Code of Conduct for Renegade UxS ApS

Introduction

At Renegade UxS, we are committed to conducting our business with integrity, respect for human rights, professionalism and responsibility. We develop and deliver technologies for demanding defence and security environments, and we recognise that such technologies may have significant operational, legal, ethical and societal implications.

This Code of Conduct sets out the standards we expect from all employees, managers, board members, consultants, partners, suppliers and other business associates. It applies across our activities, including research, development, production, testing, sales, deployment support, training and after-sales activities.

Renegade UxS is committed to complying with applicable national and international laws and to conducting business in accordance with internationally recognised standards for responsible business conduct, human rights, labour rights and responsible use of technology.

This Code of Conduct explicitly takes into account:

• NATO’s Principles of Responsible Use of AI in Defence, including lawfulness, responsibility and accountability, explainability and traceability, reliability, governability and bias mitigation.
• The UN Guiding Principles on Business and Human Rights, implementing the United Nations “Protect, Respect and Remedy” framework.
• The OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, including expectations on risk-based due diligence and responsible conduct concerning human rights, labour rights, environment, anti-corruption, disclosure, science, technology and innovation.

Purpose

The purpose of this Code of Conduct is to ensure that all business decisions, technical development, partnerships and operational activities support Renegade UxS’ commitment to lawful, ethical and responsible conduct.

The Code provides guidance for decision-making, risk management and accountability, particularly where our products, software, data, artificial intelligence, autonomy or system integrations may be used in defence or security contexts.

1. Compliance with Law, Ethics and International Standards

1.1 We comply with applicable national and international laws, including laws and regulations concerning defence products, export controls, sanctions, anti-corruption, data protection, labour rights, human rights and environmental protection.

1.2 We support and seek to comply with the International Labour Organization’s core conventions, including the prohibition of child labour and forced labour, equality and non-discrimination, freedom of association and the right to collective bargaining.

1.3 We conduct our business with high ethical standards and expect all employees, managers, partners and suppliers to act with integrity, professionalism and accountability.

1.4 We do not knowingly contribute to unlawful, irresponsible or unethical use of our products, services, software or technical support.

2. Responsible Development and Use of AI in Defence

2.1 Renegade UxS recognises that artificial intelligence, autonomy and automated decision-support technologies used in defence contexts must be developed and used responsibly.

2.2 We align our approach with NATO’s Principles of Responsible Use of AI in Defence. This means that AI-related development and use shall be:

Lawful: Designed, developed, tested and used in accordance with applicable national and international law, including international humanitarian law and human rights law.

Responsible and accountable: Subject to clear governance, defined roles, documentation and accountability throughout the system lifecycle.

Explainable and traceable: Developed with appropriate documentation, test records, auditability and traceability of relevant data, design choices, model behaviour and system limitations.

Reliable: Tested, validated and maintained to ensure appropriate performance, robustness, cybersecurity and resilience under intended operating conditions.

Governable: Designed so that appropriate human judgment, command responsibility, supervision, intervention, deactivation or override can be maintained where required.

Bias-mitigated: Assessed for risks of inappropriate bias, unintended discrimination, unreliable data, unsafe assumptions or disproportionate effects.

2.3 We design, develop and document AI-enabled functions with the objective of supporting lawful and responsible use, including appropriate human judgment, supervision and accountability by the authorised end user where decisions involving the use of force are concerned.

2.4 We seek to ensure that AI-enabled functions are bounded by clearly defined operational purposes, intended use cases, technical limitations and user instructions.

2.5 We will not knowingly support uses of AI, autonomy or data-driven systems that are unlawful, indiscriminate, intentionally directed against civilians, or inconsistent with applicable international humanitarian law.

3. Autonomous and Lethal Systems

3.1 Renegade UxS recognises the heightened ethical, legal and operational risks associated with autonomous systems and systems that may be used in lethal force contexts.

3.2 We commit to responsible design, development, testing, sale and support of systems with autonomous or semi-autonomous functionality.

3.3 Where our products or technologies may be integrated into systems capable of lethal effects, we will apply enhanced due diligence, including consideration of:

• intended and reasonably foreseeable use;
• customers, end users and intermediaries;
• compliance with export control and sanctions requirements;
• risks to civilians and civilian infrastructure;
• risks of unlawful targeting, misuse or escalation;
• ability to maintain human command, control and accountability;
• technical reliability, cybersecurity and operational limitations;
• traceability of requirements, design decisions, testing and approvals.

3.4 We do not support the use of autonomous functionality in ways that would prevent lawful human command responsibility, accountability or compliance with applicable rules of engagement.

3.5 We provide users, customers and relevant partners with appropriate documentation, instructions, limitations, safety information and, where agreed, training to support lawful, responsible and intended use of our systems.

3.6 Renegade UxS does not command, control or direct the operational deployment of its systems by end users. Responsibility for operational decisions, target selection, rules of engagement, mission planning and use of force remains with the relevant authorised end user, command structure and competent authorities.

3.7 Renegade UxS does not accept responsibility for unlawful, unintended, unauthorised or improper use of its systems by end users, including use contrary to applicable law, contractual terms, user documentation, training, technical limitations or prescribed operating procedures.

3.8 Where Renegade UxS becomes aware of credible risks of unlawful misuse, we will assess the matter and may take appropriate action, which may include additional guidance, suspension of support, refusal of further deliveries, termination of business relationships or notification to competent authorities where required by law.

