Contact Person

Chief Compliance Officer

Policy Owner

Board of Management smart Europe GmbH

The What...

Our Integrity Code governs the main principles of conduct at smart Europe. It covers our corporate principles and behaviour guidelines, i. e. in the following areas:

Complying with laws and internal regulations
Appropriate conduct within smart Europe and in dealings with authorities, government officials, business partners and customers
Dealing with conflicts of interest
Prevention of all forms of corruption
Protection of company assets
Exercising our social responsibility
Handling data
Respect for human rights

We are smart Europe!

We exist to design a smarter future. We stand at the forefront of our industry, creating a future that is more innovative, more connected, more stylish, more sustainable, more optimistic, and, simply, smarter.

We are uncompromising ally for urban life. We harness the power of opposite attraction and accompany twists & turns of life.

We are inspiring creators. We are fearlessly first to take on new ideas & opportunities, energizing others to follow our lead.

We appeal to avant-garde trendsetters. We create and collaborate together to craft new ideas and express ourselves as open-minded global citizens.

We expect all employees to act with integrity. Our corporate values of respect, passion, discipline and honesty are the foundation of our work.

Foreword

Integrity plays a central role at smart. This Integrity Code cannot anticipate every situation in which we have to make a decision. We also take responsibility in situations for which there are no clear rules or are ambiguous. We believe the most important asset of our company are the people who work for smart Europe and the passion with which they do so. We take responsibility for adhering to local laws, rules and regulations, including voluntary commitments. We will abide by this Integrity Code. Honesty, openness and transparency are the foundations of our belief. Our collaboration is based on trust, fairness and respect. The diversity of our workforce is one of our strengths. The conscientious leveraging of diversity and individuality is part of our corporate strategy. Discrimination of any kind will not be tolerated -- our goal is to achieve genuine equal opportunity. We will establish a culture of tolerance -- bullying has no place in our company.

Dirk Adelmann CEO
Martin Günther CFO

The How...

How WE Work: Our Behaviour Guidelines

Corporate information will be handled responsibly. External publications will be coordinated with the PR Department.

smart Europe`s employees have the right of freedom of expression, however, if you express your personal opinion in public, ensure that your personal views are clearly marked as such.

smart creates conditions that support a work-life balance.

We carefully weigh personal interests against the interests of the company.

If conflicts of interest arise, they will be disclosed

Conflicts of interest can arise, for instance, if employees encounter any of the following situations:

accept, offer or grant gifts or invitations

are members of the governing bodies of other companies

pursue sideline activities (as outlined in the employment contract)

invest in business partners and/or competitors (details see below).

We respect human rights and the core labor standards of the International Labor Organization (ILO). Smart Europe rejects all forms of discrimination in hiring and employment, slavery, child labor, threats against people who defend human rights and other human rights violations. We place special emphasis on the protection of fundamental labor rights. We also pay close attention that our business partners, especially suppliers and their subcontractors, respect human rights.

We strive to achieve an exemplary ecological and energy balance worldwide. Our ambition is to develop and sell products that are particularly environmentally friendly and energy-efficient along the entire value chain.

We conduct a reliable dialogue with governments and organizations.

For us, business success and social responsibility go hand in hand. smart Europe contributes to the advancement of society and promotes equal opportunity. When making donations, we do not expect anything in return. Donations and sponsorships require approval of the CEO and CFO.

We use resources carefully and sustainably. As a rule, we use the company's materials, intellectual property, assets and other resources only for official purposes. Exceptions apply when company regulations allow the personal use of company resources.

We protect information because it is valuable. Special protection is given to business secrets. Trade secrets, for example, inventions, new products or vehicle designs, secure our advantage over our competitors. We therefore protect this information to a particularly high standard. We comply with laws and internal regulations for protecting business secrets and respect the business secrets of our competitors, business partners and customers.

Compliance with Law

We are designing the mobility of the future in the safest possible way. We use technological advancements to reduce emissions and greenhouse gases. We ensure the legal and regulatory conformity of our products and we comply with product safety laws and all technical regulations.

We consider the possible impact of our actions in everything we do and openly address potential risks in our areas of responsibility (speak-up culture).

We comply with applicable tax and customs regulations, which include regulations on corporate tax, income tax and value-added tax, as well as the customs duties and excise tax to be paid on imports of goods. We reject aggressive tax avoidance schemes.

We comply with Anti-trust Law. Well-functioning competition is a fundamental pillar of our economy. We are committed to ensure fair competition in our markets and to follow all applicable antitrust and competition laws.

Antitrust risks occur in a wide variety of situations, for example: when exchanging information and benchmarking with competitors as part of investments in shareholdings and during cooperation in connection with customer service and sales regarding the permissibility of sales incentives * when engaging in trade association and retail partner activities.

We comply with all regulations under foreign trade laws. Foreign trade regulations must always be observed when exporting both tangible and intangible goods as well as services. We act with strict compliance regarding embargoes.

