Business Ethics

Overview & Highlights
Compliant Business
How we govern
Strategic Memberships
Our stakeholder engagement
Value chains

Overview & Highlights

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 2021 we have continued with the implementation of workstreams to continuously improve our compliance.

Universal rules for everyone

By the end of 2018, 89% of our staff had completed e-learning courses in our Code of Conduct, Data Privacy & Asset Protection, Competition and Anti-bribery & corruption and fraud. We continue to ensure all staff know and follow our values for conducting business. In 2020, 98% of employees had annually signed the Code of Conduct and 96% of all new employees had signed the Code.

No confirmed cases of corruption

In 2020, 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.

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 2021 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 new 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.


On the 25 May 2018, the General Data Protection Regulation (GDPR) came into force across the European Union.  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. In 2020 and moving forward we will continue to define our strategy 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 Corporate Responsibility.


Local Business

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


ESL is a partner and sponsor of AnyKey, which is an organization that advocates diversity, inclusion and equity in gaming and live streaming. Its aim is to amplify, connect and empower underrepresented players and their allies through research and strategic initiatives.


DreamHack is a supporting member of Dataspelsbraschen – the Swedish Games Industry – which is an organization that compiles and communicates the computer and video game industry’s shared responsibilities. Dataspelsbraschen focuses on the industry as a whole and its advocacy in the media.


ESL is one of the founding members of the German esports federation – Esport Bund Deutschland (ESBD). ESBD is the point of contact for esports, and the interests of esports athletes and organizations.


Both DreamHack and ESL are members of the Esports Integrity Commission (ESIC) – a non-profit association established by esport stakeholders with the purpose of working with integrity issues, particularly the prevention, investigation and prosecution of all forms of cheating and match manipulation. ESIC acts as a neutral third party to help mediate and monitor situations in which integrity can be questioned.

Fair Play Alliance

Kongregate is a member of the Fair Play Alliance, which is a global coalition of gaming professionals and companies within the gaming industry. The organization provides a forum for gaming professionals and companies to work together to promote best practice, healthy communities and player interactions in online gaming. Their vision is to be part of creating a world where games are free of harassment, discrimination and abuse, and where players can express
themselves through play without fear.


Both ESL and InnoGames are members 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.


MTG’s ESL and DreamHack are both members of the Esports Integrity Coalition (ESIC), a non-profit association established in 2015 by esports stakeholders to deal with integrity issues, particularly match manipulation and betting fraud.

USK – Unterhaltungssoftware Selbstkontrolle

InnoGames and ESL are members 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.


ESL co-founded the World Esports Association (WESA) and has a position on its Executive Board. WESA aims to further professionalize esports by developing and implementing elements of player representation, standardized regulations and revenue shares for teams.

Our stakeholder engagement

MTG’s stakeholders are selected through stakeholder mapping. We identify them through looking at MTG’s business and corporate responsibility strategy and evaluate their impact. The stakeholders include all the people and organizations that may be affected by our business and those that affect us as a company. Their input guides us in the right direction and they are vital to our success.

We engage with stakeholders as part of our everyday business and involve them in our corporate responsibility activities as well as goal-setting processes as part of our materiality assessment. This engagement aims to achieve shared goals of common interest.

During the split of MTG, Nordic Entertainment Group and MTG carried out new materiality assessments to set our priorities moving forward and maximize our positive impact across each of our markets. The outcome of the dialogues and materiality assessment resulted in our current strategy for Corporate Responsibility at MTG.


Including esports participants and enthusiasts, mobile game players and developers,
sponsors and advertisers

Regular engagement methods: Conversations, meetings, post-event customer satisfaction surveys, blogs, websites, social media, newsletters and customer support channels.

Key issues: Gender equality, inclusion, diversity, safety and security, environmental footprint, doping corruption and other forms of cheating.


Our investors

Regular engagement methods: Annual General Meeting, Annual Report, Corporate Responsibility Report, quarterly reports, press releases, Environmental Social Governance (ESG) roadshows and conferences, Capital Markets Day.

