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Supplier Code of Conduct

Last updated: May 10, 2024

Contents

Preamble

The Stepstone Group1 is one of the world’s leading recruitment platforms, helping companies hire the right talent since 1996. We2 operate in more than 30 countries — including with Stepstone in Germany, Appcast in the US and with Totaljobs in the UK.

Our company headquarters are in Dusseldorf, and we have circa 4,000 employees around the world.

We bear a special responsibility with our actions and apply high standards to our own actions. Therefore, we also demand that the people we work with maintain high ethical standards.

We are committed to responsible corporate governance. This is fundamentally based on integrity and lawful conduct. For us, this also includes a commitment to protecting the environment for a better future for everyone.

At The Stepstone Group, we respect the values of the Universal Declaration of Human Rights and are committed to good corporate governance. We are committed to complying with internationally recognized social standards and, in particular, protecting the legal positions set out in Germany’s Act on Corporate Due Diligence Obligations in Supply Chains.

The UN Global Compact and the core labor standards of the International Labor Organization (ILO) serve as a basis for this Supplier Code of Conduct. We also support the UN Guiding Principles on Business and Human Rights and strive to incorporate them into our own policies and processes.

This Supplier Code of Conduct applies to all employees throughout our business and is an expression of this endeavor. We also expect our business partners to observe these principles.

To guarantee human and labor rights as well as environmental protection, our suppliers must commit to protect the legal positions set out in Germany’s Act on Corporate Due Diligence Obligations in Supply Chains and agree to our minimum requirements for our business partners set out in this Supplier Code of Conduct. The proper implementation of, and compliance with, our Supplier Code of Conduct is a prerequisite for successful collaboration with The Stepstone Group companies regardless of less restrictive locally applicable laws and regulations. If there are any contradictions between this Supplier Code of Conduct and local legal requirements, our business partners must inform us immediately.

For purposes of this Supplier Code of Conduct,business partners include all third parties that act for, on behalf of or together with The Stepstone Group, including but not limited to suppliers, sales partners, consultants, brokers, subcontractors, commercial agents and freelancers.

Social responsibility

Our business partners respect the dignity of each and every individual

Just as we do at The Stepstone Group, our business partners must respect and support compliance with internationally recognized human rights and emphasize that everyone, without exception, is entitled to the rights and freedoms proclaimed in the United Nations Universal Declaration of Human Rights. They ensure that high human rights standards apply within their company, but also with their direct suppliers.

Tolerance of different opinions and a commitment to democratic principles and the rule of law are the basis of our collaboration.

Our business partners create an inclusive working environment

Everyone has the same opportunity to develop and advance. In particular, national and ethnic origin, social origin, health status, disability, sexual orientation, age, gender, political opinion, religion or belief and marital status play no role in business or employment decision-making.

Our business partners do not tolerate discrimination of any kind.

Our business partners create a respectful working environment

Our business partners commit to ensuring a trusting and respectful work environment that does not tolerate sexual or other forms of harassment, discrimination, bullying or intimidation in the workplace.

Our business partners are committed to the effective abolition of child labor

Our business partners are prohibited from employing children or young people in violation of the law.

Where it is permitted to employ children and young people, our business partners must ensure it is not detrimental to their physical and mental development. Their safety and health must be protected by appropriate measures.

Our business partners ensure fair working conditions

We require our business partners to act in accordance with the law and observe appropriate social and legal standards.

Wages and salaries, as well as social benefits, must meet or exceed the respective national statutory minimum standards. Working hours must also comply with applicable laws, industry standards or the core labor standards of the International Labor Organization (ILO).

Our business partners shall ensure that there is no unequal treatment. For the purposes of this Supplier Code of Conduct, unequal treatment exists if unequal remuneration is paid for work of equal value.

Furthermore, our business partners must respect the right of employees to set up an association to represent their interests, and to join and be actively involved in it. The exercise of these rights must not lead to discrimination or retaliation against the employee.

