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CODE OF CONDUCT MBA Solutions GmbH

Preamble

MBA Solutions GmbH, is a German service provider in the field of merchandise products based in Troisdorf.

We claim not only to supply our customers with good service and quality, but also to make a valuable contribution to the sustainable development of the countries and regions in which we operate.

We are committed to our social responsibility and our corporate duty of care, regardless of whether we are doing business in Germany, Europe or other parts of the world.

The Code of Conduct reflects the common basic understanding of socially responsible, entrepreneurial action in the sector of the German textile and fashion industry. At the same time, it serves as an orientation framework against which companies can individually align their decisions and measures, and also takes into account the concerns of small and medium-sized suppliers and their challenges in an increasingly global and networked economy.

We act in accordance with generally accepted values and principles such as integrity and legality, and in particular observe internationally recognized human rights and labor standards as set out in the Code of Conduct.

We are committed to our duty of care.

We share the objectives and the contents of the Code of Conduct and will make every appropriate and reasonable effort, within the scope of our respective legal and factual possibilities, to comply with the voluntary commitment on an ongoing basis at all our company sites in Germany and abroad.

If existing national regulations conflict with the contents of the Code of Conduct, or if the national context makes it impossible to comply with them in full, we will seek ways to nevertheless comply with the requirements of the Code of Conduct wherever possible.

We respect human dignity and internationally recognized human rights with reference to:

In all our business activities, we always strive neither to cause nor to contribute to human rights violations. We expect the same from our business partners. To the extent necessary and possible, we support our production partners in this regard.

We treat our employees and our suppliers with respect, including in particular the workers without whose help we would not be able to manufacture products and who play a significant role in our success.

1.0 DUTY OF CARE

We are committed to our duty of care and expect the same from our suppliers.

The goal is to strengthen the rights of those affected.

With each order, the supplier acknowledges the Statement of Principles on Respect for Human Rights by confirming the order to which our chain of custody is attached and sent with the order.

To identify adverse impacts on human rights, labor and the environment, we maintain open transparent communication with customers, employees and suppliers and provide assistance wherever possible. In return, we expect transparent information from our suppliers and a serious effort to work together to remedy problems and improve situations.

2.0 HUMAN RIGHTS

2.1. CHILD LABOR

We do not tolerate child labor and observe the applicable legal minimum age for admission to employment. In any case, we do not employ persons under the age at which compulsory schooling ends under the law of the place of employment and under the age of 15.

We expect our contractors to have adequate means of determining age in order to prevent child labor. Should child labor be identified, all necessary measures must be taken immediately to focus on the well-being, protection and development of the child.

In the case of persons under 18 years of age, the rights of adolescent workers shall be respected; they may only be employed if it is ensured that the working and employment conditions do not pose a risk to their health, safety or morals, nor are harmful to their development.

2.2. FORCED WORK

We reject any form of forced or compulsory labor, including any form of bonded labor, servitude, slavery or slavery-like practices, human trafficking or other involuntary labor and services that are inconsistent with internationally recognized labor and social standards, and expect the same from our contractors.

Our suppliers ensures that no involuntary labor, forced labor or any form of slavery happens, including in lower supply chains. Any form of labor must be voluntary.

Our suppliers ensure that employees do not have to hand over any personal documents (e.g. passports) and do not have to deposit any employment lump sums in order to get the job. All employees receive a briefing on the policy and the rights and responsibilities associated with it. Any form of punishment, psychological and/or physical, as well as other forms of human trafficking are prohibited and must be reported immediately if they become known. (See Complaint Management Portal on our website).

2.3. DIVERSITY/ DISCREMINATION

We promote a work environment that enables inclusion and values the diversity of our employees. We are committed to equal opportunity and reject any form of discrimination or unjustified unequal treatment in employment, for example on the basis of national and ethnic origin, social origin, health status, disability, sexual orientation, age, gender, political opinion, religion or belief.

2.4 WORKING TIMES

We comply with the statutory or applicable collectively agreed provisions on working hours, including overtime, rest breaks and recuperation leave. In any case, we ensure that overtime is compensated or remunerated at least in accordance with the statutory or collectively agreed regulations; its arrangement is by way of exception and exclusively on a statutory, collectively agreed or contractual basis. We also expect this from our suppliers.

