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that made us

Code of Conduct & Ethics

Preface

Business is not about winning or losing. Business is a creative process: it is about continuously building, changing and adapting. Instead of focusing on the outcome, let’s start focusing on how we play.

In this Code, the Board of Directors sets out the principles and practices that define our ethical standards and the way we do business. We are aware that the challenging part is not to define our standards and values, but rather living them even in times when things can become rough and difficult.

We follow this Code in order to foster a culture where responsible behaviour, ethical standards, integrity, accountability and trust are the key factors to protect our people, our reputation, our customers and the shareholder value.

Conduct

At that made us we understand ourselves as one family. A group of people which truly cares. Bringing meaningful inspiration & innovation to every organization and become their most loved partner is our key goal.

On top of that we will always strive to provide a sense of boundaries for performing tasks in a safe environment, which transmits culture and ensures continuity in living our values and ethics.

In our view behaving ethically is at the heart of what it means to be a professional. It distinguishes professionals from others in the marketplace. that made us, its subsidiaries and all their employees daily demonstrate their commitment and accountability to ethical behaviour by adhering to the Code of Conduct and its ethical standards.

If we do business the right and responsible way we will be a better business and a more successful one - one that truly stands for our three core values “all for one”, “we care” and “accountability & commitment”.

Our Code of Conduct and Ethics is based on our core values and is one way to put our values into practice:

ALL FOR ONE. All members of our group support each of the individual members, and the individual members pledge to support our group. An ecosystem where transparency, fairness and consistency are crucial to our success. Our rule is simple. We believe in a culture of us.

WE CARE. A culture which enables and encourages us to speak up in case of problems, risks and misconducts. We care, we excite and always thrive to challenge the status-quo. Care what is right vs. who is right. We know progress is more important than perfection. We are aware that business is change and therefore we are on the offense. All the time.

ACCOUNTABILITY & COMMITMENT. We are organized like a start-up. An organization where every single one of us is taking responsibility for whatever they do. We know that committing to our customers, co-workers and shareholders will end up in meaningful solutions. We believe that doing is like wanting, just so much more efficient...

These values represent our family. A family where trust is crucial to well-being and success. Trust, that made us.

This Code applies to everything and everyone

Our Code is owned by each employee of that made us and of its subsidiaries and sets the principles and standards we have defined for ourselves. It covers our dealings with our stakeholders and counterparties and last but not least with how we deal with each other. It is the basis for all our policies, guidelines and procedures. We do – in fact – choose our co-workers, clients & suppliers under these same principles.

Ignorance is not an excuse

As part of our company introduction and training program everyone at that made us learns about the standards in the Code and how to apply them.

All employees, company sites and partners should only do the right thing – act honorably, treat co-workers, clients & suppliers with courtesy and respect. Not knowing the Code is no excuse for violating it.

Our Leadership & our Code

This Code has the full backing from the Board of Directors and the Executive Board of all that made us and its subsidiaries. Every one of us needs to make sure that our business conduct and decisions follow those standards set out here. Foremost we must put the interests of our clients, the company and the shareholders first.

Once a year the Board of Directors will review the Code to ensure that the key developments with regards to our customers, employees and key stakeholders are reflected in this Code.

Conduct Framework

Our Code of Conduct looks at three dimensions on how we interact with each other and with our environment:

INSIDE VIEW - Our responsibility towards one and each other

Business Information and Technology

We use our information technology securely and cautiously to maintain the highest confidence our clients award us with. Information security threats are evolving rapidly and becoming always more sophisticated. We carefully store, treat and retain business information and treat it with the utmost care.

Business information may include requirements, specifications, transactional data, contracts, strategies, communication or any other information we receive from our business partners as well as co-workers. Information technology is any software or equipment used to send, store or transform images such as text, images, video, audio, data or general information.

Example: I got an e-mail that looks like from our accounting department. This e-mail asked me to review an attached contract. As the sender e-mail looked suspicious I immediately informed our IT department that I may have been subject to a virus. Thanks to my fast response no harm was done.

Communication

We communicate in a truthful, transparent and thought through manner.

How we are perceived is heavily influenced on how we communicate. Our brand is built by a timely, accurate, clear and open communication. It helps to preserve that made us’s reputation and the reputation of its subsidiaries. This is why we are careful how we communicate with one another, with our clients and other stakeholders.

Communication includes everything in written, speech, information sharing at conferences and gatherings on digital (for instance social media, mails, instant messaging) or physical channels.

Example: At a recent industry gathering I was asked by a journalist to give an interview for insights on a specific customer project. As I’m worried that I might expose some sensitive information about the project, I first contacted the account manager and my supervisor for guidance.

Conflict of Interests

All decisions we make are in that made us and its subsidiaries best interest.

Conflicts of interest may improperly affect our judgment, objectivity or loyalty. They can expose us to reputational, legal and financial risk.

Conflicts of interest arise when our personal interests interfere with those of that made us or those of its subsidiaries. Whenever we have a conflict of interest, we are transparent in disclosing our personal interest and we remove ourselves from the decision making. This behaviour fosts an open and fair environment.

