Code of Conduct

Preamble

Our aim as a company is to offer our managers and employees not just jobs, but scope for creativity. People who join us don’t look for titles, they drive issues forward and take responsibility. And that’s what it’s all about here. Responsibility is the core corporate value for us and our way of working.

This Code of Conduct is intended to serve as a compass for the decisions that we all make every day in the course of our work for Valtech Mobility GmbH. The principles set out in this Code of Conduct apply at all locations and in all business units of Valtech Mobility GmbH and cover our dealings with all colleagues, customers, suppliers, business partners and public bodies. We expect our business partners to behave accordingly. The Code of Conduct cannot exhaustively cover all the topics listed in it. Any individual topics can be regulated in more detail in the accompanying guidelines and policies of Valtech Mobility GmbH. There is therefore no principle of exclusion, but rather the Code of Conduct and any other policies and guidelines complement each other.

This Code of Conduct aims to avoid legal violations and misconduct and thus prevent damage to the company and our employees. However, if errors and violations occur, we must take responsibility and act. On the one hand, this involves clarifying the facts and limiting the damage, and on the other, learning and recognizing any new or previously unrecognized risks and dealing with them proactively. We want to be a learning organization that thinks and acts in an entrepreneurial and at the same time legally compliant manner. Valtech Mobility GmbH therefore reserves the right to adapt the Code of Conduct.

 

1  This is how we do it – this is Valtech Mobility

1.1  Lawful conduct

 

The applicable law is the basis and at the same time the framework for the business activities of Valtech Mobility GmbH. This Code of Conduct is therefore about ensuring compliance with and observance of the applicable legal provisions. Valtech Mobility GmbH organizes its business operations in such a way that its executive bodies, managers and employees act in compliance with the law. This is done in the knowledge that violations of the law can lead to massive damage and disadvantages for Valtech Mobility GmbH. This is not only about avoiding fines and claims for damages, but also about any damage to the company’s image. The latter are generally difficult to remedy. Compliance with the applicable law is therefore crucial for the long-term success of Valtech Mobility GmbH.

Culpable violations of this Code of Conduct will not be tolerated by Valtech Mobility GmbH. Anyone who violates it must expect appropriate consequences. Depending on the severity of the violation, these may range from measures under labor law to claims for damages under civil law and criminal sanctions.

1.2  Human rights & fair working conditions

The United Nations Universal Declaration of Human Rights and the European Convention for the Protection of Human Rights and Fundamental Freedoms centrally regulate the requirements and expectations of the international community regarding respect for and compliance with human rights. As a company, it goes without saying that we respect human rights. At the same time, we reject child, forced and compulsory labor as well as any form of modern slavery and human trafficking.

1.3 Equal opportunities & equal treatment

The composition of the workforce at Valtech Mobility GmbH is colorful, diverse and varied. And that is important to us. We do not tolerate discrimination on the basis of ethnic or national origin, gender, religion, ideology, age, disability, sexual orientation, skin color, political views, social background or other legally protected characteristics. Equal opportunities and equal treatment are core values of our company. The selection, recruitment and further development of our employees are always based on their respective qualifications and skills.

Employees who have experienced discrimination or harassment at work can contact Valtech Mobility GmbH’s trusted persons if they do not wish to use Valtech Mobility GmbH’s whistleblower reporting office.

1.4  Occupational safety, fire, noise and health protection

Occupational safety, fire, noise and health protection are very important to us. Risks are evaluated and documented as part of a risk matrix and in risk assessments.

We ensure occupational health and safety in accordance with the applicable legal provisions in order to prevent physical and mental illness in the working environment. All employees are provided with personal protective equipment (PPE) if deemed necessary on the basis of the workplace assessment.

The identified risks and the corresponding protective and preventive measures must be reviewed regularly. First aiders, fire safety assistants and occupational health and safety specialists are established in accordance with national law.

1.5    Use of company resources

In addition to the company budget, work equipment and appropriate equipment for Valtech Mobility GmbH employees, company resources naturally also include intellectual property – i.e. tangible and intangible assets. Careful and responsible handling of these assets within the framework of the applicable regulations and requirements of Valtech Mobility GmbH and its corporate objectives as well as the law is mandatory.

