team neusta Code of Conduct

team neusta SE Konsul-Smidt-Straße 24, 28217 Bremen


Integrity, lawful and compliant behavior are guiding principles for us. We ensure compliance with these principles and continuously develop them further. Our Code of Conduct covers compliance with the applicable legal provisions by team neusta SE, its Management 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 the sustainable safeguarding of our corporate success. They are also the elementary basis for trust and trustworthiness.
Our responsibility for compliance

For us, entrepreneurial success is crucially based on acting openly, with integrity and in an ethically correct manner. As a group of companies, we have a great responsibility towards people and society and we live up to this responsibility. That is why the rules that apply to us are observed and complied with by everyone at all times and everywhere. Our board members, managing directors and managers have a special and responsible role to play: they themselves act as role models. They prevent irregular behavior. They protect employees and act with integrity both internally and externally.
Our core values

We have developed core values and defined them in our team code:

Create values and act economically
Acting socially
Understanding diversity, participation and inclusion as an opportunity
Being reliable
Enabling development
We want to live our values in everything we do. They help us to define what we do and how we do it. This Code of Conduct helps us to identify and explain potential areas of risk and conflict and their significance for our company. The contents are 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 lived by them throughout the Group.

The 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 that we set out in this Code of Conduct are based on national laws and regulations, in particular the Supply Chain Due Diligence Act (LkSG) and international conventions such as the United Nations Universal Declaration of Human Rights, the Guidelines on the Rights of the Child and Business Conduct, 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).

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 compliant and rule-compliant behavior. They form 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 lead to considerable damage, not only to our company, but also to our employees, customers, business partners and suppliers, as well as to society. This Code of Conduct is therefore binding for all of us, regardless of whether we are employees, managers or directors of 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 range from measures under labor law to civil claims for damages and criminal sanctions. To prevent this from happening, it is the responsibility of all of us to familiarize ourselves personally with the content of this Code of Conduct, to incorporate it into our own conduct 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 and suppliers as well as all other third parties to express their views openly, to stand up for their opinions and to point out unacceptable behavior - especially if it contradicts this Code of Conduct.

The first point of contact for our employees and managers for concerns, questions and doubts regarding compliance issues is the respective manager. Our employees can contact them personally and directly with their concerns, questions and doubts. Additionally or alternatively, there is the option of using our team neusta whistleblower system. The team neusta whistleblower system is a channel through which employees as well as our customers, business partners, suppliers and other external third parties can report problems confidentially. The reports may concern possible violations of this Code of Conduct or company guidelines as well as applicable legal provisions. The anonymity of the person making the report 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.

We rely on the openness of our employees, customers, business partners and suppliers as well as all other third parties in order to identify any misconduct at an early stage and take countermeasures. They can and should always be able to confidentially report any indications of misconduct that constitute a significant violation of the law, this Code of Conduct or other internal rules. We protect those who raise their concerns in good faith and to the best of their knowledge and belief. Employees, customers, business partners and suppliers as well as all other third parties who do so and thus contribute to the clarification of possible violations will not suffer any disadvantages as a result of their behavior.

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

Asking questions

We encourage our employees to ask questions if something is unclear to them. We are aware that this Code of Conduct cannot solve 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

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

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

In detail, our social (corporate) responsibility results in the following principles:
1) Compliance with the law

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 entails economic disadvantages or difficulties for the company or individuals. If national laws contain more restrictive regulations than these principles of conduct, the national laws take precedence.
2) Human rights

Everyone has human rights. We respect the dignity of every human being and treat every human being 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 rights and children's rights as fundamental and universally applicable requirements. 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 towards violations of human rights. This applies not only to cooperation within our company, but also along our entire supply chain and, of course, to the conduct of and towards our business partners.

Our employees can also contribute to respecting human rights by observing human rights as fundamental guidelines for their actions and being vigilant against human rights violations in their environment. In the event that human rights violations threaten 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 of great importance to us. They are important cornerstones for fair, unprejudiced and open dealings. We are committed to equal opportunities and respectful and cooperative interaction, 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 views, religion, ideology or other legally protected characteristics. We embrace diversity and are actively committed to inclusion. We create an environment that promotes the individuality of each person in the interests of the company. Our aim is to create an inclusive working environment in which differences are welcomed and used positively to achieve the best possible results. Our employees are selected, hired and promoted on the basis of their qualifications and skills. Everyone has the same opportunities to develop and progress at our company.

Our employees also observe the principles of equal opportunities and equal treatment. If our employees observe violations of the principles of equal opportunities 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 bear responsibility for the environmental compatibility and sustainability of our offers and services. We aim to offer these in a sustainable manner and are aware of our responsibility for the environment. We use natural resources sparingly and protect the environment. Our aim is to keep the impact of our business activities on the environment and nature as low as possible. We pay attention to economy, reusability and sustainability. We also expect this attitude from our business partners. To reduce our impact on the environment, we avoid or reduce energy and water consumption, emissions and waste.

Our employees also take environmental protection concerns into account in their work and use resources and energy appropriately and sparingly. Our employees ensure that their activities have the least possible negative impact on the environment and that they comply with the relevant laws.
5) Donations, sponsorship and charity

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

We make donations, i.e. contributions on a voluntary basis without consideration, and sponsorship, i.e. contributions on the basis of a contractually agreed consideration, in each case with the aim of positively shaping our image and perception in the public eye. In order to avoid conflicts of interest and to 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 donations in cash and in kind for the following areas and projects in particular:

Children and young people
Learning and development
Equal opportunities
Peace and refugees
Against (right-wing) extremism
Old people
Sea rescue
Donations are only made to organizations that are recognized as charitable or are 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 only ever made on a voluntary basis and without expectation of anything in return. The purpose, the recipient of the donation and the donation receipt from the recipient are documented and verifiable.

As part of our sponsorship activities, we ensure that our sponsorship service and the agreed consideration are always in an appropriate relationship to each other. We do not use our sponsorship activities to gain unlawful business advantages.
6) Communication and marketing

We live by values such as trust, reliability and honesty, credibility and integrity and 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 an honest and legal manner 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. In the event that our employees express themselves at public, professional or cultural events or on the Internet, our employees make it clear that it is their personal opinion.

We respect the right to freedom of expression. Every employee should be aware that they can also be perceived as part of and representative of team neusta in their private lives. Employees are required to uphold the company's image and reputation through their personal conduct and appearance in public, especially when dealing with the media. As a matter of principle, our employees do not make any public statements for or on behalf of the company, but refer inquiries to Corporate Communications.

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 pass on any confidential information. We do not disseminate any offensive or insulting content. Our employees can find additional information on correct behavior in social networks in our Social Media Guidelines.

7) Political representation of interests

Politics and legislation influence the framework conditions for economic activity and therefore 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 that could give rise to concerns about our integrity and independence when engaging in politics or participating in the political (decision-making) process. Unfair influence on politics and legislation is not permitted.

We do not attempt to influence political decisions on behalf of the company and do not use our political involvement to gain improper or unfair advantages 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 involvement and our participation in the political (decision-making) process openly and transparently.

II Our responsibility as a business partner

We are convinced that integrity, transparency and fairness are crucial for creating credibility and trust in business dealings. We therefore attach particular importance to consistently implementing and clearly communicating the legal framework, internal company guidelines and corporate values.

In detail, the following principles arise from our responsibility as business partners:

1) Conflicts of interest

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

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

Our employees also exercise caution when they or their relatives pursue their own business activities that are closely related to the company's business activities. Our employees 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, a management position or a consulting position with one of our competitors is prohibited, as this directly conflicts with our corporate interests. Accepting such a position with one of our customers, suppliers or business partners requires our prior written approval. If permission is granted, the exercise of the secondary employment must not compromise the loyalty of our employees towards 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 regarding the loyalty of our employees to us or to preferential treatment for us.

2) Gifts, hospitality and invitations

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

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

Gifts or even monetary 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 improper reasons, distorts competition and harms society. Corruption can result in fines for the company and criminal sanctions 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, our employees 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 unlawful material or immaterial benefits to public officials and elected representatives or persons comparable to them, but pursue a zero-tolerance policy towards 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 - whether directly or indirectly. In particular, we do not make facilitation payments, i.e. payments to public officials to speed up routine official acts. The payment of bribes is prohibited.

