable for meeting these standards.

The Code of Business Ethics reflects our company’s commitment to conducting business responsibly including:

Everyone working for Ericsson is required to review the Code, to support and work in line with the company’s commitments stated herein, and to follow the rules in the Code addressed to us as well as all applicable laws. In addition, we must follow Ericsson’s Group policies, directives and instructions as well as local directives and instructions; failure to do so may result in disciplinary action including termination of employment and/or civil and criminal liability.

Individuals working for Ericsson – Individuals working under the staff management of Ericsson are encouraged to report any conduct that they believe, in good faith, to be a violation of laws or the Code of Business Ethics to their manager or in accordance with locally established procedure. If the manager is involved in the situation or cannot or has not adequately addressed the concerns, employees are advised to report to a manager of higher rank or in accordance with locally established procedure.

Suppliers, customers and others - Suppliers, customers and other partners involved with Ericsson may report suspected violations of laws or the Code of Business Ethics to the local operations manager or in accordance with locally established procedure.

Ericsson Compliance Line - If the above channels for reporting are not available or appropriate, and if the alleged violation

the violation may be reported through the Group’s external whistle-blower process: the Ericsson Compliance Line. Reports may be handled via this process if in accordance with local legislation

It is the responsibility of everyone working for Ericsson to treat corporate responsibility issues, including human rights, health and safety, and environmental issues, in a professional way, and to consider the company’s commitment to being a relevant and responsible driver of positive change in society by conducting business responsibly in their daily work.

We believe that communication is a basic human need that contributes to economic prosperity and social equity and provides solutions to many of society’s sustainable development challenges. We strive to ensure that our technology is a force for good in the world and minimize any negative impacts. We firmly believe that information and communication technology (ICT) promotes greater transparency and enhances many fundamental human rights, such as the right to health, education, freedom of assembly, and freedom of expression.

It is important to behave in a socially and ethically responsible way, and we strive to be responsible citizens in the communities where we conduct business. We care about the people who take part in the production and support of our products and services worldwide, and users of ICT more broadly. Ericsson is committed to upholding the 10 UN Global Compact principles, which cover human rights, labor standards, environmental management, and anti-corruption. These principles form the basis of our approach to conducting business responsibly.

Ericsson respects all internationally recognized human rights, including the International Bill of Human Rights and the International Labor Organization´s Declaration on Fundamental Principles and Rights at Work, which address freedom of association and collective bargaining, forced labor, child labor, and non-discrimination.

We are committed to implementing the UN Guiding Principles for Business and Human Rights throughout our business operations. We strive to avoid infringing on the human rights of others and address adverse human rights impacts with which Ericsson is involved. We shall, in all contexts, seek ways to honor the principles of internationally recognized human rights, even when faced with conflicting requirements.

At Ericsson we give high importance to the health and safety of our employees, our partners’ employees, our suppliers’ employees, and members of the public that may be affected by our operations. Our commitment is demonstrated by thoughtfully considering potential adverse impacts on health and safety, analyzing and planning necessary actions to avoid such impacts, and having leadership commitment at all levels. At Ericsson we have a vision and goal of zero major incidents, and have systems and procedures that apply to all employees and will help the company achieve the zero incident vision.

From a health perspective, Ericsson also encourages employees to maintain a positive work life balance.

Ericsson is committed to the sustainable development of society, which is development that meets the needs of the present without compromising the ability of future generations to meet their own needs. We define sustainability as long-term social equity, economic prosperity, and improved environmental performance. The Sustainable Development Goals provide a framework for how we describe our input on society. We are committed to using our technology and expertise to help achieve the Goals.

Ericsson shall strive to develop, produce and offer products, services, and solutions with excellent sustainability performance.

For the purpose of respecting human rights and promoting fair employment conditions, safe working conditions, responsible management of environmental issues, and high ethical standards, our Code of Conduct is based on the UN Global Compact principles. It shall be applied throughout the company´s operations including in the management, development, production, supply, sales and support of Ericsson solutions, products and services worldwide. The Code of Conduct shall also be valid for all Ericsson suppliers and applied through contractual terms and conditions.

Ericsson shall comply with all laws, rules and regulations that apply to its business. As you conduct Ericsson’s business, you may encounter a variety of legal issues. Violations of any applicable law, rule or regulation may have serious consequences, both for Ericsson and for the individuals concerned. Therefore, it is your responsibility to be familiar with and comply with relevant laws, rules and regulations, including in the areas listed below.

Trade Compliance – Specific laws, rules and regulations apply to us as a multinational group of companies in an international business environment, in particular when exporting and importing products and services. Ericsson employees must therefore be familiar with, and adhere to, applicable domestic and foreign laws, rules, and regulations related to export and import regulations, anti-boycott provisions, trade embargos, and sanctions. According to these laws, rules and regulations, individuals can be restricted from participating in certain business activities, for example, “United States persons” (US citizens, green card holders and persons physically located in the US) can be subject to such restrictions. Group Function Legal Affairs is available to support employees with questions regarding Trade Compliance.

