Introduction

 

The team neusta Group is an owner-managed group of companies that currently employs more than 1,000 people at locations including Bremen, Munich, Cologne, Berlin, and St. Gallen (Switzerland). As a full-service partner within the group, we deliver projects for our clients across the entire digital value chain. Custom software development is just as much our core business as consulting, developing, and implementing complex software, mobile, and e-commerce solutions. team neusta SE and the other companies in the team neusta group are united across all business areas by a shared set of values: Through economically, ecologically, and socially responsible actions, we aim to improve people’s quality of life, take responsibility, and lead by example. To successfully and efficiently implement our values externally as well, this Code of Conduct for Business Partners defines our expectations of our business partners and establishes binding standards for our business relationships with them.

 

Your commitment matters

 

The sustainable development and optimization of our business practices, our business relationships, and especially our supply chains are important to us. The active participation of our business partners is crucial to our success. We expect our business partners to comply with all applicable laws, in particular the Supply Chain Due Diligence Act (LkSG), respect human rights, recognize and adhere to internationally recognized environmental, social, and corporate governance standards (ESG standards), and do everything in their power to contractually implement these requirements and the principles of this Code of Conduct with their own business partners (in particular their suppliers and subcontractors).

 

 

Scope of this Code of Conduct

 

This Code of Conduct applies worldwide to all our business partners.

 

Business partners within the meaning of this Code of Conduct are all natural or legal persons not belonging to team neusta SE or another company of the team neusta Group from whom we procure goods and/or services. This includes, in particular, our suppliers, subcontractors, freelancers, consultants, and sales partners.

 

For (future) cooperation with our business partners and as the basis for all future deliveries and/or services, we agree to the applicability of the following regulations and principles of this Code of Conduct. A violation of this Code of Conduct by our business partners may ultimately constitute grounds for us to terminate the business relationship, including all supply or service contracts with our business partner.

 

 

Requirements for Our Business Partners

 

This Code of Conduct covers the ethical, social, and environmental aspects that are crucial to us in the course of our business activities, based on the principles of internationally recognized standards for responsible corporate governance. These include, among others, the United Nations Global Compact, the labor and social standards of the International Labor Organization (ILO), and the Guidelines for Multinational Enterprises of the Organization for Economic Cooperation and Development (OECD).

 

1. Compliance with Laws

We are committed to sustainability and uphold the principle of strict legality

(principle of legality). Integrity and conduct that complies with laws and regulations are the guiding principles of our business activities. Our Code of Conduct defines the boundaries within which we and our employees operate, as lawful conduct and ethical behavior are an integral part of our business activities and a fundamental prerequisite for securing our long-term business success. They also form the basis for the trust that our business partners, customers, suppliers, society, and our employees place in us.

 

Compliance with the principle of legality includes, in particular, fulfilling the obligations under the Supply Chain Due Diligence Act (LkSG) as well as adhering to our Code of Conduct and the LkSG Policy Statement.

 

2. Social Responsibility

Our business partners respect the following principles and commit to upholding the rights of their employees as well as all those affected by their business activities, in particular:

 

Human Rights

Our business partners respect internationally recognized human rights, in particular as set forth in the Universal Declaration of Human Rights (UDHR).

 

Prohibition of Forced Labor

Our business partners reject any knowingly use of forced or compulsory labor, as well as any form of modern slavery and human trafficking. Slave labor, forced or compulsory labor, debt bondage, and serfdom, human trafficking, or other forms of involuntary labor are never used or tolerated. The ILO indicators for forced labor (e.g., withholding of identity documents, withholding of wages/salaries, excessive overtime) apply. All work must be voluntary and performed without the threat of punishment. Employees must be able to terminate their employment or the employment relationship at any time, subject to a reasonable notice period. Furthermore, no unacceptable treatment of employees, such as psychological abuse, sexual and personal harassment, and/or humiliation, may take place. The hiring or use of security personnel is prohibited if, during their deployment, individuals are treated in an inhumane or degrading manner, injured, or if freedom of association is impaired.

 

Prohibition of Child Labor

Child labor is strictly prohibited. Our business partners do not use child labor at any stage of production or at any point in the supply and value chain. Our business partners comply with ILO Conventions 138 and 182 and ILO Recommendation 190 regarding the minimum age for the employment of children. Accordingly, the age of an employee shall not be less than the age at which compulsory schooling ends under the law of the place of employment, and in no case shall it be less than 15 years. If children are found working, our business partners must take measures to remedy the situation and enable the children to attend school; The 5 measures to eliminate child labor must be documented and must prioritize the well-being of the children.

 

The rights of young workers under the age of 18 must also be protected. Young workers under the age of 18 are not permitted to work overtime or perform night work. Our business partners also prohibit workers under the age of 18 from performing hazardous work. Hazardous work refers to tasks where there is an increased risk arising from the work process, the nature of the activity, the substances used, or the environment, because adequate protective measures cannot be implemented.

 

Fair Compensation

Our business partners provide fair compensation to their employees and to those working on their behalf.

Compensation for regular working hours and overtime must meet the statutory minimum wage and the industry-standard minimum wages at the workplace or the local living wage, whichever is higher. Compensation for overtime must in all cases exceed the compensation for regular working hours. If the pay is insufficient to cover the costs of a normal standard of living and to build up a minimum level of savings, our business partners are obligated to increase the pay accordingly within a reasonable period of time.

