Sustainability Report 2019 of ec4u expert consulting ag

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Sustainability Report 2019 of ec4u expert consulting ag
Sustainability Report 2019
of ec4u expert consulting ag
Sustainability Report 2019 of ec4u expert consulting ag
© ec4u expert consulting ag

Foreword

               Dear Ladies and Gentlemen,

                 Companies have a responsibility, not only to their customers, but also to partners, service providers,
                employees and the society in which they operate. Guidelines and legislation ensure that certain
              standards of this responsibility are met. However, we at ec4u feel that Corporate Social Responsibility
(CSR) is not just a duty, but a trait of our company that we have internalized as part of our corporate philosophy.

We therefore contribute with a combination of legal, voluntary and self-developed standards, specifications and
measures, which we would like to present in the following report. We have been publishing our sustainability report
in accordance with the GRI and UNGC standards since 2017.

In 2019, we were able to launch new initiatives and strengthen and elaborate on already established ones. In our
now annual fundraising campaign "Moments of Happiness", a total of € 2,500 was donated by the ec4u board at
Christmas 2019 and distributed to local associations and organizations at our various locations to support children
and families in need.

In addition to our Sustainability Weeks, which offer tips and advice twice a year on how to live a more environmen-
tally friendly life in the office and at home, we have been able to implement various measures at our locations to
reduce consumption in the offices. For example, all water dispensers are now filled with tap water and the majority
of our water bottles are made of recyclable plastic.

Our team is always motivated to find new solutions and ways to save resources and avoid waste. We are constantly
working on alternatives, for example, to reduce paper consumption or to switch to recyclable materials. It is always
striking how far even small changes can go when they are implemented throughout the entire company. You can
read about current successes and considerations for the future in this report.

In 2019, we were once again awarded Gold in the Eco Vadis CSR rating. For the second time, we were able to prove
ourselves in the top 1% of all evaluated companies and again improved our score by several points compared to
the previous year.

We are also proud of the fact that we've been awarded the title "Top Employer - Germany's most family-friendly
companies" by kununu and the media brand freundin for several years in a row. It shows that we can maintain the
quality we strive for in our dealings with our employees over the long term.

In 2019, we have increased the use of virtual measures for the further training of our employees as well as raising
awareness. In order to comply with corruption prevention, all new employees must participate in an online course
on the topic. Due to the flexibility of the online format, we were able to achieve 100% participation in 2019 and will
continue to uphold this standard in the future.

However, we also want to strengthen personal development through virtual means in order to offer employees the
same opportunities at all locations. In 2019, we provided a learning platform that offers a wide range of courses
(including language courses) and thus enables self-motivated, individual learning.

We want to continue to follow the specified standards of the UN Global Compact and set new standards to intro-
duce and comply with ecological guidelines and standards for our company. We also call on service providers and
partners to participate. We therefore require our key suppliers and business partners to sign the LGPE and comply
with its contents.

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Sustainability Report 2019 of ec4u expert consulting ag
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For 2020, we are already planning to expand or relaunch measures in many different areas and are always listening
to feedback from our employees. That is why we have decided, contrary to our initial assessment, to also use hybrid
vehicles for company use in the future. With their economical consumption and top values in the area of CO2 emis-
sions, they are a good alternative for journeys by car, which sometimes still are necessary for our business. We
currently have three hybrid vehicles and two electric vehicles in our fleet.

In addition, we found many areas in 2019, where we lack the necessary data and information to analyze the con-
sumption of resources. For 2020, we therefore plan to work on optimizing the evaluations and information gathering
in order to identify more areas where we can and want to make changes. 2019 will serve as a baseline year of some
of our greenhouse gas (GHG) emission sources to establish the gross volume. This will then be used to track pro-
gress towards a GHG target.

The digital transformation is at the core of our business model, but it also influences how we interact with each
other and the way we move, communicate and interact with our environment. As a digital transformation consul-
tancy, we have been able to apply the benefits of virtual processes in collaboration, but also in resource
conservation. Virtual meetings replace travel, digital documents save energy and paper.

We also want to pass on this knowledge to our customers, partners and employees and accompany them on their
way to becoming digital champions. However, we furthermore want to help society and the environment with our
professional and social strengths. I am therefore proud that my colleagues on the Executive
Board and all employees are so committed, show a wealth of ideas and are motivated to con-
tribute.

David D. Laux

Chairman of the Board
ec4u expert consulting ag

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Current topics

Fundraiser - ec4u Christmas Campaign 2019

After a very successful first Christmas campaign in 2018, ec4u has come up with a similar campaign for 2019 to
bring joy to children and young people from socially disadvantaged families. This year's campaign kept the motto
"Let's give moments of happiness".

The ec4u board team provided donations totaling € 2,500, which were divided into € 500 each for the locations in
Karlsruhe, Munich, Böblingen, Eisenstadt and Zurich. The local employees were able to decide together which
institution or organization that supports socially disadvantaged children and/or young people should be supported
with the donation.

The institution or organization our employees have chosen in each case is shown below.

We hope that some families were able to enjoy a better Christmas in 2019 thanks to our support. For next year, we
are planning a similar campaign to bring a smile to the faces of more children and families.

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Sustainability Weeks
The understanding of sustainable living has long since arrived in the lives of many people, but there is often a lack
of knowledge, practice or even simple ideas on how to be actively sustainable. Sustainability is especially effective
in companies when all employees join in and actively support it. Since 2018, we have established annual sustaina-
bility weeks. During these weeks, we inform colleagues about currently relevant ecological, societal and social
concerns and invite them to participate. We have continued this format of providing information and active partic-
ipation in 2019.

Zero Waste - Life without waste

In spring 2019, we launched a sustainability week with cross-site activities on the topics of environment and con-
sumption. We were inspired by Beá Johnson, the French inventor and pioneer of the Zero Waste movement. Zero
Waste fights for the three goals of resource conservation, environmental protection and health. This goal achieve-
ment is equally close to ec4u's heart, which is why we dedicated our internal sustainability week to this motto.
With the aim of informing as many employees as possible and encouraging them to be more sustainable in their
lives, we have established five motto days.

For one week, information and actions around sustainable consumption were provided. Since the environmental
impact of consumption results from a multitude of individual decisions, we developed a "step-by-step-plan" with
respective measures. Day by day, we showed our employees how they can actively choose environmentally con-
scious consumption and motivated them to get active.

The third day of the sustainability week, for example, dealt with the topic of planning, because as everyone knows,
the best waste is not created in the first place - and waste avoidance must be planned. Our ec4u drinking bottle
travelled to our locations to show the easiest way to reduce packaging waste.

