Code of Business Ethics

This Code of Business Ethics has been formalized outlining our commitment towards our people and third parties who work for and with us, but also to summarize important and basic rules when we conduct business.

This Code of Business Ethics applies to all employees at BEYOND TECHNOLOGY IE SPV Ltd., Beyond Now GmbH and its affiliated companies (all together “Beyond Now”); everyone at every level, including our board members, directors and appointed company officers at Beyond Now (“People”), and third parties where appropriate. We work only with third parties if they share the same core values and business standards.

This Code of Business Ethics is published on our website, our intranet and is part of the welcome package of each employee. Our employees are regularly asked to acknowledge its content and are being trained on its key principles; we expect all of our People to understand its content and to follow it.

Beyond Now’s success is derived from the success of our People, and people-centricity is at the core of our growth strategy. We recognize and value the unique contributions that People with different backgrounds, experiences and working styles have to offer, enabling us to interact with different cultures and global stakeholders.

We do not discriminate against anyone because of race, colour, gender identity, age, family status, marital status, religion, disability, national origin, sexual orientation, trade union affiliation or other legally protected status. Beyond Now’s policies and practices ensure we value diversity, provide equality of opportunity and ensure that no employee, job applicant, client or other business partner receives less favourable treatment on any of the grounds set out above. We are committed to treat People fairly, promoting an integrated way of working and always respecting the dignity of our People. This commitment to the equal treatment of all our People creates a positive work environment where the right of dignity at work is recognized and protected.

We will not tolerate threatening language or behaviour, or acts of violence against our fellow People, visitors, clients or any other person at any time, and we are committed to maintaining a safe, healthy, harassment-free and rewarding work environment.

Our individual actions affect Beyond Now’s reputation and can have legal consequences for all of us. Accordingly, we must:

• Act with a high sense of responsibility, loyalty, dignity, decency and respect for our colleagues, clients and all other business partners, in accordance with our core values;
• Not use or possess illegal drugs or substances. Beyond Now takes its rules regarding workplace health, safety and security very seriously;
• Discharge our duties and legal or contractual obligations in compliance with professional standards, the terms and conditions governing them and Beyond Now´s long-term interests;
• Not engage in unfair trade practices. While it is necessary and proper to obtain information about our competitors through market research, product evaluation and information that is already in the public domain, we must not obtain competitive information by improper or illegal means; and
• Not acquire, accept the offering or attempt to acquire, a competitor’s confidential information from their current or former employees or business partners.

People and third parties acting on our behalf are prohibited from offering, promising, authorizing, making or receiving from clients, suppliers, public officials or any other business relations or partners, either directly or through a third party, any inappropriate monetary or other benefit or undue advantage, and in this respect must always comply with applicable laws and regulations.

This may include cash, cash equivalents, shares, services, products, travel, lavish entertainment, event participation, promotional programs, lavish gifts or employment opportunities, including internships.

Gifts and entertainment may be offered and received to strengthen business relationships, but only if they are of moderate and not excessive value When dealing with government and public sector entities we must keep in mind that special rules may apply.

We all have the responsibility to safeguard the integrity of Beyond Now, which also protects our clients and other stakeholders. This means all business decisions must be made independently, and be informed, reasonable and solely based on what is best for Beyond Now, in alignment with our values and the principles of this code. Business decisions must not be improperly influenced or corrupted by our personal interests. A conflict of interest arises in any situation where there is an actual, potential or appearance of competition between our personal interests and our obligations to Beyond Now.

Accordingly, we must not:

• Engage in actions, directly or through associated parties, or with third parties, which may not be compatible with the interests or reputation of Beyond Now;
• Derive personal benefits from a business decision or action, nepotism, or use confidential information for purposes other than the interest of Beyond Now or disclose such information to associates, family or friends;
• Speculate directly or indirectly through another person or engage in transactions or dealings based on information obtained in connection with our work for Beyond Now;
• Pursue any outside business opportunity for ourselves that we find through Beyond Now nor use such opportunity to compete with Beyond Now directly or indirectly, and;
• Trade in our clients’ shares while possessing material, non-public information – this is strictly prohibited.

