Last updated
June 3, 2026
Code of Conduct
Instabee Group
1. Introduction
At Instabee, we recognize that a big part of our success lies in not only delivering goods and services efficiently, but also upholding the highest standards of integrity, ethics, and professionalism. This Code of Conduct (“Code of Conduct”) provides the overarching framework for our behavior, ensuring we act with integrity and respect towards our employees, business partners, customers, investors, competition, society and the planet, as well as that we protect our material and intellectual property, business and values. It does not replace laws or existing agreements but sets the common principles that guide us in every market. This Code of Conduct is applicable to the entire Instabee Group (“Instabee”, “we” or “us”).
This Code of Conduct is rooted in our four values: Raise the Bar, Perform Together, Care More, and Stay Curious (“Values”). These Values define who we are and how we work every day. By following this Code of Conduct and its underlying framework, we collectively protect our reputation and bring our Values to life in every action we take.
Compliance with this Code of Conduct is mandatory. It applies to all directors, employees, consultants, interns, and anyone acting on behalf of Instabee regardless of position or location (“Employees”, “you”). Furthermore, if you are a people manager or senior leader, you have an additional responsibility to lead by example, act with integrity, and promote a culture built on trust, accountability, and respect. As leaders play an important role in guiding others through ethical questions and difficult situations, you are expected to actively promote this Code of Conduct within your team and foster an inclusive and open speak-up culture where Employees feel safe raising concerns without fear of retaliation. This includes listening to concerns, taking them seriously, addressing issues appropriately, and escalating matters when necessary.
All internal policies and frameworks referred to in this document are available on our intranet, the Hub.
2. Statement on Responsible Business Conduct
Instabee supports internationally agreed conventions and standards on human rights, labor rights and responsible business conduct.*
*Including the UN Universal Declaration of Human Rights, the ten principles of the UN Global Compact, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the International Labor Organisation Declaration on Fundamental Principles and Rights at Work as well as the eight core conventions of ILO regarding forced labor, child labor, discrimination, freedom of association, and the right to collective bargaining (no. 29, 87, 98, 100, 105, 111, 138, and 182). Instabee and its Employees shall always adhere to the principles set out in these conventions and standards.
3. Business Ethics
Ensuring a high standard of business ethics is a core principle of Instabee. We hold ourselves to high standards in everything we do, which means we always consider the ethical implications of our decisions and actions, assessing the potential impact on others. To maintain this, we cultivate an open-minded environment — we encourage everyone to ask questions whenever faced with an ethical dilemma, and we expect our people to speak up immediately if something does not feel right.
3.1 Legal and Contractual Compliance
3.2 Anti-Corruption
Instabee maintains a strict zero-tolerance for corruption, including bribery, fraud, extortion and embezzlement. You must never offer or accept any undue benefit - monetary or otherwise - intended to improperly influence a business decision or relationship. It is your responsibility to follow our Anti-Corruption Policy, remain vigilant against suspicious activities, and report them promptly, understanding that your personal integrity is vital to Instabee’s reputation.
3.3 Conflict of Interest
3.4 Fair Competition
3.5 Trade Compliance — Exports, Imports, and Sanctions
3.6 Financial reporting & Accurate Record Keeping
3.7 Politically Neutral
Instabee does not make political contributions. Personal political activity must be kept separate from company time and resources. You must refrain from using Instabee’s brand, logos, or their professional titles in a way that suggests the company endorses a specific political candidate, party, or cause.
4. Protection of Assets, Information Security, and Privacy
Our assets, e.g. our information, software, equipment and people (“Assets”), are crucial to our work and our business - we need them to operate and to maintain our competitive advantage. Since we strongly believe in what we do, we care about protecting and maintaining these resources, and we do this with integrity.
4.1 Protection of Assets, Information Security, and Confidentiality
Instabee’s physical and intellectual Assets, e.g. laptops, software, strategies, and processes, are vital to our success and must be protected from loss, theft, or unauthorised disclosure. You must use company property with sound judgment, follow our Information Security and Digital Compliance Framework and prevent unauthorized access to our software and premises. To maintain stakeholder trust, you must never post non-public information on social media and must use non-disclosure agreements (NDAs) when sharing company information externally. Any potential security incidents must be reported immediately in relevant channels.
4.2 Privacy
Instabee is committed to respecting individuals' right to privacy by processing personal data securely and lawfully to maintain the trust of our customers and other stakeholders. You must safeguard all personal data in your possession, follow our privacy framework, and refrain from unnecessary processing. To ensure compliance with data protection laws, you must only handle data required for specific business purposes and delete it once it is no longer needed.
4.3 Artificial Intelligence (AI)
We use AI legally, responsibly, and ethically, prioritising fairness and transparency. You must comply with our Digital Compliance Framework, remain vigilant against potential biases or discriminatory outcomes in AI models and handle all data used by these systems with extreme care. Furthermore, you must never input company, customer, or personal data into public AI tools without authorization, as this can lead to unauthorized disclosure of our confidential information.
5. Respect for People and the Planet
We work together as one team by creating a safe, inclusive, and healthy working environment that relies entirely on trusting each other’s intentions and considering the impact of our actions on others. We treat everyone, inside and outside Instabee, with genuine respect, honesty, and friendliness, while actively minimizing our footprint on the planet we share.