1.6  Benefits & prevention of corruption

We do not tolerate corruption. It can lead to fines for the company and criminal prosecution of employees, not to mention damage to our company’s reputation. What does that mean in concrete terms? We only make business decisions for objective and comprehensible reasons in the interests of the company. We therefore do not accept any benefits, in particular gifts or invitations, that could influence our business decisions. At the same time, we do not offer any such benefits to our business partners or other contacts and contact persons. This also applies in particular to contact with authorities and public officials, for whom stricter requirements regularly apply than in the non-official sector. Small and customary, i.e. socially appropriate, gifts of a reasonable size remain unobjectionable, especially if they are not related to business decisions.

1.7 Conflicts of interest, review of business partners

Conflicts of interest can arise in particular from close personal relationships with business partners and other contacts in connection with business activities for our company. To avoid this, we always separate personal interests from company interests and make business decisions exclusively on the basis of objective criteria. Any personal connections in the context of company-relevant decisions must always be disclosed. Products and services are purchased via our purchasing department in accordance with internal procurement principles.

As a matter of principle, we carry out business partner due diligence before entering into business relationships in order to avoid surprises in business relationships. We check the identity of our customers and business partners with the aim of only entering into business relationships with reputable partners. In particular, this also involves compliance with the applicable provisions of foreign trade law and anti-money laundering regulations.

1.8  Donations & sponsoring

As a company, we are aware of our shared responsibility in society. Therefore, when we make a social commitment in the form of donations, this is always done on a voluntary basis and without any expectation of anything in return. We do not make donations to political parties or party-affiliated foundations and institutions. The allocation of donations is checked in advance with this in mind and is always transparent, i.e. the purpose, donation recipient and donation receipt of the donation recipient are documented and verifiable. If, on the other hand, we act as a sponsor, this is of a promotional nature with the aim of brand and image cultivation.

1.9  Business secrets, confidentiality & non-disclosure of intellectual property and protection against plagiarism

The protection of business secrets and the confidential handling of confidential information are essential to our success as an innovative company. We therefore handle all information and documents in our company, our know-how, our intellectual property, any sensitive data and other business secrets with care and protect them. All information and documents that are not suitable for disclosure to unauthorized third parties must therefore be treated confidentially and protected from access by unauthorized third parties. Reference is made to the law on the protection of business secrets. Data protection is regulated as a separate point in Section 1.12 of this Code of Conduct.

1.10    Public image & communication

We are aware of our shared responsibility for the reputation of Valtech Mobility GmbH when we act on behalf of our company, especially when we communicate publicly and privately. This applies in particular to the use of social media.

1.11   Antitrust law

The principle of fair and free competition is a central pillar of our market economy and is protected by competition and antitrust laws. In particular, agreements and concerted practices between competitors that have as their object or effect the prevention or restriction of free competition are prohibited. Violations can result in severe fines and penalties, not to mention reputational damage. We therefore consistently comply with the requirements of competition and antitrust law.

1.12    Data protection

Data protection regulates the protection of personal data and thus also in our company and in our company’s relationships with our employees, business partners and other contacts. The processing of personal data always requires a legal basis. We adhere to this principle and use technical measures to protect personal data as comprehensively as possible. The aim is always to protect the rights of data subjects. Here too, violations can result in severe fines and penalties, not to mention reputational damage.

1.13    Cybersecurity

As a tech company, reliable protection against cyber risks is crucial for our customers’ and business partners’ trust in us and therefore for the success of our company. We are constantly working on improving our measures to achieve comprehensive protection against cyber risks and map this in the Mobility Information Security Manual.

1.14 Commitment to protecting the environment and climate

We do not see economic, profit-oriented development, energy saving and the protection of our environment as conflicting goals, but as a joint task. We therefore have our own environmental policy to protect the environment and the climate and prevent environmental pollution as far as possible.

2  And if something has happened?

If mistakes have been made or there have been breaches of this Code of Conduct, or if you have any questions about how to deal with its content, you can always contact your direct line manager. The legal department is also available to provide you with advice and assistance. Last but not least, you can report violations or suspected violations – also anonymously – via the Whistleblower Reporting Office. In general, it is important to us that the aforementioned offices are not misused to report false or defamatory information. This can have consequences under civil and criminal law.

