eGroup Code of Conduct

The eGroup is a pan-European provider of telephone secretarial services and business center services. As an employer, business partner and with our growing social commitment, we assume economic, ecological and social responsibility in everything we do.

Since the foundation of the company in 2001, cooperative and always trustful behavior towards our business partners has been an essential part of our values.

I. Ethical principles and core values

In recent years, we have succeeded in changing the culture in the company and aligning it with the future. Our values help us to further drive and establish the new culture throughout the eGroup.

Each of the three brand values - reliable, caring, as well as smart - is broken down into additional points to make it easier for our team members to interpret them correctly. But what do the values mean in concrete terms? How do I live them, and what impact does that have on everyday work?

An overview:

Reliable

Our promise is to provide clients with an impeccable market presence. Our clients place their most valuable asset in our hands – their customer contacts.

That calls for absolute reliability on our part. Thanks to our extensive experience stretching back more than two decades, our thoroughness and our efficiency, our customers are able to place their full trust in us.

Caring

We believe that a good partner must be understanding and supportive.

Our empathy for the needs and wishes of our clients, our commitment to them and our desire to support them in the best possible way are what make us truly caring.

Smart

Enabling others to grow and succeed calls for solutions that go beyond the everyday.

Since our beginnings we have been open and curious, always ready to question the familiar. That makes us particularly creative and innovative. Indeed, our ambition is to lead and shape our entire industry.

 

II. eGroup and our team members


1. Anti-discrimination

We respect differences and treat each team member with respect. Diversity, equal opportunity and tolerance are paramount to us, and we respect the personal dignity, privacy and personal rights of each individual. Each of us is entitled to fair, dignified and respectful treatment.

For this reason, we do not tolerate discrimination in the workplace and want to ensure that no one in our large eGroup team is discriminated against. This applies both to dealings with colleagues, customers and business partners and to personnel-related decisions such as hiring, promoting or dismissing employees.

2. Anti-bullying

We are an attractive employer and provide a pleasant working environment. We treat all team members, customers, business partners and other stakeholders fairly and with dignity and respect at all times.

Due to the aforementioned reasons, any form of bullying, including physical, sexual, verbal or other harassment, is prohibited and will not be tolerated.

eGroup has a zero-tolerance policy towards bullying.

3. Conflicts of interest

We are expected to act in the best interests of the company, which means that eGroup business decisions should be made free of any conflict of interest. After all, even the appearance of a conflict can damage the reputation of the individual and/or the company.

To achieve this, there are operations that may only be carried out if they have been approved in advance by a member of the Board of Directors.

4. Protection and proper use of the company's assets.

We respect the company's property and the property of third parties such as our customers and business partners. For this reason, we treat all property with care. Everyone in the company is personally responsible for protecting our company assets from loss, destruction, misuse, theft, waste or other damage. It should be noted that the protection of property refers not only to tangible assets, but also to intellectual property such as copyrights and trade secrets, which we also use in accordance with applicable law and within the scope of permissible use.

As a matter of principle, we use the company's property for business purposes only. Unless otherwise agreed, company assets may not be used for private purposes. Under no circumstances may it be used for illegal purposes.

In addition, the purchase and sale of company assets must be transparent, understandable, cost-effective and at fair market conditions. Personal interests of individual employees must not influence decisions and business transactions.

III. eGroup and our external partners

A. Combating corruption and bribery

Corruption is the abuse of one's position, of whatever kind, for one's own benefit or for the benefit of another person. Corruption has nothing to do with our corporate values. It harms competition, hinders fair play and exposes the eGroup and every team member to unnecessary liability risk.

For this reason, we pursue a zero-tolerance policy towards bribery and corruption in any form. We do not take bribes from anyone, and we do not bribe anyone else, which means that we must not give or receive anything of value if it could create the impression that we are granting or receiving improper benefits.

This prohibition applies not only to government officials, employees of regulatory authorities and other public servants, but also to employees of business partners in Germany and abroad, as well as to our colleagues.

Corruption prevention is the duty of every employee. We reject all forms of corruption and ensure that applicable anti-corruption laws are always complied with and wherever we do business. We promote anti-bribery and anti-corruption practices to everyone who works for our company. We do not knowingly allow or ignore evidence that anyone is acting on our behalf to pay or receive bribes or kickbacks.

