Code of Conduct – TIER

Code of Conduct

Introduction

The trust of our employees and customers is Tier´s most important asset.

We have a shared responsibility to live up to this trust by conducting ourselves with our core values in mind at all times.

Whenever we notice something that seems to be contrary to those values or if we make a mistake or we see a mistake being made, we have to speak up. Turning a blind eye is never the right solution.

Although this Code of Conduct provides practical examples on issues that arise frequently, it is impossible to anticipate every situation that may arise.

When in doubt, we encourage you to seek advice and to speak up to disclose any situation that may violate laws or our internal policies.

If you are a team leader or manager, you have a particular responsibility to create an environment in which members of your team feel confident and able to raise concerns, to listen carefully to their concerns, and to take all appropriate action in response.

We do not tolerate any violation of the Code of Conduct. Anyone who violates the Code of Conduct must expect consequences, which, depending on the seriousness of the violation, can range from action under employment law to claims for damages under civil law, and may even extend to penalties under criminal law.

To make sure that does not happen, it is up to each and every one of us to familiarize ourselves with this Code of Conduct, to integrate the Code of Conduct into our own behaviour, and to bear the Code of Conduct in mind when making decisions. When in doubt, we should seek advice and speak up.

We therefore encourage you to read the contents of this Code of Conduct carefully and to add your signature as an agreement to the principles set out. We expect all employees to take this Code of Conduct seriously and to comply with the regulations it sets out.

Whistleblower System

When should I use the system?

Whenever you detect a behavior that is not in line with the Code of Conduct or where you feel insecure, or where you feel pressured to act against the Code of Conduct. It can be a minor problem or a big issue: We encourage you to speak up!

What should I do?

Please reach out to confidential@tier.app.

Who will read my Email?

Emails are monitored only by the compliance team. Our whistleblower system is committed to protecting the whistleblower. We do not tolerate pressure on whistleblowers. The whistleblower will stay anonymous as long as the whistleblower does not want to reveal the identity.

What will happen after I submitted a case?

We will take all reports very seriously and investigate thoroughly.

We might ask you at some point of time, if you are okay with us sharing the issue to take appropriate measures. We will never act without your consent.

Is my problem too small?

No! Please always consider that even if you do not feel pressured by the action of another person, how such behaviour could affect others. Please speak up in the interest of other colleagues.

Will any actions be taken?

The action taken depends on the specific circumstances.

No behaviour which breaches the Code of Conduct is tolerated under any circumstances. If you speak up as a whistleblower, you will be protected.

Our Company Values

Trailblaze

We are the pioneers who pave the way for others to follow. We are bold, brave and we push boundaries. We are innovators, problem solvers and creative thinkers. We challenge the status quo and we strive for positive change. We are mavericks and voyagers, creating the transportation of the future for a better world. The people who choose us are like-minded change-makers and trailblazers.

Rise

We strive for excellence and reach further than anyone else to attain the highest standards in quality, not just for our products and our vehicles but also for ourselves. We lift our co-workers, our riders and our partners to reach new heights. We are efficient, competent and cost-effective and we will always rise to the occasion. We rise above problems, adversity and average. We learn and rise when we fall or stumble. When we work together toward our goals, we rise up the ranks, we rise in value and we rise with purpose.

Care

We care about the cities we are in, about the safety and well-being of our riders, our employees and our partners. We are considerate and respectful. We care greatly for the environment. It’s the reason why we are all here and why we exist. Sustainability is at the core and our goals will not be achieved at the expense of others. We are for the people and the cities who care and make choices to change the world for good.

Play

We are like the cities we live in: vibrant, diverse, modern and exciting. We are adventurous, streetwise and we have fun doing what we do. We work hard, but we always remember to play while we do. We take our work seriously, but that is no reason to not enjoy it. Play keeps us alive. We are creative and curious because we play. We learn and move forward because we play. Our value is that we take the dull and make it a joy. We enable our riders to explore the playgrounds we call our cities, free to enjoy every ride.

