Modern Slavery Act Transparency Statement

This statement is made by TIER Mobility SE pursuant to section 54 of the UK Modern Slavery Act 2015 and covers the financial year ending 31 December 2022. This Statement sets out the steps that TIER is taking to reduce the risk of slavery and human trafficking taking place in its business and in its supply chain. It is applicable to all its subsidiaries, notably TIER Operations Limited, a company incorporated in England and Wales with current operations in the United Kingdom.

TIER Mobility SE is a company incorporated in Germany and registered with the commercial register of the local court of Charlottenburg under number HRB 198977. TIER Mobility SE and its subsidiaries (together, “TIER” or the “TIER Group”) has over 3000 employees and operates in over 24 countries. TIER Group has a global annual turnover exceeding €50 million.

TIER is committed to improving its practices and ensuring that acts of modern slavery and human trafficking are excluded from its business and from within its supply chains. We acknowledge our responsibility under the Modern Slavery Act 2015 and aim to ensure transparency within our organisation and with our suppliers of goods and services.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our newest version of Supplier Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Our Business

TIER is the world’s leading micro-mobility operator. Its headquarters are in Berlin, Germany, and it operates through branches and subsidiaries throughout Europe, the United Arab Emirates, and the United States. Its manufacturers include companies based in China and TIER’s representatives regularly visit the manufacturers’ premises. The supply contracts entered into from 2020 onwards include obligations for the suppliers to undertake compliance with TIER’s Supplier Code of Conduct.

General Statement

TIER places great importance on respecting and promoting human rights and fundamental freedoms. That includes having a zero-tolerance policy approach to all forms of slavery and human trafficking and it is also an integral part of TIER’s supplier contracts based on the Supplier Code of Conduct.

At TIER, we understand the unique responsibility of the private sector in these efforts and are committed to expanding our work to address any modern slavery risks that may arise in the course of our business.

Social Responsibility At TIER

TIER will not work with any suppliers who have demonstrably and repeatedly failed to comply with basic International Labour Organization (ILO) standards.

Combining the pursuit of economic objectives with consideration for social and environmental factors is a high priority for TIER. In addition to our Supplier Code of Conduct, we have adopted an Employee Code of Conduct and a Diversity, Equality and Inclusion Policy and carry out staff training in respect of these policies. We appointed a Group Compliance Officer in late 2021 whose role is to implement and monitor a Group-wide compliance program in pursuit of our ESG criteria. In particular, it has already been implemented:

• An updated Supplier Code of Conduct
• A third party management process, including different levels of due diligence depending on the supplier’s risk level exposure.
• The most comprehensive Procurement policy, including an updated list of preferred suppliers, ensuring appropriate due diligence is undertaken, and requiring that they abide by our Supplier Code of Conduct.
• Default terms and conditions applicable to all our relationships with our suppliers, which strengthens the obligations set out in our Supplier Code of Conduct providing TIER with the right to terminate agreements by written notice to a supplier with immediate effect if the supplier commits a material breach.
• A Whistleblowing tool, including a Whistleblowing procedure providing a secure space to all employees to raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
• An Enterprise Risk Management framework, including a specific risk owner to human rights and modern slavery, a risk assessment and a treatment onwards.
  

Also driven by the Compliance function, we regularly conduct compliance trainings so that stakeholders in connection with our suppy chain understand the signs of modern slavery and what to do if they suspect that it is taking place.

The board of directors of TIER recognizes the importance of the matters considered in this Statement, and will continue to take all measures necessary to ensure that slavery and human trafficking have no place in TIER’s business operations. This statement was approved by the Chief Executive Officer and Chief Financial Officer of TIER Mobility SE in June 2022.