Code of conduct

1. Our ambition

1.1 Living our core values

Our values and principles of conducting business are described in this Code of Conduct. It provides a framework for our everyday business decisions. This includes dealing with other employees, customers, suppliers, society at large, government authorities, regulators, investors and other business partners.

This Code of Conduct acts as a reminder for us of the requirement to act honestly, fairly and with integrity in our day-to-day work. It is by no means an exhaustive list of acceptable and unacceptable behaviour. We also have various specific policies that govern some aspects of situations that we may encounter around the world. When conducting business for CarNext, our suppliers, consultants, contractors, agents and joint venture partners are expected to observe similar principles of conducting business as CarNext employees. For this specific purpose, reference is made to the CarNext Supplier Code of Conduct as well.

Living up to our values and principles of conducting business helps us to be a socially responsible company and continue to build a business of which we are, and can remain, proud.

Keep in mind - it is all about our values:

  • We are customer focused
  • We go the extra mile
  • We are an open community
  • We are challengers

and the general principles of conducting business:

  • Honesty and trust
  • Respect for the law
  • Human rights
  • Sustainability

CarNext employees can visit the CarNext Service Portal to read through all CarNext Global and Local Policies.

1.2 Our mission and vision

CarNext is a European digital marketplace for high-quality used cars. CarNext is a two-sided marketplace operating a B2C platform where consumers can buy a wide range of high-quality used cars. CarNext also operates a B2B online auction platform for professional buyers operating in 30 countries, supported by a trader app. In addition, it offers extensive ancillary services, available online and through a network of delivery stores in 7 European countries.

Traditionally, the used car market has been fragmented, localized and inefficient. To address these limitations and transform the experience for everyone involved in the used car market - whether that’s customers, traders or suppliers - CarNext was built.

Our vision is to become the marketplace of choice for customers looking for their next used car.
CarNext is on a mission to change the way people buy a used car. Offering the right cars, experience, products and services. Seamlessly matching each customer with their perfect used car.

1.3 Our values

At CarNext we share a set of core values:

We are customer focused

  • Customers are at the heart of CarNext
  • Our customers come in all shapes and forms. From a retail customer buying their next used car to internal customers who we work with collectively
  • We are passionate about helping our customers every step of the way and having a customer mindset embedded throughout our organization
  • Our internal discussions, priority setting and our projects are centered around making all our customers happier
  • We feel truly responsible for helping all our customers, we handle each interaction with care, respect and transparency
  • At CarNext, customers can expect more focused employees, providing them the best customer experience possible

We go the extra mile

  • We are ambitious and overdeliver
  • At CarNext we set the bar high, we believe in what we are doing and are here to be bold
  • We do not settle for ok, we go the extra mile and make every action, connection and moment count
  • We like a challenge and we like to change the status quo; we do not settle and we are always pushing boundaries for our customers and our people
  • We continuously expect more from ourselves

We are an open community

  • At CarNext we embrace diversity. The workplace is a place to be truly yourself and we work as one team
  • We trust in each other, create a safe work environment and transparency in all dialogues, interactions and connections
  • We are one team and proud to thrive together; we collaborate across functions and countries
  • We celebrate our successes. We embrace the opportunity to improve and understand that success starts with accountability and ownership
  • We are in this together, look out for each other and support one and other – we are a family and we have fun

We are challengers

  • We are distributing and challenging an industry
  • We are proud to be at the center of our own innovation and at the forefront in our industry
  • CarNext is created to change an industry and this mentality is what we apply to our day-to-day business – how can we continue to stretch ourselves and improve for the customer
  • We are leading in technology capabilities, finding, building and working with the right technology that fit our business smartly
  • We make smart and bold decisions powered by data, we are agile and continually improving our insights
  • Our mindset is that of a challenger, we expect more of what we create

1.4 General principles of conducting business

We firmly believe that honesty and trust, respect for the law, human rights and sustainability form key foundations for our performance. Operating according to our values in the context of these general principles of conducting business is critical to our success.

Honesty and trust

We act with integrity, honesty, openness and fairness in our business dealings. We avoid any conduct that might harm or contribute to harming our integrity and we do not promote personal incentives that might lead to a conflict with our integrity. Our internal reward structure is aligned with this rule.

Respect for the law

We respect and adhere to all applicable laws and regulations as well as our own policies and standards. This includes local and international legislation, industry standards and policies and standards at both global and local level.