We offer equal opportunities for everyone

Key Principle

TIER is committed to providing a working environment free from discrimination, harassment and bullying and ensuring that all its staff are treated, and treat others, with dignity and respect. All TIER employees are entitled to receive equal treatment. We do not tolerate any form of racism and nobody shall be either discriminated against or favoured because of their gender, age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. We embrace diversity, actively encourage inclusion and create an environment that fosters each employee’s individuality in the interests of the company. TIER takes allegations of discrimination, harassment and bullying seriously. Anyone found to have breached this policy will be subject to disciplinary action under our disciplinary procedure.

How do I contribute?

I will not unlawfully discriminate against or harass other people, including current and former employees, job applicants, clients, customers, suppliers and visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts), and on work-related trips or events including social events.

Contact Partner

If I am not in a position to influence the events directly, I will immediately notify our People Team of the incident or make contact via confidential@tier.app

Example 1

You find out from a colleague who is a friend of yours that another colleague is not going to be considered for a well-earned promotion because of that person’s gender.

This is discriminating.

Help clarify the situation by reporting the case so that appropriate steps can be taken.

Example 2

One of your colleagues tells sexist jokes during your team meetings.

This is discriminatory and could be deemed to be bullying. It could cause offence to you and your team members.

If you feel uncomfortable or fear that someone else is feeling uncomfortable about this situation, please reach out to confidential@tier.app.

We do not tolerate corruption

Key Principle

TIER is committed to applying the highest standards of ethical conduct and integrity in its business activities. Each employee and individual acting on TIER’s behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally. A bribe is an inducement or reward offered, requested or provided in order to obtain a commercial, contractual, regulatory or personal advantage. It may take various forms and is not restricted to cash payments. The giving or offering of bribes may be a criminal offence. TIER takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.

How do I contribute?

I will not offer or accept benefits to or from business partners, customers or other external third parties except as permitted within the law and TIER’s own guidelines. I will not bribe or give other favourable treatment to others in order to seek to obtain an advantage and I shall never accept a bribe, either directly or indirectly. I shall take responsibility for informing myself by consulting the internal rules before I give or accept gifts, issue or accept invitations, or offer or receive hospitality.

Contact Partner

If I receive any information relating to potentially corrupt activity, I shall immediately inform the compliance team via compliance@tier.app.

Example 1

You prepare a tender application for a city authority. The relevant decision maker at the authority offers to influence the award of the contract in TIER’s favour in return for a cash payment to that decision maker personally.

This is corrupt behavior.

Inform your manager and compliance@tier.app immediately.

Example 2

What if you offer to take the decision maker and her colleagues out to one of the city’s best restaurants to discuss TIER’s chances of winning the tender?

This could be considered to be an attempt to influence the city’s decision.

You must consider whether any hospitality offered is reasonable and proportionate.

We do not tolerate money laundering or terrorism financing

Key Principle

Money laundering occurs when funds or other assets originating directly or indirectly from criminal offences are put into circulation in the legal economy, making their source appear legal. Terrorism financing occurs when money is made available to commit criminal acts of terrorism or to support terrorist organizations.

It is our aim to conduct business solely with reputable partners who operate in line with legal provisions and who use resources from legitimate sources.

How do I contribute?

I shall take no action that may violate money laundering provisions whether in my own country or abroad. I shall be vigilant and investigate any suspicious conduct on the part of customers, business partners and other third parties.

Contact Partner

If there is information providing sufficient grounds for suspicion, I shall immediately notify the compliance team via compliance@tier.app.

Example

A business partner is asking you to accept a cash refund instead of a refund via bank transfer, asks you to pay a third party rather than the contract partner or asks you to agree to misrepresent the quantity or price of products on an invoice.

Ask the partner why the amount cannot be repaid in the same way it was originally paid, or why they want to falsify the invoice.

If the answer does not satisfy the question, please contact compliance@tier.app.

We avoid conflict of interests between private and business interests

Key Principle

If an employee places personal interests above those of TIER, it could damage the business.

