Code of Conduct

 

Introduction

Integrity and compliance with laws and regulations are guiding principles for us. We ensure that these principles are adhered to and continuously develop them further. Our Code of Conduct covers compliance with applicable legal regulations by team neusta SE, its board members and employees, as well as the direct and indirect domestic and foreign companies of team neusta SE, their managing directors and employees. For us, lawful conduct and ethical behavior are a basic prerequisite for securing our long-term business success. They are also the fundamental basis for trust and trustworthiness.

Our responsibility for compliance

For us, business success is based on open, honest, and ethical conduct. As a group of companies, we have a great responsibility toward people and society, and we take this responsibility seriously. That is why everyone observes and complies with our rules at all times and in all places. Our board members, managing directors, and executives have a special and responsible role: they themselves serve as role models. They prevent rule-breaking behavior. They protect employees and act with integrity both internally and externally.

Our core values

Wir haben zentrale Werte erarbeitet und in unserem team code definiert:

• Creating value and acting economically
• Acting socially
• Seeing diversity, participation, and inclusion as opportunities
• Being reliable
• Enabling development

We want our values to be reflected in everything we do. They help us define what we do and how we do it. This Code of Conduct helps us identify and explain potential areas of risk and conflict and their significance for our company. The content is summarized in three basic sections:

→ Our responsibility as a member of society

→ Our responsibility as a business partner

→ Our responsibility as an employer

Scope of the Code of Conduct

This Code of Conduct is binding for all employees, managers, and board members of team neusta SE, as well as its direct and indirect domestic and foreign companies, their managing directors, and employees, and is observed and implemented throughout the group.

Applicable law forms the binding framework for our business activities. We are aware of the legal obligations relevant to us and comply with them. The principles we establish in this Code of Conduct are based on national laws and regulations, in particular the Supply Chain Due Diligence Act (LkSG), as well as international agreements such as the United Nations Universal Declaration of Human Rights, the Guidelines on Children's Rights and Business, the United Nations Guiding Principles on Business and Human Rights, the international labor standards of the International Labor Organization (ILO), and the United Nations Global Compact (UNGC). This Code of Conduct is binding for all employees, managers, and board members of team neusta SE, as well as its direct and indirect domestic and foreign companies, their managing directors, and employees, and is observed and implemented throughout the group.

The principles defined in this Code of Conduct are our minimum standards and serve as a framework for our managing directors and employees. They form the binding guideline for legally and compliant behavior. They are the basis for a sustainable and responsible corporate culture and apply both in our dealings with each other and with our customers, suppliers, and business partners.

Failure to comply with this Code of Conduct can cause significant damage, not only to our company, but also to our employees, customers, business partners, suppliers, and society. This Code of Conduct is therefore binding for all of us, regardless of whether we work as employees, managers, or executives in the company. We do not tolerate violations of this Code of Conduct. Anyone who violates this Code of Conduct must expect proportionate and appropriate consequences. Depending on the severity of the violation, these consequences range from labor law measures to civil law claims for damages to criminal sanctions. To prevent this from happening, it is the responsibility of all of us to familiarize ourselves with the contents of this Code of Conduct, to incorporate it into our own behavior, and to take it into account when making decisions.
 

Speak Out - Contact points

We are committed to a “speak out” culture. It is characterized by open, trusting dialogue at all levels. We encourage our employees, customers, business partners, suppliers, and all other third parties to openly express their views, stand up for their opinions, and report unacceptable behavior to us, especially if it conflicts with this Code of Conduct.

The first point of contact for our employees and managers with concerns, questions, or doubts regarding compliance issues is their respective manager. Our employees can contact them personally and directly with their concerns, questions, and doubts. In addition or alternatively, there is the option of using our team neusta whistleblower system. The team neusta whistleblower system is a channel through which employees, but also our customers, business partners, suppliers, and other external third parties can report problems confidentially. Reports may concern possible violations of this Code of Conduct or company guidelines, as well as applicable legal regulations. The anonymity of the whistleblower is always guaranteed. Our team neusta whistleblower system is managed by members of the compliance team. Use of the team neusta whistleblower system is voluntary. There are no disadvantages for employees who do not use the system.

In order to identify any misconduct at an early stage and take countermeasures, we depend on the openness of our employees, customers, business partners, suppliers, and all other third parties. You can and should always be able to confidentially address any indications of misconduct that constitutes a significant violation of the law, this Code of Conduct, or other internal rules. We protect those who express their concerns appropriately, in good faith and to the best of their knowledge and belief. Employees, customers, business partners, suppliers, and all other third parties who do so and thereby contribute to the investigation of possible violations will not suffer any disadvantages as a result of their actions.

We expressly point out that the Speak Out contact points, in particular our team neusta whistleblower system, must not be misused to deliberately submit false or defamatory reports. Such reports may result in civil and criminal consequences.

 

Ask questions

We encourage our employees to ask questions if anything is unclear to them. We are aware that this Code of Conduct cannot resolve every problematic situation that may arise.

If you have any questions about this Code of Conduct, please contact your managing director, the legal department of team neusta SE (Legal & Compliance), or send an email to: compliance@neusta.de

I. The (legal) framework: Our responsibility as a member of society

Compliance with laws is a fundamental principle of economically responsible conduct for us. We observe applicable laws and comply with them in the course of our business activities. In every business decision, we are obliged to observe the legal system within which we operate. Our employees must also be aware of their social responsibility, especially for the well-being of people and the environment, and ensure that our company contributes to sustainable development.

Specifically, our social (corporate) responsibility gives rise to the following principles:
 

1) Compliance with laws and regulations

We observe and comply with laws and regulations. We and our employees observe the applicable legal prohibitions and obligations at all times, even if this results in economic disadvantages or difficulties for companies or individuals. If national laws contain more restrictive regulations than these principles of conduct, the national laws take precedence.

2) Human rights

Every human being has human rights. We respect the dignity of every human being and treat everyone with dignity and respect.

The United Nations Universal Declaration of Human Rights and the European Convention for the Protection of Human Rights and Fundamental Freedoms set out the requirements and expectations of the international community with regard to respect for and observance of human rights. We respect the applicable regulations for the protection of human and children's rights as fundamental and universally valid guidelines. We reject any form and use of child, forced, and compulsory labor, as well as any form of modern slavery and human trafficking, and pursue a zero-tolerance policy toward human rights violations. This applies not only to cooperation within our company, but also throughout our entire supply chain and, of course, to the behavior of and toward our business partners.

Our employees can also contribute to the observance of human rights by respecting human rights as fundamental guidelines for their actions and by being vigilant against human rights violations in their environment. In the event that human rights violations threaten to occur or actually occur in the professional environment, our employees ensure that the violations are prevented or remedied.

3) Equal opportunities and equal treatment

Equal opportunities and equal treatment, as well as a culture of mutual trust and respect, are very important to us. They are key cornerstones for fair, open-minded, and unbiased interaction. We are committed to equal opportunities and respectful, cooperative collaboration, diversity, and tolerance.

We do not discriminate against anyone and do not tolerate discrimination on the basis of ethnic or national origin, social background, gender, age, marital status, disability, sexual orientation, skin color, political opinion, religion, ideology, or other characteristics protected by law. We embrace diversity and actively promote inclusion. We create an environment that fosters the individuality of each person in the interests of the company. Our goal is to create an inclusive working environment in which differences are welcomed and used positively to achieve the best possible results. The selection, hiring, and promotion of our employees is based on their qualifications and skills. Everyone has the same opportunities to develop and advance their careers with us.

Our employees also observe the principles of equal opportunity and equal treatment. If our employees observe violations of the principles of equal opportunity and equal treatment (e.g., through discrimination, harassment, and bullying), they point out the misconduct to the persons concerned or report the incident to their managers.

 

4) Environmental protection

We are responsible for the environmental compatibility and sustainability of our products and services. We are committed to offering them in a sustainable manner and are aware of our responsibility towards the environment. We use natural resources sparingly and protect the environment. Our goal is to minimize the impact of our business activities on the environment and nature. We pay attention to economy, reusability, and sustainability. We also expect this attitude from our business partners. To reduce the burden on the environment, we avoid or reduce energy and water consumption, emissions, and waste.

Our employees also take environmental protection into account in their work and use resources and energy appropriately and sparingly. Our employees ensure that their activities have as little negative impact on the environment as possible and that they comply with the relevant laws.

 

5) Donations, Sponsorships, and Charity

We see ourselves as an active member of society and are involved in various ways through donations and other forms of social engagement (sponsorship and charity).

We make donations, i.e., contributions on a voluntary basis without any consideration in return, as well as sponsorship payments, i.e., contributions based on a contractually agreed consideration, with the aim of positively shaping our image and public perception. To avoid conflicts of interest and ensure consistent behavior within the company, donations and sponsorship measures are only permitted within the framework of the respective legal system and in accordance with our current internal regulations.

We make monetary and in-kind donations in particular for the following areas and projects:

• Children and young people
• Learning and development
• Equal opportunities
• Sport
• Culture
• Peace and refugees
• Combating (right-wing) extremism
• Elderly people
• Sea rescue

Donations are only made to institutions that are recognized as charitable or authorized to accept donations under special regulations. We do not make donations or other contributions to political parties or party-affiliated foundations or institutions. Donations are always made on a voluntary basis and without expectation of anything in return. The purpose, the recipient of the donation, and the recipient's donation receipt are documented and verifiable. As part of our sponsorship activities, we ensure that our sponsorship services and the agreed consideration are always in reasonable proportion to each other. We do not use our sponsorship activities to gain unlawful business advantages.

 

6) Communnication and marketing

We live by values such as trust, reliability, honesty, credibility, and integrity, and we value clear and open communication with all our employees, customers, business partners, suppliers, investors, the media, and other stakeholders, because we do not want to deceive
or harm anyone. In order to maintain the trust of customers, business partners, suppliers, investors, and other stakeholders, we pay particular attention to clear communication in a fair and legal manner, especially in sales and marketing.


When communicating with each other and with our customers, business partners, and suppliers, our employees are responsible for following our internal communication guidelines. When our employees express themselves at public, professional, or cultural events or on the internet, they make it clear that these are their personal opinions. We respect the right to freedom of expression. Every employee should be aware that they may be perceived as part of and representative of team neusta, even in their private lives. Employees are required to uphold the company's image and reputation through their personal behavior and conduct in public, especially toward the media. Our employees do not make any public statements for or on behalf of the company, but refer any such inquiries to the corporate communications department. 

We are also aware of our responsibility for the reputation of our company when using social media. We respect the privacy of our colleagues, customers, business partners, and suppliers and do not disclose any confidential information. We do not disseminate offensive or insulting content. Our employees can find additional information about appropriate behavior on social networks in our Social Media Guidelines.

 

7) Political advocacy

Politics and legislation influence the framework conditions for economic activity and thus also our activities. Political involvement can therefore lead to a (potential) conflict of interest. We only participate in the political (decision-making) process in an appropriate and legally permissible manner and avoid any activities within the scope of political engagement and participation in the political (decision-making) process that could raise concerns about our integrity and independence. Unfair influence on politics and legislation is not permitted. 

We do not attempt to influence political decisions on behalf of the company, and we do not use our political engagement to gain advantages in an improper or unfair manner or to disadvantage our competitors.

We only influence the political (decision-making) process within the legally permissible framework in order to represent our legitimate interests. We conduct our political engagement and our participation in the political (decision-making) process openly and transparently.

 

II. Our responsibility as a business partner

We believe that integrity, transparency, and fairness are crucial for building credibility and trust in business dealings. We therefore attach particular importance to consistently implementing and clearly communicating the legal framework, internal guidelines applicable within the company, and corporate values. Specifically, our responsibility as business partners gives rise to the following principles:

1) Conflicts of interest

We respect the personal interests and private lives of our employees. We attach great importance to avoiding conflicts between the private interests of our employees and our corporate interests—or even the appearance of such conflicts. We therefore expect our employees to carefully separate their private and financial interests from the interests of the company, to make decisions exclusively in the best interests of the company and on the basis of objective criteria, and not to be influenced by personal interests or relationships. If an employee places their personal interests above those of the company, this can damage the company. We expressly acknowledge that in individual cases, the personal, and in particular the ethical, interests of our employees may (justifiably) conflict with the interests of the company. We take the legitimate interests of our employees into account and, in the event of a conflict of interest, endeavor to strike a fair balance between the conflicting interests of our employees and our corporate interests.

 

A conflict of interest may arise in particular from paid or unpaid (secondary) employment of our employees for a competitor, but also for a customer, supplier, and/or business partner. Any (secondary) activity for a competitor or a customer, supplier, or business partner requires prior written approval. If approval is granted, the secondary activity must not compromise our employees' loyalty to us. 

Our employees shall also exercise caution when they or their relatives engage in business activities that are closely related to the business activities of the company. Our employees shall ensure that their own business activities do not conflict with our legitimate interests.

We also consider board positions, management positions, and consulting positions in other companies to be secondary activities. Accepting a board position, management position, or consulting position with one of our competitors is prohibited, as this directly conflicts with our company interests. Accepting such a position with one of our customers, suppliers, or business partners requires our prior written approval. If approval is granted, the secondary activity must not compromise our employees' loyalty to us. Our employees are obliged to abstain from voting on decisions that directly or indirectly lead or could lead to an actual or potential conflict of interest with regard to our employees' loyalty to us or to preferential treatment for us.

 

2) Gifts, hospitality, and invitations

Gifts, hospitality, and invitations are common in business relationships. Offering and granting such gifts, as well as requesting and accepting them, is only permitted to a reasonable extent. Such benefits may be considered an improper advantage and raise concerns about our integrity and independence, as well as the appearance of improper conduct, and may violate laws, in particular anti-corruption laws.

Our employees are therefore not permitted to accept, request, offer, or grant any benefits in connection with their work activities, such as gifts, hospitality, and invitations, that exceed the scope of reasonable and customary business practice. We support our employees in assessing the appropriateness and customary nature of gifts, hospitality, and invitations, both when accepting and when granting them. Our employees are responsible for obtaining information from their supervisors or the relevant managing director. They seek advice before giving or accepting gifts, extending or accepting invitations and hospitality.

Gifts or even cash payments to government officials or public sector employees are strictly prohibited. Gifts to customers during a competitive bidding process are also prohibited.

 

3) Corruption and bribery

Corruption is a serious problem in business transactions. It leads to decisions being made for inappropriate reasons, distorts competition, and harms society. Corruption can result in fines for the company and criminal penalties for the employees involved. Corruption is therefore prohibited. We only grant benefits to customers, suppliers, business partners, or other external third parties within the legally permissible framework. We comply with all anti-corruption laws.

If our employees receive indications of corruption, they report this immediately to their superiors or the responsible managing director.

 

4) Dealing with public officials and elected representatives

Special legal conditions often apply when dealing with public officials and elected representatives, as well as governments, authorities, and other public institutions. Violations of these legal conditions can have serious consequences and permanently exclude us from being awarded public contracts. We do not tolerate any form of illegal material or immaterial benefits to public officials, elected representatives, or similar persons, but pursue a zero-tolerance policy toward any form of bribery or undue influence.

We and our employees observe the applicable special legal regulations, strictly adhere to the law in our contacts and dealings with public officials and elected representatives, and never bribe others. We never accept bribes, either directly or indirectly. In particular, we do not make facilitation payments, i.e., payments to public officials to expedite routine official acts. The payment of bribes is prohibited.

 

5) Prohibition of money laundering and terrorist financing

We do not condone money laundering or terrorist financing. Money laundering occurs when funds or other assets derived directly or indirectly from criminal activities are introduced into the legal economic cycle, thereby concealing their origin. Terrorist financing occurs when funds or other resources are made available for terrorist crimes or to support terrorist organizations. Liability for money laundering does not require the person involved to be aware that the legal transaction or transfer in question is being used to launder money. Even unintentional involvement in money laundering can result in severe penalties for all those involved.

We therefore observe all relevant economic sanctions and comply with all foreign trade restrictions. We carefully check the identity of customers, suppliers, business partners, and other third parties with whom we wish to do business. It is our declared goal to only maintain business relationships with reputable partners whose business activities comply with legal regulations and whose operating resources are of legitimate origin. We immediately assign incoming payments to the corresponding services and post them. We ensure transparent and open payment flows.

Our employees are required to have unusual financial transactions, especially those involving cash, which could give rise to suspicion of money laundering, reviewed by their manager in case of doubt.

 

6) Fair and free competition

We are committed to fair and free competition and expect the same from our employees, customers, suppliers, and business partners. Fair competition is protected by applicable competition and antitrust laws, which prevent unfair agreements or practices from significantly distorting or unduly restricting fair and free competition.

