ESG Policy

‍MISSION & AMBITION

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Mission and Motivation

eGroup is Europe’s leading provider of smart office services for freelancers and small businesses.

In view of its aim to grow, eGroup is conscious of the impact that its business conduct may have on the planet and the people living on it.

eGroup believes that conducting business in an environmentally and socially responsible manner is essential to a truly successful venture.

That is why eGroup commits itself to building a sustainable business in the long-term by achieving its sustainability objectives in the Environment, Social and Governance (ESG) domains.

Objectives and Communication

Through this Policy, eGroup intends to introduce to its Customers, Investors and Employees its commitment to achieving full ESG sustainability.

In particular, eGroup considers that the implementation of an ESG policy ensures:

a Better Protection of the Environment → Our emissions are predominantly caused by the energy consumption of office locations, online marketing services and business travel. eGroup is strongly committed at progressively reducing the degree of Carbon Intensity of its activities until reaching Carbon Neutrality.

b Better Protection of the Customers → Processing large volumes of sensitive customer information means exposure to cybersecurity risks. Ensuring Customers' Data Security is vital.

c Better Working Environment Standards for Employees → Customer satisfaction is directly related to Employees' well-being at work, which includes a positive working environment and the offer of attractive career opportunities.

d Higher Value for the Company → ESG's standards are known as the three central factors that investors use to make a decision on whether to acquire or invest in a business. Attaining ESG goals is critical to ensure that the value of the company is not affected by non-sustainable practices.

‍Beliefs and Definitions

eGroup focuses on the following ESG Key Themes:

Energy and Carbon (Environment)
Talent Management and Retention (Social)
Service Quality (Governance)
Data Security and Privacy (Governance)
Integration of Sustainability Principles (ESG)

FOCUS & APPROACH

Materiality is assessed in each ESG domain by focusing on a defined set of Material Themes, which are related to the ESG Key Themes.

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Guiding principles and Criteria

eGroup measures its ESG achievements in the Environment, Social and Governance domains by classifying its commitment according to a series of Assessment Categories, such as being Innovative, achieving Excellent results, implementing Best Practices and being Committed.

The following sections show progress made by eGroup on the relevant ESG Key Themes and the related Material Themes as well as the Methods used by eGroup to monitor its ESG performance.

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ENVIRONMENT

Energy & Carbon

eGroup acknowledges that its business activities might have adverse environmental impacts, and may contribute to a greater or lesser extent to issues such as climate change, resource depletion, waste and pollution.

eGroup's aim is to neutralize these impacts as much as possible.

That is why eGroup aims at becoming a Carbon Neutral Company.

With regard to the Energy & Carbon Key Environment Theme, eGroup has focused on the following Material Themes:

Carbon Intensity Reduction

Energy Regulations

Business Travel

Metrics and Targets

eGroup undergoes an annual Carbon Footprint Assessment.

The assessments focus on 3, main scopes:

a) Direct Green House Gas (GHG) emissions occurring from sources that are owned or controlled by the company

b) GHG emissions from purchased electricity, heat or steam consumed

c) Indirect GHG emissions from value chain.

Monitoring and Reporting

In order to achieve its Carbon Intensity Reduction Targets, eGroup decided to implement a Science-based Targets initiative (SBTi), the most ambitious strategy for companies wishing to reduce their Carbon Footprint in the long-term.

Science-based targets are in line with scenarios deemed necessary by climate scientists to meet the goals of the Paris Agreement about limiting global warming to a maximum of 1.5 ºC.

Under this program, the companies’ emissions are regularly monitored, reported on and disclosed annually, to track progress on reaching the submitted targets.

eGroup is Committed to ensure the achievement of its Carbon Intensity Reduction targets, which are as follows:

Ensuring adherence to the Energy Regulations in all the countries where eGroup operates, by implementing an Environmental Management System (e.g. ISO 14001, ISO 14064-1) with comprehensive monitoring
Achieving Energy efficiency targets of >2% per year and Science-based Carbon Targets

Implementing a Multi-year OPEX and CAPEX Plans on Energy and Carbon Reduction
Ensuring that >50% of the electricity is derived from Renewable Sources (including RECs)
Implementing a reduction in electricity consumption by intelligent power saving and LED
Evaluating suppliers based on their ESG activities
Providing Free-Charge Stations for electric cars to employees
Implementing a Travel Policy and Expense Tracking with the goal to reduce the CO2 footprint of business travel by substitution with Video Conferences and avoidance of short-distance flights. The CO2 impact of remaining necessary business travel is compensated.

eGroup has shown Excellent Results in Reducing its Energy Consumption to an absolute minimum and Implementing an Energy & Carbon Strategy aligned to reach Carbon Neutral Operations by ensuring that:

Offices in Germany and Italy procure renewable electricity. eGroup offsets grey electricity and business travel emissions through CO2 compensation programsIn the near future, all new energy contracts are from renewable sources. The company’s sourced data centre in Berlin, where the majority of servers are stored, procures renewable electricity (including RECs1)
eGroup shifts more and more services to CO2 neutral cloud providers
Smart office facility management to reduce emissions from operations include installing LED lights and smart heat valvesOffering electric car charging stations for employees, subsidizing public transportation tickets and company bicycles.