All our decisions are made exclusively on the basis of objective criteria and we do not allow ourselves to be swayed by personal interests or relations.

How do I contribute?

I shall avoid even the appearance of any conflict of interest. I shall disclose any potential conflicts of interest to my manager and the People Team so that we can jointly seek a solution.

Contact Partner

If there is information providing sufficient grounds for suspicion, I immediately get in touch with compliance@tier.app.

Example

Your manager asks you to review offers for the implementation of a new tool. You discover that one of the best tools on the market is supplied by a company where your good friend works in sales.

Inform your manager of the situation and withdraw from the decision-making process to avoid any appearance of a conflict of interest.

Product Compliance and Product Safety

Key Principle

It is not only our statutory duty but also our mission to comply with the laws and regulations as well as the internal standards that apply to our services and products.

Our products are state of the art and are developed in accordance with legal requirements.

This is monitored continually and systematically through processes and structures, as well as through product surveillance under real field conditions. We make no compromises on that. We ensure that suitable measures can be taken in good time in the event of any discrepancies.

How do I contribute?

If I notice or have concerns that our products could present a threat or that regulations are not being observed, I shall take action.

Contact Partner

I shall report the matter to my manager.

Even if the rest of my team does not think there is a problem, I will still speak up and bring it to the attention of compliance@tier.app.

Example

A customer reports technical problems with a vehicle to you. You are not sure whether or not the problems are due to a mistake on the customer’s part when operating the vehicle, but you cannot definitively rule out a manufacturing or construction defect.

Clarify the matter. It is essential to ensure that TIER will solve a problem for which it is responsible.

Even customer mistakes when operating the product may require the company to respond (e.g. by modifying operating instructions or user training).

We promote a healthy and safe work environment

Key Principle

We continually work on improvements in the working environment and preventive health-care. We will always do our best to remedy any situation that is unsafe or unhealthy.

How do I contribute?

I shall comply with the occupational health and safety rules issued by TIER. I shall never put the health and safety of my colleagues at risk. I shall take all appropriate and statutory precautions to ensure that my workplace always enables safe working.

I shall speak up if I believe that my working environment is unsafe or presents a health risk.

Contact Partner

I shall speak up if I believe that my working environment is unsafe or presents a health risk. I shall inform health@tier.app or reach out to confidential@tier.app.

Example

I find out that - during the current COVID-19 Pandemic - employees in TIER premises are not keeping the required social distance and are therefore not acting in line with our company policy. I shall inform the employees about the company policy. If they continue, I shall inform health@tier.app or confidential@tier.app.

We preserve our confidential information and respect the confidential information of others

Key Principle

Confidential information is knowledge that is not yet public and should not be disclosed. Confidential information includes trade secrets, business, investment, marketing, operations and service plans, consumer insights, engineering and manufacturing ideas, designs, databases, records, salary information and any non-published financial data or other data.

How do I contribute?

I shall not share any of TIER's confidential information with anyone outside TIER unless I know that I am authorised to do so. I am aware that the disclosure of TIER´s confidential information could damage the company and its business. I shall always seek to enter into a Non Disclosure Agreement with business partners before sharing any of TIER’s confidential information. When receiving confidential information from a business partner, I will secure the shared information so that no one not included in the project is able to review or download the confidential information shared by your business partner.

Contact Partner

When in doubt, I will contact legal@tier.app.

Example 1

A potential partner asks me to share our financial statements with him before entering into a contract with us. I shall inform legal@tier.app and enter into a Non Disclosure Agreement with the Partner before sharing any of TIER’s confidential information.

Example 2

TIER signed a mutual Non Disclosure Agreement with a municipality. The mayor’s office asks for the battery specs and technical drawings of our Scooters. Battery specs and technical drawings are confidential informations from our supplier. We are not allowed to share these without the supplier’s consent.

Please always consider who is the owner of the information which you wish to share. If you are not certain that the information belongs to TIER, please check with legal@tier.app before providing third parties with the information.