Code of Business Conduct

Preamble

We want companies to think and act consistently from their customers' point of view. To meet this goal, we develop customer experience management software that specializes in handling complex processes in customer service.

TurnFriendly solves any complaint because the experience of more than twenty years is in our industry specific software solutions. TurnFriendly wants to become the global market leader for Complaint Management Solution.

To achieve this goal, but also to prevent damage to the company, compliance with legal provisions and binding internal regulations is necessary.

Our Code of Business Conduct describes the value concept of TurnFriendly.

TurnFriendly is committed to acting in accordance with the law without any restrictions. We expect all employees to conduct themselves at all times in accordance with the applicable legal provisions and the binding internal guidelines as well as the provisions of the employment contract.

We are inclusive and intercultural

We welcome and support people of all backgrounds and identities. This includes, but is not limited to, members of any sexual orientation, gender identity and expression, ethnicity, culture, national origin, social and economic class, educational level, color, immigration status, gender, age, height, marital status, political beliefs, religion, and mental and physical ability.

We are considerate

We all depend on each other to do the best possible job as a company. Decisions always impact customers, colleagues and partners. We act with empathy and always keep the impact of our decisions in mind together.

We are respectful

We will not always all agree, and that is a good thing. We handle disagreements calmly, with focus and respect. We live and cultivate an open and constructive culture of discussion. Everyone should contribute and promote creative exchange. We ensure, always across all channels, modern and respectful communication.

We behave professionally

We always behave professionally and are friendly at all times. We do not insult or demean others. We always communicate in a non-violent manner and do not accept harassment or exclusionary behavior. This includes, but is not limited to:

• Threat of violence
• Disobedience
• Discriminatory jokes and discriminatory language
• Sharing sexually explicit or violent material via electronic devices or other means
• Personal insults, especially using racist or sexist terms
• Advocating or encouraging any of the above behaviors

We are attentive

We recognize strengths in diversity and use this as an opportunity. Different people have different perspectives on issues, and that can be valuable for solving problems or developing new ideas. If we can't understand why someone has a certain point of view, it doesn't mean they are wrong. We focus on problem solving and learn from mistakes. Because: Where no mistakes happen, nothing much else happens either. Mistakes are part of it and move us forward.

We are constructive

We always look for the best solution and work in a constructive atmosphere. We pay attention to each other in the dynamics of everyday work and permanently adjust our pace and our work processes. We recognize new perspectives in hurdles and create new scope for action through creative approaches to solutions.

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The working environment

Employees should act with integrity, comply with the law and follow company policies. They should treat customers, colleagues and partners ethically at all times. A professional working environment is ensured and actively shaped.

Conflicts of interest

A company's reputation depends on the actions and integrity of its employees. All employees have a responsibility to ensure that conflicts of interest are identified on an ongoing basis, including to avoid relationships and activities that interfere with their ability to make objective and fair decisions.

Protection of corporate assets

Employees should always act in a manner that protects Company assets, including physical, intellectual and electronic or digital property.

Combating bribery and corruption

A company's integrity is essential to maintaining its trustworthiness and good reputation. Employees should always do their work fairly, honestly and lawfully.

General Harassment and Sexual Harassment

TurnFriendly is committed to providing a work environment free from discrimination and unlawful harassment. Actions, words, jokes or comments based on, among other things, an individual's gender, race, age, religion or other characteristics protected by law will not be tolerated.

Use of smartphones at work

The private use of smartphones during working hours is permitted as long as this remains within limits.

Internet use at work

Employees may use the Internet when appropriate to access information needed to conduct Company business. Use of the Internet must not disrupt or damage the Company's computer network. The use of the Internet must not impair the productivity of an employee.

Data protection and data safety

Data security and data protection have top priority and are of fundamental importance. All employees have a special responsibility in this context.

1. All employees maintain strict confidentiality of personal data.
2. The internal data protection guidelines are binding for all employees.
3. We do not see the GDPR as a nuisance, but as a sensible basis and we comply with it.
4. We have the highest standards in developing secure software.

Environmental Protection

The employees deal responsibly with natural resources. We purchase consumables and office materials mainly from manufacturers with a sustainable and ecological orientation. Our office building has a solar system and is perfectly connected to public transport. The use of environmentally friendly means of transport is preferred, with home office commuting almost completely eliminated. Irrespective of this, every employee is entitled to a company bicycle. Our data center operator is part of the "Climate-neutral data centers" initiative, which was newly founded in 2021, and relies on a unique, patented concept for cooling with CECC (Combined Energy and Cooling Cells). This modern cooling system achieves up to 70% less energy consumption for cooling and operation. It is our goal to keep the negative impact on our environment as low as possible and to make the best possible use of the available options for saving resources.

Current status is December 2022.