We conduct our business exclusively according to the principle of performance and on the basis of fair and unhindered competition. Anti-competitive behavior can significantly damage our good reputation. In addition, violations of competition and antitrust laws can have far-reaching consequences, such as fines, imprisonment, high penalties, skimming of profits, and civil liability claims. We do not enter into any anti-competitive agreements with competitors, customers, suppliers, or business partners.

Our employees will take care not to exchange any confidential market or company information when contacting competitors. They will avoid topics that are relevant to competition between competitors in conversations or other contact with competitors.

7) Collaboration with third parties and procurement

As part of our business activities, we are contractually bound to a large number of third parties, as the nature of our business requires us to work with third parties. Third parties can be customers, suppliers, and service providers in particular, but also any other person or legal entity who is not an employee of team neusta or a group company.

We carefully select our suppliers and service providers based on objective criteria. We do not give unilateral preference to any supplier or service provider without objective reasons and avoid any conflicts of interest in our procurement activities. We are committed to environmentally and socially responsible corporate governance and expect the same behavior from our suppliers and service providers. To ensure that we only work with suppliers and service providers who, like us, strive to optimize their business activities in terms of sustainability, we carry out careful risk assessments of our suppliers and service providers as part of our sustainability management in the supply chain. In addition, we monitor our suppliers and service providers throughout the entire business relationship in order to comply with the due diligence obligations of the LkSG (German Local Government Social Responsibility Act) and future legal sustainability requirements in particular.

 

III. Our responsibility as an employer

It is in our interest to protect the health of our employees and ensure their safety. Protection and safety also apply to the data of our employees, customers, and business partners, as well as to company-specific know-how.
Specifically, our responsibility in the workplace gives rise to the following principles:

 

1) Occupational and safety and health

We take our responsibility for the safety, health, and well-being of our employees very seriously and comply with the applicable (legal) standards for occupational safety and health protection in order to protect our employees and the company from health and safety risks that may arise in the course of our business activities.
Through good management of health, safety, and well-being in the workplace, by improving working conditions, and through a variety of preventive and health promotion measures, we maintain the health, performance, and satisfaction of our employees. We promote a health and safety culture in which all employees take responsibility for themselves and others.

Our employees comply with occupational health and safety regulations. By regularly participating in occupational safety, prevention, and health promotion measures (e.g., attending occupational safety training), our employees contribute to maintaining and promoting their safety, health, and well-being in the workplace.

 

2) Relationship between employees and employers

By committing to the conventions of the International Labor Organization (ILO) and the OECD Guidelines for Multinational Enterprises, we recognize the right of our employees to establish, join, and actively participate in trade unions and employee representative bodies within the framework of national laws, collective bargaining agreements, and local customs.

 

3) Confidential company information 

We possess extensive trade and business secrets as well as technical expertise. This knowledge forms the basis of our commercial success. We are aware of the value of our company's expertise and protect it and our trade and business secrets very carefully.

The unauthorized disclosure of proprietary know-how and operational and trade secrets can cause significant damage to the company and result in labor, civil, and criminal consequences for the employee concerned. Our employees handle all company information, especially information relating to technical know-how and operational and trade secrets, with care and do not disclose it without authorization.

We recognize the intellectual property of competitors, business partners, and other third parties.

 

4) Data protection and information security

There are specific legal regulations governing the handling of personal data. The collection, storage, processing, and other use of personal data requires, in principle, the consent of the person concerned, a contractual agreement, or another legal basis. The protection of the personal data of our employees, customers, suppliers, service providers, and other affected parties is of particular importance to us. We only collect, process, use, and store personal data in accordance with legal requirements. In cases of doubt, our employees contact their supervisor or the department responsible for data protection.

Information technology (IT) and electronic data processing (EDP) are an integral part of our everyday work. We are aware that IT and EDP involve a number of risks. These include, in particular, the impairment of data processing by malware (viruses), the loss of data due to program errors, or the misuse of data (e.g., through hacker attacks).

We and our employees pay attention to IT and EDP security. We sensitize our employees to IT security and educate them about risks (e.g., through internal anti-phishing campaigns).

If they have any questions or doubts, our employees contact their supervisor or the IT security team.

As of: June 2025