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Code of Conduct

INTRODUCTION

All employees and agents working with Embers Call Center & Marketing GmbH form a team founded on mutual appreciation and trust. We live and act according to our motto: “Stronger together.”

Our Mission: We accompany customers on their customer journey. In addition to traditional telephony, we offer both complete solutions and demand-oriented concepts to specifically respond to customer needs. Our goal is to continuously evolve and implement our concepts reliably and in compliance with quality standards.

CHAPTER 1 – GENERAL GUIDELINES

1. Respect for Human Rights

Embers respects the human rights of every individual. We reject any form of discrimination against employees or any individuals working with Embers (e.g., business partners) based on nationality, origin, religion, gender, ideology, etc. (see also Chapter 6).

Embers also strongly opposes any form of forced or child labor and respects fundamental human and labor rights.

2. Compliance with Laws, Regulations, and Internal Policies

Embers adheres to all applicable laws and regulations in the countries and regions where we operate, conducts its business honestly and ethically, and refrains from any illegal actions. Embers is committed to understanding and complying with applicable laws and seeks advice from professionals, experts, and relevant authorities when necessary.

3. Social Responsibility and Contribution

Embers strives to positively contribute to society and fulfill the expectations of the communities in which it operates.

CHAPTER 2 – RELATIONS WITH CUSTOMERS AND BUSINESS PARTNERS

1. Fair Competition and Business Dealings

Embers is committed to complying with competition law and ensuring equal competitive conditions.

2. Legally Binding Contracts

Recognizing the importance of contracts and agreements, Embers is committed to strictly complying with valid contracts and agreements made with customers, business, and trading partners.

3. Protection of Corporate Values

Gifts, hospitality, or other benefits offered to our partners must adhere to customary practices and comply with legal requirements.Corruption, collusion, fraud, or bribery not only lead to severe penalties but also harm business relationships and the company’s image, which may ultimately endanger jobs within the company.

4. Dealings with Government Agencies and Public Officials

Embers commits not to offer gifts, hospitality, or other benefits to civil servants, public officials, or government representatives—unless explicitly permitted by national law.

CHAPTER 3 – ENVIRONMENT

Embers aims to be an environmentally conscious company contributing to a recycling-oriented society.

Contribution to the Environment and Society

Embers’s principle is to minimize environmental impacts from its services and operations by using energy and natural resources efficiently. Environmental protection is a consideration in all business phases.Through a largely paperless work environment, Embers contributes to resource conservation and environmental sustainability.

Embers’s home office agents work remotely – offering an eco-friendly advantage by eliminating the need for vehicles or public transport. The resulting CO₂ savings of 365 tons per year, combined with work-life balance for agents, make Embers the ideal partner for telecommunications projects.

CHAPTER 4 – INFORMATION MANAGEMENT

1. Business Information

Embers protects and properly manages all business information in accordance with legal requirements, regulations, and internal policies.

2. Protection of Intellectual Property

Embers is committed to respecting intellectual property rights.

CHAPTER 5 – ACCURATE ACCOUNTING

Embers guarantees accurate accounting practices in accordance with the relevant accounting and tax laws, regulations, and internal guidelines.

CHAPTER 6 – WORK ENVIRONMENT

Embers is committed to creating and maintaining a pleasant, healthy, safe, and productive work environment free from discrimination and harassment. Employees must always respect individual human rights and treat others fairly.

CHAPTER 7 – CONDUCT IN DAILY BUSINESS

Embers conducts its business using reasonable and appropriate methods and procedures in compliance with laws, regulations, internal rules, and generally accepted social norms.

CHAPTER 8 – CONDUCT AND RESPONSIBILITY AS A MEMBER OF THE COMPANY

All employees are required to observe the Embers Code of Conduct and to ensure that private speech or inappropriate behavior does not harm the reputation or credibility of the company or disrupt company order.

CHAPTER 9 – CONFIDENTIAL INFORMATION

Embers ensures that personal data is processed or used only within the scope of professional responsibilities. Any misuse is prohibited and punishable.

Upon joining the company, all employees are informed about data confidentiality, protection of business secrets, and social media policies. They confirm this through their signature in the confidentiality agreement.

The obligation to maintain confidentiality and not exploit disclosed information does not apply if the information was already publicly known or generally accessible prior to disclosure.

This confidentiality obligation remains in effect regardless of whether an employment relationship exists. It applies indefinitely.

Agents are also contractually informed in writing about the confidentiality of data and confirm this in their contracts.

Passwords assigned to employees or agents during their work for Embers must not be shared and must be changed regularly.