No explicit enforcement of compliance with laws and policies

Pg. 2

"Our commitment to avoid human trafficking and forced labor in our supply chain is underpinned in our Code of Conduct for Business Partners."

"The Code of Conduct expressly prohibits the use of forced, bonded, indentured and prison labor, as well as the slavery or trafficking of persons in any form. Supply chain job seekers shall not be compelled to work through force, deception, intimidation, or coercion. All work shall be voluntary, and workers shall be free to terminate their employment upon reasonable notice without penalty. Additionally, holding, confiscating or destroying original worker identification documents, passports, travel papers or other personal documents is prohibited."

"DEKRA checks take place on an unannounced basis approximately twice a year. These checks cover, among other topics, that no forced labour is taking place and that working hours do not exceed the legal regulations."

"At zLabels GmbH we have a robust Ethical Trading program in place. As part of our onboarding process, all new suppliers and factories must sign up to the Zalando Code of Conduct for Business Partners."

"For a new factory setup, if critical findings are observed, we do not begin the relationship without evidence that the existing findings have been remediated."

The statement does not mention indirect, tier 2 suppliers, nor subcontractors of any kind.