pg. 7

"Monitoring: Based on the risk analysis, partners are continuously monitored, with processes dependent on the business type. These include third party audits against standards such as SMETA (Sedex Members Ethical Trade Audit) and BSCI (Business Social Compliance Initiative) in our private labels, the Higg Brand & Retail Module for third party brand partners, and third-party audits against the Zalando Social Standards for many of our logistics providers."

pg. 8

"In our private labels we look to ensure that our sourcing partners comply with our Zalando group-wide Code of Conduct and treat workers with dignity. Our Program includes the following:

1. All Tier 1 factories must provide us with social audits on a yearly basis, which are evaluated according to our internal non-compliance matrix, based on our Code of Conduct, local legal requirements, and industry standards including SMETA and BSCI. Findings of non-compliance are classified as minor, major, or critical (zero-tolerance), from which the factory is issued an overall rating and, if necessary, a Corrective Action Plan (CAP).

2. As part of the onboarding process, new suppliers must agree to our Code of Conduct and provide a factory audit report conducted within the last twelve months. If any critical issues are observed, the supplier must provide evidence of correction, such as a new third-party, on-site audit, before we begin the business relationship. In the past year, we declined to onboard 5 factories or suppliers due to non-compliance.

3. We require existing factories to provide us with new audits every twelve months to ensure we have visibility on current factory conditions. In 2020, we evaluated 229 audit reports for new and existing factories. If a critical non-compliance issue is found at an existing factory, the factory must remediate the issue and provide a new audit within seven months. To continue our business relationship, we require our sourcing partners to demonstrate improvement."