4. Human Rights and Responsible Business Conduct

4.1 Renegade UxS respects internationally recognised human rights and conducts its business with reference to the UN Guiding Principles on Business and Human Rights.

4.2 We seek to avoid causing or contributing to adverse human rights impacts through our own activities. Where potential adverse impacts may be directly linked to our products, services or business relationships, we apply risk-based due diligence and seek to prevent or mitigate such risks within our reasonable ability and sphere of influence.

4.3 We apply a risk-based approach to human rights and responsible business conduct due diligence, taking into account the severity and likelihood of potential adverse impacts.

4.4 We expect employees, managers, partners and suppliers to raise concerns if they become aware of actual or potential misuse, unlawful conduct, human rights risks or serious ethical concerns related to our business, technologies or supply chain.

4.5 Where we identify that we have caused or contributed to adverse impacts, we will seek to address them through appropriate action and, where relevant, remediation.

5. Operational Responsibility of End Users

5.1 Renegade UxS develops, manufactures and supports systems for use by authorised customers and end users. Renegade UxS may provide documentation, technical specifications, user instructions, limitations, safety information and training to support lawful, responsible and intended use.

5.2 Renegade UxS does not command, control, authorise or direct the operational use of its systems in the field. Responsibility for deployment, mission planning, target selection, rules of engagement, compliance with international humanitarian law and decisions involving the use of force remains with the authorised end user, its command structure and competent authorities.

5.3 Renegade UxS does not accept responsibility for unlawful, unauthorised, unintended, negligent or improper use of its systems by end users, including use contrary to applicable law, contractual terms, user documentation, training, technical limitations or prescribed operating procedures.

6. Working Conditions

6.1 We ensure that employees receive fair wages and reasonable working conditions in accordance with applicable laws and recognised labour standards.

6.2 We maintain a safe and healthy working environment and implement appropriate measures to prevent accidents, injuries and work-related illness.

6.3 We value competence, learning and continuous improvement. We encourage innovation, professional development and responsible technical excellence.

7. Non-Discrimination and Equality

7.1 We do not tolerate discrimination, harassment or abusive conduct based on gender, age, race, religion, sexual orientation, disability, nationality, political opinion or any other characteristic protected by law.

7.2 We work to create an inclusive, respectful and professional working environment.

8. Freedom of Association and Collective Bargaining

8.1 We respect employees’ right to form and join trade unions and to engage in collective bargaining without fear of retaliation or negative consequences.

9. Professionalism and Business Conduct

9.1 Employees, managers and business associates are expected to act professionally, ethically and in the best interests of Renegade UxS, while respecting applicable law and this Code.

9.2 We work in an open and respectful culture where we communicate clearly, act with integrity and show respect for colleagues, customers, suppliers and partners.

9.3 We promote innovation, but innovation must never override safety, legality, human rights, ethical responsibility or sound engineering judgment.

9.4 We do not tolerate bribery, corruption, fraud, conflicts of interest, facilitation payments or improper influence in any form.

10. Environmental Responsibility

10.1 We work to reduce our environmental footprint and promote responsible use of resources.

10.2 We encourage employees, partners and suppliers to support environmental protection, waste reduction and sustainable practices where practicable.

11. Suppliers, Partners and Third Parties

11.1 We expect suppliers, partners, consultants and other third parties to act in accordance with standards consistent with this Code.

11.2 We may conduct risk-based due diligence on suppliers, partners, customers, intermediaries and intended end users, particularly where products, software or services may be used in defence, security, autonomous or lethal-force contexts. Such due diligence is intended to support responsible business decisions and does not transfer responsibility for end users’ independent operational decisions to Renegade UxS.

11.3 We reserve the right to decline, suspend or terminate business relationships where there is a material risk of unlawful, unethical or irresponsible conduct.

12. Implementation, Governance and Monitoring

12.1 This Code of Conduct is approved, dated and owned at the highest management level of Renegade UxS ApS.

12.2 Executive Management is responsible for ensuring that this Code is implemented, communicated and reviewed.

12.3 This Code shall be communicated internally to all employees and managers. Relevant parts may also be communicated to suppliers, partners, customers and other stakeholders.

12.4 Employees and managers shall receive appropriate guidance or training where relevant to their role, especially in relation to responsible AI, autonomy, export controls, human rights, anti-corruption and reporting obligations.

12.5 We conduct regular monitoring and evaluation to ensure that the standards in this Code are understood and upheld.

12.6 We will review this Code at least annually and update it when necessary to reflect legal, technological, operational or ethical developments.

13. Reporting of Concerns

13.1 Employees, managers, partners and other stakeholders are encouraged to report concerns regarding violations of this Code, unlawful conduct, unethical behaviour, human rights risks, misuse of technology, or concerns relating to AI-enabled or autonomous systems.

13.2 Reports may be made to management or through any reporting channel designated by Renegade UxS.

13.3 Reports will be treated confidentially to the extent possible, and Renegade UxS does not tolerate retaliation against anyone who raises a concern in good faith.

13.4 Renegade UxS will assess reported concerns and take appropriate action where necessary.

Conclusion

At Renegade UxS, we combine innovation with responsibility. We are committed to developing and delivering technology in a manner that supports lawful defence needs while respecting human rights, responsible business conduct, ethical AI principles and accountability.

We recognise that responsibility is not a one-time statement, but an ongoing obligation that must be embedded in leadership, culture, design, development, supply chains, partnerships and operational decision-making.