Company Policy

CloudEO Company Policy

  1. General

We believe our business can make a positive
contribution to society and the environment by managing our activities
with care and by working with responsible organisations that promote
social and environmental causes.

Our operating companies are required to comply
with this CR Policy and report performance to the parent company quarterly.

It is part of the management's core duties
to ensure that operations comply with this policy.

Suppliers of CloudEO are encouraged to comply
with this CR Policy.

  1. Corporate Governance

Corporate governance refers to the legal and
factual framework for the management and supervision of a company. This
includes the allocation of competences among the bodies of the company
(Meeting, Supervisory Board and Executive Board) with regard to management
and control of the Company. CloudEO is oriented towards and follows
the "German Corporate Governance Code."

  1. Social Investment

CloudEO and its suppliers are encouraged to:

  • Undertake pro bono work for not-for-profit organisations involved
    in tackling social and environmental issues.
  • Make appropriate financial and other donations to social and environmental
    organisations.
  1. Managing Relationships

In all our relationships we will be open, honest
and transparent and will not pay or receive bribes or inducements of
any kind.

  1. Employment Policy

CloudEO is convinced that the company’s success
depends on the talent and performance of dedicated employees. CloudEO takes appropriate measures to ensure that the rights of employees are protected within the company. CloudEO operates a structured labour
management system that is oriented towards SA 8000 and recognizes and
follows the international standard ISO 26000 guidance on social responsibility,
as well as the Fundamental Conventions of the International Labour Organization.

These principles guarantee a uniform minimum
standard for all CloudEO companies and employees.

5.1 Forced and Child Labour

CloudEO excludes any form of forced, bonded
or compulsory labour. CloudEO does not accept the employment of children
below the legal minimum age and does not have any business relationship
to entities not following these rules.

5.2 Harassment and Discrimination

CloudEO does not tolerate any mental, physical
or sexual harassment that violates an employee’s right to dignity
and respect in the workplace based on gender, race, age, skin colour,
religion, marital status, sexual orientation, heritage, national origin,
physical or mental disability or any other characteristics protected
by applicable laws or regulations.

CloudEO provides a safe and civilised workplace
free from sexual harassment or offensive behaviour.

5.3 Recruitment, Promotion
and Development of Talent

CloudEO selects and promotes the employees
only on the basis of qualifications and merit. CloudEO supports training
and career development for the employees and provides on-going training
and development opportunities through formal programs, coaching, mentoring
and on-the-job experiences.

5.4 Communication

CloudEO has high responsibilities for its partners
and customers assets and CloudEO needs highly professional and efficient
work execution by all employees to be successful. The dynamic structure
of the business requires regular company meetings, where the strategy
of the company is presented to the employees for maximum transparency.
Information-sharing and open communication is essential for CloudEO.
All employees have the right and are encouraged to actively communicate
with managers and colleagues through an open dialogue culture.

5.5 Remuneration

CloudEO remunerates according to the skills,
performance and experience of the employees based on local competitive
conditions and offers benefits in accordance with local market practices.

5.6 Health and Safety

CloudEO is committed to protecting the health
and safety of its employees and others potentially affected its activities.
Equally, the employees must comply with health, safety and environmental
protection regulations of CloudEO.

A healthy and safe working environment is provided
for employees, contractors, partners or others who may be affected by
company’s activities, in accordance with international standards and
national laws. Mechanisms are in place to ensure that health and safety
obligations are communicated and applied to parties under their control.
Products and/or services delivery meets general principles of H&S
risk prevention. Mechanisms are developed and implemented to ensure
that all employees are competent to carry out the health and safety
aspects of their responsibilities and duties. Facilities and amenities,
including employee accommodation where provided by the company, shall
be hygienic, safe and meet the basic needs of employees. The company
has systems and trainings to prepare for and respond to accidents, health
problems and foreseeable emergency situations. A means for recording,
investigating and implementing learning points from accidents and emergency
situations is in place.

5.7 Freedom of Association

Open communication and direct engagement between
employees and management are the most effective ways to build employee
relations and resolve issues.

The rights of employees to join or not to join
trade unions, or similar representative bodies and their right to collective
bargaining in accordance with local laws are respected.

5.8 Working Hours

Working hours of employees do not exceed the
maximum set by local law. In exceptional circumstances, when these hours
might be exceeded, overtime is compensated at a premium rate and workers
shall be allowed at least one day off per seven-day week.

5.9 Employer’s Expectations

All employees must follow the guidelines for
professional and reliable work and need to fully comply to agreements
with partners and customers concerning confidentiality and safety of
data and assets. They are expected to be committed to CloudEO, to behave
ethically and within the law and to treat fellow employees with mutual
trust and respect.

Employees need to handle confidential information
according to the set guidelines and with a "need-to-know policy”.
They are required to handle confidential information with due care and
skill, acting in the interests of CloudEO.

Employees are expected to seek advice and direction
when the requirements of the law or of good business practice appear
unclear. We encourage our employees to get help and advice they need.