Each employee must dedicate 100% of his professional working time to Beyond Now if not agreed otherwise. Any other business activities, including but not limited to board memberships, significant investments, or professional activities, must be formally approved by the respective employer´s managing director.

We recognize that People can develop a close personal or romantic relationship with another Beyond Now employee, client, business partner or supplier representative with whom we have regular professional contact. No employee should work in a position in which he or she has the authority to hire, directly or indirectly supervise or influence the employment action of an immediate family member or romantic partner. The same principle applies in relation to any active or prospective business relationship with a third party. In situations where a romantic partnership develops between two Beyond Now employees where one is in a direct line of performance or supervision, the more senior employee must, unless otherwise stipulated by applicable law, disclose the relationship to management or the HR representative for appropriate action. Management may choose to transfer one or both employees, change management or reporting lines, or introduce any other appropriate measures to protect the business.

In addition to respecting and protecting our People’s privacy and personal or sensitive information, we are also committed to respecting and protecting our client and business partner information and data. Beyond Now’s policies, processes and guidelines apply to all information and personal data (independent of being given in a written, electronical, visual or verbal form) entrusted to Beyond Now, and must be followed by all People, contractors and business partners who work for us, or on our behalf.

• We manage data and information with good care and do not retain unnecessarily, specifically not beyond finalizing a project.
• We dispose data or information in a timely and secure manner. 
• We maintain a quality management system and an information security management system.

We all rely upon our information technology and management resources (physical and financial assets, technology, information, research, strategies, name, image, systems and processes) to perform our duties. It is important to remember that these are to be used solely for business purposes. Incidental personal use is tolerated (or permitted) if it does not compromise the integrity and security of our, our client data, and the principles of this business conduct.

We are living in times of vast and rapidly evolving technical developments and understanding new technologies can assist us in our daily tasks. But technology, and specifically the data and information we share through this technology, must be managed properly and adequately safeguarded. We are all responsible for reducing our information security risks and protecting personal and sensitive data. Only use Beyond Now IT or client approved assets and software. Always be vigilant and safeguard the data and information entrusted to us.

Beyond Now’s success in the marketplace requires that we maintain the trust of our clients and the investment community at large. Any information concerning Beyond Now, its clients, suppliers, projects, products, services or its business that is not generally publicly available must be treated confidentially and only used for the purpose it has been provided to us. Unauthorized disclosure of confidential information can significantly damage Beyond Now´s reputation and can be in violation of applicable data protection or secrecy law and our contractual obligations.

It is important to remember that the obligation to maintain the confidentiality of Beyond Now and client confidential information remains in effect even after People no longer work for Beyond Now. Likewise, Beyond Now requires new employees to honor any continuing confidentiality obligations that they have with previous employers.

We all have the obligation to protect Beyond Now’s property and assets from loss, damage, misuse, or theft. This includes protection from any cyber-attacks. Any assets entrusted to us by our clients are only for that client’s use.

Information obtained, and work developed by our People or contractors in relation to work-related activities belongs to Beyond Now or the client and must be protected accordingly.

Beyond Now’s know-how, tools, methodologies, patents, trademarks, copyrights, and trade secrets are all considered Beyond Now´s intellectual property and People have an obligation to protect them. All work product that may be the subject of patents or other intellectual property rights, subject to registration or recordation, must always be promptly disclosed to Beyond Now´s managing directors.

Use of any third-party products, including open-source software, is subject to Beyond’s policy for use of third-party products. Protecting Beyond Now´s intellectual property needs commitment from all of us.

We are all prohibited from downloading, distributing, publicly displaying, publicly performing, or deriving modifications of copyrighted documents, graphics, software, music or video games without permission from the copyright owner when using Beyond Now time, property and resources. Content must be in line with our core values and rules for business conduct.

Environmental stewardship is a central issue for each of us and our families. We are committed to delivering sustainable results for our clients and our business. We believe that it is our corporate responsibility and social duty to meet our commitments by in parallel considering environmental sustainability; meaning that our and clients’ processes and actions have the minimum impact on our environment and the societies we operate in. We shall continually search for new ways to improve efficiency, reduce waste and minimize our carbon footprint wherever we operate.

