Code of Conduct

 

Our corporate culture is made up of values and standards of conduct that shape the way we work together every day.
This Code of Conduct serves as a guide to ensure that we treat each other respectfully, fairly, and transparently —
both internally and in our dealings with our partners and customers. Together, we create a working environment
that thrives on openness, responsibility, and diversity.

Overview

1. Code of Ethics
2. IT Security Policy / Guidelines on Data Protection
3. Related Party Transaction Policy
4. Social Responsibility

1. Code of Ethics

Basic Requirements

Acceptance and respect are the basis for fair, dignified, and equal treatment of all people. We are committed
to diversity, inclusion, and equal opportunities and create a working environment in which acceptance and respect
take center stage. Discrimination, sexual harassment, racism, and any offensive behavior directed at people because
of their nationality, gender, religion, skin color, sexual orientation, age, or disability have no place in our team.

Responsibility is extremely important, which is why we give our employees maximum independence — we believe
freedom creates initiative. We want to gain the commitment of our employees through responsibility.

Flat hierarchies make work more fun. We do not appreciate rigid pecking orders; we try to escape the
long-established craft model of hierarchy. We think intimidation and ruthlessness are unacceptable and therefore
promote human and friendly interaction. Advancement is open to all.

Shared goals and close cooperation with all employees promote respect. We want everyone involved to be proud
to be part of our cause. All stakeholders can and should communicate openly. Without feedback — no progress. We
encourage everyone to express opinions and strive to understand others’ perspectives.

Transparency and consistency are integral to our company. We stand for honesty and avoid empty promises.
We aim to create an atmosphere characterized by healthy growth and ambitious goals, while maintaining discretion,
fairness, and openness.

Safe workplaces offer employees a space in which they can feel comfortable. Anti-fatigue mats are installed
in designated work areas and there are sufficient alternative workstations. We also provide safe work equipment.

Product Conformity and Safety

Many people come into contact with our e-bikes and services every day. We have a responsibility to reduce all risks
and hazards to health, safety, and the environment to an absolute minimum. We have agreed on the following to ensure this:

Quality awareness is our top priority. Our bikes are on the road and must be equipped accordingly. Cheap imported
products are out of the question. When designing our e-bikes, we focus on quality, safety, and durability.

Experience and data are continuously gathered to identify potential service bottlenecks early, ensuring that bikes
remain on the road for as long as possible while preserving materials. Information entrusted to us is handled responsibly
and securely, respecting privacy and complying with data protection regulations.

Product development and material testing are part of our daily work. Our team strives to find innovative solutions
that meet the highest safety requirements while being environmentally friendly and sustainable.

2. IT Security Policy / Data Protection Guidelines

The protection of personal data of employees, customers, suppliers, and other data subjects is of particular importance
to SMARTVÉLO. We collect, process, use, and store personal data only in accordance with legal requirements.

We recognize that our sustainable business success depends on the confidentiality of information and data (both from
SMARTVÉLO and third parties). Confidential information of any kind must not be passed on to unauthorized persons —
internally or externally. To protect such information, confidentiality agreements are contractually agreed with our partners.

Key Principles

Technology: All technological work equipment provided by SMARTVÉLO remains company property. Employees must treat
equipment with care and ensure it is not left unsecured or unattended. Hardware and software are primarily for business use.

Property rights: All employees must observe and comply with copyrights and industrial property rights (trademarks, etc.)
and protect the SMARTVÉLO trademark.

Rules of conduct: It is prohibited to save, copy, print, share, or forward any offensive, discriminatory, obscene,
criminal, or reputation-damaging content. Electronic spying, hacking, and impersonation are also prohibited. Email
communications must always be professional and appropriate.

Data security: Data of employees, customers, or third parties, as well as passwords and access authorizations, must
be protected against unauthorized use. External systems must not be used to transfer or share SMARTVÉLO’s confidential data.

Retention guidelines: The company undertakes to retain and archive all relevant documents — whether electronic or printed —
in accordance with applicable legal requirements.

3. Related Party Transaction Policy

To ensure smooth operations, it is our policy to avoid conflicts of interest. We promote transparency in the following areas:

Gifts: Gifts, especially money or financial benefits, are prohibited. Exceptions include low-value gifts or branded items
for special occasions. All gifts must comply with company policy and be transparent.

Invitations and hospitality: Invitations with private interest intended to gain advantages for the company are prohibited.
Employees must report questionable invitations to management.

Fair competition: We are committed to fair competition, compliance with antitrust laws, and anti-corruption regulations.

4. Social Responsibility

Human rights: We respect internationally recognized human rights and strictly reject any form of child or forced labor,
human trafficking, slavery, or exploitation. We respect all personal rights and the freedom of association.

Environmental and climate protection: Resource efficiency and sustainability guide our actions. We strive to continuously
optimize our work and production processes to contribute meaningfully to environmental and climate protection.

 

This Code of Conduct is issued to all employees!

The Code of Conduct represents the corporate culture of SMARTVÉLO Mobility GmbH by combining legal guidelines and company
regulations that all employees undertake to comply with.

Non-compliance or deliberate violations of these guidelines will lead to consequences under labor law in accordance with applicable regulations.