13. September 2022

To our stakeholders:

I am pleased that BearingPoint reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labor, Environment and Anti-Corruption.
In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and the mentioned 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.
During the challenging years of 2021 and 2022 where Covid impacted our way of working, we continued to focus on our processes to ensure compliance with the 10 principles. Our 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 focusing on our purpose “Together we are more than business”. With this purpose statement we emphasize that we aim to achieve (1) more innovation to achieve (2) more for People (our People, our clients’ People, and People in Society) and (3) more for the Planet. Using our innovation power will help us to maintain resilience and help our clients and other organizations with social value to deal with their unique but also global challenges. With “More for People” we seek to act for the better of our People (by addressing their development, work-life-balance, equality, and financial resilience), our clients’ People (by sustainable project management in client engagements, supporting them to do their jobs better, and by accompanying them in their transformation towards SDG17-oriented business impacts) and People in Society (by sharing knowledge and donating time pro bono and by other donations and volunteering). With “More for the Planet” we signal that we understand the key role we and our clients have in maintaining this ecosystem by making needed adjustments to the way we think, decide and act.
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. That is why I engage in our firmwide Sustainable by Design Steering Committee and strongly support all initiatives that help us to continuously change for the better.

Kiumars Hamidian
Managing Partner
BearingPoint Group

We are a European-focused management and technology consulting firm, with no direct business operations in industries which represent a higher risk for potential human rights violations. We do, however, closely observe international human rights and related laws and regulations, and pro-actively apply the UN recommendations and other international standards in this respect.
As a technology consulting firm, we predominantly engage with suppliers in areas pertaining to IT, business support, marketing materials, and office maintenance supplies and services; areas which, from a one-tier perspective, are not generally considered in the scope of potential human rights violations.
However, given our global reach, specifically through some recent acquisitions and the versatility of the business partners we work with, be it as clients, suppliers, service providers or partners, we realise that the protection of human rights concerns us, resulting in a need for us to improve existing processes and implement new ones.
Our Goal ….
Our goal in the remaining months of 2022 and in 2023 will be to increase the visibility of potential supply chain risks beyond firm wide suppliers as well as increase the level of screening activities.

Potential human rights implications continue to be a key element of the compliance due diligence process we adhere to when engaging with clients and third parties working for us in higher risk countries. However, it is also essential for us to consider and address human rights throughout our entire supply chain.
Specifically, through recent acquisitions we have focused on new business partners in countries where we previously had no presence. Human Rights due diligence elements were included in these acquisition plans.
We also continue to push our principles through our Supplier Code of Business Ethics, either by requesting our suppliers to acknowledge it or by reviewing their Code of Conduct, to ensure alignment with our standards and the standards of the UN Global Compact.

We are already complying with requests from clients to conduct external assessments (e.g., EcoVadis or TRACE certifications) and aim to continue to deliver these successfully in the future. Moreover, specifically our EU work in the public sector is frequently assessed to ensure compliance concerning questions of Human Rights in line with the EU supply chain regulations.
In 2021, we successfully established an automated process, rolling out our Supplier Code of Business Ethics to firm wide suppliers and continue to advocate for its use at the country level for local suppliers.
Furthermore, we conduct general and targeted trainings for employees to raise awareness and ensure compliance with dedicated principles. In 2023, further elements on Human Rights will be included in our new version of the Code of Business Ethics training.
In 2023, we also consider to establish a specific automated ESG risk screening if and when available on the market for all our firmwide business partners.

BearingPoint’s success is derived from the accomplishments of our people and the people-centric approach which lies at the core of our corporate strategy. We recognise and value the unique contributions that people with different backgrounds, experience and working styles have to offer, enabling us to interact with different cultures and global stakeholders.
We do not discriminate against anyone based on their race or ethnicity, skin colour, gender identity, age, family status, marital status, religion, disability, national origin, sexual orientation, trade union affiliation, or other legally protected statuses. BearingPoint’s policies and practices reflect how we value diversity, provide equality of opportunity, and ensure that no job applicant, employee, client, or other business partner receives less favourable treatment on any of the grounds set out above.
We strongly condemn child or forced labour and pro-actively apply the UN recommendations and other international standards in this respect. Moreover, we support freedom of association and the right to collective bargaining across our entities.

