Governance & Business ethics

Compliant Business
How we govern
Strategic Memberships
Our stakeholder engagement
Value chain


Ethical business culture is a key aspect of our commitment to making a positive impact. Our Code of Conduct and associated policies clearly set out the values and standards we expect from each other. We also take the extra step of enhancing the understanding and knowledge of our employees by training them on core policies such as the Code of Conduct.

We have appropriate mechanisms to address any instance when we fall short, which strengthens our governance and encourages a culture of transparency and accountability. We respect the rights of every individual to data privacy, and throughout 2022 we have continued with the implementation of workstreams to continuously improve our compliance.

Universal rules for everyone

We continue to ensure all staff know and follow our values for conducting business. In 2022, 99% of employees had signed the Code of Conduct and 98% of all new employees had signed the Code.

No confirmed cases of corruption

In 2022, we had zero confirmed cases of corruption and no incidents that led to employee dismissal or disciplinary action.


Compliant Business

At MTG we promote a culture of openness, responsibility and accountability. We want to conduct business in full compliance with laws, regulations, international initiatives and standards.

We have not had any cases of non-compliance with law or regulations nor no fines were paid during 2022.

Code of Conduct

Our Code of Conduct is built on our values; striving to inspire and ignite, exploring opportunities, enhancing lives and shaping the future. More importantly, the code is a guide for all our employees on how we do (and don’t do) business. It helps us navigate the ethical and legal situations we face daily.

Our code describes our responsibilities towards customers, business partners, shareholders and each other. It also sets out our position on topics such as fair working conditions, asset protection, anti-corruption practices, conflicts of interest, competition, data privacy and much more.

As a responsible global business, we are committed to international initiatives and standards such as:

We review our policy framework annually and if significant changes are made we need approval from the Board.

Whistleblower process

As we promote a culture of openness, responsibility and accountability, we want everyone to feel comfortable about raising concerns, including possible violations of our Code of Conduct, policies, applicable laws and regulations. It is important for all our employees to know that their concerns will be taken seriously and investigated properly without fear of retaliation and that their confidentiality will be respected. Therefore, we have established a Whistleblower process and encouraged our employees to raise their concerns directly.

Should an employee not feel comfortable raising concern with their line manager or manager’s manager, they can contact our Whistleblower channel.

Anti-bribery and corruption

At MTG we take anti-bribery and corruption seriously, which is why we have the Anti-Bribery and Corruption Policy. During 2022 we had no confirmed incidents of corruption and no incidents that lead to employee dismissal or disciplinary action. No contracts with business partners had to be terminated or not renewed due to violations related to corruption, and no legal cases were brought against us or our employees.

Supplier Code of Conduct

We also want to develop and maintain strong business relationships with suppliers who are committed to ethical standards equivalent to our own. Our Supplier Code of Conduct sets out the standards with which all companies providing products or services to MTG are expected to comply. It is important to note that failure to comply with the standards and provisions in the Supplier Code may result in MTG reviewing and potentially ending a co-operation with a supplier.

Data protection

A core central team consisting of the Group Head of Data Protection works closely with appointed local Data Protection Managers and Human Resources to make sure data protection matters are handled correctly within all companies of MTG Group.

We have continued to follow our roadmap which includes activities such as updating privacy notices and data processing agreements, reviewing retention periods, handling data subject requests, establishing data breach procedures, as well as producing policies/guidelines and different types of training and awareness activities.

We have established a clear framework that manages data incidents and breaches which will ensure that we report possible personal data breaches within 72 hours. All personal data breaches are documented centrally. Complying and working with GDPR has become part of our daily work as we have moved into a governance phase and processes are starting to fall into place. We are continuously improving our workstreams and processes to ensure to include GDPR into daily work, to keep GDPR relevant and prioritized.

How we govern

Modern Times Group MTG AB is a Swedish public limited liability company. The company’s governance is based on the Articles of Association, the Swedish Companies Act, the listing rules of Nasdaq OMX Stockholm, the Swedish Code of Corporate Governance, and other relevant Swedish and international laws and regulations.


Our valuable investors who can exercise their right to decide on issues affecting the company and its operations at the AGM.


The AGM is the highest decision-making body, at which the MTG shareholders vote on various resolutions, sign off the accounts, appoint MTG’s Board of Directors (the Board) and its Chairman, appoint MTG’s Auditors and may also make other proposals. Shareholders should submit proposals in writing at least seven weeks before the AGM.

Nomination Committee

The Nomination Committee evaluates the Board of Director’s work and composition, submits proposals to the AGM regarding the election of the Board, the Chairman of the Board and the Auditors, prepares proposals regarding fees paid out to the Board and the Auditors as well as proposals for the Chairman of the AGM. Additionally, the Committee prepares proposals for the administration and order of appointment of the Nomination Committee for the AGM.

