SUPPLIER

 

CODE OF CONDUCT

Moving people closer, responsibly.

 


At Dott, our purpose is to move people closer: to each other, and to the lives they want to live. We are building a future in which cities are pollution-free and designed for people, not cars. We cannot do this alone. The partners in our supply chain, from vehicle and battery manufacturers to logistics, technology and service providers, are essential to delivering safe, sustainable and reliable mobility.

This Supplier Code of Conduct (this “Code”) is issued by TIER Mobility SE and its affiliates, trading as Dott (“Dott”, “we”, “us”, “our”). It sets out what we expect of those partners, and it reflects the same values and standards that guide our own people under the Dott Code of Conduct, grounded in internationally recognised principles of human rights, labour, environmental protection and business ethics. We ask every Supplier to embrace it, to apply it across their own operations and supply chain, and to work with us to raise standards across our industry.

 

 

Our Values

Act as One: 

We succeed with our partners, not at their expense. We expect open, honest and collaborative relationships built on mutual respect.

Do it Right:

We do the right thing even when it is not the easy thing: complying with the law, acting ethically, and putting people and the planet first.

Lead the Way:

We hold ourselves and our partners to the highest standards, going beyond minimum compliance to help set the standard for sustainable mobility.

    How This Code Works

    Suppliers, meaning our suppliers and their employees, agents and contractors, must adhere to this Code at all times in relation to their facilities and operations, including manufacturing, distribution, packaging, sales, marketing, product safety and certification, intellectual property, labour, immigration, health, worker safety and the environment.

    Suppliers are responsible for ensuring compliance with this Code by all of their own suppliers, vendors, agents and subcontractors, whether direct or indirect.

    Where this Code requires a higher standard than applicable law, the Supplier shall meet the higher standard. Where this Code conflicts with mandatory local law, the Supplier shall comply with local law and inform Dott of the conflict.

    Suppliers are expected to act consistently with internationally recognised standards, including the United Nations Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the Ten Principles of the UN Global Compact, the core Conventions of the International Labour Organisation, and the OECD Guidelines for Multinational Enterprises.

    We may revise this Code from time to time and expect Suppliers to review it at least annually. Failure to comply may lead to corrective action, suspension or termination, as set out in Section 12.

    1.   Human Rights And Fair Labour

    Doing it right starts with people. We are committed to upholding the human rights of everyone who works in our supply chain and to treating them with dignity and respect. This applies to all workers, including temporary, migrant, student, agency, contract and direct employees. Suppliers must:

    • not use forced, bonded or indentured labour, involuntary or exploitative prison labour, slavery or human trafficking, at any stage of manufacturing or sourcing;
    • ensure that all employment is freely chosen, allow workers to leave on reasonable notice, and not retain identity documents, require monetary deposits, or otherwise restrict a worker’s freedom of movement;
    • bear the cost of recruitment so that no worker pays recruitment fees or related costs (the employer pays principle), and repay any such fees found to have been charged;
    • not use child labour at any stage of manufacturing or sourcing, and protect any lawfully employed young workers from hazardous work;
    • comply with all applicable wage and working-time laws, pay at least the legal minimum wage on time and in full, provide clear wage statements, and make no unlawful or disciplinary deductions;
    • limit working hours in line with applicable law and, save in genuine emergencies, to a maximum of 60 hours per week including overtime, keep all overtime voluntary, and allow at least one day off in every seven;
    • respect workers’ rights to freedom of association and collective bargaining;
    • maintain a workplace free from harassment and unlawful discrimination, including on the basis of race, colour, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, trade union membership, protected genetic information or marital status, and never subject workers to harsh or inhumane treatment;
    • provide their own workers with a confidential mechanism to raise grievances without fear of retaliation;
    • conduct human rights due diligence across their operations and supply chain, consistent with the UN Guiding Principles and applicable EU law (including the Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive), and refresh it as circumstances change.

    2.   Health, Safety And Wellbeing

    Nothing we do is worth compromising a person’s safety. Suppliers must provide a safe and healthy working environment and manage the specific risks of our products, including batteries. Suppliers must:

    • identify hazards and put in place controls, personal protective equipment, warning notices and training covering mechanical, electrical, chemical, fire, physical and battery and thermal hazards;
    • implement specific controls for battery and thermal-runaway risks, and follow safe handling, storage, packaging and transport requirements for batteries and other dangerous goods;
    • complete fire safety measures and maintain emergency preparedness, including accessible exits, alarms, equipment and drills;
    • ensure workers have access to clean toilet facilities, potable water and sanitary food facilities, and that any worker accommodation provided is safe and hygienic;
    • report, investigate and address every work-related injury, illness or near-miss regardless of severity, and act to prevent recurrence.

    3.   Environment, Sustainability And Responsible Sourcing

    Sustainability is at the core of what we do. We expect Suppliers to minimise their environmental impact and to help us build a circular, low-carbon supply chain. Suppliers must:

    • hold all required environmental permits to operate their business;
    • operate an environmental management system, minimise the use of natural resources, and eliminate or reduce waste, emissions and discharges of pollutants;
    • measure and reduce their greenhouse gas emissions, energy and water consumption, and air emissions, and support Dott’s decarbonisation goals;
    • implement systems for the disposal, reduction and recycling of waste, and comply with all applicable laws on the use, labelling, handling and disposal of materials;
    • identify, label and safely manage, across their lifecycle, all materials that pose a hazard to people or the environment;
    • ensure compliance with all applicable EU regulations and standards for goods supplied to Dott, including but not limited to CEN standards and type-approval, the Machinery Regulation, the Low Voltage Directive, RoHS, the EU Battery Regulation, the General Product Safety Regulation, WEEE and REACH;
    • design for circularity, favouring repairable, refurbishable and recyclable parts, and support Dott’s take-back, reuse and second-life programmes;
    • apply OECD due diligence to critical minerals (including lithium, cobalt, nickel, tin, tungsten, tantalum and gold), refrain from sourcing where there are unresolved forced or child labour or unsafe artisanal-mining indications, and, on request, report sourcing using recognised templates (for example the RMI Conflict Minerals and Extended Minerals Reporting Templates);
    • certify batteries to applicable safety and transport standards (for example UN 38.3 and IEC 62133) before shipment, maintain traceability of cells and packs, not substitute cells or chemistries without prior written approval and re-certification, and promptly disclose any safety defect or recall.

    4.   Business Ethics And Anti-Corruption

    We compete and win on the merits, and we expect our Suppliers to do the same. Suppliers must:

    • uphold the highest standards of integrity in all business interactions and comply with all applicable local and international laws;
    • maintain a zero-tolerance policy prohibiting bribery, corruption, extortion, embezzlement, facilitation payments and kickbacks. Nothing of value may be promised, offered, authorised, given or accepted, directly or through a third party, to obtain or retain business, direct business, or gain an improper advantage. Suppliers must implement monitoring and enforcement procedures to ensure compliance with anti-corruption laws;
    • not make political contributions on Dott’s behalf, and keep any gifts and hospitality modest, occasional and transparent, particularly during a tender or negotiation;
    • ensure transparency in all dealings and keep accurate and complete books and records;
    • avoid and promptly disclose any actual or potential conflict of interest, including any personal, family or financial relationship between the Supplier’s personnel and Dott personnel that could influence, or appear to influence, a decision.

    5.   Fair Competition

    We believe fair competition drives better products and better cities. Suppliers must:

    • comply with all applicable competition and antitrust laws;
    • never engage in price fixing, bid rigging, or the allocation of customers or markets;
    • not exchange competitively sensitive information with competitors, and not use Dott’s pricing, specifications or bid strategy improperly.

    6.   Trade Compliance, Anti-Money Laundering And Sanctions

    As a global business, Dott expects its partners to trade lawfully and transparently. Suppliers must:

    • comply with all applicable anti-money-laundering, counter-terrorist-financing, sanctions, export-control and customs laws;
    • not transact with sanctioned parties or embargoed destinations, and screen their own supply chain against applicable sanctions and denied-party lists;
    • not facilitate money laundering or tax evasion, and maintain adequate controls to prevent them.

    7.   Data Protection And Privacy

    We earn trust by protecting the personal data of our riders, customers and colleagues. Where Suppliers process personal data connected with Dott, they must:

    • comply with all applicable data protection laws, including the EU General Data Protection Regulation, and process personal data only for legitimate, specified purposes, applying data minimisation, purpose limitation and storage limitation;
    • where acting as a processor for Dott, process personal data only on Dott’s documented instructions and under a written agreement consistent with Article 28 GDPR;
    • apply strong technical and organisational security measures appropriate to the risk;
    • transfer personal data internationally only where a valid transfer mechanism is in place, such as an adequacy decision or Standard Contractual Clauses;
    • engage sub-processors only with Dott’s prior authorisation and flow down equivalent data protection obligations;
    • assist Dott in responding to data subject requests, data protection impact assessments and regulator enquiries;
    • notify Dott without undue delay, and in any event within 24 hours, of any personal data breach affecting Dott data;
    • return or securely delete Dott personal data at the end of the engagement.

    8.   Cybersecurity And Responsible Technology

    We lead the way by using technology thoughtfully and securely. Suppliers must:

    • protect Dott’s systems and data with recognised security controls, secure development practices and vulnerability management, and align with applicable cybersecurity law (including the NIS2 Directive where relevant);
    • not connect unaudited firmware, telematics, hardware or software to Dott’s vehicles, fleet or IT systems without a prior security review;
    • report any cyber incident affecting Dott data or connected-vehicle or fleet systems without undue delay and within 24 hours;
    • where they develop, provide or operate artificial intelligence or algorithmic systems for Dott, comply with the EU Artificial Intelligence Act (Regulation (EU) 2024/1689) and other applicable law, avoid prohibited practices, and ensure such systems are safe, transparent, subject to appropriate risk management and data governance, free from unlawful bias, and subject to meaningful human oversight.

     

    9.   Confidential Information, Inside Information And Market Conduct

    As TIER Mobility SE is an issuer of listed debt securities, some Suppliers may receive material non-public information about Dott. Handling it correctly is both a legal obligation and a matter of trust. Suppliers must:

    • protect Dott’s confidential information and intellectual property, use them only for the agreed purpose, and not disclose them without authorisation;
    • treat any inside information (material non-public information) about Dott or its counterparties as strictly confidential;
    • not deal, attempt to deal, or recommend or induce others to deal, in the securities of Dott or any other company on the basis of inside information;
    • not engage in market manipulation or the unlawful disclosure of inside information, and comply with the EU Market Abuse Regulation (Regulation (EU) No 596/2014) and other applicable market-abuse laws;
    • cooperate with Dott’s insider-list and disclosure obligations, and return or destroy inside information on request.

    10.   Speak Up: Reporting And Non-Retaliation

    We want to hear about anything that is not right. Suppliers, and their workers, may report suspected or actual violations of this Code to Dott Compliance through:

    • the Dott whistleblowing Integrity Line (dott.integrityline.com);
    • email to compliance@ridedott.pro; or
    • post to emTransit Sp. z o.o., ul. Inflancka 4, 00-189 Warsaw, Poland.

    All reports are handled confidentially, without disclosure unless required by law. Dott does not tolerate retaliation against anyone who raises a concern in good faith, and Suppliers must likewise not retaliate against any worker who does so.

    11.   Management Systems, Monitoring And Audit

    Good intentions are not enough. We expect Suppliers to build the systems that make this Code real, and to show us how they work. Suppliers must:

    • adopt and document internal controls and processes to ensure compliance with this Code, including clear management responsibility, risk assessment, worker training, corrective-action processes and record-keeping;
    • monitor and review these regularly for continuous improvement, and evidence compliance on request through self-assessments or independent audits, including third-party sustainability assessments;
    • allow Dott, on reasonable notice, to inspect and audit their facilities and records to confirm compliance.

     

     

    12.   Compliance, Consequences And Acknowledgement

    This Code is a condition of doing business with Dott. Suppliers must:

    • work with Dott on a corrective action plan where improvement is needed; Dott may suspend or immediately terminate the relationship, including any purchase orders and contracts, for failure to comply, and in particular for serious breaches such as forced or child labour, corruption, a serious safety failure, or a serious data or security breach;
    • not supply, and acknowledge that Dott will not knowingly procure, any product or service made with forced labour, consistent with the EU Forced Labour Regulation;
    • note that any waiver of this Code requires the prior written approval of Dott’s General Counsel or Head of Compliance, and any amendment requires the approval of both;
    • on request, acknowledge this Code in writing and periodically certify their compliance, and be able to demonstrate how they cascade its requirements through their own supply chain.

     

     

    Questions about this Code can be raised at any time with Dott Compliance at compliance@ridedott.pro

     

    Effective Date: 14 July 2020
    Last Updated: 11 August 2026