Code of Conduct

Scope and purpose

The Code of Conduct (“the Code”) is a single point of reference for employees of TIER, its affiliates and subsidiaries. 

The Code provides guidelines to enable all employees to act lawfully, honestly, ethically, and in the best interests of the Company while performing their duties on behalf of TIER.  It is applicable to everyone across TIER, including Members of the Board.

We are all individually and collectively responsible for adhering to the Code. Managers, leaders and supervisors have additional responsibilities. They need to help their team members understand and apply the Code and demonstrate our values through their behavior in practice.

If one of the requirements in this Code is found to be in conflict with the national laws of a given country, the stricter requirements should be applied.

To make sure that does not happen, it is up to each and every one of us to familiarize ourselves with this Code, to integrate it into our own behaviour, and to bear the Code in mind when making decisions. When in doubt, we should seek advice and speak up.

TIER encourages employees to report violations of the Code. You can report your concerns via the Integrity line  (accessible here: https://tier.integrityline.com/frontpage) or to the compliance department directly at compliance@tier.app. We are committed to protecting any one who reports a violation.

Our company values

Trailblaze

We are the pioneers who pave the way for others to follow. We are bold, brave and we push boundaries. We are innovators, problem solvers and creative thinkers. We challenge the status quo and we strive for positive change. We are mavericks and voyagers, creating the transportation of the future for a better world. The people who choose us are like-minded change-makers and trailblazers.

Care

We care about the cities we are in, about the safety and well-being of our riders, our employees and our partners. We are considerate and respectful. We care greatly for the environment. It’s the reason why we are all here and why we exist. Sustainability is at the core and our goals will not be achieved at the expense of others. We are for the people and the cities who care and make choices to change the world for good.

Rise

We strive for excellence and reach further than anyone else to attain the highest standards in quality, not just for our products and our vehicles but also for ourselves. We lift our co-workers, our riders and our partners to reach new heights. We are efficient, competent and cost-effective and we will always rise to the occasion. We rise above problems, adversity and average. We learn and rise when we fall or stumble. When we work together toward our goals, we rise up the ranks, we rise in value and we rise with purpose.

Play

We are like the cities we live in: vibrant, diverse, modern and exciting. We are adventurous, streetwise and we have fun doing what we do. We work hard, but we always remember to play while we do. We take our work seriously, but that is no reason to not enjoy it. Play keeps us alive. We are creative and curious because we play. We learn and move forward because we play. Our value is that we take the dull and make it a joy. We enable our riders to explore the playgrounds we call our cities, free to enjoy every ride.

We observe the principle of fair treatment

TIER is committed to providing a working environment free from discrimination,  harassment and bullying and ensuring that all its staff are treated, and treat others, with dignity and respect.

All TIER employees are entitled to receive equal treatment. We do not tolerate any form of racism and nobody shall be either discriminated against or favoured because of their gender, age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. We embrace diversity, actively encourage inclusion and create an environment that fosters each employee’s individuality in the interests of the company.

This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts), and on work-related trips or events including social events.

Respect and mutual appreciation should be the hallmark of cooperation. That means that we allow different opinions, address problems openly and seek solutions together. This manifestation of mutual appreciation is the only way to maintain an environment of trust, tolerance, and fairness.

We do not tolerate corruption

We do not do business at any cost and we want to win contracts in a fair and legal manner. TIER does not tolerate unethical or corrupt behavior by its employees or business partners and will take action against it.

We pay special attention to ethical behavior in our contact with political parties, public authorities and their officials both at home and abroad. Under no conditions do we grant payments, favors or other monetary contributions to civil servants, public employees or employees of governmental organizations in order to win contracts or gain advantages for the Group or other individuals. This applies even when benefits are expected or “common” for official duties. We also do not try to influence specific business dealings with private enterprises by making illegal payments.

In our business dealings, we always pay special attention to avoid even the mere appearance of impropriety, such as an attempt to influence our business partners or customers.

Gifts, benefits and invitations: Inappropriate gifts, entertainment and hospitality can be seen as an attempt to unfairly obtain business benefits and constitute an unlawful bribery. Gifts to, entertainment or hospitality by public officials entail an increased risk of alleged bribery and always require prior consultation with the compliance department (compliance@tier.app). We commit to follow internal processes for registration and approval of gifts, entertainment or hospitality (given or received).

We do not tolerate money laundering or terrorism financing

TIER is committed to complying with all applicable laws and policies related to the prevention of money laundering and the fight against terrorism. Money laundering occurs when funds or other assets originating directly or indirectly from criminal offences are put into circulation in the legal economy, making their source appear legal. Terrorism financing occurs when money is made available to commit criminal acts of terrorism or to support terrorist organizations.

It is our aim to conduct business solely with reputable partners who operate in line with legal provisions and who use resources from legitimate sources.

We shall take no action that may violate money laundering provisions whether in our own country or abroad. If an employee suspects that TIER may have or have come into contact with funds whose source is doubtful, then these circumstances must be reported immediately to the Compliance department (compliance@tier.app). If there are indications of money laundering or financing of terrorism, we will immediately report this matter to the relevant supervisory authority.