Human rights

We recognise that human rights should be considered fundamental and universal; which is why we respect the human rights as stated in the United Nations’ Universal Declaration of Human Rights and the principles of the International Labour Organisation. We avoid being complicit in human rights abuses of any kind. We do not use forced or compulsory labour and nor do we employ child labour.

Sustainability

As a responsible company, we will be part of a sustainable solution by working towards environmental, social and corporate governance policies for all our employees.

Challenge yourself

Acting in line with our core values and principles of conducting business is often common sense. Asking yourself a few questions can help you when in doubt:

  • Is this in line with the Code of Conduct?
  • How would I feel if this made the headlines?
  • Do I support this decision or behaviour?
  • How would I feel if others were to act like this?

2. Our stakeholders

2.1 Our employees worldwide

We believe that a truly inclusive organisation delivers many benefits: helping us attract and retain talented people, allowing us to better understand our stakeholders’ needs, and helping us develop an international mindset, thus contributing to a high-performing organisation.

To facilitate the execution of our strategy, we are therefore making significant investments in our people, including the development of a comprehensive training program to help our people grow the skills and competencies required to succeed in a changing and increasingly digitised landscape. Our commitments to employees are as follows:

  • we maintain a safe, healthy and non-discriminatory work environment;
  • we provide equal employment opportunities based on an individual’s capabilities and experience and without regard to race, colour, gender, age, religion, national origin, disability or sexual preference;
  • through the value and power of diversity, we actively strive for the inclusive environment that is needed to attract, develop, deploy and retain the best people to drive current and future needs;
  • we offer the opportunity for self-development to enable employees to reach their full potential;
  • we provide fair and just remuneration to our employees in the context of the labour markets where we operate and ensure that working hours are not excessive and, as a minimum, comply with applicable global and local laws.

2.2 Our ccustomers 

At CarNext we strive to create and maintain mutually beneficial long-standing relationships with our customers that meet their needs and exceed their expectations. We assist our customers in achieving their goals by giving them the right level of advice and support at the right time. We are dedicated to providing our customers with the best-quality products and services and ensuring that they receive correct and accurate information in this respect.

We handle comments and complaints on our service diligently, fairly and quickly and we learn from our mistakes. We measure client satisfaction and take action where needed.

2.3 Our suppliers 

CarNext has created a separate Supplier Code of Conduct that establishes minimum ethical business standards around 10 key principles, which are listed below, that we expect our suppliers and their supply chain to uphold. While the Supplier Code of Conduct does not address every situation our suppliers may face, it does illustrate the important principles of ethical business conduct that we expect our suppliers to keep in mind when working with, for, or on behalf of CarNext. A full copy of the CarNext Supplier Code of Conduct can be downloaded from our Service Portal (ServiceNow).

  • Honesty and trust
  • Respect for the law
  • Human rights
  • Responsibilities to employees
  • Sustainability
  • Confidentiality and intellectual property
  • Privacy of individuals and data protection
  • Fair competition
  • Conflicts of interest
  • Bribery prevention

2.4 Wider society and the environment

We recognise our responsibilities to wider society and the environment by adhering to the following:

  • We act in accordance with relevant local and internationally recognised environmental standards;
  • We develop sustainable business models and products;
  • We seek ways to improve our own eco-footprint as a business;
  • We contribute positively to the development of our industry;
  • We support good causes and our employees participate in community projects and volunteer activities worldwide.

3. Our business

3.1 Our products

We have a separate Product Approval Process Policy which ensures that, prior to market introduction, the products and services under development and changes to existing products and services will continue to:

  • meet market demand and ensure duty of care towards customers;
  • meet requirements with respect to risk management;
  • be compliant with internal policies and external laws and regulations;
  • be communicated properly within CarNext, allowing for sharing of good practices and leveraging economies of scale in their development.

We are transparent about our products and services and their costs and risks. Our product documentation contains clear terms and conditions.

We contribute to reducing health and safety risks related to our services and products.

3.2 Our brand 

Our positioning is supported by our brand and bold tagline: “Great cars. Hassle free”. We believe this brand helps us to promote the value propositions we are developing and to forge a strong emotional connection with our customers.

3.3 Our intellectual property 

CarNext’s intellectual property, including but not limited to trademarks, databases, domain names, copyrights and trade secrets, are valuable assets which have to be carefully protected.

