SUSTAINABILITY POLICY

1. Self-image, business model and sustainability mission statement

1.1 Business model and structure

SCANDIC FINANCE GROUP LIMITED sees itself as a globally active finance, technology, data, media and service ecosystem that is particularly active in the following areas:

• Financial and payment services (SCANDIC FINANCE, SCANDIC PAY, SCANDIC COIN, SCANDIC CARDS, SCANDIC TRUST),
• premium transport and mobility (SCANDIC FLY, SCANDIC CARS, SCANDIC YACHTS),
• real estate and asset solutions (SCANDIC ESTATE),
• data, data centre and technology infrastructure (SCANDIC DATA),
• health and digital health services (SCANDIC HEALTH),
• company formation, structuring and trust solutions (SCANDIC SETUP, SCANDIC TRUST),
• media and investment activities in association with LEGIER Beteiligungs Gesellschaft mit beschränkter Haftung.

Value creation is based on a digital-first strategy, international locations and a networked brand ecosystem that requires uniform compliance, risk and sustainability standards.

1.2 Sustainability mission statement

SCANDIC FINANCE GROUP LIMITED and the SCANDIC brand ecosystem pursue a mission statement based on the following principles:

2. Sustainability goals and objectives

2.1 Climate and environmental goals

SCANDIC FINANCE GROUP LIMITED has defined the following long-term goals for its own locations (including data centres, offices and other infrastructure) and within the Group's sphere of influence:

2.2 Social and governance goals

3. Governance structure and responsibilities

3.1 Overall responsibility

Ultimate responsibility for this Sustainability Policy and its implementation lies with the Board of SCANDIC FINANCE GROUP LIMITED and senior management, in particular:

• the management or the Executive Board of SCANDIC FINANCE GROUP LIMITED,
• the respective management bodies of the brands in the SCANDIC brand ecosystem, insofar as they are operationally active.

3.2 Sustainability Committee (ESG Committee)

For effective management, a Sustainability Committee (Environmental, Social and Governance Committee) will be established, consisting of representatives from the following areas in particular:

• Climate and environment,
• human rights, labour, supply chain,
• Data, information security and artificial intelligence,
• Compliance, law, finance and risk,
• Human resources and culture,
• Media and communication (where relevant).

Tasks of the committee:

• Setting sustainability goals, priorities and measures,
• Monitoring implementation and measuring progress,
• Coordinating sustainability reporting,
• Advising the board,
• Escalating significant violations.

3.3 Policy library

The Sustainability Policy is part of a comprehensive policy library that includes, among other things:

• Code of Conduct,
• Supplier Code of Conduct,
• Environmental and climate policy,
• Human rights and labour rights policy,
• Modern Slavery and Forced Labour Statement,
• Information security policy,
• Data protection policy,
• Responsible Disclosure Policy,
• Guidelines for the ethically responsible use of artificial intelligence,
• Media and communication policy (where relevant).

4. Human rights, working conditions and social responsibility

4.1 Recognition of international standards

SCANDIC FINANCE GROUP LIMITED recognises in particular:

• The United Nations Universal Declaration of Human Rights,
• the International Labour Organisation's core labour standards,
• the United Nations Guiding Principles on Business and Human Rights,
• the Organisation for Economic Co-operation and Development Guidelines for Multinational Enterprises.

4.2 Principles for employees

The following applies in particular to all employees within the SCANDIC brand ecosystem:

• Prohibition of forced, child and debt bondage labour.
• Prohibition of discrimination and harassment.
• Safe and healthy working conditions.
• Right to freedom of association and collective bargaining.
• Fair remuneration and social benefits.

4.3 Complaint and whistleblower systems

SCANDIC FINANCE GROUP LIMITED establishes anonymous, confidential and multilingual complaint and whistleblower systems through which reports of violations of human rights, labour standards, environmental regulations, data protection, anti-corruption laws and other material legal violations can be made.

The procedures ensure:

• Careful, prompt and impartial investigation
• protection of whistleblowers from reprisals,
• comprehensible documentation,
• effective remedial measures,
• a target median processing time for complaints
• within a maximum period of fourteen days for standard cases.

5. Sustainable supply chain that complies with human rights

5.1 Supplier code of conduct and contract design

SCANDIC FINANCE GROUP LIMITED contractually obliges all suppliers and key service providers to comply with a supplier code of conduct, which contains rules on, in particular:

• human rights and working conditions,
• Health and safety,
• Environmental protection, resource consumption and emissions,
• diversity, equality and inclusion,
• Data protection and information security,
• Prohibition of corruption, fair competition and prevention of money laundering,
• Cooperation in audits, providing information and remedial measures.