Also, eGroup has shown Best Practices in:

Developing YoY Efficiencies of > 2% and Average Carbon Reduction of 7% or aligned with 1.5°C climate scenario
Ensuring that Critical energy-intensive processes or machines are replaced by more Energy-Efficient Alternatives
Implementing Onsite Renewable Energy Production, where >75% of the energy is derived from renewable sources (including RECs).

SOCIAL

eGroup values its Employees’ health and safety.

eGroup strives to ensure proper and safe working conditions within its operations and throughout its supply chain in order to provide high-quality and safe services.

We believe that a prerequisite to ensuring Customers' satisfaction is that Employees feel at ease in a safe, inclusive, and livable working environment, where they can achieve their personal aspirations.

Indeed, eGroup believes that offering attractive Development Opportunities and a positive Working Environment can enhance Productivity as well as Retention Rates.

Talent Management & Retention

With regard to the Talent Management & Retention Key Social Theme, eGroup has focused on the following Material Themes:

Employee Well-being

Fair Labour Conditions

Talent Management

Monitoring and reporting

eGroup regularly monitors its Social performance by:

Ensuring that its Human Resources Department is endowed with proper operative tools and an open-mind to support employees in the best possible way
Conducting surveys to collect feedback and idea^[1]

For the benefit of its Employees, eGroup is Committed at:

Ensuring proper training to Employees by extensive training on the job, mentoring and coaching and additional external courses
Attracting and retaining diverse talent by offering flexible employment conditions (e.g. possibility of remote working from abroad)

Implementing KPIs and targets on Employees retention and engagement
Providing an E-Learning management system and Cooperating with E-Learning Partners
Providing Employee benefits including flexible working hours, subsidies for public transportation, relocation support and contributions to fitness club membership, among others.

GOVERNANCE

eGroup has a focus on best-practices for Corporate Governance and Business Integrity, as well as for Fair Management.

The Company and its Employees adhere to the Company's Code of Conduct^[2] and must at all times exhibit honesty, integrity, fairness and respect in any business dealing.

Data Security & Privacy – Service Quality - Sustainability

With regard to Data Security & Privacy, Service Quality and Integration of Sustainability Principles Key Governance Themes, eGroup has focused on the following Material Themes:

Business Integrity

Data Security

Service Quality

Continued ESG Policy Implementation Monitoring

Business Integrity

With regard to Business Integrity, eGroup formalized in its Code of Conduct its Principles and Best Practices to fight:

Corruption
Discrimination
Conflict of Interest
Abusive Gifts and Benefits
Unfair Competition Practices
Money-laundering

eGroup grants Whistleblowing Protection in order to make sure that any unfair or illegal practice that may occur in our daily business are known and properly dealt with by the Management.

Data Security and Privacy Protection

Also, ensuring Data Security and Privacy Protection is key to our Governance Sustainable Practices.

With regard to Data Security and Service Quality, eGroup is Committed at:

Ensuring Service Quality through the implementation of a Quality Management System (ISO 9001)
Ensuring a Data Security Management; eGroup information security management system was certified in 2021 according to ISO 27001
Ensuring Organizational Structures with specific Data Security & Privacy Management Roles assigned
Implementing Employee Awareness in Data Security and Privacy Protection
Implementing an Action Plan to improve Customer Satisfaction.

Monitoring and Reporting

With regard to the Continued ESG Policy Implementation Monitoring, eGroup ensures an Annual Monitoring and Updating of its ESG Policy and is committed to implementing an ESG Action Plan with Key Performance Indicators and Targets.

eGroup regularly monitors its Governance performance by:

Constantly Monitoring NPS and Customer Health Score
Regularly monitoring Clients' Feedback and conducting surveys^[3]
Implementing a Company-wide Action Plan with Key Performance Indicators (KPIs) to evaluate and update Data Security and Privacy Protection Processes on an annual basisHaving organizational structures with specific Compliance, Data Security & Privacy roles assigned (e.g. Compliance Manager, Data Protection Officer, Chief Information Security Officer).

eGroup has shown Innovative Practices at:

Ensuring Long-term Processes for a Preventive Approach to Data Security & Privacy Protection, establishing an industry-leading track record
Embedding Long-term Improvement and Continuity Processes into the Company Operations and Culture.

eGroup ensures proper Reporting and Review of Financial and Tax Information by Annual Audits.

Roles and responsibilities

eGroup's has entrusted some of its officers and managers with ESG adherence oversight, which includes carrying out checks on the advancement of the ESG Action Plan and handling escalations of ESG breaches.

Controls and escalations

Managers and Officers responsible for the implementation of the ESG Action Plan are as follows:

· CEO

· COOVP Finance

· VP Marketingthe Head of IT

· the HR Team Leader.

For any queries about this Policy, please contact:

eGroup Holding GmbH

Roland Becker (COO)

Haupstr. 8, 10827 Berlin

Germany

E-Mail : roland.becker (at) egroup.io

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^[1]eGroup conducted an employee engagement survey in Q4 2020. Results show that 78% of participants were very satisfied or satisfied and only 1% were unsatisfied.

^[2] (Available at this link: https://www.egroup.io/code-of-conduct)

^[3]A Clients' satisfaction survey was conducted in 2021.

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