The supplier shall comply with all nationally applicable laws and binding industry standards on working hours, overtime, breaks and paid rest leave.

* the regular weekly working hours are not exceeded during the week.

* the right to rest breaks is respected each working day.

* after six consecutive working days, there is regularly at least one day off.

at least one day off.

* legal or religious holidays and vacations are respected.

2.5. COMPENSATION

The supplier pays its employees in accordance with the local minimum wage law and applicable collective bargaining agreements in line with industry standards.

Supplier shall pay workers in a timely manner.

Employment documents must be written in the language the worker understands. Wage deductions not permitted by law, including wage deductions as a disciplinary measure, will not be tolerated by us.

2.6 FREEDOM OF ASSEMBLY/TRADE UNIONS

We respect the right of employees to freedom of association and assembly, as well as the right to collective bargaining and collective bargaining, insofar as

this is legally permissible and possible in the respective country of employment. If this is not permissible, we seek appropriate compromises.

Our suppliers recognize these rights and promote the ability of workers to participate in union representation elections without threat, to the extent permitted by the political circumstances of the country.

2.7 WORKING PROTECTION

We comply with national and international occupational health and safety standards and ensure a safe and healthy working environment in order to maintain the safety and health of our employees, protect third parties and prevent accidents, injuries and work-related illnesses.

In close communication with our suppliers, they ensure the implementation of occupational health and safety by applying an approach to health and safety management appropriate to their business with the aim of preventing accidents, maintaining the health of workers. This includes protective devices on the machines, protective work clothing where necessary.

3.0 ECOLOGICAL RESPONSIBILITY / ENVIRONMENTAL PROTECTION

The protection and preservation of natural resources concerns and obligates us all. With this in mind, we conduct our business activities with due regard for ecological aspects and are committed to the goal of a global climate-neutral future.

We expect our suppliers to comply with all applicable environmental laws, regulations and standards and to implement an effective system to identify and eliminate potential environmental hazards.

If this is incomplete or has gaps at the start of business, our suppliers undertake to ensure that gaps are closed and remedial action is taken, to the extent that this is legally possible in the countries of production. We plan, promote and control the continuous improvement process.

This applies in particular to :

* professional and responsible handling of hazardous substances and other chemicals as well as waste, including disposal;

* efforts to reduce or avoid waste and minimize emissions/pollutants from operations (e.g. wastewater, exhaust air, noise, greenhouse gases), as well as from traffic and transportation to factories.

* responsible and economical use of water

* conservation of natural resources, for example through measures to save water, chemicals and other raw materials;

* Promoting the use of climate and other environmentally friendly technologies, processes, raw materials and products;

* Efforts to increase energy efficiency and the share of green or renewable energies in energy consumption at our company sites.

3.1. ANIMAL AND SPECIES PROTECTION

We observe the principles for the protection of animals and biodiversity and align our corporate actions accordingly.

The keeping and use of animals must comply with the applicable legal animal welfare requirements and be appropriate to the species. The Washington Convention on International Trade in Endangered Species 11 must be observed.

We explicitly oblige our suppliers to comply with animal protection laws and not to torture or injure animals, to let them suffer in unacceptable animal transports and to keep them in non-species-appropriate conditions or to otherwise abuse them.

4.0 ETHICS ECONOMY AND INTEGRITY/ COMPETITION AND TRADE

We pursue only legitimate business goals and practices and maintain business relationships only with reputable partners.

We behave fairly and appreciatively toward our business partners and customers. We respect the different legal, economic, social and cultural backgrounds and conditions of the countries and regions in which we operate. We always base our business activities on generally accepted ethical values and principles, including integrity and respect for human dignity.

We support free and fair global trade and comply with the laws and regulations of the countries and regions in which we do business.

We expect our suppliers to do the same and to comply with applicable competition and antitrust laws.

4.1. CONSUMER INTERESTS

Insofar as our products and services affect the interests of consumers, we have taken appropriate measures to ensure the safety and quality of the products or services we offer. In doing so, we ensure that our products or services comply with the relevant statutory consumer protection provisions.

