1. Scope

This Policy applies to all Personnel for all business segments and units, including members of the board of directors, officers, and employees of TIER Mobility SE and its subsidiaries (“Dott”), and their corporate affiliates, as well as contingent workers (e.g. agency workers, contractors and consultants) and others working on Dott’s behalf. 

This Policy is subject to change and may be amended, supplemented or superseded by one or more separate policies. Any policies or procedures that are specifically applicable to your jurisdiction will take precedence to the extent they conflict with this Policy.

Line Managers are responsible for ensuring that their employees are aware of this procedure and that they observe it accordingly. Employees are responsible for familiarising themselves with the provisions of the Policy and observing them.

This Policy shall be implemented in accordance with the EU principles of precaution, prevention, polluter-pays, and correction at source, as enshrined in the European Green Deal and EU environmental law.

2. Purpose

Dott is Europe’s leading shared micromobility provider, with a mission to change mobility for good, together. Sustainability represents a core principle of Dott’s business model. With this Policy, Dott therefore commits to: 

• • Ensuring compliance with all applicable environmental legislation and official regulation at all times
  • Continuously improving its environmental performance as an integral part of its operations and ongoing business practices
  • Creating the necessary conditions for achieving the targets as set out in its annual Sustainability Reports
  • Taking full responsibility for any negative environmental impacts arising from its operations and taking immediate action to avoid or at least minimise all identified negative impacts wherever possible. Taking responsibility also includes remedying environmental damage in line with the EU “polluter pays” principle

As a supporter of the Sustainable Development Goals, this Policy shall underline Dott’s commitment to continuously drive responsible environmental business practices, environmental innovation and a more sustainable future. In particular, Dott commits to lifecycle-based sustainability, ensuring that products are durable, repairable, reusable, energy-efficient, and recyclable in line with Regulation (EU) 2024/1781.

3.Roles and Responsibilities

The Environmental Policy is approved by Dott’s Sustainability Committee, which is a committee which is established by and reports to the Administrative Board and which is committed to continually minimising our environmental impact by maintaining a governance framework (management system) and securing resources to deliver this Policy by:

• • Establishing objectives and targets
  • Measuring progress 
  • Reporting our results in a transparent and timely way
    

The role of the central management body for all environmental management issues is fulfilled by our cross-functional Sustainability Team. The team is responsible for driving and coordinating progress towards Dott’s sustainability targets and ensures that all internal stakeholders are seamlessly working together. The team meets regularly to review our targets, identify needs for action and deliver progress reports to the Sustainability Committee, Administrative Board and our stakeholders. 

The Sustainability Team is also responsible for publishing an annual Environmental Performance Statement, including lifecycle emissions data, waste management outcomes, and progress against Science Based Targets initiative (SBTi) goals.

4. Our Approach

4.1 Minimising resource consumption
Dott commits to continuously reducing the consumption of energy, water and material resources across the full lifecycle of our vehicles, by adopting circular practices that align with EU Standards and accepted best practices. In this context, Dott commits to: 

• • Continuously improving the lifespan of all vehicles by increasing both the modularity and repairability of our vehicle design
  • Minimising the use of hazardous materials in production and during operations 
  • Minimising the generation of waste from our business operations by incorporating the principles of the waste hierarchy, avoiding waste disposal, and optimising the share of waste sent to recycling or secondary raw material markets 
  • Increasing the share of secondary (reused and recycled) materials in our products 
  • Working with our Original Equipment Manufacturers (OEMs) to optimise sourcing and production of vehicles and batteries
  • Developing transformative products that can be easily repaired and deconstructed at end of life, to enable the recovery of resources within a circular economy 

All design and procurement decisions will be benchmarked against EU Ecodesign and Sustainable Products Regulation requirements, including durability, reusability, and recyclability metrics.

4.2 Reducing and avoiding harmful emissions to the environment
Dott is committed to achieving ambitious emission reduction targets in alignment, at a minimum, with the Paris Agreement’s 1.5°C pathway. To achieve its emission reduction targets, Dott will:

• • Measure and analyse its corporate carbon footprint
  • Minimise the emissions from its own operations by consistently reducing emissions connected to the operations fleet, offices, and warehouses
  • Prioritise sea and rail shipments and avoid air freight
  • Map the CO2e emissions associated with the production of its vehicles to identify and substitute CO2e-intensive materials 
  • Engage with our suppliers to support them in assessing their emissions and setting SBTi-compliant reduction targets
  • Give due consideration to environmental issues and energy performance when acquiring office and warehouse space, operations vehicles, and other operational equipment
  • Publicly disclose progress on Scope 1, 2, and 3 emissions in alignment with EU Corporate Sustainability Reporting Directive (CSRD) and ESRS standards

4.3 Ensuring continuous improvement
To ensure continuous improvement of Dott’s environmental management practices, Dott will:

• • Ensure all employees understand their responsibilities in relation to this Policy 
  • Provide necessary training and support to enable employees to implement this Policy 
  • Appoint key sustainability contacts in every unit across Dott to form a cross-functional Sustainability Team, which is responsible for driving forward relevant goals and commitments
  • Inform suppliers of our sustainability goals, incorporate our Supplier Code of Conduct into our contracts, and work with them to adopt effective sustainability management practices
  • Solicit input, ideas, and initiatives from employees, suppliers, customers, and board members to help meet our sustainability goals
  • Implement and review an overarching environmental management system as well other related objectives, targets, policies, and practices
  • Review this Policy regularly 
  • Establish measurable KPIs (e.g., GHG emissions per passenger-km, percentage of batteries recycled) and include them in annual sustainability reporting

5. Queries

If you have any questions about this Policy or its application, please contact sustainability@ridedott.com.

Concerns about non-compliance with this Policy or with environmental regulations may also be reported confidentially via the Company’s whistleblowing mechanism.