Any form of forced labor, i.e. any work required of a person against their will and under threat of punishment, as well as forms of modern slavery and human trafficking, is strictly prohibited. All employees must have the freedom to terminate their employment relationship with reasonable notice.

Our business partners ensure health and safety in the workplace

The Stepstone Group requires its business partners to take the required measures at all places of work to prevent work-related accidents and illnesses, whether physical or mental in nature by implementing adequate safety standards in the provision and maintenance of the workplace and work equipment.

If private or public security forces are employed to protect a business project, our business partners must ensure that the fundamental rights of the workers are respected through instruction and monitoring. Specifically, business partners are required to commit to a ban on torture and cruel, inhuman or degrading treatment, as well as injury to life and limb. Furthermore, the freedom of association and the freedom to organize must not be impaired.

Data and technology

Our business partners protect data

Data protection laws protect personal data (for example, name, email address, account data, customer number, address, and date of birth) and therefore the personal rights of customers, users, business partners and employees. All parties involved must handle this data responsibly and observe the data protection requirements and the principles for processing personal data set out therein.

When collecting, storing, processing or transferring personal data from employees, customers or other third parties, our business partners shall exercise the utmost care and strict confidentiality and comply with applicable laws and regulations on data protection and data security. More detail on data protection requirements can also be found in the agreements with our suppliers.

Our business partners address cyber threats rigorously

Having reliable information security is crucial for the trust we place in our business partners.

The data processed by The Stepstone Group holds significant value, but it is also susceptible to unauthorized duplication and distribution. Each of our business partners is required to take appropriate security measures to ensure this data is adequately protected against cyber threats such as destruction, theft, unauthorized access, unlawful disclosure or other misuse.

In the event of a security incident, our business partners promptly inform the affected parties.

We contractually define further specific requirements directly with our suppliers.

Compliance with laws

Our business partners do not participate in corruption

Good business is important, but not at any price.

Our business partners are prohibited from engaging in bribery in their dealings with public officials and in business dealings. Business decisions must be made on transparent and objective grounds in the interests of the company and avoid even the mere appearance of undue influence, for example, by accepting perks or other benefits. Our business partners must be fair, correct and transparent toward partners and business contacts.

Our business partners must not accept gifts or other benefits (for example, invitations) that could influence their business decisions. Conversely, they are prohibited from offering benefits in order to influence their business partners or other contacts to their advantage.

Our business partners observe antitrust law

At The Stepstone Group, we believe fair competition and the free market are the cornerstones of our economy.

We promote effective competition as standard practice. Each business partner must therefore observe antitrust law and may not enter into agreements or other arrangements with competitors, suppliers or other companies that impede fair competition. Practices such as price agreements, market-sharing agreements (for example, division of sales territories, customer, or product) and agreements on other market practices and business strategies are strictly prohibited.

Our business partners must not unfairly call for a boycott and shall prohibit discrimination against competitors, either in the sale or purchase of goods and services.

Our business partners disclose conflicts of interest if and when they arise

Conflicts of interest can mean that business decisions are no longer made impartially. Therefore, our business partners are required to disclose potential or actual conflicts of interest in a timely manner and to resolve them promptly.

Our business partners observe foreign trade and anti-money laundering law

Our business partners must observe all relevant economic sanctions and comply with all restrictions imposed under foreign trade law.

Business with individuals, companies or organizations associated with terrorism or drug trafficking, or whose funds are derived from criminal activities, will not be tolerated.

Privacy and confidentiality

Our business partners protect business secrets

Our business partners are held to the highest level of confidentiality. All information and documents not suitable or intended for disclosure to third parties are treated as strictly confidential and are protected from unauthorized access and misuse.

Our business partners do not participate in insider trading

Important information for the capital market may result from a collaboration between The Stepstone Group and our business partners.