Policy on handling invitations and gifts in a business context

Dealing with gifts and invitations (= gratuities) in a business context

1. fundamentals

• Dispatch and delivery of benefits: exclusively via the business address; the same applies accordingly to the acceptance of benefits from business partners,
• not accepting or giving gifts of money or money-like gifts,
• no benefits dependent on the making of operational decisions and also not immediately before or after a business decision (exception: appropriate meal invitations),
• no claims for benefits from business partners or employees of Valtech Mobility GmbH,
• No benefits to third parties who are related to employees of business partners, or demands for benefits to third parties who are related to employees of Valtech Mobility GmbH,
• In principle, no benefits to decision-makers in the area of procurement or purchasing (alternatively: transparency through clarification with the management).

2. appropriateness of the benefit

Benefits must always be appropriate. The decisive factor is that they are not suitable for improperly influencing business decisions in the individual circumstances of each case. And what is “appropriate”? These are relatively low-value gifts that are considered socially appropriate, i.e. customary and customarily recognized (different standards apply to public officials; see below). And how do you actually assess this? The following questions, which you must answer honestly, can help:

• Do customary practices permit the gift or is it appropriately related to the occasion?
• Would you tell the management or colleagues about the gift or invitation or would you want to avoid it?
• Are the gift or invitation likely to influence the recipient’s business decision to such an extent that the giver or inviter is unfairly favored?
• If you were the recipient, would you feel indebted to the giver/inviter?

 

3. procedure and value limits for accepting and giving gifts

Below you will find the value limits for accepting and giving gifts. These are company-specific, i.e. set by Valtech Mobility GmbH. It is therefore possible that business partners may not be allowed to accept gifts due to different company regulations.

• No acceptance or granting of individual gifts with a gross value of more than EUR 50,
• per employee per business relationship: no higher total value of all gifts accepted or granted of more than EUR 300 gross in a calendar year,
• without informal written approval (e-mail ok) from the superior: no acceptance or giving of gifts between EUR 50 gross (individual) and EUR 300 gross (cumulative),
• without informal written approval (e-mail ok) from the management: no single or multiple gifts cumulated within one calendar year in excess of EUR 300 gross per person and business relationship,
• if the value of a gift is unknown or unclear, it must be estimated in gross terms according to market value.

 

4. procedure and value limits for the acceptance and awarding of meal invitations

• no acceptance of meal invitations with a gross value of more than EUR 50 per person,
• Total value of all meal invitations accepted or granted by an employee per calendar year per business relationship: not > EUR 300 gross,
• Without informal written approval (e-mail ok) from the line manager: no acceptance or issuing of meal invitations with a gross value of > EUR 100 per person.

5. procedure and value limits for accepting and issuing invitations to events

The acceptance and awarding of invitations to events must always be considered and classified holistically. The invitation may only be accepted or issued to business partners if the criteria for the event are predominantly positive in accordance with the following aspects. In case of doubt, the supervisor or management must be consulted.

Positive expression:

• Objective: no unfair competitive advantage or breach of duty towards the company,
• Position of the recipient: high-ranking business partner from the business world,
• Relationship of the parties involved: no operational business contacts,
• Procedure: Transparency of the benefit (e.g. through approval by the line manager),
• Value: appropriate,
• Number: occasionally, 1-2x in a period of 12 months,
• Timing: independent of specific business decision,
• Presence of the inviting party or a representative: present, guest support therefore available,
• Duration: < 24h,
• Circle of invitees: open

Negative expression:

• Objective: unfair competitive advantage or breach of duty towards the company,
• Position of the recipient: Public official,
• Relationship of the parties involved: (close) operational business points of contact,
• Procedure: no transparency of the benefit (e.g. through approval by the superior),
• Value: high value or inappropriate,
• Number: frequently, e.g. weekly or monthly,
• Timing: proximity to a business decision, e.g. directly before or after,
• Presence of the inviting party or a representative: present, guest support therefore available,
• Duration: > 24h incl. overnight stay/s etc.,
• Circle of invitees: exclusive invitation, invitation of related parties

Special case: Benefits to public officials

Public officials are not only civil servants in public authorities, but also members of the federal and state governments as well as managers and employees of companies in which public authorities hold a majority stake. In cases of doubt, the Legal Department will be happy to answer any questions. The decisive factor is in which function and in the context of which activity (e.g. mandate activity or specific administrative tasks assigned) a contribution is made. Due to the restrictive criminal law regulations, benefits may not be granted to German, European and foreign public officials. Exceptions may be made in the following cases:

• small gifts (e.g. advertising / promotional items) with a gross value of up to EUR 10 or customarily recognized benefits (e.g. invitation to a cup of coffee, cab ride from the airport to a meeting),
• customary and appropriate events in which the office holder participates as a representative of his office or as part of his social obligations,
• Approval (= in advance) or immediate approval (= retrospective) by the competent authority to accept the approvable grant.