We avoid conflict of interests

We are expected to use our judgment to act, at all times and in all ways, in the best interests of TIER while performing our job duties. As such, we should avoid actual or apparent conflicts of interest.

A conflict of interest exists when your personal interests interfere with the best interests of TIER. For example, a conflict of interest may occur when you or a family member receives a personal benefit as a result of your position in the Group. Similarly, you may not use your position at the Group to request personal benefits for yourself or your family members. A conflict of interest may also arise from your personal relationship with a customer, supplier, vendor, competitor, business partner, or other supervised employees if that relationship impairs or may be perceived to impair your objective business judgment.

All our decisions should be made exclusively on the basis of objective criteria and we do not allow ourselves to be swayed by personal interests or relations.

The best rule for any situation that appears to present a conflict of interest is to “abstain and disclose.” If it is not possible to avoid participating in the event or activity creating the conflict, promptly disclose the potential conflict and avoid participating in decisions that might raise the appearance of a conflict until you receive appropriate guidance (compliance@tier.app).

We do not tolerate anti-competitive behaviour

We are committed to ensuring fair competition in our markets and to obeying applicable antitrust and competition laws. We prohibit illegal agreements and coordinated behavior that intends to or may limit competition. If we discover such agreements, we immediately terminate them and impose sanctions.

Fair competition is a prerequisite for the free development of the markets and the social benefits stemming from them. Fair competition promotes the development of innovative products and services. Antitrust law protects just this competition. In the competition for orders and market shares, every employee is obliged to comply with the rules of antitrust law.

Our goal is to do the best business with the best products in a decent manner. Accordingly, we treat our competitors fairly and cooperate with our business partners and customers respectfully and in a spirit of trust. These common principles form the basis for these relationships and are meant to guide our business transactions. Therefore, we select our direct business partners according to their adherence to the same principles that we have established for ourselves in this Code.

If there is any doubt as to whether a conduct may violate antitrust rules, employees must contact the Legal (legal@tier.app) or Compliance Departments (compliance@tier.app).

We take care of Tier’s property and assets

It is in our common interest to safeguard the property and assets of TIER. It is only natural for us to protect the company’s assets, to handle them with care and not to use or embezzle them for our own inappropriate or unauthorized purposes. Depriving TIER of financial and material assets through misappropriation or misuse is detrimental to the company and harms us all.

We must ensure that the appropriate steps are always taken to protect the interests of TIER, in particular intellectual property and other company secrets, documents and data carriers, against unauthorized access by third parties and unauthorized use by third parties.

Any misappropriation or misuse must be reported to the Compliance department (compliance@tier.app).

We promote a healthy and safe work environment

We continually work on improvements in the working environment and preventive healthcare, and we will always do our best to remedy any situation that is unsafe or unhealthy. Employees shall obey the local and national regulations as minimum standards. We create motivational and inspirational working conditions.

We are committed to a violence-free work environment, and TIER will not tolerate any level of violence or the threat of violence in the workplace.

Employees shall comply with the occupational health and safety rules issued by TIER, and shall never put the health and safety of their colleagues at risk.

Employees should speak up if they believe that their working environment is unsafe or presents a health risk, and inform the Health and Safety team at safetier@tier.app.

We preserve our confidential information and comply with data privacy requirements

Whether confidential or not, we should always take care to ensure that all business records and communications are clear and accurate. Potential risks from inaccurate or misleading statements include claims of false advertising, misrepresentation, breach of contract, securities fraud, unfair disclosure, and antitrust violations.

We shall not share any of TIER's confidential information with anyone unless we know that we are authorised to do so. Confidential information includes trade secrets, business, investment, marketing, operations and service plans, consumer insights, engineering and manufacturing ideas, designs, databases, records, salary information and any non-published financial data or other data.

Personal data, which are individual details about personal or material circumstances of a certain or determinable natural person, may only be collected, stored, processed, forwarded or used in any other way, as far as this is expressly permitted by law. They must be stored securely and protected against unauthorized access and unauthorized transmission. The use of data must be transparent to those affected. Our individual legal rights to information, opposition, blocking and deletion must be upheld. If an employee has any questions, they should contact the data privacy team at dpo@tier.app.

We comply with the code

TIER expects the members of its Board, its managers and its employees to obey this Code. All employees are required to familiarize themselves with its contents, know them and act in compliance with them. After all, it forms the foundation of our daily work.

This Code cannot encompass the standards, procedures, and regulations for our Group in every detail. The specific policies, instructions, or regulations for individual cases which have been adopted by the Group are binding.

Business units, departments or individual entities with specific conditions may require additional regulations. These regulations are also binding.

We do not tolerate any violation of the Code of Conduct. Violations of this Code and other Group policies and regulations may have consequences on the employment relationship and other legal implications in accordance with the principle of proportionality.

Legal restrictions leading to non-compliance or exceptions with the standards described above must be identified, documented and reported to the Compliance team. TIER will not retaliate, and prohibits all employees from retaliating against any employee who in good faith reports suspected unethical conduct, violations of laws, regulations or company policies.