5.10 Employees’ Expectations

CloudEO takes the opinion of its employees
seriously and asks regularly for their feedback. Employees can report
compliance concerns confidentially and anonymously. CloudEO runs an
employee survey to solicit candid, anonymous feedback on needs and expectations
to enable identification of areas for improvement.

5.11 Infringements

Employees shall mention immediately to CloudEO
management, if they feel that any of those guidelines may not be fulfilled.
Employees should actively identify any events or workflows, which might
lead by chance. Any evidence of wilfully breach of the agreements shall
be immediately brought to the management.

5.12 Implementation

CloudEO is committed to enforce this Policy
and uses it as the foundation on which our employment processes are
designed on and monitored against. Likewise, the company expects all
employees to act in accordance with this Policy. If any employee suspects
this Policy is being violated, they should bring this to their managers
immediately. The responsible manager is required to take the necessary
steps to terminate violation of any provision of this Policy. CloudEO
will not retaliate against employees for reporting violations of this
Policy and will not tolerate retaliation by managers, co-workers or
other employees.

  1. Quality Management

CloudEO operates a structured quality management
system that is oriented towards international standard ISO 9001. This
internal quality management process is constantly being developed.

6.1 Principles

The customer is our most important employee.
Therefore, CloudEO strives towards a continuously improvement based
on customer surveys and their evaluation.

6.2 Resources

Communication within the company results from
personal discussions and regular meetings.

The requirements of occupational health and
safety are perceived by an internal health and safety officer.

For compliance with the legal / regulatory
requirements, as well as for the infrastructure and working environment
the management is responsible.

Our employees are trained on a regular basis.

6.3 Processes

6.3.1 Management Process

By means of the management processes a clearly
defined structure of our company is illustrated. For this purpose objectives
are defined and their performance systematically monitored to derive
steps for fulfilling these objectives.

6.3.2 Value-added Processes

Our value-added processes align with the requirements
of our customers. This results in a continuous adaptation to the demands
and wishes of our customers.

6.3.3 Supporting Processes

Supporting processes are provided for smooth
running of the value-added processes. Thus, the implementation of customer
requirements is assured.

6.4 Measurement, Analysis and Improvement

The effectiveness of CloudEOs quality management is monitored by evaluating the customer satisfaction-dissatisfaction surveys and the results of internal audits.

The management system is subject to scheduled
and unscheduled audits. By means of these audits the compliance with
the applicable instructions, as well as the effectiveness of the measures
taken is determined by objective evidence. Necessary corrective measures
can be initiated. Their implementation is monitored.

By a regular review the quality management
is evaluated and further developed. The measurement and monitoring of
processes ensures that customer requirements are met. In the on-going
processes corrective and preventive measures are systematically initiated
and their implementation is monitored.

6.5 Applicable Documents

Attachment 1: Process Map

Attachment 2: Organization Chart

  1. Marketing Ethics

CloudEO complies with applicable regulations
and self-regulatory codes of practice in the countries in which it operates.

CloudEO will not knowingly create work which
contains statements, suggestions or images offensive to general public
decency and will give appropriate consideration to the impact of its
work on minority segments of the population, whether that minority is
by race, religion, national origin, colour, sex, sexual orientation,
gender identity, age or disability.

CloudEO will not undertake work designed to
mislead in any respect, including social, environmental and human rights
issues.

  1. Environment

CloudEO operates a structured environmental
management system and recognizes and follows the international standard
ISO 14001 – Environmental Management.

In particular, CloudEO will respect the environment
by minimising their impact from:

  • Energy use
  • Transport

    In particular, CloudEO infrastructure is set up to make full use of
    modern remote professional cooperation tools. CloudEO employees shall
    consider workflows for internal and external cooperation, which utilize
    these facilities for their daily work – saving travel costs and time.
  • Consumption of paper and other resources.
  • Managing any significant CR risks in our supply chains.
  1. Human Rights

CloudEO companies will uphold the principles
contained in the United Nations Universal Declaration of Human Rights
and the International Labour Organisation’s fundamental conventions
on core labour standards.

We support the right of our people and their
families to basic human rights including the right to organise, the
right to fair conditions of work, freedom of opinion and expression
and freedom from forced labour and child labour. CloudEO working environment
provides a significant number of jobs, which can be at least partly
executed from home offices and at flexible working hours. Additionally
part time employments can be offered.

CloudEO encourages its employees to take largely
benefit from this set up to be able to perform professional work for
the company as well as taking care for their children or elderly relatives
and to achieve a healthy work life balance.

  1. ICC Anti-corruption
    Clause

CloudEO operates a structured management system
and follows the ICC Anti-corruption Clause for companies. CloudEO complies
with the ICC Rules on Combating Corruption.

  1. Related Links

German Corporate Governance Code

ISO 26000

SA 8000

ILO Fundamental Conventions

ISO 9001

ISO 14001

ICC Anti-corruption Clause

  1. Entry into Force

This Policy was updated and approved by the
Corporate Management on March 01, 2013 and entered into force the same
day. It replaces the previous edition dated Jan. 01, 2013.