 

To clarify: All gratuities that are aimed at the performance of official duties by the public official in breach of duty are prohibited. This is the case if the public official violates their official duty, i.e. the official act itself violates a law, an official regulation or a specific individual instruction from their superior.

Tax aspects

Gifts to employees are generally subject to taxation as income for the recipient. This does not include so-called promotional items (e.g. pens) up to a value of EUR 10. Please therefore note that certain tax aspects must be taken into account when accepting and giving gifts and invitations (including lump-sum taxation in accordance with Section 37 b EStG). In this respect, please refer to the Finance department.

Supplier Code of Work Ethic

 

1. preamble

Valtech Mobility GmbH regards responsible, sustainable and lawful conduct as an essential part of its corporate strategy. With this in mind, this Supplier Code of Work Ethic reflects Valtech Mobility GmbH’s policy on working conditions and human rights for suppliers and business partners. The principles set out in this Supplier Code of Work Ethic apply at all locations and in all business units of Valtech Mobility GmbH and cover dealings with all customers, suppliers, service providers, other business partners and public bodies. We expect our business partners to behave accordingly. The Supplier Code of Work Ethic supplements the Code of Conduct of Valtech Mobility GmbH as well as all other guidelines and policies of Valtech Mobility GmbH. Any individual topics can be regulated in more detail in accompanying guidelines and policies of Valtech Mobility GmbH. The Supplier Code of Work Ethics and any other policies and guidelines complement each other. Valtech Mobility GmbH reserves the right to adapt the Supplier Code of Work Ethics.

 

2  Work Ethics at Valtech Mobility GmbH

2.1  Lawful conduct

The applicable law is the basis and at the same time the framework for the business activities of Valtech Mobility GmbH. This Supplier Code of Work Ethic is therefore about ensuring compliance with and observance of the applicable legal provisions. Valtech Mobility GmbH organizes its business operations in such a way that its executive bodies, managers and employees act in compliance with the law. This is done in the knowledge that violations of the law can lead to massive damage and disadvantages for Valtech Mobility GmbH. This is not only about avoiding fines and claims for damages, but also about any damage to the company’s image. The latter are generally difficult to remedy. Compliance with the applicable law is therefore crucial for the long-term success of Valtech Mobility GmbH.

Culpable violations of this Supplier Code of Work Ethic will not be tolerated by Valtech Mobility GmbH. Anyone who violates it must expect appropriate consequences. Depending on the severity of the violation, these may range from measures under labor law to claims for damages under civil law and criminal sanctions.

2.2  Human rights and fair working conditions

The United Nations Universal Declaration of Human Rights and the European Convention for the Protection of Human Rights and Fundamental Freedoms centrally regulate the requirements and expectations of the international community regarding respect for and compliance with human rights. As a company, it goes without saying that we respect human rights. At the same time, we reject child, forced and compulsory labor as well as any form of modern slavery and human trafficking.

2.3  Freedom of association & right to collective bargaining

Our suppliers and business partners recognize the right of all employees to form employee representative bodies within the framework of applicable laws and to conduct collective bargaining to regulate working conditions. Employees may not be favored or disadvantaged because of their membership or non-membership in a trade union or employee representative body.

2.4  Land, forest and water rights and forced evictions

Our suppliers and business partners respect the rights of indigenous peoples and local communities, including the right to land, forests and water resources. In the context of our joint projects, they undertake to ensure that no unlawful forced evictions occur or are supported.

2.5  Remuneration and benefits, working hours

The remuneration paid or services rendered by our business partners and suppliers correspond to at least the legally valid and guaranteed national minimum, or exceed it. We recognize the principle of equal pay for work of equal value, especially between different genders. At the same time, the principle applies that working hours must at least comply with the respective national legal requirements.