On the fourth day, some of our colleagues became active against environmental pollution. As part of an internal
"ec4u goes plogging" campaign during lunch break, ec4u colleagues ventured outside and picked litter off of the
green spaces around our offices.

The participating employees were rewarded for their commitment with a small give-away in the form of sustainable
chewing gum. In addition, at the end of the sustainability week, we provided interested employees with a recyclable
fruit and vegetable net that makes practical and environmentally conscious shopping easier.

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Outlook Sustainability Week 2020 in cooperation with MGG

In May 2019, we received a request from our cooperation school Markgrafen Gymnasium Karlsruhe-Durlach to
accompany a student project, a so-called seminar course, as a client for the school year 2019/2020. The seminar
course is an application project that replaces an oral "Abitur" examination as a special learning achievement. Over
the course of the eleventh school year, a group of approx. three to five students work on a project together with a
client from the private sector, which is then carried out, documented and presented.

As the client, ec4u has decided to conduct the seminar course on the topic of "ec4u and sustainability". The objec-
tive for the group of students is to ascertain the status quo of ec4u in the area of Corporate Social Responsibility
(CSR) and to compare this with other technology companies in Karlsruhe in order to acquire basic knowledge on
the topics of general corporate responsibility and sustainability in the context of CSR. The central point of the sem-
inar course is to promote employee awareness of sustainability by developing concrete measures in the form of
the Sustainability Week 2020.

At the beginning of the school year, a group of pupils met in September 2019 for a first kick-off meeting. We will
report on the collection of ideas and the implementation of the sustainability week in spring 2020 in the coming
reporting year.

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 Providing information to strengthen sustainable action
 In order to raise awareness among our employees, we provide information on sustainable topics at regular inter-
 vals and thus encourage reflection. In the reporting year 2019, we addressed the following topics:

           Mobile Banking & Sustainability
           World Earth Day "SOS - Save our species"
           Fashion from plastic / sustainable consumption
           Earth Overshoot Day under the motto #movethedate
           Microplastics

                              We also like to inform our colleagues about local projects so that they can participate in
                              person if they want. For example, in the summer of 2019 we reported on the "RefillKA"
                              initiative, which is working to reduce plastic waste with the participation of around 40
                              shops and restaurants in Karlsruhe. Instead of buying water in plastic bottles, you can
                              have your tap water filled for free in many places. This not only saves resources by avoid-
                              ing plastic waste, but also saves money.

Source: https://refill-
deutschland.de/karlsruhe/

 Sustainable Development Goals (SDG)
 At the United Nations General Assembly in 2015, the participating states adopted a resolution entitled "Transforming
 our world: the 2030 Agenda for Sustainable Development". It is valid for all states of the world. The Agenda primarily
 refers to the level of nation states, but the role of non-state actors from business, science and civil society in
 achieving the goals is emphasized. Part of this agenda are the 17 global sustainable development goals, the so-
 called Sustainable Development Goals (SDG).

 Numerous goals and sub-goals are directly addressed to companies. The SDG are a call to all companies to con-
 tribute to more sustainable development through their business practices and encourage companies to reduce
 their negative impact and strengthen their active contribution to sustainable development.

 In 2017, ec4u identified five SDG that are primarily within its sphere of action. In the past reporting year, the focus
 was adjusted and a stronger strategy integration will take place for the coming reporting year. The respective goals
 and measures will then be reported on.

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Awards

For the fourth time in a row, kununu and the media       In addition to the size of the company, the main se-
brand freundin have named us "Top Employer - Ger-        lection criteria were the kununu ratings. ec4u is thus
many's most family-friendly companies" in 2019.          one of the 1,000 best employers from a total of 22 in-
The criteria for the award are, in particular, family-   dustries.
friendliness, work-life balance and benefits that sup-
port employees and their families and create
flexibility in everyday working life.

Other kununu awards in 2019 that ec4u received
were "Open Company", for authentic companies, "Top
Company", for companies that have received partic-
ularly good ratings, including from former
employees, and "Top Employer in the SME sector", in
cooperation with FOCUS-BUSINESS. For this award,
the best employers were chosen from circa 13,000
companies.

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                                                         GRI 102-3
General Reporting Initiative - GRI                       Headquarters location
Standards                                                The organization’s head office is located in Germany,
                                                         Karlsruhe, Zur Giesserei 19-27B. Main business loca-
                                                         tions are locations where more than ten employees
GRI 102 | General disclosures                            work and are regularly on site. In addition to Karls-
                                                         ruhe, these include the locations in Munich,
                                                         Böblingen (Stuttgart) and Eisenstadt in Austria. Zur-
                                                         ich in Switzerland is also a very important location for
Organizational profile                                   us, but we do not currently include it among the main
                                                         business locations in the sustainability report ac-
                                                         cording to GRI, as the criterion of regular on-site
                                                         presence is not fulfilled here. This definition applies
GRI 102-1
                                                         to all subsequent content.
Name of the organization
ec4u expert consulting ag
                                                         GRI 102-4
                                                         Locations
GRI 102-2
                                                         In addition to the main business locations, we have
Activities, brands, products and services
                                                         further locations in Germany, Switzerland, Bulgaria
Our vision: You are the digital champion of your cus-
                                                         and Spain. In total, we are represented at twelve
tomers.
                                                         locations in five European countries.
As a leading consulting firm in the field of customer
                                                         Headquarters in Karlsruhe
management, we support our clients in the digital
                                                         ec4u expert consulting ag
transformation of all business-critical processes in
                                                         Zur Giesserei 19-27B
the areas of marketing, sales and service throughout
                                                         D-76227 Karlsruhe
the entire life cycle (customer journey). In doing so,
we take the entire project lifecycle into account and
                                                         Office in Böblingen
offer consulting, implementation and support from
                                                         ec4u data experts gmbh
strategy and technical consulting to technological
                                                         Konrad-Zuse-Str. 10
implementation, support, service center and further
                                                         D-71034 Böblingen
development.

In addition, we use customer analytics and business      Office in Munich
intelligence methods and offer additional services       ec4u marketing experts ag
such as the development of customer lifecycle man-       Willy-Brandt-Allee 2
agement, the provision of demand centers or active       D-81829 Munich
social media monitoring.
                                                         Office in Frankfurt
The aim of our offerings is to provide our customers     ec4u expert consulting ag
with modern, digital, efficient customer management      Reuterweg 49
through                                                  D-60323 Frankfurt am Main
    a clear, customer-focused strategy,
                                                         Office in Düsseldorf
    IT-supported business processes,
                                                         ec4u expert consulting ag
    transparent KPI-based monitoring and control,
                                                         Monschauer Str. 1
    and, last but not least, strength-oriented staff
                                                         D-40549 Düsseldorf
     development and leadership.

