The Hypoport Code of Conduct: Tech, Teamplay and You. 

Why does this Code of Conduct exist? 

This Code of Conduct reflects our shared identity and the standards we pursue in all companies of the Hypoport Group (collectively “Hypoport”). It forms the framework for our further Hypoport compliance regulations and Hypoport principles. The goal: To strengthen the trust of all those associated with Hypoport and to underline our role as a reliable partner. This Code of Conduct is a clear sign of our commitment and integrity. It determines our daily actions here and now and our long-term goals. 

Hypoport: A force shaping markets
We take responsibility for our actions, remain visionary and cooperative. As shapers of markets and workplaces, we are all challenged every day to demonstrate our special collegiality and innovative spirit. You are encouraged to ensure compliance with the principles of this Code of Conduct. Familiarize yourself with its contents and integrate its principles into your professional actions.  

Who does the Code of Conduct apply to?

This Code of Conduct applies to everyone at Hypoport: It applies to all companies of the Hypoport Group and at all levels, i.e., to all employees and management alike (collectively “Hypoportler”*).

What you can rely on: Our core values for ethical behavior. 

• We rely on fairness, transparency, and integrity. 
• We do our best in all areas of our business. 
• We treat each other, our customers, business partners, and other stakeholders with respect and goodwill. 
• We take responsibility for our actions and are aware of our impact on society and the environment.  

You are in the right place. And important. 

Promoting diversity: Hypoport’s commitment to fairness, respect, and equal opportunities
The strength of Hypoport lies in our employees. We live an inclusive culture that respects and values every person in their diversity – regardless of role and background. The diversity of our employees is a crucial success factor for us in a complex world. We are committed to a work environment characterized by fairness, respect and equal opportunities and create structures that do justice to this diversity.  

Actively against discrimination, harassment, and extremism
We do not tolerate any discrimination based on gender, age, origin, sexual orientation, or religious affiliation, disability, or other similar characteristics, nor any harassment, bullying, abuse of power or violence. Our goal is to create a safe and supportive work environment where we, as well as our customers and business partners, can move without fear at all times. This claim goes beyond the workplace at Hypoport: We clearly distance ourselves from political parties, movements, and organizations classified or monitored as extremist by the Office for the Protection of the Constitution. 

Technology is as ethical as we design it. 

Data protection
Taking the protection of personal data seriously, prioritizing it, and ensuring its implementation in products and services is crucial for our sustainable success. You are obliged to comply with the relevant data protection regulations and internal data protection policies. We also expect you to participate in the regular internal data protection training of your Hypoport company.  

Cybersecurity and IT usage
We protect our IT systems and data from unauthorized access and cyber threats. You are obliged to use the IT provided to you responsibly and only within the permissible framework, to comply with internal IT policies, and to participate in the internal IT security training of your Hypoport company.  

Ethical development and use of AI and automated processes
Observing ethical principles is also an important factor in the development and use of AI and automated processes. We ensure that the AI systems we use operate transparently, fairly, and without bias. 

Intellectual property, trade secrets, and confidential information
Our business models, products, algorithms as well as processes and their continuous development are crucial for our business success as a technology provider. Accordingly, we are committed to protecting intellectual property, trade secrets and confidential information. We expect you to be aware of the importance of protecting Hypoport’s intellectual property, trade secrets and confidential information, as well as those of our customers and business partners, and to ensure this through appropriate measures.  

Compliance: Guided by reason and integrity.  

The ethics of right decisions
Compliance is the responsibility of everyone. You are obliged to make decisions that maintain Hypoport’s integrity. This means that in our daily work, we consider not only the economic efficiency of our actions but also legal requirements and our ethical principles. Our decisions should be understandable, justified and fair. 

Gifts, benefits and combating corruption
Although gifts and benefits can be part of business relationships, they must never influence business decisions or create the appearance of influence. All gifts, benefits, perks and invitations must be appropriate to their purpose and documented according to our Benefits & Gifts Policy. Hypoport disapproves of any form of corruption and other criminal acts such as extortion, fraud, breach of trust, bribery and corruption. Sponsorship of mega-events and donations to political parties or lobbying associations must be avoided if they serve the purpose of unfair influence. 