 

Equal pay is provided for equal work without discrimination. Pay deductions as punitive measures are not permitted. Our business partners must ensure that their employees and persons working on their behalf regularly receive clear, understandable, and detailed written information regarding the composition of their pay.

 

Fair Working Hours

Our business partners ensure that working hours comply with applicable national laws and industry standards, as well as ILO Conventions 1, 14, and 106. Overtime is permitted only if it is performed on a voluntary basis and does not exceed twelve (12) hours per week; employees must be granted at least one (1) day off after six (6) consecutive working days. The weekly working hours must not regularly exceed 48 hours.

 

Freedom of Association

Our business partners respect the freedom of association and the right of their employees to form organizations of their choice, join them, engage in collective bargaining, and strike. They also respect the right of their employees to freely elect their own representatives and to associate independently and freely for the purpose of collective bargaining.

 

Employee representatives must be protected from discrimination. They must be granted free access to their colleagues’ workplaces to ensure they can exercise their rights in a lawful and peaceful manner. Employees must also not be discriminated against on the basis of establishing, joining, or being a member of such an organization.

 

Diversity / Prohibition of Discrimination

Our business partners promote diversity within their companies and reject any form of sexual harassment or prohibited discrimination in the hiring and employment of their employees, e.g., on the grounds of national, social, or ethnic origin, skin color, gender, age, religion, nationality, sexual orientation, physical or mental disabilities, marital status, pregnancy, union membership, or political views, provided these are based on democratic principles and tolerance toward those with differing opinions (ILO Conventions 100 and 111). Our business partners respect the personal dignity, privacy, and personal rights of employees.

 

Health and Fire Safety, Workplace Safety

The safety of people, their physical and mental health, and their well-being are our top priority and must be among the core values of our business partners. Our business partners are responsible for providing a safe and healthy work environment and ensure occupational safety, health protection, and fire safety in the workplace in accordance with national legal regulations. Our business partners take all necessary preventive measures against accidents and health hazards that may arise in connection with their employees’ work. Our business partners inform their employees about identified hazards as well as the preventive measures taken to minimize these risks.

 

In addition, our business partners provide training for employees on the prevention of work-related health issues, the avoidance of workplace accidents, first aid, and fire safety.

 

Our business partners provide their employees with appropriate protective equipment and clothing free of charge and install suitable fire safety equipment, such as fire alarms and fire extinguishers.

 

Our business partners take appropriate measures to prevent excessive physical or mental fatigue among their employees and ensure their employees have access to sufficient drinking water and clean sanitary facilities.

 

Preservation of Natural Resources

Our business partners ensure that they do not deprive people of land, forests, or water bodies—the use of which secures their livelihoods—in violation of legitimate rights. Our business partners refrain from harmful soil alterations, water and/or air pollution, noise emissions, and excessive water consumption, particularly when this harms people’s health, significantly impairs the natural resources necessary for food production, or prevents people’s access to safe drinking water or sanitation facilities.

 

 

3. Environmental Responsibility

 

Our business partners are responsible for continuously improving the environmental performance of their services and for reducing the use of natural resources, and they commit to complying with relevant environmental laws and regulations in all countries where they, their suppliers, and/or business partners operate, in particular:

 

Environmental and Climate Protection

Our business partners comply with all applicable national and international environmental laws, regulations, and standards and commit to contributing to environmental and climate protection within the scope of their business activities.

 

With regard to the environmental and climate impacts of their business activities, our business partners adopt a sustainable approach and make reasonable efforts to ensure the most effective environmental protection possible and to continuously reduce environmental impacts. They are also encouraged to promote the development of climate-friendly services, processes, and procedures both within their own companies and among their suppliers and business partners.

 

Resource and Energy Consumption / Energy Efficiency

Our business partners ensure energy-efficient and environmentally friendly use of resources. Our business partners reduce the use and consumption of resources (including water and energy) in the course of their business activities, avoid the generation of waste of any kind, and monitor and document energy consumption. Our business partners will make reasonable efforts to find cost-effective solutions to improve energy efficiency and minimize energy consumption.

 

Waste and Wastewater Management

Our business partners ensure that all waste and wastewater are disposed of or discharged safely and in an environmentally sound manner in accordance with applicable regulations.

 

Prior to discharge or disposal, our business partners classify, monitor, test, and treat wastewater from operational activities, manufacturing processes, and sanitary facilities. Furthermore, our business partners will strive to implement measures to reduce wastewater generation.

 

 

Our business partners follow a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste. Our business partners comply with the prohibitions on the export of hazardous waste under the Basel Convention of March 22, 1989, as currently in force.

 

Management of Air Emissions

Our business partners identify, monitor, verify, and treat, as necessary, general emissions (air and noise emissions) as well as greenhouse gas emissions from operational processes prior to their release and monitor their exhaust gas treatment systems; our business partners are also required to find cost-effective solutions to minimize all emissions.

 

 

Handling of Conflict Minerals

For the conflict minerals tin, tungsten, tantalum, and gold, as well as for other raw materials such as cobalt, team neusta establishes processes to fulfill its due diligence obligations to promote responsible supply chains for minerals from conflict and high-risk areas in accordance with the Guidelines of the Organization for Economic Cooperation and Development (OECD); team neusta also expects this from its suppliers and business partners

 

The smelting and refining of such conflict minerals without appropriate, audited due diligence processes should be avoided.