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Berlin office                                           Our main project languages are German and English,
ec4u expert consulting ag                               but due to the multicultural diversity in our company,
Leipziger Platz 15                                      other languages are also quite common in everyday
D-10117 Berlin                                          life.

Office in Hamburg (until 31.05.2019)                    Besides our headquarters in Karlsruhe, Germany, we
ec4u expert consulting ag                               have additional offices in Böblingen, Munich, Berlin,
Dike road 17                                            Frankfurt am Main, Düsseldorf, Hamburg and outside
D-20457 Hamburg                                         Germany in Switzerland (with a head office in
                                                        Schindellegi), Austria, Bulgaria and Spain.
Office in Bulgaria / Sofia                              Our core industries are financial, telecommunica-
Mladost 4, Business park                                tion, life science and high-tech companies as well as
Building 1 B                                            energy providers. However, we also have various
B-1766 Sofia                                            projects in other industries and serve clients in both
                                                        the B2B and B2C segments.
Headquarters in Switzerland
ec4u expert consulting (switzerland) ag
Chaltenbodenstrasse 16                                  GRI 102-7
CH-8834 Schindellegi                                    Scale of the organization
                                                        At the end of 2019, the ec4u Group had a total of 335
Zurich office                                           employees at twelve locations. The ec4u Group gen-
ec4u expert consulting (switzerland) ag                 erated a total of € 39.6 million in revenue and carried
Nordstrasse 9                                           out 206 projects. Due to the fact that ec4u does not
CH-8006 Zurich                                          prepare consolidated annual financial statements,
                                                        the information only refers to the parent company
Headquarters in Austria                                 ec4u expert consulting ag. Borrowed capital in the
ec4u marketing experts (austria) gmbh                   reporting year amounted to € 5,373,000, equity to €
Main Street 43 - 45                                     7,990,000, and total assets to € 13,363,000.
A-7000 Eisenstadt
                                                        GRI 102-8
Office in Spain / Barcelona                             Information on employees and other
ec4u expert consulting (españa) s.l.u                   employees
World Trade Center                                      ec4u has a total of 335 employees as of the reporting
Edificio Sur - 2a Planta Muelle de Barcelona            date of December 31, 2019. The majority of our em-
E-08093 Barcelona                                       ployees are in permanent employment. The following
                                                        are employed by us on a temporary basis
GRI 102-5                                               Young talents, including dual students, trainees, in-
Ownership and legal form                                terns, thesis writers and working students.
ec4u expert consulting ag is an unlisted employee       thesis writers and student trainees. The total number
stock corporation under German law. The majority of     of our employees by employment contract and gen-
shares are held by the founders of the company and      der breaks down as follows:
the management.
                                                        Gender                      Female          Male
The remaining shares are held in free float by man-
agement and employees.                                  permanent                      72            183

                                                        limited                        20             37
GRI 102-6
Markets served                                          permanent part-time            17              6
Our focus is on projects in the DACH region (Ger-
many, Switzerland and Austria), but within the scope
of our project activities we are active worldwide to-
gether with our clients.

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© ec4u expert consulting ag

We employ staff in the consulting area as well as in
the area of corporate services (company administra-        Gender            Female         Male         limited
tion). The difference in the total number of permanent
employees (excluding fixed-term contracts) by type         Böblingen             8            23           16
of employment below is due to the business purpose
of ec4u.                                                   Eisenstadt           12            15            0

                                                           Karlsruhe            58           129           26
Gender                         Female           Male
                                                           Munich               19            22            7
Consulting                       55              175
                                                           Switzerland           2            21            0
Corporate Services               34              14
                                                           Other                10            16            4
ec4u's business activities are increasingly carried
out by employees bound by instructions.
                                                           GRI 102-9
Gender                       Female          Male
                                                           Supply chain
Management                      5              27          As a service provider, ec4u's supply chain is rela-
                                                           tively short compared to a manufacturing business.
Employees (bound by                                        In total, depending on the type of service provision,
                               104            199
instructions)                                              approximately two to five parties are involved.

The following percentages of regional fixed-term           Typically, the supply chain is limited to the allocation
                                                           of ec4u staff to deliver services for a client project.
contracts represent object-limited contracts rather
                                                           Service delivery typically involves the provision of
than time-limited contracts. Permanent employment
                                                           knowledge and expertise, e.g., technical or technol-
is the rule after completion of training or studies. The
                                                           ogy consulting.
fixed-term employment usually results from the train-
ing context, i.e., dual studies, training, internship,
thesis or working student.

                                                                                                Custo-
                                                                                                 mer

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The ec4u service portfolio serves as an overview of the available consulting fields.

Should it happen that no internal capacities are available, a pool of highly qualified freelancers or partner compa-
nies can be used. In these cases, the supply chain looks like this:

Freelancer       Agent/Agency                          Customer or         Partner-                           Customer
                                                     Employees of the      company
                                                         Partner

Within the scope of technology consulting, software is adapted and integrated on behalf of the customer. However,
the software is not purchased and charged for. Only the customization of the software is carried out. The supply
chain then looks as follows:

             Technology            Customer                                            Customer
               owner

Likewise, ec4u offers support in downstream processes, such as maintenance and execution of campaigns in cor-
responding demand centers.

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The type of suppliers used thus results from the sup-     As a consulting firm for customer relationship man-
ply chains described which are typically:                 agement, ec4u has integrated the precautionary
                                                          principle as a risk management measure for antici-
     ec4u's own employees                                patory and early hazard prevention.
     Freelancers
      ­ Direct  known persons
      ­ Indirect  agencies/partner companies             GRI 102-12
     Employees of partner companies                      External initiatives
     Technology owner or customer                        ec4u joined the UN Global Compact initiative in July
                                                          2015 and has committed to integrating its ten princi-
The total number of suppliers, especially freelancers,    ples into our corporate strategy and culture as well
used by the organization is approximately 115.            as into our day-to-day business. We pursue this com-
                                                          mitment at all our locations in Germany, Switzerland
The geographical location of our freelancers is
                                                          and Austria and the principles are supported by all
spread over the countries Germany, Switzerland,
                                                          our employees.
Czech Republic, Bulgaria, Poland and Greece. The
estimated monetary value of payments made to free-
lancers (excluding other suppliers) is approximately      GRI 102-13
7.1 million euros, rounded.                               Membership in associations
                                                          ec4u is not active in any associations, neither na-
Overall, the sector-specific supply chain is very la-     tional nor international at the organizational level. It
bor-intensive, which is due to the service industry.      doesn't occupy a management level, it does not par-
The service is developed by ec4u employees and the        ticipate in any working groups, it does not pay out
work performance is sold to the customers. This in-       significant financial resources beyond the usual
cludes in particular knowledge, expertise and skills      membership fees and does not consider these mem-
at project and process level.                             berships to be strategic.