Key issues: The protection of children and minors, event safety, environment, governance, data protection and privacy, gender equality, corruption and cheating.

The Board

MTG’s Board of Directors.

Regular engagement methods: Board of Directors meetings, feedback interviews and meetings upon request.

Key issues: Our Corporate Responsibility strategy – particularly gender equality and diversity, event security and safety, governance framework and strategy management.


Our team members.

Regular engagement methods: Governance framework (reading and signing of our Code of Conduct and policies), local surveys, personal development reviews, training, workshops, daily dialogues, statistic engagement tools, on-boarding and off-boarding processes.

Key issues: Gender equality and inclusion, environment, employee health and well-being, and the protection of children and minors.

Suppliers & Partners

The companies whose products and services we buy and partners that we collaborate with.

Regular engagement methods: regular meetings and calls including raising awareness of corporate responsibility issues – e.g. gender equality and inclusion, environmental, data protection and privacy.

Key issues: Discussions on the implementation of corporate responsibility issues and partner demands.


The non-governmental organizations with which we work.

Regular engagement methods: Continuous dialogue (locally and centrally), supporting
research, and participation in forums and workshops.

Key issues: The protection of children and minors, gender equality, diversity and inclusion.

Trade associations & Industry

Our peers and colleagues.

Regular engagement methods: meetings and calls, association events, workshops and conferences, discussions with stakeholders, sharing best practices with industry peers and colleagues, long-term projects and joining advocacy efforts.

Key issues: regulation of the gaming and esport industry, protection of children and minors, gender equality, and diversity and inclusion, employee health and well-being and data protection and privacy

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.

To illustrate and explain the development of our transformation we have divided our business into two verticles: Gaming (InnoGames, Kongregate, Hutch, Ninja Kiwi and PlaySimple) and Esports (ESL Gaming with the brands DreamHack and ESL, and DreamHack Sports Games).

The value chain of gaming

Our gaming companies InnoGames (Germany), Kongregate (US), 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

Kongregate regularly works with large known IP owners, such as entertainment and broadcasting companies, which license the rights to develop and publish games based on their IPs. Kongregate’s title ‘TMNT: Mutant Madness’ is an example of such a title.

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. Kongregate also operates as a third-party publisher, which means it distributes and markets for other external game developers.

Additionally, Kongregate operates its own publishing platform, which is a large community of indie game developers and players.


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, Kongregate, 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.

The value chain of esports

Our esports value chain centers around our esports brands housed within ESL Gaming: DreamHack (Head office in Stockholm, Sweden) and ESL (Head office in Cologne, Germany). They are two of the world’s largest independent esports tournament organizers. They organize esports tournaments and gaming festivals around the world, mainly in Europe and North America, that attract a spectrum of esports audiences and players – from enthusiasts to professional (esport) athletes. Additionally, we operate DreamHack Sports Games (Head office Copenhagen, Denmark), which partners with sports leagues to develop and operate esports leagues.

Distribution (online and offline)

Our esport content is distributed through online and offline channels. For online distribution, esport enthusiasts can consume our events and BYOD, LAN festival content using digital third-party distribution platforms. As our esport companies own the distribution rights to the original esport production, the content rights are sublicensed to networks and digital services in multiple languages. Enthusiasts can experience the action live at a venue after purchasing event tickets.

Brand partners & advertisers

At esport events (online and offline) and festivals, we sell sponsoring opportunities and advertising space to brand partners and advertisers. There are a variety of purchasing opportunities to promote products at different stages of the value chain (such as commercial breaks, social media marketing and venue activations). We provide both endemic and non-endemic brands with effective exposure channels toward the esports audience.

Other stakeholders

ESL Gaming works closely with all stakeholders throughout the value chain. This includes collaborating with game publishers on a license basis to ensure the effective management of their games. Furthermore, we continuously interact with esport organizations, athletes and teams to ensure they are able to compete at their best level at our tournaments.