Conflicts of interest may arise from personal relationships, financial interests or external positions or activities. These could negatively affect our individual performance or company interest.

Example: I’m in charge of hiring a new developer to our team. A distant relative applied and while she might be suitable for the position, I am biased. I therefore disclose this to human resources and take myself out from the decision making process.

Preface

A diverse and inclusive environment where everyone is treated with respect and without discrimination or harassment is our standard - nothing less.

Different talents, perspectives, backgrounds allow us to better understand our clients and to create richer and more meaningful solutions. Working together in such a diverse and inclusive environment enriches the team spirit and increases productivity.

We are committed to a supportive work environment, where employees have the opportunity to reach their fullest potential. At that made us we are all expected to do our utmost to create a workplace culture that is free of harassment, intimidation, bias, and unlawful discrimination.

We are fully committed to fair and equal treatment. We provide equal opportunity for all individuals to develop professionally. This is valid regardless of age, race, ethnicity, nationality, gender, religion, sexual orientation, disability or any other class protected by law.

Example: A recent colleague has great ideas but rarely choses to share them in the team meeting as other colleagues take all of the airtime and he is afraid to speak up. Since I know how valuable particularly a new perspective can be I encourage the team to listen to him. If this does not work I will speak to my manager.

Fraud

We behave honestly and in a transparent way to do legitimate business purposes.

Engaging in intentionally misleading or deceitful activity constitutes fraud. We are committed to ensure the highest standards of integrity and do not tolerate any form of fraud. Acting with the highest integrity fosters trust and builds a solid brand and reputation while increasing the customer loyalty and mutual respect.

Examples of fraud include theft of property, falsification of information, submitting dishonest timesheets and/or claims.

Example: End of the month I’m asked to turn in my timesheets. As I forgot to track my time beginning of the month, I’m tempted to estimate the hours worked. On the other hand I know the recordings must reflect reality. So instead of making up the hours, I try to construct the worked time based on the e-mails sent throughout the day and I do inform my supervisor.

Health, Safety and Security

We keep our workplace free from anything that endangers our health, safety or security.

Vital to our well-being and team spirit is a healthy, safe and secure working environment. Our value “all for one” also encourages us to look out for another’s health and safety. Acts that undermine or damage our community are not tolerated.

We proactively avoid, detect and assess hazards. We follow security procedures and report accidents, injuries, unsafe practices and conditions in a timely manner. We only engage in activities that allow us to conduct our work safely, effectively and always plan for business continuity.

Example: In our latest office anyone can enter our building without identification or batch. Anyone just can walk into the office without registration. As I want to keep our workplace safe I report this instantly to our office manager.

We are a dog company

We like any form of beings. Dogs especially.

And they are welcome in our offices. However, before bringing your canine companion to the office, please make sure to speak with your manager upfront about the guidelines.

Dress Code

Dress well.

Dress well, come in the office how you feel good. Is it wearing a tie - go for it! Is it more casual, go for it! Just dress simply better and more conscious than on the beach ;)

Intellectual Property

Knowledge is the key to our success, we are therefore obsessed in both the creation and protection of it.

Although we believe that the future will be about wisdom, creativity and LQ, knowledge is still a key part of that made us and its subsidiaries. Our ability to offer our expertise and to keep on building the above these are key to success and most important to our clients and reputation. We therefore protect it all the time at all costs. We respect the intellectual properties of others since not doing so can cause financial and reputational damage.

that made us and its subsidiaries own all intellectual property we create during the course of our work. Some of the intellectual property we get in touch with is owned by our clients. Even after we leave the company, it remains the property of that made us, its subsidiaries or the clients. Intellectual property could include strategy documents, requirements, software specifications, source code or transactional data.

Example: I recently got my laptop replaced. The old laptop does contain source Code from several client projects. As I recall that this might be sensitive for our clients I pro-actively clean up the laptop before I turn it in to our IT department.

Whistleblowing

We actively speak up if actions we observe are against the Code of Conduct and therefore may harm the company's future.

We immediately report any potential violations of laws, rules, regulations, policies, professional standards and the principles laid out in this Code of Conduct to our manager or human resource department.

Any form of retaliation against whistleblowers is unacceptable.

We expect our line managers to escalate and report any violations of laws, rules, regulations, policies, professional standards and the Code of Conduct.

Example: During a recent customer visit I noted that one of my colleagues copied data to an USB stick. As we are usually working in the client environment I found this highly suspicious. I therefore informed my line manager.

OUTSIDE VIEW - our responsibility towards our business partners and society

Bribery and Corruption

We conduct business in a fair fashion without accepting or offering benefits intended to improperly influence the decision making.

We do not engage in bribery and corruption in any way. It is not only illegal but also compromises our integrity and reputation and undermines fair market opportunities. A long-lasting relationship with business partners is based on a truthful and ethical exchange. Trust is the most powerful quality indicator for our family.

The giving and receiving of gifts, hospitality, charity or sponsorships must never improperly influence our decision or those of our business partners. This includes bribes indirectly made through third parties.

Example: During a recent business trip to a client I observed that the account manager in a quiet minute gave the client a white envelope. As I found this highly unusual and suspicious I reported this anonymously using our whistleblower site to the management.