GRI 102-10
Significant changes in the organization and its sup-
ply chain                                                 Strategy
There were no significant changes in structure
(changes in location including opening and closing
of facilities), ownership (changes in share capital       GRI 102-14
structure and other asset formation) or supply chain      Statement/byword by the Chairman of the Board of
(changes in location of suppliers, structure/relation-    Directors
ships) in the organization in 2019.                       See foreword on page 1.

GRI 102-11
Precautionary principle and precautionary
measures
The precautionary principle was introduced by Prin-
ciple 15 of the Rio Declaration on Environment and
Development at the United Nations Conference in
1992. It states that a lack of complete scientific cer-
tainty with regard to imminent serious or lasting
damage must not be a reason for postponing cost-
effective measures to prevent environmental degra-
dation, among other things. The precautionary
principle is a guiding principle at EU and German
level and is a central component here, since it is al-
ready contained in the Treaty establishing the
European Community. The business community is
thus also assigned a key role.

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Ethics and integrity                                         E | Ethics
                                                             Ethical principles form the basis of our actions. We
GRI 102-16                                                   are confronted with ethical questions every day,
ec4u values, guidelines, standards and norms of              consciously or unconsciously. This also includes
conduct                                                      clarifying grievances and openly addressing miscon-
The Code of Conduct serves as a binding code of              duct. Our corporate guidelines provide orientation
conduct for our employees, business partners and             for decisions and daily actions.
suppliers to orient themselves and develop a holistic
awareness. It accompanies us in our daily activities.        C | Compliance
                                                             Compliance - the observance of laws and guidelines
The Code of Conduct was published internally and             in the company, but also of voluntary codes - encom-
externally for the first time in 2014. It will be reviewed   passes all activities in the company that we must
annually, and any changes will be made if necessary.         consider together. This includes, among other things,
The Code of Conduct is valid for ec4u expert consult-        ensuring data protection, truthful statements in mar-
ing ag as well as for all companies associated with          keting and the prevention of corruption.
it. It is carried by the board of directors down to the
individual employees. It is handed out with further in-      4 | Social
formation for a successful start in the company every
time an employee is onboarded or joins the company.          Our employees are a central component of our suc-
                                                             cess. For this reason, this component deals with
At present, we do not consider explicit training and
                                                             employee promotion, anti-discrimination, health &
written signatures to be necessary, but trust in the
                                                             safety, work-life balance and compliance with social
cooperation of all participants.
                                                             standards, among others.
 In addition to the substantive standards of conduct,
the Code of Conduct regulates the scope of applica-          U | Environment
tion, compliance, how to deal with violations and
contact persons. If a party becomes aware of a pos-          In addition to the three building blocks already men-
sible violation of our Code of Conduct, we encourage         tioned, the Code of Conduct concludes with an
them to report it. As a rule, this is done via the direct    awareness of the environmental resources we use
superior. For topic-specific questions or sugges-            on a daily basis. We take our responsibility for the
tions, we have appointed contact persons who deal            environment very seriously and have therefore de-
with concerns confidentially.                                fined measures and goals.

The Code of Conduct is made up of four components:
1) Ethics; 2) Compliance; 3) Social and 4) Environmen-
tal.

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Governance

GRI 102-18
Management structure
The management structure of ec4u, including the committees of the highest governance body, is shown below.

Supervisory Board

 Elmar Buschlinger                        Michael Diemer                            Tönnies-Hilmar von Donop
 Chairman of the Supervisory              Supervisory Board                         Supervisory Board
 Board                                    Michael Diemer has been a member          Tönnies-Hilmar von Donop has been
 Elmar Buschlinger has been a mem-        of the supervisory board of ec4u ex-      a member of the Supervisory Board
 ber of the Supervisory Board of ec4u     pert consulting ag since 2015.            of ec4u expert consulting ag since
 expert consulting ag since 2007 and                                                2015.
 Chairman of the Supervisory Board
 since 2009.

Board of Directors

 David D. Laux                          Steffen Deufel                          Jens Rehwinkel
 CEO                                    CPO                                     CFO/CHRO
 David        D.       Laux        is   Steffen Deufel is co-founder and        Jens Rehwinkel is co-founder and
 Chairman of the Board of ec4u ex-      board member of ec4u expert con-        board member of ec4u expert con-
 pert consulting ag. He is              sulting ag. As Chief Product            sulting ag. As Chief Financial
 responsible for the overall strategy   Officer, he is responsible for ec4u's   Officer, he is responsible for the ar-
 and further development of ec4u as     portfolio and its further develop-      eas of Finance and Controlling as
 well as the areas of Corporate         ment.                                   well as Human Resources & Or-
 Communications, Legal & Govern-                                                ganization.
 ance and Corporate Finance.

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 Mario A. Pufahl                        Dr Peer Stehling
 CSO                                    COO
 Mario A. Pufahl is a board member      Dr Peer Stehling was a member of
 of ec4u expert consulting ag and,      the Management Board of ec4u ex-
 as Chief Sales Officer, is responsi-   pert consulting ag until the end of
 ble for Sales and Business             2019 and, as Chief Operating Of-
 Development.                           ficer, was responsible for ec4u's
                                        service provision.

GRI 102-32
Decision-making bodies on economic, environmental and social issues
Within the company, we have formed a CSR Circle with corresponding responsibilities (roles). Each role is taken
on by a specialist expert and is dealt with in terms of content.

The role of the highest governance body in sustainability reporting
The sustainability report and all associated topics are processed across all departments within ec4u. For this pur-
pose, different roles have been defined according to the technical expertise, which ensures that all essential
aspects are taken into account. The final approval of the sustainability report is given by the Executive Board.