Fair competition – Ericsson is dedicated to promoting fair competition. Fair competition provides the best incentives for business efficiency. It encourages business development and innovation and it creates a wider choice for consumers. Most countries have laws prohibiting business practices that interfere with fair competition (competition or antitrust laws). These laws govern the ways companies deal with their

Ericsson financial instruments during a closed period of 30 days before the publication of financial reports. All Ericsson employees are recommended not to trade in Ericsson financial instruments during this period even if they do not possess inside information.

Privacy - Ericsson is committed to protecting the privacy of personal information, including personal

It is important that Ericsson employees have a good understanding of their units’ operational and financial performance to increase involvement in improving operations. This must be balanced with Ericsson’s financial disclosure policy and legal requirements, specified in frameworks such as the insider rules, and the listing and reporting rules of stock exchanges and supervisory authorities for securities. Ericsson’s obligation to comply with these requirements defines the way that individuals working for Ericsson shall manage material news that might impact the company’s stock price. Comments about financial performance and prospects to external parties shall only be made by official company spokespersons, as authorized in the spokespersons directive and in conjunction with activities supported by Group Function Marketing & Communications.

We shall make business decisions based on the best interests of the Group rather than personal considerations or relationships. A conflict of interest arises when anything interferes with or influences the exercise of our independent judgment in the best interest of Ericsson. We must avoid situations in which our personal interest may conflict with, or even appear to conflict with, the interests of the Group.

The following are examples of situations to be particularly aware of:

Business opportunities – You may not take business opportunities for yourself, your family or friends that are identified in the course of your work for Ericsson if this could be contrary to the interests of Ericsson. Nor may you otherwise use Ericsson property or information or your position at Ericsson for personal gain or for the gain of your family or friends.

Other Employment or engagement – You may not take any employment or engagement outside Ericsson, with or without compensation, that harms or may harm job performance at Ericsson or creates or may create a conflict of interest. Ericsson employees may not engage in outside business interests that divert time and attention away from Ericsson responsibilities or require work during Ericsson working time. Ericsson employees shall avoid any potential conflict of interest by not accepting employment or engagement from any ICT organization or any supplier, contractor, agent, customer, or competitor of Ericsson, unless the engagement is on behalf of or at the request of Ericsson.

Board assignments outside Ericsson – Ericsson employees must not take a board position in any entity or association (including non-profit organizations) if it creates a conflict of interest or

Zero-tolerance – Ericsson has a zero-tolerance policy towards any form of corruption and financial irregularity, including bribery, kickbacks, facilitation payments, fraud, embezzlement, and money laundering, as follows.

Bribes and kickbacks – No one representing Ericsson may, directly or indirectly, demand or accept from, or offer or give to, employees or other representatives of business partners (such as customers, suppliers, and channel partners) or any other third parties (e.g. authorities), any kind of bribe, kickback or any other unlawful or unethical benefit.

Gifts and entertainment – No one representing Ericsson may offer to, or accept from, business partners or any other third parties, gifts, benefits, reimbursements, or entertainment that would constitute a violation of laws or that could suggest a conflict of interest, divided loyalty, or be perceived as an improper attempt to influence business decisions or otherwise affect the recipient’s performance or work duties. Ericsson employees should normally not accept gifts from business partners or any other third parties except for promotional items with insignificant value.

All gifts or entertainment should be:

Certain gifts or benefits are never allowed to be either offered or accepted, including money, loans, gift vouchers, kick-backs, work for private purpose, unethical benefits, vacations, or similar benefits addressed to individuals.

Further guidelines are available in Ericsson steering documents and e-learnings.

Ericsson has a wide variety of assets, including physical assets, proprietary information and intellectual property. You are responsible for protecting Ericsson property entrusted to you and for helping to protect Ericsson’s assets in general. To do this you must be aware of and understand Ericsson’s security directives. You must be alert and report any loss, or risk of loss, of Ericsson properties to your manager or Ericsson Security as soon as they come to your attention.

Below, you will find certain instructions for internal and external handling of information, communication systems and intellectual property.

Intellectual property – Intellectual property includes a variety of properties, such as computer programs, technical documentation and inventions. Certain intellectual property is, or can be made, subject to special protection through copyright, patent right, trademark right, etc.

Intellectual property is an asset of utmost value to Ericsson and must be treated with appropriate care. You must follow and, in case of doubt, seek instructions on how you shall act to protect this valuable asset. For example, it is important that open source software is used and distributed only in accordance with Ericsson’s regulations on open source software.

Intellectual property created by Ericsson employees under the employment is transferred and assigned to Ericsson by law and/or the employment contract or other agreement, with the exceptions stated in

Protecting Ericsson’s confidential and proprietary information and that of our customers, partners and suppliers

Persons working for Ericsson have access to information owned by Ericsson and sometimes also to information owned by third parties. Such information may be financial information, business plans, technical information, information about employees and customers, and other types of information. Non-authorized access, use and disclosure may damage Ericsson or the third party and, therefore, you are not allowed to access, use or disclose the information unless you have been properly authorized to do so. Non-authorized access, use and disclosure may also be a violation of laws, including privacy regulations. Whenever you are in doubt of your authorization, you must seek instructions from your manager or Ericsson Security.

Here are some rules that will help protect non-public information of Ericsson and its customers, partners and suppliers: