To our stakeholders

I am pleased to confirm that BearingPoint reaffirms its support of the Ten Principles of the United Nations Global Compact in areas of Human Rights, Labour, Environment and Anti - Corruption. In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

In 2020 we all saw that change can be unexpected, and it can happen more suddenly than anyone imagines. However, we have seen how quickly people can adapt to new circumstances. The priority now is what happens next. Strategy 2025 is our way forward. Working together, and working with purpose, I am confident that we will emerge from the crisis stronger than ever. 2020 starts a decade of purpose for BearingPoint. We are renewing our efforts in order to maximize the social impact of everything we do – within our CSR pillars of People, Planet, and Society. And we are maintaining our commitment to invest at least 1% of our annual EBIT directly to CSR.
I am personally convinced that our future success and our ability to leverage new and existing opportunities in a sustainable way depends on how consistently we live up to our values and addressing these challenges.

Sincerely yours,
Kiumars Hamidian
Managing Partner

As a European-focused management and technology consultancy firm, we do not have direct business operations in industries which represent a higher risk for potential human rights violations. We do however observe international human rights and related laws and regulations and pro-actively apply the UN recommendations and other international standards in this respect. We recognise that human rights violations and modern slavery matters are still being reported in the news, including in countries BearingPoint in which BearingPoint operates. As a technology consulting firm, we engage mainly with suppliers for IT, business support, marketing materials and office maintenance supplies and services, all areas which do not normally fall in the obvious scope of potential human rights violations. However, given our global reach and the versatility of the business partners we work with, be it as clients, suppliers, service providers or partners, we realise that these issues concern us and this is a subject where we need to do more throughout our supply chain. As a minimum, we need to ask questions and find out where our equipment comes from.

Our goal in the remaining months of 2020 and in 2021 will be to continue to include these elements into our firm-wide procurement process and follow up with selected suppliers to obtain further assurances.

Potential human rights implications are already a key element of the compliance due diligence process when engaging selected clients and third parties working for us in higher risk countries, but we must also be concerned about this throughout our whole supply chain. With the creation of a firm-wide procurement function, we are including an array of different requirements, including the commitment to adhere to human rights principles in the selection process. We are currently selecting, on a risk- based approach, the number and type of existing suppliers, who will be part of this review.
We also support our clients in their commitments when selecting us as their business partner:
• Specifically, we included the Modern Slavery Act and general human rights elements into our new (Supplier) Code of Business Ethics
• Enforcement of these principles through our new Supplier Code of Business Ethics towards all our direct suppliers is managed through the firm wide procurement department
• Rollout of a mandatory Code of Business Ethics and CSR online session for all employees and selected third parties
• Specific UK Slavery face to face awareness sessions in our UK practices organized through our Group Compliance department

We are already complying with requests from clients for external assessments, for example EcoVadis or TRACE certifications, and aim to continue to deliver these successfully in the future.

With our goals for 2020, we aim to create a better automated track record for the selection criteria for our suppliers. For example, forwarding our revised Supplier Code of Business Ethics to our suppliers and automatically tracking compliance or if applicable agreed mitigation actions.

General and targeted trainings for employees to raise awareness and ensure compliance with dedicated principles.

BearingPoint’s success derives from the success of our people and people centricity is at the core of our growth strategy. We recognise and value the unique contributions that people with different backgrounds, experience and working styles have to offer and this enables us to interact with different cultures and global stakeholders. We do not discriminate against anyone because of race or ethnicity, colour, gender identity, age, family status, marital status, religion, disability, national origin, sexual orientation, trade union affiliation or other legally protected status. BearingPoint’s policies and practices reflect how we value diversity, provide equality of opportunity and ensure that no job applicant, employee, client and other business partner receives less favourable treatment on any of the grounds set out above.
These principles are anchored in our Code of Business Ethics and supported by a specific Diversity Policy (our DIVE Policy) that People at BearingPoint are required to comply with. An essential component of BearingPoint’s corporate social responsibility is our commitment to being good corporate citizens within the communities where we do business. That is why we promote relations with providers, business partners and sub-contractors operating under the same values. We expect any third party working with or for us to apply the same.
We strongly condemn child or forced labour and pro-actively apply the UN recommendations and other international standards in this respect. Freedom of association and the right to collective bargaining is ensured across all BearingPoint’s legal entities. This is shown, for example in our worker’s councils or in affinity initiatives, too.

Our Goal is to be an inclusive firm that creates a feeling of belonging with the people working with and for us. This means that we want to bring policies to life and celebrate inclusiveness – beyond group-specific markers. We aim to make diversity, inclusion, and equality ongoing topics in internal communications, to make everyone aware of the topic – and make it everyone’s individual responsibility. In doing so, we automatically position ourselves against any form of discrimination.

In 2019, we have strengthened our commitment and activities with respect to diversity and inclusion through the appointment of a firm wide Corporate Social Responsibility manager, who is leading and coordinating our efforts in this area. Diversity and inclusion is also covered within this function.
One central role of the CSR and Diversity manager is to coordinate our regional activities and to co-develop a joint diversity and inclusion approach, that reflects both firm-wide objectives and regional specialities . So, one way to implement our goals is to provide a platform for regular exchange and discussion with all responsible (and otherwise supportive / engaged) people for the topic.To promote inclusiveness, BearingPoint works with an intercountry DIVE Council (with sponsors from Leadership). In addition to agenda setting, trainings and awareness interventions, we invite our people to initiate so-called affinity initiatives (also known as Employee Resource Groups).
Through our human resource recruitment, we are committed to making BearingPoint a truly inclusive organisation, where each of us can fulfil their potential and be themselves, regardless of background.

In 2019, we conducted a firm wide survey on fair treatment at BearingPoint. This survey is not only used to inform and receive feedback on our diversity and inclusion strategy,but also to assess the degree of perceived inclusiveness at BearingPoint. This KPI is an indicator measuring the potential gap between ambition and people reality. The Women@BearingPoint Network is our strongest affinity network. We are also very proud to confirm that we see various LGBTQ activities occurring within the Proud@BearingPoint Network. Also, our People started the Ability@BearingPoint community raise awareness of physical and mental health issues. We are open to the creation of other groups as required by our people .
We have launched a revised DIVE policy at the end of 2019 and started communicating more (internally and externally) about how we promote inclusion at BearingPoint. Various legal entities have created workers council representations.

We do not operate industrial plants or package our services in plastic. Yet, we are very much aware that a service / people business such as consulting also comes with environmental effects that require management. Consequently, we take responsibility for the ecological effects that our business affects. This means – using CO2 management principles – avoiding or reducing environmental effects where possible. For environmental effects which cannot be avoided, we see it as mandatory to offset our footprint. Following a materiality analysis, we found that our biggest pain point is our CO2 footprint related to business travel. Thus, we see it as our responsibility to enable our people to make wise travel decisions. The basis of this is given within our Code of Business Ethics, where we commit ourselves to protecting the environment. We also have a CSR Policy in place, which we revised due to changes in the governance model and due to the increased priority of the CSR topic overall. Also, a firm-wide travel policy is currently being finalized which ensure that the avoidance of CO2 emissions is a clear goal and that clarifies on priorities and incentives to encourage less travel or more eco-sensitive traveling, respectively. Accordingly, we will continue to track our CO2 emissions by using our internal IP “Emissions Calculator”. While reducing CO2 emissions certainly is our priority, we take a wider approach to ecological action. We put together the program BE GREEN, which is a collection of activities promoting a (more) sustainable business conduct within the firm and within our value chain (suppliers). One major pillar of this 6-layer program is the continuing implementation of a BE GREEN and CO2 emission reporting, with which we will create transparency on progress.

Our Goal…
Strategy Reporting: It is our goal to further improve our governance and reporting structure. This will enable us to keep track of our actions to tackle our environmental challenges, predominantly travel-related, to connect the dots and ensure ongoing reporting, offsetting and green improvement. We also aim to use the data to further develop concrete emission goals.
Kick-off all BE Green activities in 2020

BearingPoint has made environmental responsibility a priority in 2019 and beyond.
GOVERNANCE: Consequently, BearingPoint has created a function addressing the overall CSR agenda on a firm-wide level. The responsibility of this role is to span a strategic umbrella around the regional CSR activities across the pillars People, Planet and Society, to coordinate activities and to enable ongoing exchange between practices and across regions, levels, and functions. This firm-wide manager is leading the so-called CSR Council (a group of regional / local CSR leads). A firm-wide CSR Sponsor from the Partner level supports this role. In addition, BearingPoint has built a network of so-called Sustainability Agents who help to promote sustainable thinking, innovation and decision-making across the firm, individual offices as well as amongst our People and CSR leads – on a voluntary basis.
AGENDA: The BE Green program mentioned above summarizes our approach to ecological sustainability. With this agenda, we have defined a collection of activities across six layers of action. It deals with all our major environmental concerns (mobility, IT & Devices, Offices, Client Offerings) and corresponding actions from the Firm and its People to keep improving in this area.
ACTION: A significant share of the activities to reduce our CO2 / environmental footprint depends on the support of our people. While some campaigns have been initiated by them (#plasticfree campaign), BearingPoint also provides platforms to engage and exchange. With internal groups – we call the communities of practice – theme experts share knowledge and facilitate people involvement. This logic we adapt for the sustainability topic, too. We organize people campaigns, and invite to share suggestions on how to improve our CSR doing with a central ideation platform.
We encourage our People to set www.ecosia.com as their standard browser, who is using the add revenue from our searches to plant trees where they are needed most.

In 2019, we implemented a revised CSR policy which covers the three fields of responsibility at BearingPoint (People, Planet, Society). This revised CSR policy has replaced the former Sustainability Charter. Also, we developed the program BE Green, which will guide our actions in the next five years in moving to a 100% green firm in the future. It covers 6 layers (sustainability client-offerings, travel, offices, IT and devices, cooperation, and standards). Below find some concrete actions:
TRAVEL:
We will continue offsetting the CO2 footprint of our firm-wide travels in 2020/21. We aim to extend the compensation on further sources of CO2 emissions (servers and offices). Further, we initiate exchange on COVID-19 remote working experience to establish a new way of working. Apart from that, we will further extend the E- and green offerings for alternative modes of transport for the different practices we are active in. Further, we will launch an app for our people to raise awareness on CO2 emissions caused by individual travelling and commuting and spread the idea of compensating for CO2 emissions.
OFFICE:
We nominated Sustainability Agents for the majority of our offices to take responsibility for sustainability improvements there. Also, we will follow-up on switching to Renewable Energies with our offices (exceptions from this require an explanation). In addition, our sustainability agents have launched how-to guides to run the office greener, buy sustainable gifts and have sustainable events – these will be shared with all our colleagues via a campaign page on our intranet.
Apart from this, we are continuously working on running our offices more sustainably – assisted by smart / automated devices and awareness campaigns among our people. Offices will communicate on the single actions they are taking (since we have different starting points here).
IT & DEVICES:
One concrete measure (next to robust collaboration and knowledge exchange tools) is to further equip all our offices with robust and state-of-the-art video conferencing tools which allows effective remote collaboration and, thus, helps to avoid unnecessary business trips. STANDARDS & REPORTINGS:
For our offices, we are currently collecting office data across all offices to delineate consumption goals and room for improvements based on the data for 2019.
COOPERATIONS:
We seek cooperation with sustainable start-ups within our partner Wayra. We also started a cooperation with Mindful Mission, a green start-up from Austria, with whom we are developing a Green App (see Mobility). Also, we seek to further engage in Pro Bono cooperation with nonprofits and social start-ups.
SUSTAINABILITY OFFERINGS:
We provide a community of practice to enable firm-wide team exchange on client-related sustainability offerings, background information (current studies) and material sharing

BearingPoint's reputation for integrity goes back over one hundred years and is one of our most important assets. We are proud that BearingPoint has consistently maintained a strong focus on integrity throughout its history and we are committed to ensuring that it continues to do so. To support this our Code of Business Ethics prohibits our people and third parties acting on our behalf from offering, promising, authorizing, making or receiving from clients, suppliers, public officials or any other business relations or partners, either directly or through a third party, any inappropriate monetary or other benefit or undue advantage and in this respect must always comply with applicable laws and regulations.

In addition, specific guidelines on gifts and entertainment have been specified. Since we operate in countries with different cultural and business ethics in relation to financial improprieties, we set up specific compliance approval and due diligence requirements for our business partners in specific higher risk countries and areas of operation.

Bearing Point has significantly increased measures to combat corruption and promote business practice in all countries and industries where we operate. The creation of a new independent compliance function and the appointment of a Chief Compliance Officer has paved the way for a new enhanced compliance programme, designed to take preventative action against corrupt practices.

For 2020 we aim to increase the level of awareness with respect to this topic, strengthen our procedures to ensure that no conflict of interest arises between our employees and business partners and also initiate the first steps of monitoring the robustness of the implementation of our policies and procedures.

In 2019, the focus of our activities in this area was to establish and tighten the due diligence and approval process when operating in higher risk countries and to raise awareness. BearingPoint applies various approaches to ensure our people are adequately and correctly trained for the functions they perform and are aware of the critical legislation affecting our business.

Mandatory online modules have been designed to address compliance-related topics, such as the principles of Code of Business Ethics, including anti-bribery and corruption rules which were rolled out in the second half of 2019. A dedicated online module on GDPR and Information Security is already in force. In addition, training materials and additional guidelines have been prepared and made available to specific teams in the context of formal awareness and training sessions, including dedicated third parties. Awareness material is also being made available on our intranet.
BearingPoint has introduced a confidential TrustLine, specifically encouraging our people to report concerns over non-compliant conduct, including any alleged corrupt practices. TrustLine is an anonymous and confidential online reporting system developed by Business Keeper AG: The Business Keeper Monitoring System. Only selected members of the Group Compliance team have access to the information and are overseeing any potential investigation in cooperation with the relevant subject matter experts.

The Chief Compliance Officer discusses the level of implementation of the program monthly with the Managing Partner, the Chief Operating Officer and the Chairman of the Partnership Board. Specific focus is being placed on the monthly measurement of the level of awareness, given by the completion status of the various e-learnings, which have been made available to selected third parties