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Stakeholder engagement                                      With its help, we were able to make an assessment
                                                            of the importance of the report's content.
GRI 102-40                                                  In addition to the activities related to the sustainabil-
Listing of stakeholder groups                               ity report, customer satisfaction surveys are carried
In 2017, ec4u recorded and differentiated internal          out in the stakeholder group "customers". Every ec4u
and external stakeholder groups as relevant stake-          customer is asked once a year about their satisfac-
holders. The internal stakeholders are employees            tion with the service and advice provided by ec4u
and shareholders as well as the Executive Board and         staff, provided it is reasonable within the course of
Supervisory Board. The external stakeholder groups          the project. After the completion of a project at the
include technology and consulting partners, custom-         latest, the survey is sent to the clients for their re-
ers, suppliers and NGOs. In the current reporting           sponse.
year, these stakeholder groups continue to be con-
sidered as the relevant stakeholders of ec4u.               ec4u is also in regular dialogue with its employees,
                                                            who, along with customers, are one of ec4u's rele-
                                                            vant stakeholder groups. An annual employee survey
GRI 102-41                                                  is carried out on the areas of working atmos-
Collective agreements                                       phere/environment and own tasks/responsibilities,
In this reporting year, as is the rule in the industry,     leadership at ec4u and ec4u corporate guidelines,
ec4u does not belong to any collective agreement            employee development and ec4u as an employer.
and is therefore not subject to any regulated obliga-       The results are made available to the employees and
tion to fulfil requirements. The percentage of the total    appropriate measures for optimization are derived
workforce covered by collective agreements is               and implemented.
therefore 0%.
                                                            In the course of strengthening the dialogue with
                                                            stakeholders, it was defined that all stakeholders
GRI 102-42
                                                            identified as relevant should be informed about pro-
Identifying and selecting stakeholders
                                                            gress in the context of the sustainability report at
In the course of ec4u's first sustainability report 2017,
                                                            two-year intervals.
the corporate environment was analyzed in connec-
tion with ec4u's business activities to determine           The goal formulated in 2018 of sending out the sus-
relevant stakeholder groups. The selection within a         tainability report by post for the first time was
stakeholder group was made using an ABC analysis.           successfully implemented in the reporting year. In
According to this, the individual stakeholder groups        accordance with our two-year interval, we will again
were divided into A, B and C classes. Depending on          inform our stakeholders about goals, measures and
the stakeholder group, different classifying charac-        progress in the context of our sustainable business
teristics were defined. For external stakeholders,          activities in the reporting year 2020.
with the exception of NGOs, the characteristic of
turnover was defined for classification. No delimita-
                                                            GRI 102-44
tion was made for internal stakeholders. All
                                                            Key topics and concerns
employees are given the opportunity to actively par-
                                                            ec4u conducts a company-wide employee survey
ticipate.
                                                            once a year on an anonymous basis. The results and
                                                            the open dialogue with employees lead to topics
GRI 102-43
                                                            where our employees would like to see a change. We
Approach to stakeholder engagement
                                                            are constantly working on these.
Stakeholder engagement is an important component
of the GRI reporting principles, including the princi-      From the 2018 staff survey, three major areas were
ple of materiality. A stakeholder analysis was              identified where our staff would like to see optimiza-
therefore carried out in the 2017 reporting year,           tion. These were broken down into various
which was incorporated into a materiality analysis.         measures, which were continuously worked on dur-
The identified stakeholders were involved. The              ing 2019. The results of our staff survey in 2019 have
stakeholder analysis itself served to identify the in-      produced some significant improvements in the ap-
terest groups and for a direct dialogue.                    proval ratings in these areas.

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For example, our training offer was supplemented by       GRI 102-47
an internal online learning management platform, the      List of the main contents of the report
content of which is gradually being expanded. In ad-      The following topics and concerns related to the GRI
dition, the flow of information within the organization   Guidelines were identified as material in the stake-
was expanded. Since the fourth quarter, company-          holder survey that was conducted.
wide calls on current topics, figures and develop-
ments have been held on a monthly basis to create         1.   Customer data protection
transparency.                                             2.   Education and training
                                                          3.   Diversity and equal opportunities
With regard to our customers, ec4u regularly con-         4.   Fighting corruption
ducts customer surveys to analyze customer                5.   Employment
satisfaction and the quality of our own services. The
customer survey serves to consistently improve and        The five most important aspects identified will con-
further develop the advisory and service perfor-          tinue to be worked on and communicated more
mance.                                                    intensively. Specifically, we would first like to exam-
                                                          ine where we as a company see opportunities for
                                                          action in these aspects and specifically seek dia-
                                                          logue.
Reporting                                                 Through joint development with stakeholders, the
                                                          following material aspects were identified in the 2017
                                                          reporting year, which ec4u also considers material
GRI 102-45                                                this year. In order to review the materiality of the as-
Entities included in the consolidated financial state-    pects, ec4u would like to renew the stakeholder
ments                                                     survey at five-year intervals and thus identify any
ec4u does not include this sustainability report in the   changes.
management report of the annual financial state-
ments and does not currently provide consolidated
annual financial statements due to the size of the        Key GRI aspects of ec4u:
company. The report covers ec4u as a whole, includ-
ing all subsidiaries, whereby the reporting                   Education & Training
characteristics must be taken into account in each            Fighting corruption
case.                                                         Employment
                                                              Customer data protection
                                                              Diversity and equal opportunities
GRI 102-46
                                                              Anti-competitive behavior
Provisions of the report content and topic delimita-
                                                              Employee-employer relationship
tion
                                                              Equal treatment
The report content and the identification of material         Emissions
sustainability aspects within the ec4u value chain            Energy
were defined using a materiality matrix. By compar-           Socio-economic compliance
ing the company's expectations with those of the
                                                              Occupational safety & health protection
stakeholders, it was possible to identify the material
                                                              Procurement practices
report content and to distinguish it from less material
                                                              Evaluation of suppliers in terms of labor prac-
information. Topics that were classified as relevant
                                                               tices
by ec4u from an economic, ecological and social
                                                              Freedom of association
perspective, as well as with regard to their im-
                                                              Evaluation of suppliers with regard to ecologi-
portance for the business success, are also
                                                               cal aspects
presented as comprehensively as possible in the
                                                              Water
2019 Sustainability Report with regard to the GRI re-
                                                              Environmental protection
quirements.
                                                              Market presence
                                                              Wastewater and waste

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GRI 102-48 / GRI 102- 49
Reformulation of information / change in reporting
This sustainability report was prepared in accord-
ance with the GRI guidelines. There are no changes
with regard to the reporting period.