Our Goal ….
… is to be an inclusive firm that creates a feeling of belonging with the people that chose to work with and for us. This means that we want to bring written policies to life and celebrate inclusiveness – beyond group-specific markers. We aim to address diversity, inclusion, variety, and equality (DIVE) in internal communications, to establish awareness on the topic – and make it everyone’s individual responsibility. In doing so, we automatically position ourselves against any form of discrimination.
We have formulated a commitment (Sustainability Goal) regarding the representation of females within BearingPoint by the end of 2025.
• 40% female staff across levels
• For leadership, we aim for 20% female partners
• All leadership teams with female representation

In the past year, we have strengthened our governance to ensure diversity and inclusion and avoid discrimination at work.
Supporting our Global Lead Sustainability, we have nominated firmwide Sponsors from the leadership team to ensure that we induce change at this level with the support from our partners. Furthermore, we have introduced the role of Sponsor Sustainability in the Management Committee. In our holistic understanding of Sustainability, DIVE is a key element which extends into our Sustainable by Design Steering Committee, which meets every six weeks.
One central role of the Global Lead Sustainability is to coordinate our regional activities and to co-develop a joint DIVE approach that reflects both firmwide objectives and regional specialities. One approach to implement our goals is to provide a platform for regular exchange and discussion with all responsible (and otherwise supportive / engaged) people, referred to as the DIVE Council, which consists of FW and country representatives.
In the past months, we engaged even more in the exchange with our firmwide affinity initiatives. In 2022, we coordinated our firmwide actions and messaging around four shared focus areas that represent our four firmwide affinity initiatives.
With our goal of Female Acceleration, we do not only aim to increase female representation but know that we need to challenge the stereotypes within the consulting culture to achieve a more family supportive environment – for all genders. Thus, we implemented the firmwide “Framework Family Supportiveness” as clear guideline for all our local practices (next to a “Framework Female Acceleration”). These principles are anchored in our Code of Business Ethics.
We have also recently revised our Diversity Policy (DIVE Policy) that all People at BearingPoint are required to comply with. With the latest revision, we ensured that our concrete DIVE goals and frameworks are anchored in our ways of working. With our firmwide Office of Business Conduct, we ensure that any non-compliance can be reported (either directly or anonymously) and addressed appropriately.
An essential component of BearingPoint’s corporate social responsibility is our commitment to be good corporate citizens within the communities in which we do business. We therefore continuously 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 approach, which is laid out in our Supplier Code of Business Ethics, reflecting the UN Global Compacts 10 principles – and requiring compliance.
Freedom of association is ensured across all of BearingPoint’s legal entities. This is reflected, for example, in existing worker’s councils but also in less formal employee organisation (such as engagement with our four employee-driven affinity initiatives).

We have developed key performance indicators and other qualitative measures of outcome.
We ensure Freedom of Association and Collective Bargaining in all our practices. Our various legal entities have created 11 local workers council representations. In addition to formal ways of collective bargaining and association, we continuously work on improving transparency and feedback mechanisms, since they represent the origin of fair business conduct.
Regarding child labour and/or forced / compulsory labour, the services provided with highly skilled consulting and with client contact are not suspected to such practices. Still, our practices are set up to ensure no malpractice, especially in our service centres. We aim to prevent engaging with business partners that engage in such malpractices. To address this issue, an official statement condemning such practices is included in the catalogue that all central suppliers of BearingPoint need to share.
To address the topic of Diversity and Inclusion (acting against discrimination and harassment), we have defined concrete goals on female representation in our firm in addition to our core KPI of “Belonging”.
Female representation is a key but not the only diversity target. However, we are convinced that making female acceleration a priority will benefit all people within our firm. Moreover, female acceleration is an overdue task. And progress can be reliably tracked and measured, allowing us to share status via frequent updates of our DIVE Dashboard.
To ensure that we achieve our Sustainability Goal regarding female representation within the firm, we set up a dedicated working group called “Female Acceleration”. This working group regularly presents its ideas, roadmaps, and progress at the “Sustainable by Design” Steering Committee. In 2022, the main action points were to develop a roadmap with the country teams to address female acceleration and family support initiatives.
We have included Belonging into our frequently conducted People Survey for continuous tracking and analysis. With our People Survey from 2021, our people have on average indicated a belonging score of 4.9 (out of 6), representing an increase of 0.1 as compared to 2020.
We invite all people to engage in existing groups (such as our affinity initiatives comprising: Women (female colleagues + allies), Proud (LGBTQ+ colleagues + allies), Ability (colleagues with health impairments + allies), and MORE (Minorities of Religion and Ethnicity). Moreover, we collect ideas on DIVE for internal firmwide discussion with our Sustainability Hub of Innovation – an idea platform.

We take responsibility for the ecological effects that our business comes with. This especially means avoiding or reducing the environmental footprint and negative climate impact, where possible. As a professional service firm basing its work on knowledge transfer and digital services, our environmental impact related to our core work is negligible. Thus, our doing is focussed on emission measurement, tracking, and management. While avoidance and reduction are what we need to focus on, we still face remaining emissions, that we currently qualify as unavoidable, we see ourselves obliged to compensate.
Following our emission materiality analysis, it became clear that our biggest pain point concerning the emission footprint is related to our travel practices.
We still need to provide the complete picture (our overall emission footprint) to track reduction progress and further elaborate a concise reduction roadmap. Beyond data transparency, we see it as our responsibility to enable our people to make wise and informed travel decisions. This comes with a combination of directives, clear communication, and awareness. The basis of this is given within our Code of Business Ethics, where we commit ourselves to protecting the environment.

Our Goal…
It is our goal to have a governance in place that enables us to keep track of our actions to tackle our environmental challenges, predominantly travel-related, to connect the dots and ensure ongoing reporting, improvement, and compensation for the remaining emissions.
Beyond tracking, it is a key priority to drive action for effective emission reduction. We have started this by recently formulating an ambitious emission reduction goal, demanding a reduction of our firmwide CO²e emissions by 50% as compared to 2019 by end of 2025 for the SBTi 1.5° path.
Also, other environmental challenges shall be continuously tackled across the firm (IT waste, plastic waste, etc.) to reduce any detrimental impact.
Regarding up- and downstream relations, we aim to tackle sustainability aspects as follows:
- Regarding our suppliers, we expect them to also be able to show their authentic endeavours to improve their environmental footprint. It is our goal to only work with suppliers that can document these endeavours through policies and action.
- Regarding ourselves, we see that we, as a consulting firm, can create even more impact, by helping our clients with their sustainable transformation.

BearingPoint is a Management and Technology Consulting Firm. We understand it as our responsibility to encourage sustainable innovation not only within our firm, but also with our clients, covering the ideas of both economic and ecological sustainability.

Our Goal…
We want to be known with our clients as a consulting partner that helps them with their key transformation challenges – while in the past this was often related to digital challenges, we see that a parallel urgent transformation need is the transition to sustainable practices. This includes both consulting and IP/solutions.
In addition to regular client engagements, we aim to increase the resilience of social and ecological value organisations such as non-profits and social enterprises, by providing our services on an in-kind or reduced-price basis. With our program “We enable help(ers)”, we made pro bono support a key pillar of how we engage for the benefit of the communities we serve.

BearingPoint has officially made Sustainability a priority in 2019, following a tradition of previous, especially local engagement.
We have further strengthened our Governance for sustainability in general and especially pertaining to ecological sustainability. We have a Sustainability Policy in place, which we revised due to changes in the governance model and due to the accelerating priority of the Sustainability topic overall.

Our Global Lead Sustainability is supported by a Sustainability Sponsor in our Management Committee, as well as by two Subject-Matter Sponsors within the partner base (namely a Sustainability Partner Sponsor and a DIVE Partner Sponsor).
The named roles are key participants in our "Sustainable by Design” Steering Committee (complemented by our Managing Partner, our Chief People and the Project Managers of the priority teams). including our Managing Partner, the Managing Committee Sponsor for CSR (including Diversity), and partner sponsors that lead dedicated priority teams, which tackle our Sustainability Goals (including the emission ambition).
Also, a firmwide travel policy will ensure that the avoidance of CO2 emissions is a clear goal and that incentives are set up to encourage this.
The Sustainability Council (former CSR Council) still ensures both country support with firmwide activities as well as local actions.
To not rely on chance, a mandatory training for sustainability is about to be launched in September 2022. All people in our firm will be required to conduct this e-learning course to learn about global challenges, where we will also introduce the SDG17.

We built a strong network of sustainability consultants across the firm (countries, levels and our served industries) with our Sustainability Services Community.
Here, we engage in knowledge exchange and co-development. Moreover, we share regulatory updates and inspiring reads on sustainability topics.
In the past year, we have also created a Community of Practice, which is a space in the intranet, where all materials and contacts from countries as well as asset owners are presented. With this, we have built a full picture of our assets, community, and services footprint.
In parallel, we not only promote and scale existing offerings in the fields of Sustainability Client Offerings, covering topics such as Green IT, Sustainable Finance, and Sustainable Supply Chain Management, but we also seek to develop further offerings of sustainable value (e.g., via dedicated innovation challenges). With our new Purpose, “Together, we are more than business”, we reiterate that innovation is a key element for us to tackle sustainability challenges (incl. environmental aspects) with our clients. New asset development for Sustainability topics is supported via a dedicated charge code. As a parallel initiative, we will bring the sustainability reflection to the conversations with our client project teams and with clients – which is another working stream of our initiative Sustainable Ways of Working.
Suppliers are demanded to accept and act in compliance with our Supplier Code of Business Ethics.

We are still improving our emission dashboard to define the baseline year (2019) emissions, create emission transparency, and track progress more frequently – especially regarding high material sources of emissions (business travel – esp. plane travel)
We continued with our extensive tracking of emissions as started for 2020 (and backwards for our baseline year 2019). While the travel footprint makes for the highest emission impact, we have collected data for commute, IT and offices. We are transparent as regards the way we collect, build, and analyse the data – and also detect ways for further refinement. All information is provided in the appendix of our Sustainability Report 2021 (Reporting Year 2020). In the future, we will share updates on these figures on an annual basis.
We still rely on the IP and support of our internal BearingPoint Emissions Calculator team for most of the calculation.
Doing so, we can show how we as a firm follow-up on our concrete emission target that we formulated for the end of 2025 based on the SBTi analytic approach.
To accomplish this goal, we involved our country offices. Not only did we break down our firmwide goal to country goals, but we also encouraged the constitution of country teams that develop a reduction roadmap for the respective country / region. A firmwide “[E]Mission Zero” team is facilitating exchange and aims to mitigate identified challenges and dependencies. This “[E]Mission Zero” team is also participant in our Sustainable by Design Steering Committee and responsible for data collection and sharing.
For the remaining emissions, we are committed to compensate for the together with our partner “Forliance”.
Lately, we have issued our first CDP questionnaire. In parallel, we have made sustainability a stream with our firmwide Enterprise Risk Management.
In addition, another priority team called “Sustainable Ways of Working” is designing approaches to ensure that our daily doing is promoting the defined emission reduction sustainability goal. With Sustainable Ways of Working, we aim to deliver all our projects sustainably by the end of 2025. In the past year, we have developed a scheme to bring Sustainable Ways of Working to our client teams. This routine includes a definition of sustainable project management, a reporting procedure and new roles with projects that ensure that a team sticks to its defined sustainability commitment. This routine is currently being piloted and will be evaluated (and probably refined) at the end of 2022.
To raise awareness for and support our people with sustainable action, we encourage individual action, too. We continued the sharing of Sustainability Hacks on Sustainably Working thanks to engaged consultants. Beyond this, we have conducted a firmwide ongoing campaign “Sustainable PrACTices” together with our Sustainability Council. We seek to come up with a new intervention for the benefit of the planet every month and engage people firmwide. In the first half of 2022, we have had awareness campaigns on Sustainable Fashion, No Mow May or a mobilisation to use the bike more frequently.

Our Sustainability Services Community is one of the most active communities. We count more than 500 participants and a high interaction rate. The share in revenue with our Sustainability Services is increasing steadily. Lately, we have acquired a specialised boutique consulting firm (I Care). With 70 specialised consultants, we have strengthened our skill-base and offering portfolio.
Also, we have made sustainability services and element of our pro bono support.

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 conflict of interest, 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.

Our Goal
We aim to continue to increase the level of awareness with respect to this topic specifically to new employees and employees transferred to BearingPoint following acquisitions, strengthen our procedures and increase the level of automated monitoring tools in our contractual and financial systems to ensure the robustness of the implementation of our policies and procedures.

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 e-learning modules have been designed to address compliance-related topics, such as the principles of Code of Business Ethics, including anti-bribery and corruption rules, conflict of interest and continues to be mandatory for all new hires. 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.
Specifically, around Conflict of Interest we introduced new processes which include annual confirmation from our Partners and senior managers in selected countries. .
In addition, we introduced automated control and data analytics continuously monitoring processes, specifically in the area of expense control with third parties and payment control to and from countries with higher risks for financial improprieties.

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 also made available to more and more third parties in 2022. Specifically, we increase the number of third parties for whom it is required to do our mandatory trainings.
2022 was also the year of the final roll-out of our automated continuous monitoring and data analytics tests in our main operation systems to increase the level of transparency and real time transaction review from our compliance and other risks departments. Specific focus in on expense control towards and of third parties and payment flow controls to and from higher risk countries.
We also increased the level of compliance engagements in projects in higher risk countries and a specific focus on this area was placed during the due diligence phase for new acquisitions.