We observe economic sanctions and support the community of states to fight against money laundering and terrorism financing.

We design our business processes with the aim of preventing financial crime. Employees of the involved units are required to keep up to date on current sanctions lists. The employees responsible for the business processes are obliged to design these in such a manner to prevent all forms of financial crime.

We do not give or take bribes. We impress our business partners and customers with our products and services and not through undue influence. We also do not allow others to exert undue influence on us. Decisions are made for objective and verifiable reasons.

smart Europe does not tolerate corrupt behaviour by its employees, business partners or customers. Corruption is detrimental to competition and the common good. When dealing with government authorities, we avoid even the mere appearance of an undue influence , for example, through monetary payments, non-cash rewards and other benefits. We follow this rule even when such gifts are expected or supposedly customary for official business.

Through regular training and audits, we ensure that corrupt behaviour is prevented, detected and punished.

When dealing with business partners gifts and invitations (hereinafter collectively "rewards") are permitted within appropriate limits. We reject inappropriate rewards from business partners. Invitations must serve a business purpose and be appropriate for the occasion. This policy should be read and applied in conjunction with the Gifts and Entertainment Policy. In case of doubt whether a gift or an invitation is appropriate, our Chief Compliance Officer has to be consulted.

We document the acceptance of rewards above the reference values. The documentation is carried out by the Chief Compliance Officer.

Rewards given to business partners and customers must be appropriate, we follow the principle that even the mere appearance of undue influence must be avoided. Rewards are permitted only when they have an appropriate value and are given in the context of ordinary business activities. We are cautious and especially critical when determining whether it is appropriate to give rewards to government agency employees, public officials, politicians and employees of government-owned enterprises.

smart Europe expects its employees and those of its subsidiaries to comply with our Integrity Code and laws. smart Europe also expects its business partners, such as suppliers and sales intermediaries, to do likewise.

We subject potential business partners to a risk-based integrity check within the Due Diligence process before entering into any contracts. The employees who are responsible for choosing the business partners are obliged to screen them to the extent allowed by law using a transparent selection process. This process ensures that potential business partners fulfil the requirements and standards of this Integrity Code. Our business partners are required to comply with our Integrity Code after entering into contracts. Our business partners are also urged to require their suppliers to comply with our Integrity Code.

Paid sideline activities (in particular, outside employment) by our employees must be disclosed to the responsible HR manager before employment starts. In the event of a conflict of interest, the sideline activity can be prohibited to protect the company's legitimate interests.

The acknowledgement of a position on a governing body (e. g. supervisory board) for other companies could lead to conflicts of interests and requires approval of the Chief Compliance Officer.

Owning shares in business partners or competitors must not result in a conflict of interest and must be disclosed before joining our company and thereafter once per year.

Digitalization is creating new opportunities that we want to exploit responsibly.

We use personal data only to the extent allowed by law and permitted by data subjects. Our employees, business partners and customers should be able to trust that their data is safe with us. We protect the data of our employees, business partners and customers from being accessed by third parties.

Social networks like Facebook, LinkedIn, Instagram and Twitter are having stronger and stronger influence in shaping public dialogue. Tolerance and respect are important for us. This also applies to protecting the privacy of our employees. We do not tolerate any hate-filled, derogatory or discriminatory posts on social media. This policy should be read and applied in conjunction with the Social Media Policy.

Examples of other unacceptable posts include those which: convey subversive content offend the dignity of other users threaten harmony within the company discredit our reputation and the reputations of our employees * harm our relations with key stakeholders.

Complying with the Integrity Code

All employees are required to know the content of the Integrity Code and act accordingly. Our consulting platform is open to all employees for any compliance questions and support under compliance@smart.com. Our business partners are also expected to follow the Integrity Code. smart Europe expects its managers and employees alike to set an example for others. We promote a culture of respectful interaction.

Our business model requires a certain readiness to assume risks. Therefore, mistakes will be unavoidable. As individuals and an organization, it is our desire to learn from mistakes. Wrong decisions are recognized, discussed and corrected. Our error management culture leads to openness, fairness, trust and lessons learned.

Treatment of violations

Violations of laws, policies and other regulations can cause massive financial losses, involve the risk of fines being imposed on smart Europe and its employees and damage our image and reputation. Therefore, violations must be detected in a timely manner in order to prevent smart Europe and its employees from suffering harm. If we observe a violation of rules or regulations, we do not hesitate to address it internally to the respective supervisor and/or the Chief Compliance Officer.

Our whistleblower system (hereinafter "WBS") is open to all employees, business partners and third parties. The WBS accompanying the processing of tip-offs until the case has been closed. Confidentiality and fairness are the most important principles of our WBS. We examine each case individually to determine which consequences are suitable, necessary and appropriate. The presumption of innocence applies.

If you have evidence of violations, please contact your direct supervisor or the Chief Compliance Officer