B. Invitations, Gifts & Benefits

In many countries, it is normal business practice and a sign of respect to exchange gifts.

However, the granting and acceptance of invitations, gifts and other favors may also give rise to suspicion of corruption. In this context, it is necessary to prevent the appearance and suspicion of such an offense.

We are confident that our team members will be guided by common sense and judgment when giving or receiving gifts or invitations, and that they will never make gifts with the aim of gaining a competitive advantage.

C. Donations, grants and sponsoring

As a responsible member of society, we are not afraid to assume social responsibility. Therefore, the promotion of education, science, environmental protection, art, culture, social issues and sports is an important concern for us. This support takes the form of monetary and in-kind donations for non-commercial and charitable purposes; eGroup can also act as a sponsor of events and projects for the above-mentioned purposes.

However, we never make donations or other contributions to obtain business or other improper benefits for eGroup, that is, benefits that cannot be obtained honestly or legally, or if they create the appearance of bribery. Sponsorships and donations are only granted in accordance with applicable laws and regulations to prevent corruption and conflicts of interest.

D. Compliance with competition law regulations

1. Fair competition and antitrust law

We place great emphasis on free and fair competition and help combat practices prohibited by competition and antitrust laws. We strive to compete fairly and ethically under all applicable competition laws because anti-competitive practices can harm the Company's business and reputation. Accordingly, we never discuss prices or pricing components, such as discounts or payment terms, with competitors.

2. Subsidy fraud and incitement to subsidy fraud

To ensure free and fair competition, our contribution to combating prohibited practices under competition law also requires us to take strict action against fraudulent practices, in particular subsidy fraud.

Subsidy fraud involves the misrepresentation of subsidy-relevant facts to the subsidy provider by means of false information or certifications, or the use of material or monetary subsidies in contradiction to subsidy conditions.

3. Prevention of money laundering

The cross-border exchange of services is an important component of our success as an internationally active company. We comply with all legal requirements in this context without exception. In addition to the rules already mentioned for imports, exports, domestic trade, international sanctions and trade restrictions, we ensure that we also comply with the legal requirements for the prevention of money laundering.

Money laundering occurs when assets of criminal origin are concealed (i.e., "laundered") through legitimate transactions and business activities or when legitimate funds are used to support criminal activities.

Each team member must comply with money laundering laws and immediately report any suspected case of money laundering (of employees, customers and business partners) to the internal Money Laundering Officer.

eGroup only works with reputable business partners who act within the framework of the law and do not use illegal financial means.

4. Insider trading

We comply with the regulations on insider trading.

It is prohibited to use insider information, including information from other companies, when trading in securities or other tradable financial instruments, and to pass on insider information to others for such purposes.

Insider information is concrete information about circumstances which are not publicly known and which, if they became known to the public, could significantly influence the price of securities or similar financial instruments. Examples of such circumstances are profit increases and decreases, major orders, plans to merge or acquire a company, significant new products or changes in management.

IV. Data handling

A. Privacy, confidentiality, data protection and data security

As an internationally active company, eGroup considers the use of modern information and communication technology to be an essential part of our business processes. We protect the rights of team members and others to privacy and data protection and maintain the confidentiality of all information worthy of protection, regardless of whether it concerns our colleagues, customers, business partners or other involved parties.

We treat company-related and personal data in a confidential and professional manner in accordance with national and international data protection laws. Personal data may only be collected, used and stored in accordance with applicable laws. This means that we exercise great care and strict confidentiality when collecting, storing, processing or transmitting personal data from family members, customers, suppliers, competitors or other third parties. Confidential information also includes all non-public strategic, financial, technical or business information as well as all trade or business secrets of our business partners.

To ensure effective data protection, eGroup has set up a data protection organization with an internal data protection officer.

B. Information technology and internet use

In connection with our use of modern information and communications technology, we regularly use IT systems in our day-to-day business.

For this reason, our employees are expected to assist the company in protecting the entire computer system infrastructure and data against intentional malicious acts by persons inside or outside the company. We take great care with the content of emails, attachments, downloaded files, and stored voice resources. We ensure the security of our passwords and do not share them with other employees or third parties under any circumstances. We are also mindful in the use of our communication media such as social media channels.

