CAREER POLICY

1. Purpose, scope and principles

1.1 Purpose of the Career Policy

This Career Policy defines the fundamental principles, processes and quality standards for:

• the recruitment, selection and hiring of employees,
• professional development, promotion and career planning,
• the design of working conditions, remuneration and benefits,
• the fair, non-discriminatory and transparent treatment of applicants and employees within SCANDIC FINANCE GROUP LIMITED and the SCANDIC brand ecosystem, including the cooperating structures of LEGIER MEDIENGRUPPE.

1.2 Scope

This policy applies – to the extent possible under labour law – to:

• all applicants,
• all employees (full-time, part-time, fixed-term, permanent),
• interns, trainees, freelancers and comparable groups of people,
• executives and management at all levels within the SCANDIC brand ecosystem.

For locations outside the European Union, local labour law provisions apply, but the EU standards defined here are understood as minimum standards, provided they are compatible with local law.

1.3 Legal and regulatory basis

The career policy is based in particular on:

• the relevant EU directives on equal treatment and non-discrimination in working life,
• the principles of the EU Charter of Fundamental Rights,
• the provisions of the Supply Chain Due Diligence Act (LkSG) and corresponding EU initiatives,
• the EU Whistleblower Directive,
• working time, occupational health and safety and data protection regulations (including the GDPR),
• international standards such as the ILO core labour standards, the UN Guiding Principles on Business and Human Rights and relevant anti-discrimination standards.

2. Mission statement and understanding of careers

2.1 Mission statement

SCANDIC and LEGIER understand career as:

• the long-term development of skills, responsibility and prospects
• in an international, value-oriented and innovation-driven environment,
• with clear, transparent and fair framework conditions.

The values of integrity, innovation and inclusion form the basis of every personnel decision.

2.2 Connection to the LEGIER MEDIA GROUP

The LEGIER MEDIA GROUP (LEGIER Beteiligungs mbH, Berlin) is an affiliated media company with a global newspaper portfolio. Career paths can be designed across the board – within the scope of legal and organisational possibilities – for example through:

• international projects,
• editorial, technical or commercial assignments within the media group,
• cross-functional roles between media, finance, IT/data and trust services.

3. Equal treatment, diversity and non-discrimination

3.1 Principle of equal treatment

SCANDIC is committed to strict equal treatment of all applicants and employees, regardless of:

• gender, sexual orientation, gender identity,
• ethnic origin, nationality, skin colour,
• religion or belief,
• age, disability or health impairment,
• family situation or other characteristics protected by law.

3.2 Diversity and inclusion

• Diversity in teams and management levels is a strategic goal.
• Discriminatory behaviour, harassment or bullying will not be tolerated.
• Managers have a particular responsibility to create an inclusive culture in which all employees can develop their potential.

3.3 Accessibility and special protection needs

• Application processes and workplaces should be designed to be as accessible as possible.
• Special protection needs (e.g. pregnancy, severe disability, caring for relatives) are respected and appropriate arrangements are made.

4. Recruitment and selection processes

4.1 Transparent job advertisements

• Open positions are published as transparently as possible (career pages, internal platforms, selective external portals).
• Job advertisements are formulated in a neutral and inclusive manner and contain clear information on tasks, requirements, location, working time model and application procedure.

4.2 Fair application process

• The application process is standardised, transparent and documented.
• Selection decisions are based solely on qualifications, suitability and potential.
• Discriminatory criteria are not permitted.
• Where suitability is comparable, diversity targets may be taken into account, provided this is legally permissible.

4.3 Selection methods

• Interviews, tests, work samples or assessment elements are used for professional reasons.
• Care is taken to ensure that selection procedures are proportionate, objective and culturally sensitive.
• Candidates receive appreciative feedback wherever possible.

4.4 External service providers & headhunters

• External recruiters or agencies are obliged to comply with the principles of this career policy.
• Agreements with service providers must ensure data protection, non-discrimination and transparency.

5. Onboarding, induction and probationary period

5.1 Structured onboarding process

New employees receive structured onboarding, including:

• Introduction to the company structure and the SCANDIC brand ecosystem
• Presentation of guidelines on compliance, LkSG, data protection, information security,
• Induction plan with clear learning objectives and contact persons.

5.2 Probationary period

• The probationary period serves as a mutual assessment of suitability.
• Performance and integration are discussed regularly; early feedback is used for improvement, not as a sanction.
• Decisions on the continuation of the employment relationship are justified transparently.

6. Working conditions, working hours and flexibility

6.1 Working hours and compatibility

• Working hours are based on the applicable legal provisions (such as the EU Working Time Directive and national labour laws).
• Flexible working models (flexitime, part-time, remote work/home office) are encouraged – as far as operationally possible – in order to facilitate the compatibility of work and private life.

6.2 Remote work and international cooperation

• Clear rules apply to remote work with regard to availability, data protection, IT security and the provision of work equipment.
• In the case of cross-border work (residence in a country other than the employer's location), special social security, tax and labour law issues are examined.

6.3 Occupational health and safety

• SCANDIC is committed to high standards of occupational health and safety in line with EU requirements and local standards.
• Risk assessments, ergonomic equipment and health services (such as mental health programmes) are part of our human resources policy.

7. Performance appraisal, feedback and career development

7.1 Performance appraisal

• Performance reviews are conducted regularly and according to clearly defined criteria (goal achievement, quality, team behaviour, compliance, contribution to innovation, etc.).
• Assessments must be documented in a comprehensible manner and be free of discrimination.