2.6  Equal opportunities and equal treatment

The composition of the workforce at Valtech Mobility GmbH is colorful, diverse and varied. And that is important to us. We do not tolerate discrimination on the basis of ethnic or national origin, gender, religion, ideology, age, disability, sexual orientation, skin color, political views, social background or other legally protected characteristics. Equal opportunities and equal treatment are core values of our company and we expect this from our suppliers and business partners. Employees of our suppliers and business partners who have experienced discrimination or harassment at work can use our whistleblower reporting office in confidence (https://valtech-mobility.de/compliance/).

2.7  Occupational safety, fire, noise and health protection

Occupational safety, fire, noise and health protection are very important to us. Risks are evaluated and documented as part of a risk matrix and in risk assessments. We expect the same from our suppliers and business partners. If our suppliers and business partners work with machines or technical equipment, the relevant standards and specifications for machine safety must be met. We and our business partners ensure occupational health and safety and noise protection in accordance with the applicable legal provisions in order to prevent physical and mental illness in the working environment. All employees of our suppliers and business partners are provided with personal protective equipment (PPE)  if deemed necessary  based on the workplace assessment.

The identified risks and the corresponding protective and preventive measures must be reviewed regularly. First aiders, fire safety assistants and occupational health and safety specialists must be established in accordance with national law.

3.  obligation to protect the environment and climate

We do not see economic, profit-oriented development, energy conservation and the protection of our environment as conflicting goals, but as a joint task. We therefore have our own environmental policy to protect the environment and the climate and prevent environmental pollution as far as possible. We also expect our business partners to commit to protecting the environment and conserving resources.

4.  due diligence

We expect our suppliers and business partners to regularly carry out an appropriate due diligence analysis with regard to compliance with human rights and environmental protection requirements in their supply chain.

5 Confidentiality, intellectual property and protection against plagiarism

The protection of trade secrets and the confidential handling of confidential information are essential to our success as an innovative company. Our suppliers and business partners therefore undertake to handle all information and documents from our company, our intellectual property, any sensitive data and other business secrets with care and to protect them. All information and documents that are not suitable for disclosure to unauthorized third parties must therefore be treated as strictly confidential and protected from access by unauthorized third parties. All work and products submitted by suppliers and business partners must be original and must not be unlawful copies or imitations.

1. objective, purpose, scope of application

1.1. Zielsetzung

Valtech Mobility GmbH (hereinafter also referred to as “we” or “our company“) pursues the goal of preventing unlawful behavior within the company, but in any case to comprehensively clarify and remedy it. In doing so, we rely on the assistance of whistleblowers, whose protection we want to ensure against this background.

1.2. Zweck

This policy sets out the framework conditions for reporting information on possible legal violations in our company. It is intended to ensure that information on violations can be processed, stored, passed on and archived in accordance with the legal requirements of the Whistleblower Act and taking into account the necessary confidentiality. At the same time, the policy describes the protective measures that exist in the interests of bona fide whistleblowers and the consequences that can result from a deliberate false report.

2. notes

2.1. Hinweisgeber

Persons who obtain information about legal violations in our company in connection with their professional activities or in the run-up to them are entitled to report such information. This applies in particular to our employees, applicants, the management and our business ^partners1.

2.2. Meldefähige Verstöße & Folgen von Falschmeldungen

The whistleblower can report violations that

• are punishable by law, e.g. fraud, corruption, insult, sexual harassment,
• are subject to fines, e.g. violations of antitrust law,
• violate federal or state legislation or directly applicable legal acts of the European Union and the European Atomic Energy Community, e.g. in the areas of GDPR, product safety, money laundering and terrorist financing.

A report requires reasonable grounds for suspicion or knowledge of actual or potential violations as well as attempts to conceal such violations that have already been committed or are very likely to occur.

Before making a report, the whistleblower should therefore thoroughly check whether such reasonable grounds for suspicion actually exist. The deliberate reporting of false facts can lead to criminal liability for the whistleblower and result in disciplinary measures. An intentional or grossly negligent false report can also lead to liability for damages against the person concerned.

 

¹ In the following, for reasons of simplification, the term “whistleblower” is used consistently.