We take the protection of CarNext’s intellectual property seriously, both by complying with CarNext’s policies and procedures and by keeping confidential information that belongs to CarNext secret. Just as we expect third parties to respect our intellectual property, so too are we committed to respecting the intellectual property rights of others. We will take appropriate action against third parties that infringe our intellectual property rights.

4. Our business conduct

4.1 Information security and privacy

We are committed to protecting customer, business partner and employee data, together with any CarNext business data with the highest standards of security. We do this in compliance with our security and privacy standards and with applicable security and privacy laws and regulations. As technology develops and our use of data changes, CarNext is working continuously to improve policies, processes and systems.

CarNext’s Group Privacy Office and CarNext’s Group Information Security Office are promoting compliance with applicable data protection and privacy rules and regulations. You can contact them at privacy@CarNext and security@CarNext.

Keep in mind - You are expected to:

  • be aware of the information security requirements as defined in the CarNext Information Security policies and standards and the CarNext Privacy Policies and to apply them in all situations when dealing with information and when processing information. Our Privacy Policies include the overall Privacy Policy, Data Retention & Deletion Policy, and the Employee Privacy Policy, explaining how CarNext treats personal data;
  • act in accordance with the CarNext standards, procedures and policies applicable when using CarNext technology or devices. This includes any Acceptable Use Policies;
  • familiarise yourself with the applicable data breach and security incident rules and to act accordingly in case you believe you have discovered a data breach or security incident.

Data protection laws safeguard information about individuals including, but not limited to, name and contact details, date of birth and license plate number. CarNext respects the right of individuals, including employees, customers, drivers, suppliers and other business partners, to privacy. When processing, gathering or using personal data, we respect a person’s right to privacy and follow CarNext’s Privacy Policies, statements and the applicable laws.

Challenge yourself - Data is valuable for our business, but yet, processing personal data should be limited and we need to ask ourselves:

  • Am I processing personal data and, if yes, what kind of data and on what ground?
  • Do I really need the data to provide the services for the client, drivers or employees?
  • Could I also perform my tasks with less data or with anonymous data?
  • How would I feel if I knew that others could read the data I keep about individuals?
  • How do I protect the data from unauthorized disclosure, access, loss or damage?
  • Do I still need the data or can it be deleted or anonymized?

4.2 Competing fairly 

At CarNext, we believe in a strong, competitive and fair marketplace and we recognise that our competitive advantage must be achieved through excellent, customer-oriented and innovative products and services. The competitive marketplace in which CarNext operates around the world is promoted and protected by, among other things, competition law. Our Competition Compliance Policy defines our key risks and provides an overview of actions required by CarNext to prevent and reduce the risk of competition law violations. The Competition Compliance Policy builds on our Code of Conduct and the values we stand for.

Keep in mind - You should be aware of the risks presented by trade and professional associations. You are required to abide by the following rules:

  • obtain prior approval from the group legal department when you envisage a visit to a trade or professional association;
  • only attend meetings if an agenda has been circulated and ensure that minutes of such meetings are drafted and circulated;
  • do not discuss commercially sensitive information. Leave immediately if commercially sensitive information is being discussed and contact the group legal department for guidance.

4.3 Conflicts of interest 

We avoid contact or conduct that may lead to or could be perceived as creating a conflict between business and private interests or could otherwise damage CarNext’s reputation. A conflict of interest is when one’s personal interests, personal relationships or activities outside work influence or could be perceived to influence any business-related activities and actions. The conflict of interest requirements in our Employee Behaviour Policy address those situations.

We recognise that it can be important to contribute to society through a position within an external organisation, either on behalf of CarNext or in a personal capacity. We would, however, discourage this if the position could potentially lead to or present a conflict of interest which may negatively impact the reputation of CarNext or the individual involved. The outside positions requirements in our Employee Behaviour Policy explain what to do and what to avoid when accepting a position outside CarNext.

Keep in mind

  • If the outside position is in a personal capacity, you should ensure that you never act or appear to act on behalf of CarNext in that capacity.
  • If you are ever in doubt as to whether you have a conflict of interest while performing your business responsibilities, discuss this with your manager to put your interests in perspective and determine whether a conflict exists.