Data Protection

We handle personal data with the utmost confidentiality and use it only for legitimate and specific business purposes.

Our clients and stakeholders expect us to process and protect their personal data properly and with the greatest care. Data protection is vital to the trust we earn from our stakeholders and it allows us to conduct our business effectively and securely. Personal data is any information that can be used to identify someone such as a name, address, data of birth. The same applies to confidential information of our competitors. We respect them and want to compete with them in a fair manner. But we do not want their or a former employer’s confidential information.

Example: I recently got a dataset from one of our clients for test purposes which includes their whole staff with what appears to be real data including the date of birth or private address. While I understand that test data is best as close as real world data, I talk to the client first on ways to get a fully anonymized data set. As this was not possible for my client I will talk to my manager to make sure we can put additional security measures into place.

Sustainability and Human Rights

We deliver products and services that do not compromise our future.

Sustainability is at the forefront of or our business and behaviour. Taking this long term view helps us to improve our economic efficiency, protect the environment and contributes to sustainable development of societies in the countries we are active.

that made us and its subsidiaries are dedicated to corporate responsibility and intends to sign the UN Global Compact and is committed to implementing its ten principles in the area of human rights, labour, the environment and anti-corruption. Human rights are the basic standards needed to lead one’s life with dignity.

Our respect for those principles allow us to develop a balanced approach to our decisions. We select business partners that share these same values.

The ten principles of UN Global Compact include

Human Rights:

Principle 1 : Business should support and respect the protection of internationally proclaimed human rights

Principle 2 : Make sure that they are not complicit in human rights abuses

Labour

Principle 3 : Business should uphold the freedom of association and the effective recognition of the right to collective bargaining

Principle 4 : The elimination of all forms of forced and compulsory labour

Principle 5: The effective abolition of child labour

Principle 6 : The eliminiation of discrimination in respect of employment and occupation

Environment

Principle 7 : Business should support a precautionary approach to environmental challenges

Principle 8: Undertake initiative to promote greater environmental responsibility

Principle 9 : Encourage the development and diffusion of environmental friendly technologies

Anti-Corruption

Principle 10 : Business should work against corruption in all its forms, including extortion and bribery.

ENVIRONMENT - our responsibility towards the planet

Environmental Compliance

We comply with all applicable legislation and sustainability commitments. We strongly believe in a lean approach whatever we do. We care about all the resources we have and try to handle them with care and consciousness on a daily basis.

Offices

We rent eco-friendly, modern offices that are appropriate in size and incorporate energy efficiency measures.

We are in a very collaborative discipline and as such meeting people in person at different locations is a key element. We however strive to reduce our office footprint and rent location which are state of the art in terms of energy consumption and efficiency at the cities we are located. Our office fits the current and projected size of the next 2 years thus reducing spare capacities.

Example: Wherever possible we are using a “hot-desk” approach with dedicated spaces for collaboration instead of a fixed office, fixed desk allocation.

Waste and Recycling

We separate waste in all our locations and have it recycled wherever possible.

As a company we prevent pollution and reduce the consumption of resources through waste management strategies that promote waste minimisation re-use and recycling wherever appropriate.

Example: An employee leaves the company within the first year. As his laptop was acquired less than a year ago we will have it re-used with the next employee that enters the company.

Smart Resource Management

Thoughtful consumption of resources is also applicable to spending time and / or money. We prefer to spend our resources wisely. Plan your time and also the time of others sensibly. Also if you’re uncertain about whether you should spend money or submit an expense for reimbursement, check with your manager.

Transportation

How we move drives our main energy consumption as a consulting company.

Part of our job is to travel to different locations at our clients to deliver our service. Therefore, the mode of transportation we choose is a major driver for our energy consumption as a company. We therefore always strive to have the best economical/ecological ratio, to balance the travel time with the carbon footprint we incur.

Example: Some clients require our specialists to work on premise. For employees which do travel often we cover the public transportation costs in favour of reimbursement of individual transportation.

Physical and Virtual Meetings

A virtual meeting might be more efficient and sustainable. They may reduce our carbon footprint and allow us to work more efficiently. Nevertheless, for that made us and its subsidiaries, personal meetings are and will always be a crucial cornerstone of its company’s values and success. It is still a way to express our appreciation towards one another. Therefore, carefully decide whether you conduct a virtual or personal meeting.

For meetings outside our work location or country whenever possible and feasible we aim for virtual meetings in order to respect our responsibility towards the planet and our resources. We do support technologies that enable us to work virtually and synchronously.

Example: The monthly management meeting at one of our subsidiaries has been held in person so far. As one of the board members however needs to fly in, we changed it to once a quarter in person while the rest of the meetings are virtual.

Conclusion

We will never be able to describe every possible scenario. If you find yourself in an unexpected situation, apply these standards to the best of your judgment, seek guidance or simply ask your manager or HR for help.

We trust you will make the right decisions for our organization and your co-workers. Never forget to put personal resentments or personal enrichment aside and always see our organization at the center of your attention. Treat any human being respectful. At any time for any reason. We trust you will make the right decisions.