5.2 Risk analysis and prioritisation

A systematic risk analysis of the supply chain is carried out, particularly in the following risk areas:

• Hardware and digital infrastructure,
• Data centre services and cloud infrastructure,
• Media, content and creative services,
• Logistics services,
• Other critical services.

5.3 Preventive and remedial measures

Preventive measures are developed on the basis of the risk analysis, such as:

• Specific clauses in contracts
• Training for purchasers,
• Information material and training for suppliers,
• consideration of sustainability performance in procurement.

If violations are detected, remedial measures must be taken, such as:

• written warnings and deadlines,
• jointly developed improvement plans,
• more intensive checks,
• restriction or termination of the business relationship if no improvement is made.

6. Environmental, climate and resource management

6.1 Principles

SCANDIC FINANCE GROUP LIMITED is committed to the following principles:

• Priority of avoidance and reduction over compensation,
• Holistic approach along the value chain,
• Transparent measurement and reporting of key environmental indicators.

6.2 Energy, data centres and digital infrastructure

The following applies in particular to data centres and digital infrastructure:

• Energy efficiency with target figures for energy efficiency,
• Gradual conversion to electricity from renewable energy sources,
• Optimisation of cooling concepts, enclosure of cold and hot aisles, virtualisation and utilisation optimisation.

6.3 Water, waste and circular economy

• Recording water consumption, introducing waste separation, reuse and recycling.
• Use of certified service providers for data deletion, recycling and proper disposal of hardware.

6.4 Mobility, travel and events

• Reduction of business air travel to the necessary minimum, promotion of video conferencing, use of efficient means of transport,
• Establishment of internal guidelines for "avoid, reduce, compensate" for business travel.

7. Data protection, information security and protection of civil liberties

7.1 Data protection principles

SCANDIC FINANCE GROUP LIMITED complies with the fundamental data protection principles of the applicable data protection laws, in particular lawfulness, purpose limitation, data minimisation, storage limitation, integrity and confidentiality, and accountability.

7.2 Information security

The Group establishes an information security management system in accordance with the international standard 27001 or an equivalent recognised standard with systematic risk analysis, defined security objectives, organisational and technical measures, and regular audits.

7.3 Fundamental digital rights and civil liberties

When designing products, in particular financial, media and data products, SCANDIC FINANCE GROUP LIMITED respects the fundamental rights and civil liberties of users and recognises the right to informational self-determination, freedom of expression and information, and protection from disproportionate surveillance.

8. Use of technology and artificial intelligence

8.1 Principles for artificial intelligence

The use of artificial intelligence follows these principles:

• Legality and compliance,
• Transparency and traceability,
• Human oversight,
• Protection against discrimination,
• Security.

8.2 Committees and processes

• Establishment of a committee for artificial intelligence governance,
• Conducting impact and risk analyses, documenting models, training data, intended use and control mechanisms.

9. Corporate governance, compliance and integrity

9.1 Code of Conduct

SCANDIC FINANCE GROUP LIMITED has a code of conduct that applies to all employees and board members and regulates lawful conduct, transparent and fair business relationships, dealing with conflicts of interest, prohibition of corruption and prevention of money laundering.

9.2 Corruption prevention

• Clear prohibitions on improper payments
• Training on corruption prevention,
• Anonymous reporting channels,
• Consistent investigation of suspected cases.

9.3 Risk management and internal control

Integrated risk and control system that also covers sustainability risks, with annual risk inventory, assessment, thresholds, controls and monitoring.

10. Employees, diversity and work culture

• Promotion of a diverse and inclusive work culture,
• Targets for representation and fair remuneration,
• Occupational health and safety,
• Training and development programmes.

11. Stakeholder dialogue and social contribution

• Identification of key stakeholders,
• Dialogue formats with customers, employees,
• Suppliers, regulators and civil society,
• Programmes for financial education, digital media literacy and support for educational, cultural and social projects.

12. Targets, key figures and reporting

• Setting targets for energy, emissions, supply chain,
• whistleblower system and artificial intelligence,
• Reporting in a regular sustainability report in accordance with international standards,
• Gradual external review of key performance indicators.

13. Implementation, review and sanctions

• Defining responsibilities,
• Creation of implementation plans,
• Training of employees,
• Integration into management systems,
• Annual review of the policy,
• Labour law measures in the event of violations,
• Restriction or termination of business relationships in the event of serious violations.

14. Final provisions

This Sustainability Policy shall enter into force upon formal adoption by the management of SCANDIC FINANCE GROUP LIMITED. It shall be interpreted in conjunction with the respective national legal systems. In the event of any conflict between this Policy and mandatory legal requirements, the legal requirements shall prevail.

SCANDIC FINANCE GROUP LIMITED regards this policy as a living management tool for responsible, forward-looking and value-based corporate governance and will continue to develop it further.