We take consumer interests into account in our information and sales activities by applying fair business, marketing and advertising practices and promoting consumer education. We pay particular attention to the interests of children, senior citizens, people with disabilities and other vulnerable consumer groups.

4.2. CORRUPTION/TRADE CONTROL/MONEY LAUNDERING

We reject any form of bribery and corruption and already avoid any appearance thereof, such as in the form of granting or accepting unfair advantages.

We act in accordance with applicable import and export control regulations and comply with legal requirements for the prevention of money laundering. In return, we expect our suppliers to also comply with the law.

4.3 COMPETITION

We advocate free and fair competition. We do not tolerate any anti-competitive agreements and ensure that we act in accordance with applicable antitrust laws. We reject competitive advantages through unfair business practices. Conflicts of interest shall be avoided if they are detrimental to the business relationship and the worker environment and impair objectivity.

Supplier shall comply with all applicable export controls, sanctions and customs laws and regulations, including prohibitions and restrictions („Trade Laws“). In particular, Supplier shall ensure that Supplier itself, its beneficial owner(s), any of its agents and any other subcontractors used by Supplier are not included on any applicable sanctions list as a „Denied Party“.

4.4. PROTECTION OF INFORMATION AND INTELLECTUAL PROPERTY

We respect the personal rights of our employees, business partners and customers and comply with the applicable legal and regulatory requirements for the processing of personal data and for information security when handling personal information.

We take great care to ensure that the business secrets and other confidential information of our business partners and customers entrusted to us are adequately protected against unauthorized acquisition, use and disclosure, at least in accordance with the relevant legal provisions on the protection of business secrets.

We are committed to information security with regard to data (according to DSGVO) including personal data.

5.0 IMPLEMENTATION

We respect the intellectual property of our business partners, customers and other third parties and ensure that sufficient precautions are taken to protect intellectual property rights when transferring know-how and technologies. We place the same requirements on our suppliers.

We make suitable and reasonable efforts to ensure that the contents of the Code of Conduct are continuously complied with at all our company sites. We have established suitable measures and processes for this purpose and document their implementation within the company in an appropriate manner. The management keeps itself informed at regular intervals about the implementation and work of the responsible departments and persons.

As a matter of principle, we rely on long-term business relationships based on partnership. We therefore identify and check our contractual partners in an appropriate manner before entering into a supply relationship, e.g. by means of self-disclosure, supplier evaluation or similar.

We reserve the right to monitor our supply partners‘ compliance with our expectations, e.g. by means of auditing.

If serious violations are identified, we reserve the right to appropriate contractual consequences, including termination of the business relationship. In any case, we expect that identified violations will be responded to with appropriate preventive or remedial measures and will ourselves react immediately if we receive a complaint.

5.1 TRAININGS

We communicate the contents of the Code of Conduct to our employees, business partners and other key stakeholders and train our employees on individual topics of the Code of Conduct as required. We expect our employees to comply with the Code of Conduct. We provide assistance to our suppliers for the implementation of certifications and communicate the necessities. We expect our suppliers to also participate in continuous training. We have installed suitable measures for this purpose.

5.2. EXPECTATIONS/MEASUREMENTS/CONTROLS

The contents of the Code of Conduct also reflect our expectations of our supply partners and other contractual partners in our supply chains. In this respect, we expect them to orient themselves to the contents of the Code of Conduct or to apply a comparable code of conduct and encourage them to demand this expectation from the contractual partners in their supply chain.

5.3 DISCLAIM

We take any violation of the Code of Conduct very seriously.

In the event of reports of violations, we initiate measures to clarify the matter in an orderly and confidential manner and, if necessary, take appropriate countermeasures in the sense of remedial action or prevention.

We encourage anyone who identifies violations of the provisions of this Code of Conduct to report them to us. We also encourage workers in factories to write to us and tell us about their problems. Mail: complaint@mba-solutions.de

5.4 GOAL: CONTINUOUS IMPROVEMENT

We encourage suppliers to submit innovative ideas that contribute to further social, economic or environmental improvements. We promote open, transparent exchange with our customers, employees, suppliers and all stakeholders on a partnership basis.

 

Troisdorf, March 24, 2023 Management Board/ Jochen Pütz-Kurth