2.3. Meldung

2.3.1. Interne oder externe Meldung

We generally encourage whistleblowers to make use of our internal reporting channels (see section 2.3.3), as some issues can be processed and clarified more quickly and appropriate measures can be taken more quickly as a result. Nevertheless, whistleblowers are free to contact the authorities directly. However, this option is still available to a whistleblower even if an internal company report was initially made and this was not followed up for whatever reason.

2.3.2 Responsible internal office

activeMind.legal Rechtsanwaltsgesellschaft mbH is the external ombudsman responsible for receiving, processing and following up on reports within our company. Valtech Mobility GmbH ensures that this ombudsman’s office can carry out its activities independently and without conflicts of interest and that it has the necessary expertise.

2.3.3 Type of message (message channel)

The notification can be made electronically, in writing or verbally.

• Electronic messages can be sent: By e-mail to the following address: [email protected]

• Written reports can be sent by post to the following address: activeMind.legal Rechtsanwaltsgesellschaft mbH externe Ombudsstelle der Valtech Mobility GmbH, Potsdamer Str. 3, 80802 Munich, Germany

• Verbal reports can be made by telephone at the following number: +49 (0)89 / 91 92 94 – 900.

Subject to the whistleblower’s consent, his reports shall be documented by making an audio recording of the conversation in a permanent and retrievable form or by a complete and accurate transcript of the conversation by the competent body; the whistleblower shall be given the opportunity to review the minutes of the conversation, correct them if necessary and confirm them with his signature. At the request of the whistleblower, the report can also be made by way of a physical meeting; the whistleblower must be granted a corresponding appointment within 10 working days of notification of such a request. The above regulations on verbal reports apply accordingly to the documentation.

 

3 Procedure after receipt of notification

3.1 Checking the notification

The internal unit shall immediately examine the facts of the case for the validity of the allegations made in the report and the existence of the requirements of section 2.2 of this Guideline and, if necessary, initiate the necessary and reasonable follow-up measures (in particular, e.g. internal investigations including, if necessary, the questioning of persons concerned or any other whistleblowers, referral of the whistleblower to the competent authorities, measures to confiscate operating resources, transfer of the proceedings to a competent authority for further investigation or the conclusion of the proceedings). If necessary, the internal office will ask the whistleblower for further information.

3.2 Termination of the proceedings

If a report is obviously unfounded, if it was obviously made solely for denunciatory motives, if it is a minor case or if there is insufficient evidence, no further investigation is required. Attention is drawn to any consequences of false reports (see section 2.2).

3.3 Report of the internal body

For each notification, the internal office shall prepare a report in text form to the management on the violation, the result of the audit and the recommended measure, including the steps required for this and the timetable in response to the result. This shall also apply in the event of discontinuation in accordance with section 3.2. If the management wishes to deviate from the recommendation, this must be documented and justified. If the recommendation contains measures that result from mandatory legal provisions, the management cannot deviate from the recommendation. If the following conditions are met, the ombudsman’s office is obliged to inform the management within 24 hours of becoming aware of the recommendation: – immediate danger to life, limb and health of people, – significant risk of damage to the company’s reputation.

3.4 Informing the whistleblower

The ombudsperson confirms receipt of the report to the whistleblower within seven days at the latest. No later than three months after this confirmation, it shall provide the whistleblower with feedback on planned and already taken measures as well as the reasons for these. The obligation to provide feedback also applies if, in the case of longer investigations, no result of the investigation is available after three months. In this case, the feedback is limited to information on the current status of the investigation. Feedback may only be provided to the whistleblower if internal inquiries or investigations are not affected by this and the rights of the persons who are the subject of the report or who are named in the report are not impaired. Feedback is not possible if the report was made anonymously.

4 Protection of the whistleblower

4.1 Protection from reprisals

A whistleblower must not be subject to reprisals or threats of reprisals as a result of their report. Any adverse action against the whistleblower in connection with his/her report is prohibited. Reprisals within the meaning of this policy are direct or indirect acts or omissions in a professional context that are triggered by an internal or external report or disclosure and which cause or may cause the whistleblower an unjustified disadvantage.

4.2 Compensation in the event of reprisals

Whistleblowers are entitled to compensation in the event of reprisals.

