At MobilityWorks we are aware of our social role and our responsibility towards customers, business partners, shareholders and employees. Therefore, we have a set of clear principles that define how we conduct our business and social activities.

Our activities are determined by our shared values of trust, passion and performance. These values ensure that we have a common identity and can be found in concrete terms in this Code of Conduct.

All our company employees are required to act in a way that is independent, honest, loyal, full of integrity and respectful towards others and the environment. Our managers need to lead by example.

Our company’s fundamental goals are to achieve company success by providing our customers with the services they need. We strive to constantly improve the quality of our products and services and thereby achieve a sustainable rate of return in line with the market for the MobilityWorks shareholders.

To this end, we rely on:

• the skills, strength and dedication of our employees;
• a reliable, social and political environment;
• opportunities provided by scientific and technological advances;
• a clear focus on customers when developing innovative products.

There are three primary objectives to this Code of Conduct. Firstly, it encourages all employees to take responsibility for their own actions and provides employees with the necessary guidance to this end.

Secondly, it defines the goals and principles that guide our business activities.

Finally, it sets the standards for collaborating with contractual partners and provides a common basis on which to build contractual relationships.

I. Scope of application

The Code of Conduct applies uniformly throughout MobilityWorks. Subsidiaries of MobilityWorks outside of Belgium may consider the particular customs of their own countries when implementing the Code of Conduct, so long as this does not contradict the Code’s basic principles. The Code of Conduct extends to company interests and all areas in which employees are perceived as representatives of MobilityWorks.

II. Compliance with laws and regulations

It is important for us to be successful in the long term. We believe that this is only possible if we maintain our integrity in all aspects of our business activities. We must therefore comply with all laws, directives and comparable regulations. These constitute the framework that determines how we act. We make sure that we ourselves act in a way that complies with the law, and we expect the same from our partners.

III. External relations

General principles

We only wish to achieve our business goals by using legal and ethical means. We expect our partners to do the same. Private interests must remain strictly separate from the interests of the company. Should a conflict of interest arise, it should be disclosed and resolved. Indeed, we must avoid even the impression of a conflict of interest. We manage the company’s tangible and intangible assets appropriately and protect them from being lost, stolen or misused. We also respect third-party property and are committed to protecting business secrets.

We may not solicit or accept monetary benefits from third parties, nor may we offer or give them to third parties. Other types of benefits are only allowed within the bounds of customary business practices, under the condition that such benefits will not lead to the impression of undue influence. Cash benefits are prohibited. We make sure that we handle personal data very carefully.

Conduct towards customers

We offer our customers a wide range of ICT products and services. It is very important for us to deal with customers fairly and to offer them suitable and efficient solutions.

Conduct towards shareholders

The MobilityWorks’ shareholders capital is the prerequisite and foundation of our business activities. We therefore want to preserve this capital and achieve returns on it in line with market conditions.

Conduct towards business partners

We advocate free competition and transparent markets and are against unfair competition and restrictions of competition. This means that we comply with requirements regarding tax levies, subsidy grants and procedures for awarding public contracts.

Through our activities, we would like to set an example and work towards propagating the set of principles in our Code of Conduct. We therefore expect companies that enter into a business relationship with MobilityWorks to accept the principles in our Code of Conduct as the basis for the partnership. This happens by including the principles that are part of our MobilityWorks Code of Conduct in the contractual relationship. Should competing policies come into conflict with each other or the application of the principles of conduct not be possible during the business relationship, we strive to agree on a common set of standards that is at least equal to the level of the UN Global Compact. If it becomes publicly known that a business partner has violated these responsibilities, we will re-examine our business relationship with that partner and take any appropriate measures that we deem necessary.

When choosing consultants and agents, we focus especially on their qualifications and integrity. In all business relationships, we observe the applicable national and international sanction and embargo directives as well as any other applicable foreign trade law restrictions. We also take all necessary and appropriate measures to prevent money laundering.

Conduct towards the public

We publish company information in accordance with Belgium and international capital markets provisions in order to enable proper trading in company securities.

At the same time, non-public information that could reasonably be expected to significantly affect the price of company securities must remain confidential until it is officially released and must not be used as the basis for decisions about buying or selling securities. All communications from MobilityWorks are full, fair, accurate, timely and understandable. We respect the professional independence of journalists and the media.

Only authorized persons can disclose information concerning MobilityWorks or its subsidiaries to the public, the media or to other third parties.

IV. Conduct towards policy-makers

Dialogue with representatives of government bodies and political parties is indispensable, but we want to avoid even the impression that MobilityWorks exercises undue influence. For this reason, we are committed to remaining non-partisan and do not make any contributions to any political parties or organizations and foundations that are closely associated with political parties. MobilityWorks does not employ any employees whose main occupation is to hold public office or a parliamentary seat. Nor do we make consultancy agreements or similar ‘payment for services’ agreements with representatives from such groups of people.

V. Commitment to corporate responsibility

A sense of responsibility towards society and the environment is an essential factor in maintaining the success of a company. We are aware of this, and therefore support corporate citizenship – especially in social, ecological and cultural areas. We seek to be in dialogue with groups that are affected by our business activities or whose activities influence MobilityWorks business activities. We are happy for our employees to engage privately in civic, political and democratic as well as social initiatives, especially for charitable and social causes, as long as these activities do not conflict with our business interests. MobilityWorks does not pursue its business interests through its employees’ activities in this area.

VI. Internal relations

Equal opportunity and mutual respect

We respect the dignity and individuality of all employees. Our interactions with each other are characterized by mutual respect, fairness, team spirit, professionalism and openness. No employee or job applicant will be discriminated against on grounds of gender, marital status, ethnic background, nationality, age, religion, sexual orientation, or physical or mental disability. Our employees abilities and qualifications are the most important criteria for how we select, train and develop our employees. We advocate equal opportunity and diversity.

We endeavour to help our employees achieve a work-life balance and pay special attention to helping them reconcile their family lives with their careers.

Occupational health and safety

We work towards constantly improving the occupational health and safety conditions for our employees and the safety of our facilities.

All employees are responsible for helping to protect other people and the environment in their work environment. All managers are required to instruct and support their employees in fulfilling these responsibilities.

VII. Code of Conduct and reporting – implementation, consolidation, compliance

General principles

This Code of Conduct forms the basis of our company culture and is of course a part of our day-to-day work. Nevertheless, it falls especially on the managers to actively encourage and request again and again that employees implement and comply with the Code of Conduct.

The Group audit will pay close attention to the level of compliance with the Code of Conduct, and the Code’s general principles will be a part of the audit criteria. The Code of Conduct is the basis for additional company regulations that will consider factors specific to the industry and country concerned.

Contact partners

All employees should actively speak with their line manager if they have any questions related to the Code of Conduct or compliance. The same is true if they come across any indications that the Code of Conduct has been breached.

An external contact person is also available for you to contact if you have any information concerning a breach of the Code of Conduct. Information given to the external contact persons will be passed on to the Chief Compliance Officer of MobilityWorks – anonymously, on request – who will then handle the information as described above.

You can find the contact details of the Compliance Officer and external contact persons on the intranet site.

Confirmation and reporting

All managers who are responsible for employees need to give an annual report about the implementation of the Code of Conduct in their areas of responsibility.

Documentation

Benefits given to public officials that are of relevance in accordance with our policies, donations and sponsoring measures as well as consultancy contracts and agent contracts are documented in a Group-wide register.

Rekem-Lanaken, January 2020