Cancom : Non-financial report 2020

2020

NON-FINANCIAL REPORT CANCOM SE

TABLE OF CONTENTS

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Table of contents

1	GENERAL INFORMATION	3
	1.1	Legal framework	3
	1.2	The ten principles of the UN Global Compact	3
2	THE CANCOM VALUE SYSTEM	4
	2.1	Sustainable corporate governance at CANCOM	4
	2.2	CANCOM Core Values	4
	2.3	CANCOM Code of Conduct - Fair, with respect, compliant	4
3	COMPLIANCE WITH THE VALUES	5
	3.1	Responsibility at CANCOM	5
	3.2	Compliance	5
	3.3	Whistleblowing	5
4	BUSINESS MODEL	6
5	RISKS IN CONNECTION WITH NON-FINANCIAL MATTERS	6
6	HUMAN RIGHTS	7
	6.1	Code of Conduct and Human Rights	7
	6.2	Diversity and gender equality	7
	6.3	Personal rights - data protection	8
	6.4	IT security / information security	9
7	LABOR STANDARDS	9
	7.1	Code of conduct	10
	7.2	ILO Core Labor Standards	10
	7.3	Employees of the CANCOM Group	10
	7.4	Further training	11

7.5 Internships, student traineeships, final theses,

		further training measures, school partnerships	11
	7.6	Training and dual studies	12
	7.7	Health and safety	12
	7.8	Work flexibility	14
	7.9	Supplier relationships	14
	7.10	Trustworthy business partner	15
8	ENVIRONMENTAL PROTECTION	15
	8.1	Energy policy and emissions	15
	8.2	Energy and environmental management	17
	8.3	Green IT	17
	8.4	Travel and vehicle use	18
	8.5	Facilities	18
	8.6	Disposal	18
9	FIGHT AGAINST CORRUPTION	19
10	SOCIAL CONCERNS	19
	10.1	Donations and charitable projects	19
	10.2	Memberships	20
	10.3	Party donations	20

NON-FINANCIAL REPORT

1 GENERAL INFORMATION 1.1 Legal framework

In this non-financial Group statement, CANCOM provides information on the corporate social responsibility topics required by section 289c and 315c of the German Commercial Code (HGB). CANCOM has supported the UN Global Compact since 2015. This initiative, which was launched by the United Nations with the aim of promoting sustainable and responsible corporate governance, is based on ten universal principles. Through its membership, CANCOM undertakes to actively support these ten principles

in the areas of human rights, labor standards, environmental protection and anti-corruption, and to promote them within its sphere of influence. This also includes that CANCOM consistently pursues the anchoring of these principles in its corporate strategy, its corporate culture and in its day-to-day business and reports annually on the progress made.

The ten principles of the UN Global Compact, including human rights, labor standards, environmental protection and anti-cor- ruption, comprise significant parts of the reporting topics required in the non-financial Group declaration in accordance with HGB 298c (2) and (3). CANCOM has therefore based this declaration

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You can find this and all previous years' sustainability reports in German and English on the Company's website www.cancom.de in the "Investors" section. For reasons of sustainability, CANCOM does not print this report.

The Supervisory Board of CANCOM SE has reviewed this non- financial Group report and approved it on 27 April 2021.

1.2 The ten principles of the UN Global Compact

HUMAN RIGHTS

Principle 1	Businesses should support and respect the protection
of international human rights; and
Principle 2	ensure that they are not complicit in human rights
abuses.
WORKING STANDARDS

on the structure of the format proposed by the United Nations for annual reporting in accordance with the UN Global Compact framework. The declaration and its contents have been supplemented with additional disclosures where this appeared necessary from CANCOM's point of view in order to fully comply with the requirements of the German Commercial Code.

Principle 3

Principle 4

Principle 5

Principle 6

Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining, and should also provide for

the elimination of all forms of forced labor;

the abolition of child labor; and

advocate the elimination of discrimination in respect of employment and occupation.

This report covers the period from 1 January 2020 to 31 December 2020. The key figures were recorded by the respective departments and divisions and apply to the entire CANCOM Group unless otherwise stated. Key figures and statements that relate only to parts or specific markets of the CANCOM Group are also marked.

ENVIRONMENTAL PROTECTION

Principle 7	Businesses should support a precautionary approach
to environmental problems,
Principle 8	take initiatives to create a greater sense of
responsibility for the environment; and
Principle 9	promote the development and diffusion of
environmentally friendly technologies.

ANTI-CORRUPTION

Principle 10	Businesses should work against corruption in all its
forms, including extortion and bribery.

NON-FINANCIAL REPORT

2 THE CANCOM VALUE SYSTEM

CANCOM's value system is based on the conviction that contemporary entrepreneurial action must be sustainable. Our understanding of corporate governance and our corporate values are based on this assumption.

2.1 Sustainable corporate governance at CANCOM

CANCOM believes that corporate responsibility for the environment and society and corporate growth are not mutually exclusive. On the contrary, CANCOM believes that social responsibility is indispensable for adequate sustainable growth. This is another reason why sustainability is one of CANCOM's three core values, along with agility and innovation. It is part of CANCOM's vision to grow while always assuming responsibility in society. All members of the Executive Board are committed to acting sustainably.

For CANCOM, an effective sustainability policy to protect the environment is an essential building block in the pursuit of long-term corporate goals. For this reason, the CANCOM Group implements measures at all levels and in all locations to operate in the spirit of sustainable development. IT as a means and a product makes a decisive contribution to greater sustainability - for customers and for CANCOM.

