Code of Conduct
At Kahoot!, we are committed to running a healthy business grounded in ethical behaviour in every aspect of the group companies’ processes and professional relationships. This Code of Conduct (“Code“) is Kahoot!’s main ethical framework and describes expectations, commitments and requirements for how we should act. Kahoot!’s Code reflects our values, forms the foundation of our culture and is at the top level of Kahoot!’s governing hierarchy.
The Code applies to Kahoot!, its subsidiaries and joint ventures where Kahoot! AS holds decisive control through majority interest or otherwise (referred to as “Kahoot!”).
All individuals working for or representing Kahoot! in any capacity, regardless of contractual arrangements, are obligated to adhere to this Code. This encompasses board members, directors, employees and contracted personnel.
This Code sets a baseline that applies to all entities within the Kahoot! Group. Group operating subsidiaries are responsible for adapting policies and procedures to reflect local conditions where appropriate, and for implementation, oversight and monitoring within their specific businesses.
We expect everyone at Kahoot! to familiarise themselves with the Code, along with other governing documents and policies. Everyone involved in Kahoot!’s operations shall adhere to applicable laws and regulations relevant for our business and in the countries in which we operate. It is the responsibility of each person working for or representing Kahoot! to comply with this Code.
To ensure that the Code is implemented, Kahoot! conducts training of its employees on these matters, including during onboarding of new staff.
1 Introduction
1.1 Our mission and values
Our mission is to make learning awesome. This mission sets the direction for our choices and priorities. It inspires innovation and drives change. Everything we do must be in line with our mission.
Our values describe how we will deliver on our mission. They describe what we expect from each other, and from our contractors and business partners. The values reflect the way we build and develop our product’s features. They impact design in the visual identity of the product, our brand, and our team mentality. Our values act as reminders of fundamental characteristics which shape and guide our everyday actions to drive excellence in business operations and priorities.
The values of Kahoot! are:
| We are playful | Play is the first language we learn. It is how we discover the world and understand our place in it. When we make learning fun, we make it engaging for everyone. |
| We are curious | Curiosity is part of human nature and lies at the heart of all great endeavors. It is what turns learners into amazing leaders — and keeps those leaders learning. |
| We are inclusive | We are team players at Kahoot! and believe that no learner or employee should ever be left out. Kahoot! strives to ensure that everyone has the chance to succeed. |
2. The Kahoot! Way
2.1 Human Rights
Kahoot! respects human rights and is committed to maintaining ethical working conditions and business operations.
As part of this commitment, Kahoot! shall never engage in or contribute to any form of human or labor rights violations. We oppose all forms of slavery, forced labor, human trafficking, child labor, and violations of human rights in Kahoot!’s own operations or in connection with our business partners and supply chain.
When conducting our business operations, we are committed to upholding internationally-recognized human and labor rights, as outlined in key conventions and guidelines such as the United Nations Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights of 1966, the International Covenant on Civil and Political Rights of 1966, the core conventions of the International Labour Organization (ILO) regarding fundamental principles and rights at work, the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. In line with the Norwegian Transparency Act, we also carry out human rights due diligence assessments of our own operations, supply chain and business partners, and publish a public account of these assessments annually.
2.2 United Nations Sustainable Development Goals
Kahoot! is committed to sustainable, economic, social, and environmental development in our industry. We believe engaging learning is the key to development and empowerment at school, at home and at work. Kahoot!’s focus as a company is to operate in a sustainable way, in alignment with the United Nations Sustainable Development Goals (“SDG”) and the impact on learning we aim to make around the world.
Quality education: SDG 4 advances inclusive and equitable quality education and the promotion of lifelong learning opportunities for all by 2030. This goal is key to Kahoot!’s mission and operations. We contribute to literacy, numeracy, overcoming language barriers, making learning more inclusive and ensuring that learners acquire knowledge to promote sustainable development. Kahoot! supports quality education through our main platform, as well as its portfolio companies including DragonBox and Poio, award-winning math and reading apps, as well as the Drops apps which make language learning natural with immersive visuals and play. Together, we are on a mission to empower children of any background to learn through play and to build the world’s largest sustainable learning community.
2.3 Accessibility and Inclusion
Making learning more inclusive: We at Kahoot! believe that learning should include everyone, and we work to eliminate barriers to education. Kahoot! is an easy-to-use tool for everyone, putting students front and center, with equal chances of becoming classroom heroes. In response to COVID-19 and the global shift to distance learning, Kahoot! offered free access to premium features for all educators impacted by the pandemic, working to ensure that educators could continue to connect with and engage their students, whether in the classroom or at home. Inclusion is one of our core values and it informs how we operate as an organization. To further promote accessibility, we aim to be compliant with the Web Content Accessibility Guidelines (WCAG) version 2.0, to an AA conformance level. Please see Kahoot!’s Inclusion and Accessibility policy for more information.