Avoiding conflicts of interest
We expect you to avoid situations where you may have a conflict of interest. This includes your economic and personal activities that may conflict with Hypoport’s interests. This not only affects you but also your relatives, close persons, or organizations with which you are associated. If you still find yourself in a conflict of interest, you are obliged to disclose it transparently and help resolve it. 

Misuse of company property and expenses
Company property, both material such as office supplies and equipment and immaterial such as working time or intellectual property, is intended exclusively for business purposes. We expect you to respect, protect and use company property responsibly. Use your judgment to ensure that purchases and related expenses are necessary and appropriate for the intended business purpose. Personal expenses may generally not be charged. For expenses and travel costs, please follow the internal regulations of your Hypoport company.   

Conducting business lawfully: Always.  

Legal compliance
We expect you to comply with the relevant legal requirements. Ensuring compliance and keeping yourself informed is the responsibility of each of us. We ensure that you are informed about changes and additions to the applicable compliance regulations, including this Code of Conduct.

Fair competition
We believe in the free market economy and fair competition, as it promotes innovation and brings about effective solutions. We compete ethically and legally and comply with relevant antitrust and competition laws that prevent unfair and/or anti-competitive business practices.

Suppliers and supply chain
Suppliers should only be engaged after careful and fair review regarding technical requirements, economic efficiency and sustainability. You are obliged to follow the Procurement Policy and the Policy on the Involvement of External Parties. Some suppliers are centrally engaged for reasons of economic efficiency.

Prohibition of insider trading
Insider trading is strictly prohibited. If you have access to precise, confidential, non-public information, you must not use this information to trade stocks or other financial instruments if they are likely to significantly influence the stock price of Hypoport SE or publicly traded customers, business partners, or partners. For more details, please refer to the Insider Trading Prevention Policy, which you are obliged to comply with.

Hypoport: Shaping society.  

A safe workplace that fits life
A healthy work-life balance and the safety and health of employees are important to us. We want you to work as self-organized and responsibly as possible. This also applies, where reasonable, possible, and permissible, to the workplace and working hours. We expect you to use any flexibility and freedoms granted to you responsibly. We comply with relevant regulations in the area of occupational safety and those that ensure the protection of special groups of people, such as expectant mothers, people with disabilities.

Ecology matters
The massive impact of climate change affects us all. It is up to you and all of us to actively pay attention to the following: reducing greenhouse gas emissions, minimizing waste production, using natural resources and energy more efficiently, and thus reducing the consumption of limited resources. Where reasonable and possible, we avoid the use of fossil fuels and instead use sustainable energy sources. You are – like all of us – part of something bigger. Let’s make a difference together.

We communicate transparently
The most important rule of our exchange with each other is transparency. For the best result, it is important that you always communicate openly, honestly as well as promptly and also address conflicts or tensions in a trusting and respectful manner with your counterpart before a situation escalates. 

How do we deal with misconduct?  

We are all responsible for adhering to the principles of this Code of Conduct and the further Hypoport compliance regulations and Hypoport principles. In our daily interactions, we live a culture of integrity and responsibility. In this culture, management and leaders lead by example.  

Reporting misconduct or suspected cases
To create transparency and uncover possible misconduct, it is important that misconduct or a suspected case is reported. There are different channels you can use for this, such as your supervisor, the HEB, or – if available – the compliance advisor of your Hypoport company or – insofar as relevant – the digital whistleblowing system of your Hypoport company. Hypoport SE has also set up a central whistleblower system. You can find more details in the procedural rules for the whistleblower system of Hypoport SE.

Are you unsure whether misconduct has occured? Then use this guide. It helps you analyze the situation and gives you an indication of whether you should take action and who you can contact.

How do we handle the reporting of misconduct and suspected cases?
Uncovering misconduct is essential for our credibility as an employer and business partner. Therefore, we will act as quickly as possible in the event of a report to clarify the facts. We proceed confidentially, professionally and objectively. If misconduct is present or a suspicion is confirmed, different preventive and remedial measures may be considered depending on the severity: from warnings and training measures to disciplinary measures and legal or personnel consequences. We are committed to ensuring fairness in every case and to preventing a recurrence as much as possible.

A clear no to discrimination and punishment
We believe in the value of open and honest communication. Therefore, we assure you that your report, made to the best of your knowledge and belief, will not have negative consequences for you. Discrimination and punishment contradict our core values and will result in corresponding disciplinary measures. If you have been a victim of discrimination or punishment, please report it as well.