The Executive Board of CANCOM SE manages the Company and the CANCOM Group with the aim of creating sustainable value. In doing so, the members bear joint responsibility for the entire management of the Company. The members of the Executive Board work together as colleagues, exchange information and keep each other constantly informed about important measures and processes in their business units. This includes topics from the areas of corporate social responsibility and corporate governance or compliance. In addition, one member of the Executive Board

is responsible for ESG (Environment Social Governance). The Management Board is publicly committed to the values of sustainable corporate governance; the Management Board's statement on corporate governance and sustainable corporate governance is published on the company website in the section Company > Corporate Governance.

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The Executive Board and Supervisory Board work closely together in the interests of the Company. The intensive and continuous dialogue between the two bodies forms the basis for efficient corporate management at CANCOM. The Executive Board informs the Supervisory Board regularly, promptly and comprehensively about all material aspects of the CANCOM Group's business development, significant business transactions, planning, risk situation, risk management and compliance. The Executive Board and the Supervisory Board discuss the strategic direction of the Company and the status of strategy implementation at regular intervals. The Supervisory Board advises the Management Board on the management of the company and monitors its activities. The Supervisory Board appoints a member from among its members who, as an ESG expert, contributes expertise in the areas of environment, social affairs and governance to the Supervisory Board.

As a listed company, CANCOM already regularly publishes various information on the subject of responsible corporate governance. CANCOM sees this non-financial Group report as a supplement to the reporting obligations already fulfilled elsewhere. We therefore refer in particular to the declaration on corporate governance

in accordance with sections 289f and 315d of the German Commercial Code (HGB), which is published on our website at www.cancom.de in the section Company > Corporate Governance.

2.2 CANCOM Core Values

CANCOM's corporate culture is based on three Core Values: Innovation, Agility and Sustainability. These values determine our entrepreneurial actions, the way we work, and our collaboration with our customers and business partners. The values and guidelines of the CANCOM Group can be found online at www.cancom.com/our-values.

2.3 CANCOM Code of Conduct - Fair, with respect, compliant

CANCOM is aware of its role in society and its responsibility towards customers, business partners, shareholders and employees. The CANCOM Code of Conduct is an important instrument that is binding for all employees. It creates an awareness of everyone's responsibility for sustainable and responsible business practices and anchors the ten principles of the UN Global Compact in the CANCOM Group.

NON-FINANCIAL REPORT

With its principles, the Code of Conduct forms the basis for responsible, value-driven and compliant action. Under the motto "Fair, with respect, compliant", the Code of Conduct reflects the Executive Board's goal of strengthening ethical standards throughout the company and creating a working environment based on integrity, respect and fair conduct. The Code of Conduct thus forms the basis for CANCOM's business activities and applies throughout the CANCOM Group. It thus also directly covers the subject areas of this non-financial Group report discussed below: human rights, labor standards, environmental protection and anti-corruption. All employees sign the Code of Conduct when they are hired as part of their employment contract and are regularly informed of any new developments and changes. Annual training is provided for all employees on the contents

of the Code of Conduct.

3 COMPLIANCE WITH THE VALUES

Sustainability in the CANCOM Group is supported by all our colleagues. The core values of agility, innovation and sustainability form the basis for a corporate culture in which all employees bring these values to life every day. The CANCOM Group's Code of Conduct, which is binding for all employees, provides guidance for this.

3.1 Responsibility at CANCOM

As a matter of principle, CANCOM conducts its business in compliance with applicable national and international laws. CANCOM's compliance management ensures that the requirements are adhered to. CANCOM has established an anonymous whistleblower system to give all employees and external stakeholders the opportunity to report violations.

3.2 Compliance

Compliance management is an important component of corporate governance. Its purpose is to ensure that the Company's activities comply with statutory and voluntary regulations. In CANCOM's view, the most important instrument of compliance management is an effective compliance management system (CMS). This system comprises all measures and processes that serve to pursue the objectives of compliance management.

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At CANCOM, a Compliance Officer, who reports directly to the Executive Board, ensures compliance and is responsible for the organization of compliance management and the functionality of the instruments used. This essentially includes the general process organization of compliance management, the whistleblower system, which can be accessed both internally and externally and is also anonymous, compliance directives within the framework of guidelines and the Code of Conduct, regular information for all employees via update e-mails, annual e-learning training for all employees and additional dedicated training for specific employee groups, investigation of (potential) compliance incidents, reporting and documentation as part of the annual compliance reports, and immediate reports to the CEO in the event of compliance incidents. The Compliance Officer also informs the Chairman of the Supervisory Board on a regular basis and as required.

The employees of the CANCOM Group are made aware of the requirements and innovations in the area of compliance through their participation in an annual one-houre-learning training course. The course sensitizes employees to the contents and requirements of the Code of Conduct.

3.3 Whistleblowing

CANCOM expects all of its employees to comply with existing laws, policies and processes. All CANCOM employees are encouraged to report any violations of legal or internal requirements that they discover or even suspect in good faith. Reporting channels are available for this purpose, either by stating one's own name or by using an anonymous whistleblower mailbox.

The receipt of reports received by e-mail, by post or via the reporting mailbox will be acknowledged within five working days. The whistleblower will be informed about follow-up measures within three months at the latest.

Incoming reports as well as internal investigations derived from them, the involvement of authorities if necessary and derived measures are documented comprehensively but confidentially by the Compliance Officer. Authorities such as the police, public prosecutor's office and/or supervisory authorities are called in after determining the facts and if necessary.