Business partners in possession of confidential information capable of significantly influencing the share price of listed companies in which The Stepstone Group maintains stake or is considering taking a stake or the price of financial instruments that are linked to the share price of such companies (insider information) if it were to become publicly known may not buy or sell such securities or disclose such information without express authorization.

Sustainability

Our business partners are committed to environmental sustainability

The Stepstone Group has set ambitious climate targets. Among other things, we intend to be climate-neutral and to reduce our carbon footprint in the long term.

Sustainability is one of our key corporate values. Our business partners should also set targets and take appropriate measures to avoid or mitigate environmental risks. At all stages of production, we expect our business partners to adopt eco-efficient technologies and materials that protect the environment, conserve natural resources and promote recyclability and sustainability. We expect that reasonable efforts will be made to avoid or minimize the consequences of accidents that may have a negative impact on the environment.

We use natural resources sparingly and promote the sustainable use of natural resources. Our goal is to minimize the impact of our activities on humans and the natural world. We also expect this attitude from our business partners. Land, forests, and waters that serve as a person’s livelihood may not be unlawfully cleared or taken away for the purpose of acquisition, construction, or other use.

Our business partners shall avoid harmful soil changes, water pollution, air pollution, harmful noise emissions, and excessive water consumption that significantly affect the natural basis for food preservation and production, deny or impede access to clean drinking water and sanitation, or destroy or harm health. We require our business partners to comply with the Minamata Convention on Mercury, the Stockholm Convention on Persistent Organic Pollutants, and the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal.

Implementation of our Supplier Code of Conduct

Responsibility of our business partners

We make this Supplier Code of Conduct part of the contractual agreements with our business partners.

Our business partners are required to ensure the implementation of and compliance with our Supplier Code of Conduct in the contractual relationship with The Stepstone Group.

In this context, our business partners shall pass on this Supplier Code of Conduct to all employees who work for us and work towards compliance. We require our business partners to pass on these requirements to their business partners that are associated with the goods or services provided to The Stepstone Group (for example, as subcontractors) and ensure the compliance thereof.

We reserve the right to audit compliance with this Supplier Code of Conduct. For this purpose, our business partners must provide information in response to inquiries and, if necessary or if risks are identified on the part of The Stepstone Group, actively cooperate in the development of remedial measures. If necessary, our business partners will provide insight into documentation and operating processes for the purpose of the respective audit.

In the event of non-compliance, our business partners are obligated to immediately and independently initiate necessary remedial measures.

Reporting and handling of compliance violations

Violations of laws, policies and other regulations must be recognized in a timely manner to prevent damage to The Stepstone Group and our business partners and to ensure a fair and trusting partnership.

If our business partners become aware of a violation of this Supplier Code of Conduct, they must report it to The Stepstone Group immediately. We require cooperation with any subsequent clarification measures.

The Stepstone Group expects its business partners to enable their employees to raise concerns without fear of disadvantage or retaliation.

At The Stepstone Group, employees and external parties have the opportunity to submit an anonymous report via our electronic whistleblowing system. The electronic whistleblowing system is managed by employees from The Stepstone Group Compliance Team. In the event of an allegation of a violation of this Supplier Code of Conduct and/or applicable laws by a business partner, such business partner must provide and cooperate with all requests for information. In the event of a confirmed violation, The Stepstone Group reserves the right to require all necessary remedial action including, but not limited to, termination of contract and the overall business relationship in compliance with the contractual or legal provisions.

Compliance team contacts

Chief Compliance Officer

Heiner Tent

Email: [email protected]

Head of Compliance

Verena Krüger

Email: [email protected]

Compliance team

Email: [email protected]

Downloadable version of this Supplier Code of Conduct

The-Stepstone-Group_Supplier-Code-of-Conduct_May-10-2024_EnglishDownload PDF

Footnotes

1. ‘The Stepstone Group’ always means ‘The Stepstone Group GmbH and all controlled companies of The Stepstone Group.’

2. ‘We’ always means ‘all employees, managers and members of executive bodies of The Stepstone Group.’