4.3 No responsibility

The whistleblower may not be held legally responsible for the procurement of or access to information in their report, unless the procurement or access constitutes a criminal offense. If the whistleblower had reasonable grounds to believe that the disclosure of certain information was necessary in the context of his report, he does not violate any disclosure restrictions.

5 Confidentiality, data protection

5.1 Confidentiality

All information and content, including information about the whistleblower themselves and third parties named in the report, will be treated confidentially. The persons handling the information as part of the whistleblowing procedure have either been expressly obliged to maintain confidentiality or are subject to a statutory duty of confidentiality (e.g. as a lawyer). The duty of confidentiality does not apply if:

• the whistleblower has expressly consented to the publication of his/her identity,
• has intentionally disclosed his or her identity in the context of a disclosure or
• the disclosure is a necessary and proportionate obligation in the context of an official or judicial investigation, in particular to safeguard the data subject’s rights of defense.

5.2 Data protection

The personal data provided as part of a notification and collected in the further course of the procedure will be processed in accordance with the relevant data protection laws. Valtech Mobility GmbH has taken appropriate technical and organizational measures to ensure the protection of personal data during and after completion of the procedure. The documentation created during the respective procedure will be deleted two years after completion of the respective procedure.

6 Revision

The legal department is responsible for the maintenance and further development of these guidelines. The regulations contained herein are to be reviewed on an ad hoc basis, otherwise regularly at least once a year, to determine whether they

• complete,
• current,
• effective and efficient,
• known to the employees concerned
• and can be integrated into the operating process with reasonable effort.

We do not see economic, profit-oriented development, energy conservation and the protection of our environment as conflicting goals, but as a joint task. We are therefore committed to protecting the environment and preventing environmental pollution as far as possible. We do this by gradually integrating sustainable, ecologically-oriented processes into all business matters and by reducing our environmental impact through continuous improvement in environmental protection.

In particular, we are committed to complying with all applicable laws, ordinances and other regulations on environmental protection. Furthermore, we anchor an environmentally conscious corporate policy, particularly in the management and strategic planning areas.

As part of our environmental management system, we focus in particular on the following aspects of our business activities:

• Reduction of greenhouse gases (decarbonization) by reducing energy consumption and the use of renewable energies, particularly in
  • Server operation, business trips and vehicle fleet
  • Heating and air conditioning technology and electricity procurement at the locations (as far as our influence allows within the scope of the rental)
  • Supporting the climate strategy of our parent company Valtech SE as part of the Science Based Targets Initiative (SBTi).
• Energy-efficient and resource-conserving design, implementation and operation of our software solutions and products
• Consideration of ecological aspects when selecting service providers, suppliers and products. In addition to the energy-oriented aspects mentioned above, ecological aspects also include animal welfare and chemical management, where relevant. We also pay attention to ensuring deforestation-free supply chains.
• Reduction of waste, promotion of reuse and use of recycled products

The annual development of an environmental program is an integral part of our environmental management system, which includes in particular the definition of environmental targets to improve our environmental performance.

When developing solutions and new products, we consider relevant environmental impacts at an early stage during the design, implementation and operation of our solutions and products, as well as at the end of their useful life. We therefore optimize our development process over the entire life cycle from a sustainability perspective and try to consciously weigh up conflicting goals . During development, we also make sure that our solutions and products help to reduce the consumption of energy and other resources when used by our customers.

In our development, operational and logistics processes, we minimize our emissions and waste products as well as the consumption of energy, floor space and other resources wherever possible. As part of our management systems, we regularly monitor our resource consumption and emissions and report on specific developments.

We always take a holistic approach to environmental protection, i.e. with regard to water, soil, air, raw materials and people. We find sparing solutions for land use and avoid deforestation if our processes have an impact on it. The diversity of species is important to us, which is why we avoid potential threats in our actions.

We encourage all of our employees to avoid waste as far as possible and to give preference to resource-saving and low-packaging products as early as possible in the procurement process. In the course of continuous improvement, we want to design all processes to waste as few resources as possible and thus keep waste to a minimum. We want to promote and expand the use of recycled products and reuse.

This also includes the use of renewable energy and recycled resources, which will enable us to further reduce the waste generated by our operations.

The Management Board is responsible for the environment and sustainability. The environmental policy is a component of our compliance program and is part of our internal training program and is published on our website (https://valtech-mobility.de/compliance/).