External Auditors

The External Auditors examine the Annual Report and financial accounting, and the Board’s and CEO’s administration. They report their findings to the shareholders in an Auditor’s Report which is presented to the AGM. They also address detailed findings at each of the Audit Committee’s meetings and to the full Board as necessary.

Board of Directors

The Board comprises of seven non-executive directors, all of which are independent of the Company and its management and are independent of the major shareholders. The Board has the overall responsibility for MTG’s organisation and administration and governs MTG’s Corporate Responsibility. The Remuneration Committee appointed by the Board is responsible for issues related to salaries, pension plans, bonus and remuneration programs, the structure and levels of remuneration at MTG as well as providing advice on long-term incentive schemes and the Guidelines for remuneration applicable to the Chief Executive Officer and Executive Management.

Audit Committee

The Audit Committee appointed by the Board monitors MTG’s financial reporting, efficiency relating to internal control, internal audit and risk management, impartiality and independence of the auditor, assists the Nomination Committee in preparing for auditors’ election at the AGM and when applicable, monitors and secures the quality and fairness of transactions with related parties.

Executive Management

The Executive Management oversees the day-to-day implementation of the business strategy and Sustainability together with the Head of Corporate Sustainability.


Local Business

It is the local CEO’s responsibility to implement MTG’s Corporate Sustainability strategy which forms an integral part of our various businesses. We also communicate with team members across the organization to drive and execute Corporate Sustainability initiatives on a group level.

Strategic Memberships & Associations

As a global digital entertainer, MTG maintains memberships in industry associations, national and international organizations and additional bodies. Of these memberships, the following are considered strategic and/or significant to our business:


InnoGames is a member of the German Games Industry Association (game), which has a mission to make Germany the best games location. game is an expert partner for media, social and political institutions and addresses topics regarding market development, games culture and media literacy.

Leaders for climate action

InnoGames is a member of Leaders for climate action, which aims to combat climate change through various actions and initiatives, together with its over 900 members from a variety of German digital enterprises. Their vision is a global economy powered by 100 percent renewable energy by 2050.

USK – Unterhaltungssoftware Selbstkontrolle

InnoGames is a member of the German Entertainment Software Self Regulation Body (USK), which offers a wide range of services for developers, publishers and content providers, such as information on the classification of games, apps, online content, and trade fairs and events. The USK ensures that games can be tested both technically and in terms of their content for a wide range of game platforms. It also oversees Classification Committees, classification deadlines and regulations, and provides ongoing training for everyone involved in classification procedures.

Diversity works NZ

Ninja Kiwi is a member of the organization Diversity Works NZ, a national body for workplace diversity and inclusion. The organization provides members with tools and knowledge on what diversity is, how to increase diversity within organizations as well as assessment tools for identifying areas for improvement.

New Zealand Game Developers Association (NZGDA)

Ninja Kiwi is a member of the organization NZGDA, a non-profit organization aiming to champion, support and grow video game development in New Zealand though collaboration between different actors within the industry in New Zealand.

Our stakeholder engagement

Stakeholders are identified based on their engagement and influence on our corporate sustainability initiatives. This engagement guides us and provides input for our sustainability strategy and continued focus.

How often we communicate with stakeholders depends on the group and need as well as any events during the year that may have impacted them. Engagement with the Board is always scheduled one year in advance. We also regularly engage with employees through internal channels on both group and local levels, while engagement with suppliers is needed.


Value chains

As a global digital entertainer, we offer a wide range of products and services for multiple markets across a broad range of distribution channels. Even though we are many brands, we are one organization. That means we follow the same processes and work towards the same goal: to create value for our customers, partners, employees and shareholders, as well as for society.

The value chain of gaming

Our gaming companies InnoGames (Germany),Hutch (UK), Ninja Kiwi (NZ) and PlaySimple (IN) develop free-to-play mobile and browser games. They work with all aspects of the development and launch of a game – from idea generation and IP development, to coding, artwork and marketing.

IP Licensing

All InnoGames’ IPs are fully owned by the company.

Hutch has the license to develop and market mobile games under the F1® IP license, which is the foundation for the F1® Manager title.

Ninja Kiwi develops and self publishes games for mobile, console and PC. Their own developed and published game title ‘Bloons’ functions like a platform, with a number of titles existing within the Bloons universe.

PlaySimple develops and self publishes casual games such as themed crossword puzzles, Solitaire and other word games.

Distribution & Publishing

Our free-to-play games are distributed through different publishing platforms. For our owned titles, we operate as a self-publisher using the common smartphone app stores (Google Play and App Store) as well as gaming platforms such as Steam and Epic Game store.


Game developers and publishers interact with their players on an ongoing basis and have a broad range of tools to monetize their users, primarily through in-app purchases and advertisements. As InnoGames, Hutch, Ninja Kiwi and PlaySimple focus on free-to-play games, the companies generate the vast majority of their revenue through in-app purchases from a fraction of the total userbase that wishes to progress faster or unlock additional in-game features.