7.2 Feedback culture

• Managers are obliged to provide continuous, constructive feedback.
• Employees have the right to request feedback on their own development and to express criticism of processes or leadership in an appropriate manner.

7.3 Career paths and internal mobility

• SCANDIC develops transparent career paths (specialist career, management career, project career).
• Internal applications for advertised positions are expressly encouraged.
• The possibility of changing positions within the SCANDIC FINANCE GROUP LIMITED is actively explored, provided this is legally and organisationally possible.

8. Further training, talent development and international prospects

8.1 Further training and lifelong learning

Employees are entitled to targeted further training that meets the requirements of their position and their development goals.

In addition to specialist topics, training courses also cover:

• Compliance & ethics,
• LkSG / human rights / sustainability,
• Data protection & IT security,
• Leadership, communication and intercultural skills.

8.2 Talent programmes

• High-potential employees (talents) are identified and promoted through structured talent programmes (mentoring, coaching, project responsibility, international assignments).

8.3 International assignments

• International exchange (at the locations of the SCANDIC FINANCE GROUP Group is a central element of our understanding of careers.
• Residence, tax and labour law requirements are strictly observed for international assignments.

9. Remuneration, benefits and transparency

9.1 Appropriateness and market conformity

• Remuneration systems are appropriate, transparent and in line with market conditions.
• The principles of performance orientation and equal treatment apply (equal pay for equal or equivalent work, insofar as this is legally required and operationally feasible).

9.2 Variable remuneration

• Variable remuneration (bonuses, premiums, incentives) must not create incentives for legal violations, excessive risk-taking or breaches of compliance and LkSG obligations.
• Sustainability targets, compliance behaviour and team performance may be included in variable remuneration.

9.3 Benefits

Possible benefits include, among others:

• Health and pension benefits,
• company pension schemes,
• flexible working time models,
• access to the association's media products,
• participation in conferences, specialist events and internal events.

10. Human rights, LkSG and work-related due diligence obligations

10.1 Prohibition of forced and child labour

• SCANDIC FINANCE GROUP LIMITED strictly rejects any form of forced labour, child labour and exploitative working conditions.
• This applies internally as well as to suppliers, service providers and partners; corresponding clauses are enshrined in contracts.

10.2 LkSG-related obligations

• As part of human rights due diligence (LkSG), work-related risks (working hours, wages, occupational safety, freedom of association and others) in supply chains and project structures are identified, assessed and minimised.
• Reports from employees regarding human rights violations are taken seriously and handled according to a defined process.

11. Complaints, conflicts and whistleblowing

11.1 Internal complaint channels

Employees can address professional concerns, conflicts or experiences of discrimination to:

• their direct supervisor,
• HR/People & Culture,
• an ombudsperson appointed by SCANDIC FINANCE GROUP LIMITED
• Compliance functions.

11.2 Whistleblowing system

There is a confidential whistleblowing system through which employees (and external third parties) can report suspected violations of:

• laws,
• compliance rules,
• human rights and environmental standards,
• internal guidelines.
• Whistleblowers are protected from reprisals in accordance with applicable legal norms.

11.3 Conflict resolution

• Where possible, conflicts are initially resolved in a cooperative and constructive manner.
• In the event of serious incidents (such as discrimination or harassment), formal investigations are conducted; if violations are confirmed, appropriate measures under labour law are taken.

12. Data protection and handling of applicant and employee data

12.1 Applicant data

• Applicant data is used exclusively for the purposes of the application process,
• on the basis of a clear legal basis (such as Articles 6 and 88 of the GDPR (General Data Protection Regulation) in conjunction with national or international law),
• and deleted or anonymised after the expiry of statutory or agreed periods, unless there are legitimate interests in retaining the data.

12.2 Employee data

• Employee data is only processed within the framework of the employment contract and for the fulfilment of legal obligations.
• Transparency (data protection information), purpose limitation, data minimisation and technical and organisational protective measures are guaranteed.
• Employees' rights to inspect their personnel files are respected.

13. Roles, responsibilities and implementation

13.1 Responsibility of management

• The management of SCANDIC FINANCE GROUP LIMITED bears overall responsibility for the implementation of this career policy.
• It ensures that sufficient human, financial and organisational resources are available to implement the defined measures.

13.2 Responsibility of HR / People & Culture

• HR/People & Culture is responsible for:
• o Designing and continuously developing HR processes
• o Training on career, diversity and compliance topics,
• o Monitoring and reporting on relevant key figures (e.g. staff turnover, internal recruitment rates, diversity data, to the extent permitted by law).

13.3 Cooperation with partner companies

• SCANDIC ASSETS FZCO, LEGIER Beteiligungs GmbH and SCANDIC TRUST GROUP LLC provide support as service units in recruitment, administration and international career planning, or the legal responsibility of SCANDIC FINANCE GROUP LIMITED is assumed or affected by the cooperation partners in any way whatsoever.
• You undertake to observe the principles of this policy in all activities relating to human resources and careers.

14. Monitoring, audit and continuous improvement

• Compliance with this career policy is regularly reviewed through internal audits, HR reports and compliance reviews.
• Findings are incorporated into a system of continuous improvement.
• Changes in legislation, new EU requirements or significant changes in the corporate structure are taken as an opportunity to update the guideline in a timely manner.

15. Entry into force and final provisions

This career policy shall enter into force upon resolution by the management and, where applicable, the shareholders of SCANDIC FINANCE GROUP LIMITED.

It forms the binding basis for all career and personnel decisions within the SCANDIC brand ecosystem and also serves as a framework for career paths associated with the cooperative companies.