GRI 102-50
Reporting period
The reporting period covers one financial year of
ec4u and relates to the calendar year 2019.

GRI 102-51
Date of the most recent report
The most recent previous report was prepared and
published in July 2019. It covers the reporting period
01.01.2018 - 31.12.2018 or the entire calendar year
2018.

GRI 102-52
Reporting cycle
Reporting takes place in an annual cycle.

GRI 102-53
Contact details for questions regarding the sustain-
ability report
Contact for questions regarding the report or its con-
tents: Anja M. Benesch as CSR Officer

E-mail: anja.benesch@ec4u.com
Phone: +49 (0) 174 1880 536

GRI 102-54
Statements on reporting in accordance with the GRI
standards
ec4u reports in accordance with current and recog-
nized standards of sustainability reporting, both in
terms of content and structure. In particular, the
standards of the Global Reporting Initiative (GRI) and
the standard of the UN Global Compact (UNGC) were
used. It was prepared in accordance with the Sus-
tainability Reporting Standards in the "core" option
and also serves as a Communication on Progress
(COP), which reports on goals, progress and
measures within the framework of the UNGC mem-
bership. An external report review for the
Sustainability Report was waived.

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GRI 102-55
GRI Content Index
GRI 102 | General disclosures

Organizational profile                                         Page      Comment
GRI 102-1
                                                                8
Name of the organization
GRI 102-2
                                                                8
Activities, brands, products and services
GRI 102-3
                                                                8
Headquarters location
GRI 102-4
                                                                8
Locations
GRI 102-5
                                                                9
Ownership and legal form
GRI 102-6
                                                                9
Markets served
GRI 102-7
                                                                9
Scale of the organization
GRI 102-8
                                                                9
Information on employees and other employees
GRI 102-9
                                                                10
Supply Chain
GRI 102-10
                                                                12
Significant changes in the organization and its supply chain
GRI 102-11
                                                                12
Precautionary principle and precautionary measures
GRI 102-12
                                                                12
External initiatives
GRI 102-13
                                                                12
Membership in associations
Strategy
GRI 102-14                                                               See foreword of the Sus-
                                                                12
Statement/ Byword by the Chairman of the Board of Directors              tainability Report
Ethics and integrity
GRI 102-16
                                                                13
ec4u values, guidelines, standards and norms of conduct
Governance
GRI 102-18
Management structure                                            14

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                                                                      Page      Comment

GRI 102-32
                                                                       15
Decision-making bodies on economic, environmental and social issues
Stakeholder engagement
GRI 102-40
                                                                       16
Listing of stakeholder groups n
GRI 102-41
                                                                       16
Collective agreements
GRI 102-42
                                                                       16
Identifying and selecting stakeholders
GRI 102-43
                                                                       16
Approach to stakeholder engagement
GRI 102-44
                                                                       16
Key topics and concerns
Reporting
GRI 102-45
                                                                       17
Entities included in the consolidated financial statements
GRI 102-46
                                                                       17
Provisions of the report content and topic delimitation
GRI 102-47
                                                                       17
List of the main contents of the report
GRI 102-48 / GRI 102- 49
                                                                       18
Reformulation of information / change in reporting
GRI 102-50
                                                                       18
Reporting period
GRI 102-51
                                                                       18
Date of the most recent report
GRI 102-52
                                                                       18
Reporting cycle
GRI 102-53
                                                                       18
Contact details for questions regarding the sustainability report
GRI 102-54
                                                                       18
Statements on reporting in accordance with the GRI standards
GRI 102-55
                                                                       19
GRI Content Index
GRI 102-56
                                                                       25
External audit

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Specific data                                                       Page      Comment
GRI 200 | Economic
GRI 202 | Market presence as
Employer
GRI 103
Management approach                                                  27
(including GRI 103-1; 103-2; 103-3)
GRI 202-1
Ratio of standard entry level wages by gender to local minimum       27
wage
GRI 202-2
                                                                     27
Proportion of managers hired from the local community
GRI 204 | Procurement practices
GRI 103
Management approach                                                  27
(including GRI 103-1; 103-2; 103-3)
GRI 204-1
                                                                     28
Proportion of spending on local suppliers
GRI 205 | Fight against corruption
GRI 103
Management approach                                                  28
(including GRI 103-1; 103-2; 103-3)
GRI 205-2
                                                                     29
Information and training on anti-corruption policies and measures
GRI 205-3
                                                                     29
Confirmed incidents of corruption and actions taken
GRI 206 | Anti-competitive behavior
GRI 103
Management approach                                                  29
(including GRI 103-1; 103-2; 103-3)
GRI 206-1
                                                                     30
Lawsuits for anti-competitive, cartel and monopoly behavior
GRI 300 | Ecology
GRI 302 | Energy
GRI 103
Management approach                                                  32
(including GRI 103-1; 103-2; 103-3)
GRI 302-1
                                                                     32
Energy consumption within the organization

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                                                                      Page      Comment
GRI 302-3
                                                                       33
Energy intensity
GRI 305 | Emissions
GRI 103
Management approach                                                    34
(including GRI 103-1; 103-2; 103-3)
GRI 305-1
                                                                       35
Direct greenhouse gas emissions (Scope 1)
GRI 305-3
                                                                       37
Other indirect (Scope 3) greenhouse gas emissions
GRI 306 | Wastewater and waste
GRI 103
Management approach                                                    41
(including GRI 103-1; 103-2; 103-3)
GRI 306-3
                                                                       41
Significant leakage of harmful substances
GRI 306-5
                                                                       42
Water bodies affected by discharge and/or runoff
GRI 307 | Environmental Compliance
GRI 103
Management approach                                                    45
(including GRI 103-1; 103-2; 103-3)
GRI 307-1
                                                                       45
Non-compliance with environmental laws and regulations
GRI 308 | Assessment of suppliers with regard to ecological aspects             For details see GRI 204 |
                                                                                Procurement practices
GRI 308-2
Negative environmental impacts in the supply chain and measures        28
taken
GRI 400 | Social
GRI 401 | Employment
GRI 103
Management approach                                                    47
(including GRI 103-1; 103-2; 103-3)
GRI 401-1
                                                                       47
Newly hired employees and employee turnover
GRI 401-2
Benefits provided to full-time employees other than temporary or       48
part-time employees
GRI 401-3
                                                                       48
Parental leave