4.4 Business and corporate communications

We recognise the importance of CarNext’s reputation and that all our communications reflect on CarNext and our stakeholders. This concerns both regular business communications (on the part of each employee) as well as corporate communications (official statements). In our communications we ensure that:

  • We act in line with our core values and principles of business conduct and other elements of this Code of Conduct, CarNext’s mission, vision and strategy;
  • We take the interests of employees, customers, media and other relevant stakeholders into consideration;
  • Our message is consistent, true, accurate, open, responsive, not misleading and looks to prevent the dissemination of information which is incorrect or unconfirmed;
  • We express ourselves in a professional and responsible manner and do not use wording that could be perceived as discriminatory, insulting or obscene or that would otherwise not be appropriate or acceptable within CarNext’s working environment.

Challenge yourself

  • Should I answer this question or should I refer it to an authorised spokesperson?
  • Are the contents and tone of my communication appropriate and acceptable within CarNext's working environment?

Keep in mind

  • Whatever you tweet, post or like will be published on the internet for everyone to see.
  • You are personally responsible for the information you publish.

5. In conclusion

5.1 Living up to our Code of Conduct 

We have the necessary policies in place and provide training to assist our employees in abiding by this Code of Conduct. We expect our managers to lead by example and create a culture which facilitates adherence to the Code of Conduct. They are the first point of contact for questions about the rules and are expected to take responsibility for ensuring that their employees are aware of, understand and abide by the spirit and letter of this Code of Conduct. This includes adhering to our values, principles of business conduct and other elements of this Code of Conduct and putting them into action.

Challenge yourself

Each of us has the responsibility to abide by this Code of Conduct, and to use common sense in circumstances for which it does not provide explicit guidance.

  • What would others think of my actions?
  • Would I want to be held accountable for this?

5.2 Preventing bribery

At CarNext, we do not tolerate any form of bribery and corruption. Bribery and corruption could seriously harm our reputation, lead to considerable financial losses and embarrass our business partners. Therefore, we are committed to preventing our employees, employees of our joint ventures and third parties acting for or on behalf of CarNext, from giving or receiving advantages that may constitute or be perceived as bribery or corruption. We have a separate Anti-Bribery and Anti-Corruption Policy which provides us with practical rules on how to prevent and detect bribery-related issues and how to act if an incident of bribery arises.

Offering and receiving gifts or business hospitality can be a lawful and legitimate way to strengthen client and supplier relationships. However, we do not accept or provide any gift or business hospitality if, by doing so, we or our customers or suppliers might appear to be no longer independent of the opposite party or that CarNext or our business partners may be embarrassed.

Keep in mind

  • Local laws and customs regarding gifts and business hospitality can differ.
  • Gifts and business hospitality allowed between private companies may not be allowed in relationships with public officials.
  • Monetary gifts in the sense of cash payment are not allowed.
  • Gifts and business hospitality are not allowed during a tender process with a client.

5.3 Anti-money laundering, combating the financing of terrorism and sanctions

CarNext does not do business with counterparties that are involved in unethical or illegal behaviour such as money laundering, financing of terrorism, human rights violations or breaches of export regulations or that are designated as sanctioned persons or entities. Our AML, CTF and Sanctions Policy sets the path in combatting money laundering, terrorist financing and transactions with sanctioned persons or entities.

5.4 Asking questions and raising concerns 

Living up to the standards of conduct is our joint responsibility. Doing so helps us to be a socially responsible company and to continue to build a business of which we are, and can remain, proud. Every employee is responsible for alerting of actual or potential violations of our business principles. CarNext treats all alerts and reports of actual or potential violations with appropriate confidentiality.

Within CarNext, there are several channels for asking questions about any issues covered by this Code of Conduct or raising concerns about suspicious activity. CarNext whistleblowing requirements are included in the Whistleblowing Policy. The policy is applicable to all CarNext employees worldwide.

Withing each of our entities:

Generally, your direct supervisor or manager will be in the best position to resolve any questions or concerns. However, direct supervisors or managers are not the only option. Other resources may include:

  • next-level management:
  • the Country Managing Director

Withing CarNext group:

Several channels exist within the CarNext group for asking questions, raising concerns or reporting a potential violation:

  • The Head of Risk and Compliance
  • Chief Human Resources Officer

Concerns can also be raised anonymously through the CarNext Whistleblowing Policy

5.5 Enforcement 

Non-compliance with this Code of Conduct is taken seriously and any claims of wrongdoing will be investigated and remedied. Failure to comply with this Code of Conduct may lead to disciplinary action in accordance with internal disciplinary procedures, up to and including termination of employment.

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