We observe international human rights and related laws and regulations, strongly condemn child labor and forced labor and pro-actively apply the UN recommendations and other international standards in this respect. An essential component of Beyond Now’s corporate social responsibility is our commitment to being good corporate citizens within the communities where we do business.

We promote relations with suppliers, business partners and sub-contractors operating under the same values.

All charitable donations and sponsorships are managed and authorized by the managing directors of Beyond Now, if appropriate in consultation with the legal and finance department.

Any contributions made directly or indirectly to a political party, political fund-raising organization, or candidate, anywhere in the world, are prohibited.

Individual involvement in political activities or groups is a matter of personal choice. However, we must ensure that any political opinions we express are understood to be personal and are not made on behalf of, or may be attributed to, Beyond Now.

The principles in this Code of Business Ethics are not meant to be exhaustive. Above all we should always ensure that we comply with all mandatory laws and regulations of the countries in which Beyond  Now operates in or which are internationally applicable, that includes specifically rules on sanctions, export control, anti-money laundering and anti-bribery and corruption.

Beyond Now and its People must maintain clear, truthful, complete and accurate business and financial records, including time and expense recording, and should retain such records in accordance with legal requirements. Whenever we receive a notice, written demand or threat of litigation or legal proceeding from a third party, as well as any communication from legal or regulatory authorities, we must inform the legal department as soon as possible. We must not alter or destroy documents or records in response to an internal or external investigation or any other legal request.

Requests from financial institutions or creditors about our financial position must be forwarded to the Chief Financial Officer.

The only persons with the authority to legally represent any Beyond Now company are those expressly appointed by management and granted such power by applicable law or by relevant powers of attorney.

To protect Beyond Now’s reputation and avoid exposing the company to contractual liability, all representations made concerning our products, services and solutions must be current, accurate and clear, and not misleading or false. We recognize that social media assets can and should be a valuable tool for enhancing communication and promoting Beyond Now and its values.

But remember, we foster safe, professional and appropriate online behavior and will treat unacceptable “electronic behavior” through social media and other means, in the same way as we would treat other unacceptable behaviors, so always remain vigilant.

People are prohibited from disclosing any non-public or confidential information relating to Beyond Now or its business activities to the media including social media, without the prior approval of Beyond Now´s managing directors and/or, whenever appropriate, the marketing department.

Any enquiries and requests from the media and requests for company, product or service information must be forwarded to Beyond Now´s managing directors and/or, whenever appropriate, the marketing department.

Beyond Now works actively with governments around the world on public policy issues which may affect the firm. All enquiries about public policy positions should be referred to Beyond Now´s managing directors. No public policy statements must be made without their prior written approval.

In many cases, failure to comply with our Code of Business Ethics may expose Beyond Now to substantial fines, criminal prosecution, loss of licenses and access to government contracts.

People involved may also face fines, criminal prosecution and other disciplinary measures. Therefore, we must be sure to seek help and guidance wherever there is a doubt regarding the best course of action.

If you believe you have experienced or observed or are otherwise concerned over possible instances of non-compliant conduct either by an employee, client, supplier or other business partner, you are encouraged to immediately raise your concern.

Should a concern lead to an allegation which requires an investigation, Beyond Now will assign an appropriate expert to ensure that a full and fair investigation is completed as promptly as possible. Investigations are overseen by the legal counsel. Beyond Now does not tolerate retaliation against any employee who, in good faith, reports a potential violation, or cooperates with an internal investigation.

Safeguarding the reputation, assets and interests of Beyond Now is the responsibility of every person who conducts business on our behalf. In most cases we can achieve this by applying common sense, professionalism and personal integrity in everything we do. However, we must always remain aware of our responsibilities and stay alert to any situation where a potential problem could arise. We regularly publish additional information in our Intranet, but please also check the information provided on other functional pages. These complement our Code of Business Ethics, and we expect our People to learn and abide by it.

Questions about the Code of Business Ethics and its application should be sent to the managing directors of Beyond Now and if required will be forwarded to the most appropriate person within the relevant functions.