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                                                                     Page      Comment
GRI 402 | Employee-employer relationship
GRI 103
Management approach                                                   49
(including GRI 103-1; 103-2; 103-3)
GRI 402-1
                                                                      49
Reporting deadlines for operational changes
GRI 403 | Occupational health and safety
GRI 103
Management approach                                                   49
(including GRI 103-1; 103-2; 103-3)
GRI 403-1
                                                                      49
Occupational health and safety management system
GRI 403-2
                                                                      49
Hazard identification, risk assessment and incident investigation
GRI 404 | Education and training
GRI 103
Management approach                                                   52
(including GRI 103-1; 103-2; 103-3)
GRI 404-1
Average number of hours of education and training per year per em-    52
ployee
GRI 404-2
                                                                      52
Employee skills enhancement and transition assistance programs
GRI 404-3
Percentage of employees receiving regular performance and career      53
development reviews during the reporting period.
GRI 405 | Diversity and equal opportunities
GRI 103
Management approach                                                   53
(including GRI 103-1; 103-2; 103-3)
GRI 405-1
                                                                      54
Diversity in governance processes and employees
GRI 406 | Anti-discrimination
GRI 103
Management approach                                                   54
(including GRI 103-1; 103-2; 103-3)
GRI 406-1
                                                                      54
Incidents of discrimination and remedial actions taken

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                                                                      Page      Comment
GRI 407 | Freedom of association and Right to collective bargaining
GRI 103
Management approach                                                    54
(including GRI 103-1; 103-2; 103-3)
GRI 407-1
Operations and suppliers where the right to exercise freedom of as-    54
sociation and collective bargaining may be at risk
GRI 414 | Social assessment of suppliers                                        For details see GRI 204 |
                                                                                Procurement practices
GRI 414-2
                                                                       28
Negative social impacts in the supply chain and actions taken
GRI 418 | Customer Privacy
GRI 103
Management approach                                                    55
(including GRI 103-1; 103-2; 103-3)
GRI 418-1
Substantiated complaints about breaches of customer privacy and        56
loss of customer data
GRI 419 | Compliance
GRI 103
Management approach                                                    56
(including GRI 103-1; 103-2; 103-3)
GRI 419-1
Non-compliance with laws and regulations in the social and eco-        56
nomic sphere

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GRI 102-56
External audit
ec4u does not currently plan of having the sustainability report audited externally. Independently of an external
report audit, ec4u has participated in an annual CSR assessment since 2014, which also includes the provision of
this sustainability report. We receive feedback on this as well as a corresponding rating. In addition, the report is
audited internally by several bodies, see also GRI 102-18 and GRI 102-46.

The assessment is divided into 21 criteria across four areas (environment, labor and human rights, ethics and sus-
tainable procurement). These are based on international CSR standards, such as the principles of the Global
Compact, the internationality of the Labour Organisation (ILO) conventions, the Global Reporting Initiative (GRI
standard), the ISO 26000 standard and the CERES principles. The results of the assessment help us to reflect on our
measures and objectives and - where necessary - to make appropriate adjustments.

The most recent assessment took place in November 2019. We achieved 75 out of 100 points and received the "Gold
Award" for the fifth time in a row. We are still among the top 1% of companies assessed by EcoVadis. EcoVadis
certified us as having Advanced CSR Activity/Performance. The individual potentials for improvement can be found
in the following report.

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Specific data

GRI 200 | Economic

Corporate principle

                 For our customers and partners, we are the guarantor of excellent customer management
                 through the highest quality and passion. We create a perfect balance of demanding successful
                 results with efficient and economical project realization at the same time. Regarding both our
                 service and our procurement practices, our stakeholders can rely on fair and transparent coop-
                 eration.

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GRI 202 | Market presence as                             GRI 204 | Procurement practices
Employer

GRI 103                                                  GRI 103
Management approach                                      Management approach
(including GRI 103-1; 103-2; 103-3)                      (including GRI 103-1; 103-2; 103-3)
As far as possible, we look for and recruit employees    Sustainable procurement is an important part of
locally and also within a regional radius of our vari-   ec4u's procurement process. We have set ourselves
ous locations. Due to our main business activity,        the goal of continuous development as well as creat-
employees in the consulting sector must be willing to    ing and raising awareness.
travel to a certain extent, therefore, a more distant    Our principles for avoiding negative impacts and
place of residence is also conceivable. Salaries         risks in relation to supplier selection include the fol-
within our company are, as is customary in the indus-    lowing guidelines:
try, well above the respective national averages.
                                                             Consideration of our Code of Conduct and the
                                                              principles laid down therein
GRI 202-1
                                                             Compliance with the ten principles of the UN
Ratio of standard entry level wages by gender to lo-
                                                              Global Compact
cal minimum wage
                                                             Classification of supplier and business partners
In principle, legal provisions on minimum wages are
                                                              according to information in a questionnaire
relevant at the individual ec4u locations. We comply
                                                             Prevention & reduction of environmental pollu-
with these and pay above the minimum wage, de-
                                                              tion and damage
pending on qualifications and irrespective of gender.
                                                             Consideration of identifiable consequences of
The work regularly requires at least an apprentice-
                                                              climate change and use of potentials for adap-
ship, so we do not have any unskilled workers on the
                                                              tation to climate change
job, which is reflected in the pay.
                                                             Promoting health protection at the workplace
                                                              and occupational safety for employees
GRI 202-2                                                    Attention to negative impacts and risks in the
Proportion of managers hired from the local com-              supply chain
munity                                                       Supplier locality
No local managers were hired in the 2019 reporting           Preference for recycled products
year. Executives generally belong to the manage-
ment; team leaders are not included here. Local in       By signing our supplier
this case refers to the respective country of the main   and business partner
business location. The largest proportion of manag-      declarations (LGPE),
ers are distributed among the main business              we want to continu-
locations, which are largely represented in Germany.     ously expand, ensure
For this reason, we have decided against a separate      and raise their aware-
overall overview of the ACTUAL situation of local        ness of human rights, decent work practices,
managers. Previous settings can be found in the Sus-     environmental protection and corruption prevention.
tainability Report 2018.                                 Our suppliers and business partners are requested to
                                                         observe our principles and to pass them on to those
                                                         involved in the supply chain. In accordance with the
                                                         mission statement, award decisions should increas-
                                                         ingly include criteria of corporate social
                                                         responsibility in a supplier evaluation.