V. eGroup and society

A. Communication

1. External communication

Open communication and honesty with our customers and business partners is very important for successful cooperation and the company's overall success. We therefore communicate company information intended for the public and not subject to secrecy in an honest and transparent manner.

Internal company information that is not intended for the public is always treated confidentially. If we are in doubt as to whether corporate information may be disclosed to the outside world, we treat it confidentially and forward the inquiry to the legal department for a further decision on its response. This applies in particular to press and interview requests.

In social media channels, we treat eGroup, our products and our colleagues, as well as our customers and business partners, with respect and formulate public statements of opinion in such a way that it is recognizable that they are private opinions and not the opinion of the company.

2. Handling records

Regarding our documentation, we are committed to ensuring that information, data and documents are always complete and that the documentation is truthful. Our business records must meet the highest standards of accuracy and reliability and always comply with applicable regulations.

It goes without saying that we also comply with the statutory obligations to retain, delete and document records.

B. Social responsibility

In our view, every company has a social responsibility towards people and nature. Our aim is to take a leading position in the area of corporate responsibility towards society. As a company operating throughout Europe, we base our actions on international agreements and guidelines. These include the United Nations Declaration of Human Rights, the United Nations Global Compact and the OECD Guidelines for Multinational Enterprises.

1. Towards people

Considering this, it is very important to us to provide a safe and healthy working environment in which team members do not have to fear injury or illness.

For this reason, we reject any form of exploitation or discrimination and ensure strict compliance with the relevant laws. We comply with the law to ensure fair working conditions, including regulations on compensation, working hours and privacy. In addition, we are committed to acting in accordance with human rights and in compliance with the rules against child labor.

In the interest of the health and safety of all our team members and visitors, each employee must comply with applicable laws, regulations and standards governing workplace safety. It is the responsibility of management to ensure that appropriate procedures and safeguards are in place to ensure health and safety in the workplace.

It is important to us that these instructions are also implemented and followed in our own supply chain; we expect the same from our employees, customers, suppliers and other business partners.

2. Towards our environment

We also take our social responsibility regarding nature and our environment very seriously and act sustainably. In the provision of our services, we make every effort to maintain the ecological balance, avoid environmental pollution and - particularly in the selection of service providers supporting us - conserve scarce natural resources (water, energy, materials and soil), thereby contributing to the reduction of CO2 emissions.

Each team member is jointly responsible for environmental protection in his or her area of work and undertakes to comply with the laws, regulations and standards relating to environmental protection.

VI. Reporting and whistleblowing procedures

A. Reporting and protection against retaliation

At eGroup, we live the "speak up" culture. Questions can be asked and concerns about possible misconduct expressed at any time. Our interactions should be characterized by mutual respect and trust, so that we can discuss misconduct in an open and constructive dialog.

To ensure that this “speak-up” culture and the conduct of all employees comply with this Code of Conduct, applicable laws and regulations, and our internal policies and organizational directives, we rely on the support of every team member. Violations can be reported in person through direct contact with the supervisor, the Compliance Officer, by e-mail or by telephone (anonymously).

On the other hand, eGroup ensures protection against retaliation for reporting concerns of any kind. Care will be taken to ensure that team members who report possible violations in good faith and without malicious intent will not suffer any disadvantage as a result. In addition, no one who participates or cooperates honestly in our company's investigation will be subject to retaliation. Any actual or threatened retaliation will be considered a serious violation of this Code of Conduct and will result in consequences.

B. Contact and Compliance Officer

If you have any concerns or questions about this Code of Conduct, you can talk to people in your immediate work environment, such as your supervisor. You can also contact the appropriate department, for example, Human Resources for questions about employment contracts.

If clarification is not possible with the supervisor or the responsible specialist department, or if you still have concerns, the Compliance Officer is available as a contact person. The Compliance Officer can also be contacted directly and anonymously at any time if desired.

If violations of the Code of Conduct become known, there is even an obligation to inform the Compliance Officer immediately.


Contact details of the Compliance Officer:

eGroup People & Culture GmbH

RA Clemens C. Vogelsberg
Hauptstraße 8
10827 Berlin
Germany
Telefon +4930 / 52004 1202
E-Mail:  compliance@egroup.io

Berlin, 23/02/2022