Kahoot! aims to foster partnerships with organizations and institutions that both share our vision for positive social impact and have important content to offer the youth audience – our future game-changers. Our partnerships with organizations including the United Nations, UNICEF, Common Sense Education, Amnesty International, Rebel Girls, the National Institute of Health, the Marine Stewardship Council and many more are examples of our strong shared commitment to this vision. In close collaboration with these partners on the important topics of human rights, children’s rights, bullying prevention, cyberbullying, online safety, diversity and inclusion, inspiring women in history, the dangers of drugs & alcohol use and sustainability, we’ve been able to engage millions of learners and their educators around the world. Our partnerships with organizations such as Tiimo and the Ad Council reflect our commitment to this belief and enable Kahoot! to offer meaningful and inspiring learning content that opens minds and breaks stereotypes associated with gender, ethnicity, religion, and neurodiversity (e.g., advocating for the acceptance and inclusion of individuals with diverse neurological conditions such as autism spectrum disorder, attention-deficit/hyperactivity disorder (ADHD), dyslexia, and others).
2.4 Open, honest and unambiguous communication
In order to make the right decisions and create the best learning and working environment, internal communication at Kahoot! must be open, honest and unambiguous. The same applies to our external communication to build public trust in Kahoot!.
Both internal and external communication shall be timely and correct. Employees should give and receive feedback with the intention of making improvements, and we speak up if something is not good.
Kahoot! values the creativity and free expression of our users and contributors. We are therefore committed to protecting our users and providing a safe and engaging learning environment for all. We take steps to protect our users from harmful and illegal content and reserve the right to remove content that breaches our policies and values. Content on the Kahoot! platform shall comply with our Acceptable Use Policy and Editorial Guidelines, and we take measures to ensure the safety of our platform. These practices are detailed in our Safety Guide, where we also describe the tools we make available for users to increase safety in their own games, such as user anonymization through our nickname generator.
Kahoot! does not serve targeted ads on our platform, and we do not sell or share user information with third parties for marketing purposes. We also do not allow marketing activities by others on our platform unless expressly authorized by Kahoot! and consistent with applicable law.
2.5 Privacy and security
All Kahoot! employees have a duty of confidentiality in relation to users, prospective users, other employees, our company and its activities. Thus, important stakeholders shall be able to rely on us to protect information and maintain confidentiality. This duty applies both externally and internally, regardless of the circumstances under which we have received the information. Employees are bound by the duty of confidentiality after the end of their employment relationship with Kahoot!.
Kahoot! is dedicated to protecting the personal data that we process. To honor our commitment to privacy, all employees shall be aware of and strictly comply with Kahoot!’s internal Privacy Policy which sets out how personal data is collected, processed and used by Kahoot!. We have also implemented a comprehensive information security program to keep our data safe.
2.6 Health, safety and environment (HSE) and work environment
Kahoot! is committed to ensuring the safety of our employees and complying with all applicable health and safety laws and regulations. Kahoot! shall have a positive working environment that promotes lifelong learning, physical, mental and social well-being. Our culture shall be open, safe and supportive. No personnel at Kahoot! shall work in hazardous situations. We shall also work to maintain and continuously improve our health, safety and environmental practices to prevent occupational accidents and injuries. Everyone at Kahoot! should familiarize themselves with internal safety procedures and participate in HSE training where offered.
Kahoot! is dedicated to fostering a safe and responsible corporate culture that promotes inclusivity, positivity and a sense of community. Our organization is built upon the principles of dedication, respect and humility towards our work and colleagues. We strive for an environment with open communication, teamwork and high standards of professionalism. All tasks performed at Kahoot! are expected to meet high standards of quality and professionalism, while treating customers, coworkers, and the surrounding community with respect.
We expect our staff to show consideration for those around us in the workplace and ensure that no one is excluded. We shall speak respectfully to and about those around you in the workplace. If you observe or become aware of conditions that negatively affect the work environment or may threaten safety, you should report it to your closest manager or another designated person.
2.7 Anti-discrimination and harassment
Kahoot! has a zero-tolerance policy towards discrimination, harassment and intimidation of any nature. Everyone at Kahoot! must comply with applicable laws and regulations related to anti-discrimination and harassment.
Inclusivity is one of our core values, and we believe our team’s diversity is a driver of success. Our global team includes members of over 30 nationalities. Kahoot!’s full team of leaders, including Executive Management, consists of 24 individuals of 10 nationalities, with 42% being women. By growing our team to include the voices of a diverse range of professionals, we are able to build a more dynamic and creative company culture at Kahoot!. As we collaborate and contribute our unique points of view, social and cultural awareness, and language abilities, we drive greater innovation and global growth. Members of the K!rew are protected in a safe work environment by the Norwegian Working Environment Act and the Gender Equality and Discrimination Act. We value a good work-life balance, invest in our employees and welcome feedback from all in our mission to make learning awesome.
Employment at Kahoot! is based on individual merit and qualifications directly related to professional competence.
Kahoot! greatly values and promotes diversity. We do not accept any form of discrimination based on factors such as gender identity or expression, age, pregnancy status, ethnicity, religion, mental or physical disability, sexual orientation, employment status, or political conviction, nor does Kahoot! tolerate any form of harassment, including unwanted sexual attention. This applies to all of Kahoot!’s employees’ interactions with users, fellow employees, suppliers and others.