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Since the introduction of the LGPE in 2015, a total of     GRI 414-2
80 suppliers have been approached and committed            Negative social impacts in the supply chain and ac-
to compliance. 84% of these suppliers have recog-          tions taken
nized our LGPE.                                            We did not identify any suppliers in our supply chain
                                                           who caused any significant and potential negative
On the basis of the evaluation and extended consid-        impact. As a result, no remedial measures had to be
erations, supplier management is to be further             agreed upon and/or no business relationship had to
professionalized successively in the following years.      be terminated.
The future goal should be to continuously oblige all
major suppliers and business partners to comply
with our LGPE and its contents. Another goal is to fur-
ther expand supplier evaluation and sharpen its
focus. Unfortunately, the goal set for 2018 - to expand    GRI 205 | Fight against corruption
supplier assessment and sharpen its focus - could
not be achieved in the past reporting year. No further
suppliers could be won over to sign the LPGE. In the       GRI 103
course of the introduction of a supplier management        Management approach
tool, the procurement practices as well as further ob-     (including GRI 103-1; 103-2; 103-3)
ligations to comply with and sign our supplier and -       ec4u has dealt intensively with the prevention of cor-
business partner declarations will be re-evaluated         ruption. As corruption offences are violations in the
and adjusted in 2020.                                      sense of the Criminal Code (StGB), we reject any cor-
                                                           rupt and illegal behavior. In particular, the
                                                           exploitation of a position of power for personal gain
GRI 204-1                                                  in disregard of moral norms and laws is strictly pro-
Proportion of spending on local suppliers                  hibited throughout ec4u. It is fundamental for us to
ec4u's purchasing is covered by a budget that is           prevent corruption as an exchange of advantageous
managed at the organization’s headquarters (Karls-         services. Our Compliance Department is always
ruhe office, Zur Gießerei).                                available for consultation. It also takes over the in-
In its geographic definition of "local", ec4u includes a   vestigation and initiates appropriate measures in
surrounding area with a radius of 30 km from the           case of violations.
main business location and at least the adjacent           In the context of anti-corruptionec4u does not dis-
county. According to this geographic definition, ec4u      tribute donations that are related to our business
supports 53 local suppliers and service providers. On      activities or that could provide an advantage to ec4u
average, the local suppliers are located within a ra-      and/or ec4u employees. The communication of ap-
dius of 9.47 km from the respective main business          propriate guidelines is part of the fight against
locations. With the help of local suppliers, ec4u          corruption.
mainly carries out operational business activities.
                                                           The guidelines are presented during the onboarding
We are currently unable to provide a presentation of       of new employees and provide clarification.
the percentage of spending with local suppliers. We
have set ourselves the goal of expanding our supplier      As a participant in the UN Global Compact, we ad-
management and paying more attention to sustaina-          here to Principle Ten and work towards its
ble procurement in the future.                             implementation.

                                                           GRI 205-1
GRI 308-2                                                  Audit of operations for corruption risks
Negative environmental impacts in the supply chain         Feedback from EcoVadis to date has indicated that
and measures taken                                         there is potential for improvement in the area of eth-
We did not identify any suppliers in our supply chain      ics, as supporting documentation for corruption and
who caused any significant and potential negative          bribery risk analysis as well as for third party anti-
impact. As a result, no remedial measures had to be        corruption and bribery audits has not yet been pro-
agreed upon and/or no business relationship had to         duced.
be terminated.

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An external audit of the operating sites for corrup-       competences and expertise of the purchased free-
tion risks has not yet been carried out.                   lancers are necessary for ec4u's project success
                                                           and we prefer to raise awareness.
Due to the fact that there are no incidents of corrup-
tion in the company's history and that our employees
have also been trained in this regard and receive on-      GRI 205-3
going training, we are currently refraining from an        Confirmed incidents of corruption and actions taken
audit.                                                     We are not aware of any incidents of corruption. Nei-
                                                           ther in our own company, by employees, nor by
                                                           business partners. Furthermore, there are no legal
GRI 205-2                                                  disputes pending in this regard. In order to
Information and training on anti-corruption policies       strengthen the corruption awareness of employees
and measures                                               and managers, we published a survey in the form of
Following the publication of the Group-wide Anti-          a knowledge quiz throughout the entire corporate
Corruption Policy in 2017, we implemented its binding      group in Q3/2019. Participants can apply, deepen and
nature as a further measure in 2018. For this purpose,     check their knowledge from online training courses
an additional annex was added to the policy to con-        on corruption prevention. The aim is also to identify
firm compliance and acknowledgement. We were               any gaps in awareness and to preventively close
able to achieve 100% employee participation.               them.
In order to further expand the area of corruption pre-
vention, we established a webinar "Corruption
Prevention" as an online training course in the sec-
ond half of 2019, which is mandatory for all               GRI 206 | Anti-competitive behavior
employees to complete. At the end of 2019, participa-
tion was 77%. We aim to achieve 100% participation
by the end of 2020. We have also added a "corruption       GRI 103
prevention quiz" to our repertoire, which can be           Management approach
solved by all employees on our internal learning plat-     (including GRI 103-1; 103-2; 103-3)
form.                                                      In order for a free and fair market to develop, clear
                                                           regulations are needed that prevent distortions of
Moreover, since the training is to be completed
                                                           competition and prohibit anti-competitive practices.
online, there is no need for a separate listing of
breakdowns by region.                                      For this reason, ec4u is guided by the legal require-
                                                           ments of the law on unfair competition (UWG) and
Since the 2019 financial year, the anti-corruption
                                                           against restraints of competition (antitrust law). It is
guideline has been sent as a standard annex to the
                                                           important to us to observe and comply with the legal
service contract when new contracts are concluded
                                                           regulations in order to prevent distortions of compe-
with contracting business partners. We will continue
                                                           tition and to ensure fair competition. Our employees
to do this on an ongoing basis. In the 2019 reporting
                                                           are regularly informed about new regulations and
year, we were unable to identify any rejections of our
                                                           guidelines. We try to convey to our employees what
anti-corruption guideline. However, should this oc-
                                                           responsibility they themselves bear regarding the
cur, we will question the outstanding feedback.
                                                           prevention of anti-competitive behavior and rely on
Should it become apparent after personal discus-
                                                           their feedback.
sions that a business partner does not represent the
values set out in the anti-corruption guideline, it will   Should anti-competitive cases become known, we
be discussed together with the respective project          will investigate them and take action. In order to
managers whether the business relationship should          raise our employees' awareness even more, we
be terminated or whether the content can be                have decided in 2019 to establish a training course
adapted to the project and customer.                       on antitrust law in 2020.

We consider it detrimental to business to terminate        When selecting business partners, we are guided by
business partnerships with immediate effect, as the        whether they conform to our compliance guidelines.

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