5.1 Mutual Respect
We foster a work environment built on dignity, inclusivity, and professionalism for all Employees, our business partners and other stakeholders. We maintain zero tolerance acts or threats of violence, including physical, verbal, or psychological violence, or any other type of unwelcome conduct that creates an intimidating, offensive or hostile work environment at Instabee, e.g. sexual harassment. You are expected to model respectful behavior, follow our Non-Discrimination & Anti-Harassment Policy, and address conflicts constructively by speaking up and reporting any concerns immediately.
5.2 Equality, Diversity, and Inclusion
We promote equity and prohibit discrimination in all forms, valuing the diverse perspectives and backgrounds that drive our success. You must treat all colleagues with fairness and ensure that every individual is provided equal opportunity regardless of their characteristics or circumstances. This includes conducting unbiased recruitment based solely on talent and skill, following our Non-Discrimination & Anti-Harassment Policy, and proactively speaking up if you notice any discriminatory behavior.
5.3 Health and Safety
We prioritize the safety and well-being of our Employees, business partners and other stakeholders. We work to prevent accidents, injuries, work-related illnesses, and unsafe conditions by identifying risks, mitigating hazards and promoting safe practices. You have the right and responsibility to stop any work that you consider to be imminently dangerous to yourself or others. You must follow all health and safety policies, routines and guidelines, including our Work Environment, Alcohol and Drug, and Road Safety policies, and never take shortcuts that compromise your own or others' safety.
All Employees are expected to report to work fit for duty, able to perform their work safely, and capable of exercising sound judgment at all times. Employees must never work while impaired by alcohol, illegal drugs, or other substances in a way that negatively affects safety, work performance, decision-making, or the work environment.
For Employees working in safety-sensitive roles or environments - including driving, terminals, and the operation of vehicles or machinery - strict zero tolerance regarding alcohol and illegal drugs applies while working or performing duties on behalf of Instabee.
Employees must never drive or operate vehicles, machinery, or equipment while impaired by alcohol, drugs, or medication and must always follow applicable traffic laws and safe driving practices.
5.4 Human and Labor Rights
We condemn all forms of human rights abuses, including slavery, child labor, and inhuman or degrading treatment. All Employees have the right to work voluntarily, to end the employment without excessive restrictions, and to exercise freedom of association and collective bargaining. We strictly prohibit forced or bonded labor and any working conditions that threaten life or health; it is your responsibility to refuse participation in such practices and to report any violations or concerns through our established reporting channels.
5.5 Environmental Responsibility
We are committed to minimizing the environmental impact of our operations and integrating sustainability into our decision-making and daily work. This includes conserving resources, reducing waste, and lowering our carbon footprint. We continuously work to improve our environmental performance by setting measurable targets and monitoring progress to preserve the environment for future generations. You are expected to integrate our Sustainability Strategy into your daily tasks, demonstrate responsible care for the environment, and proactively suggest ways to improve our performance and preserve the planet for future generations.
6. How to Speak Up
Speaking up is a shared responsibility and an important part of maintaining a safe, respectful, and ethical workplace. Raising concerns early helps us prevent issues from escalating and protects our people, business, customers, partners, and communities.
If something feels wrong, inappropriate, unsafe, or inconsistent with our Code of Conduct, our policies, our Values, or the law, you are encouraged to speak up. You do not need to be certain that misconduct has occurred before raising a concern. It is always better to raise it early so it can be reviewed appropriately.
We understand that speaking up can sometimes feel difficult. Reports made in good faith will always be taken seriously, handled as confidentially as possible, and reviewed fairly. Instabee does not tolerate retaliation against anyone who raises a concern or participates in an investigation in good faith.
How to raise a concern
There are several ways to speak up, and you should choose the option you feel most comfortable with:
Talk to your manager: We encourage open and honest conversations among colleagues, as concerns are often best resolved early and directly. If you are uncomfortable addressing the issue directly with the person involved, you can also raise it with your manager.
A trusted colleague: If the concern involves your manager, feels sensitive, or you need support or guidance, you can contact People & Culture, Legal, your Second Level Manager or a local safety representative.
Use the Whistleblowing Channel: For serious misconduct (e.g., human rights violations, safety hazards, or harassment) where you wish to remain anonymous, use our secure whistleblowing portal. The report shall be made, and will be handled, in accordance with the Whistleblowing Policy.
The Promise: Every report is taken seriously, treated confidentially, and investigated thoroughly. Reports made in good faith will never imply any negative consequences for the person reporting.
7. Violations of the Code of Conduct
We take violations of this Code of Conduct seriously, as they undermine our values, culture, and the trust placed in us by our stakeholders. When violations occur, we are committed to taking appropriate and fair disciplinary actions in accordance with the at the time applicable and shared procedure on disciplinary actions. The consequences for violations may vary depending on the nature and severity of the infraction, the Employee's disciplinary history, mitigating circumstances, any applicable laws or regulations, and more. Such consequences can include demotion, reprimands, suspension or termination of employment or engagement. We may also take legal action in cases of corruption, theft, fraud, or any other unlawful behavior.
8. Validity
This Code of Conduct has been adopted by the Board of Directors of Instabee Holding AB, and shall remain valid, binding, and effective until further notice.
All Employees are required to sign or otherwise acknowledge their understanding and agreement to abide by this Code of Conduct.
We will keep this Code of Conduct under regular review and continuously update it when deemed necessary. The CEO is authorized to make non-material amendments or administrative updates to this Code of Conduct as necessary. The latest version of this Code of Conduct will always be available in the Hub.
This Code of Conduct was approved by Instabee's Board of Directors and CEO on 2026-06-03