We treat people fairly and with respect, and we shall not express opinions, make jokes, or write messages that are offensive, derogatory or inappropriate. Be mindful of how your statements and actions may be perceived and experienced by others.
Report if you observe or become aware of someone being discriminated or harassed. If you do not wish to intervene directly, you can report to your closest manager or another designated person.
2.8 Conflicts of interest
A conflict of interest occurs when personal interests, participation in external activities or business interests can affect decisions that employees make on behalf of Kahoot!. These could for example be due to close personal relationships, financial interests, positions of trust or similar roles or ownership interests. A conflict of interest can also arise between requirements and expectations from authorities, customer interests, Kahoot!’s business goals and expectations from its owners.
Kahoot! shall seek to avoid conflicts of interest, but if they arise, we shall be open about them and solve in an appropriate manner.
2.9 Inside information
Kahoot!’s employees may get access to information about Kahoot! that is not publicly-available. Such information may be considered inside information, which shall be processed in a correct and legal manner. Employees shall not misuse inside information and shall follow Kahoot!’s instructions for handling such information.
2.10 Anti-bribery and corrucption
Kahoot! has zero tolerance for all forms of corruption, including fraud and bribery, and shall act in an open, transparent and accountable manner. Corruption implies that you give or receive an offer of undue benefit related to your job, position of trust or the execution of a commercial decision. A benefit could be money, discounts, coverage of costs, trips or participation in events. Employees shall never accept or offer financial or other undue benefits. Employees must report offers of gifts or other benefits from customers or other parties in accordance with established rules and procedures.
For more information, please see Kahoot!’s anti-corruption policy.
2.11 Anti-money laundering
Kahoot! has zero tolerance for money laundering and shall never directly or indirectly contribute to money laundering or terrorist financing, and follow all applicable legislation in this area. To avoid money laundering and terrorist financing, it is crucial that we know our business partners, suppliers, customers, etc., and whether any funds originate from illegitimate sources. All Kahoot!’s business partners, suppliers and customers shall be lawfull-established and conduct law-abiding business.
Kahoot! expects everyone to be attentive to any unusual payments, invoicing or banking arrangements. or atypical tax status of business partners, suppliers or customers.
We encourage you to be vigilant if a business partner, supplier or customer suggests an unusual payment method, invoicing process or abnormal/complex transaction structure. We do not accept funds from third parties where the source of the funds is unknown or does not align with their business activities. Payments to and from any designated tax haven must be approved by Legal before processing.
2.12 Tax
Kahoot! has zero tolerance for tax fraud and violation of tax laws and regulations. Kahoot! shall comply with all applicable tax laws and regulations and refrain from engaging in or facilitating any illegal tax activities, such as tax evasion.
2.13 Sanctions and Trade Control
Kahoot! shall adhere to Norwegian, EU, UK, and US sanctions and trade controls laws and regulations, as well as applicable laws and regulations in all other countries in which Kahoot! operates.
We shall assess whether those we conduct business with are subject to sanctions, and whether any services or technology is subject to export control regulations.
Requirements and rules related to sanctions and export control are further outlined in Kahoot!’s Sanctions Policy.
2.14 Environment
We strive to keep our environmental footprint minimal by investing in offices with natural lighting and recycling, while using more clean energy. We focus on educating our employees on sustainability and encouraging them to promote this effort in their work.
2.15 Fair competition
Kahoot! is mindful of its obligations under competition law, which apply to all business arrangements, whether written, oral or any other form. Kahoot! shall refrain from engaging in activities or entering into agreements that could limit competition, such as price-fixing arrangements, bid-rigging, market allocation schemes and abuse of a dominant position. Additionally, sharing any commercially-sensitive information without authtorization from Legal shall be strictly prohibited.
2.16 Substance abuse
Kahoot! shall offer a drug free workplace. No one shall be under the influence of illicit drugs, alcohol, or other intoxicating substances while working for Kahoot!. In social settings, and at events where it is appropriate and acceptable, alcohol may be served, though consumption in moderation is expected.
Legal stimulants, including prescribed medicines and use of tobacco where permitted, are not regarded as intoxicating substances in this context.
2.17 Use of Kahoot!’s assets
Employees have access to Kahoot!’s assets to carry out their work. This includes physical properties, equipment, corporate cards, software, systems and the like that are owned by the company. Such assets shall be stored in a responsible manner and used in accordance with applicable guidelines. Kahoot! does not accept any form of misuse of its assets or funds.
2.18 Violation of this Code
Any staff person who violates this Code or applicable laws and regulations may face disciplinary action, which can include termination of employment and the involvement of relevant authorities. Everyone working at Kahoot! shall be subject to the same consequences, regardless of their position or seniority. Leaders who passively tolerate violations by their team members may also face disciplinary action.
Kahoot! aspires to having a culture based on openness with a low threshold for reporting illegal or reprehensible conduct. This includes violations of law, ethical guidelines or norms. Employees are entitled to submit anonymous notifications of such violations which shall be treated in a confidential manner. Please see our Whistleblowing Policy for more information.