5) Prohibition of money laundering and terrorist financing

We do not encourage money laundering and terrorist financing. Money laundering occurs when funds or other assets derived directly or indirectly from criminal offenses are brought into the legal economic cycle and their origin is thus concealed. Terrorist financing occurs when funds or other resources are made available for terrorist offenses or to support terrorist organizations. Liability for money laundering does not require the person involved to be aware that money is being laundered through the legal transaction or transfer in question. Even unintentional involvement in money laundering can result in severe penalties for all parties involved.

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

Our employees are requested to have unusual financial transactions, especially those involving cash, which could give rise to suspicion of money laundering, checked 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 the applicable competition and antitrust laws, which prevent fair and free competition from being significantly distorted or unreasonably restricted by unfair agreements or practices.

We conduct our business solely on the basis of merit and on the basis of fair and unrestricted competition. Anti-competitive behavior can significantly damage our good reputation. In addition, violations of prohibitions under competition and antitrust law can have far-reaching consequences, such as fines or imprisonment, high fines, confiscation of profits made and civil liability claims. We do not enter into any anti-competitive agreements with competitors, customers, suppliers or business partners.

Our employees will ensure that no confidential market or company information is exchanged during any contact with a competitor. In discussions or other contact with competitors, they will avoid topics that are important for competition with each other.

7) Cooperation with third parties and procurement

We have contractual relationships with a large number of third parties as part of our business activities, as the nature of our business means that we work with third parties. Third parties can be, in particular, customers, suppliers and service providers, 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 unilaterally favor a supplier or service provider without objective reason and avoid any conflict of interest in our procurement activities. We are committed to ecologically 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 with regard to our suppliers and service providers as part of our sustainability management in the supply chain. We also monitor our suppliers and service providers throughout the entire business relationship, in particular in order to comply with the due diligence obligations of the LkSG and future statutory sustainability requirements.

III Our responsibility as an employer

It is in our interest to protect the health of our employees and ensure their safety. Protection and security also apply to the data of our employees, customers and business partners as well as to company-specific expertise.

In detail, our responsibility in the workplace results in the following principles:

1) Occupational health and safety

We take our responsibility for the safety, health and well-being of our employees very seriously and comply with the applicable (legal) standards on occupational health and safety in order to protect our employees and the company from health and safety risks that may arise in the course of our business activities.

We maintain the health, performance and satisfaction of our employees through good management of health, safety and well-being in the workplace, by improving working conditions and through a variety of prevention and health promotion measures. 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 health and safety, prevention and health promotion measures (e.g. participation in occupational health and safety instructions), our employees contribute to maintaining and promoting their safety, health and well-being in the workplace.

2) Relationship between employee and employer

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 form, join and actively participate in trade unions and employee representative bodies within the framework of national laws, collective agreements and local practices.

3) Confidential company information

We possess extensive company and business secrets as well as technical know-how. This knowledge is the basis of our business success. We are aware of the value of proprietary know-how and protect it and our trade and business secrets very carefully.

The unauthorized disclosure of proprietary know-how and trade and business secrets can cause very high losses for the company and have consequences under employment, civil and criminal law for the employee concerned. Our employees handle all company information with care, especially information relating to technical know-how and trade and business secrets, 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

Special legal regulations exist for the handling of personal data. In principle, the collection, storage, processing and other use of personal data requires the consent of the data subject, a contractual provision or another legal basis. The protection of the personal data of our employees, customers, suppliers and service providers as well as other data subjects is of particular importance to us. We only ever collect, process, use and store personal data in accordance with the legal requirements. In cases of doubt, our employees should contact their line manager or the office responsible for data protection.

Information technology (IT) and electronic data processing (EDP) are an integral part of our day-to-day work. We are aware that IT and EDP harbor a variety 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 IT security. We sensitize our employees to IT security and inform them about risks (e.g. through internal anti-phishing campaigns). If our employees have any questions or are in doubt, they can contact their line manager or the IT security team.
Status: April 14, 2024