pg. 6

"4.2 Policies

As reported in our 2020 statement, our expectations towards all our employees and business partners are set forth in our policies which highlight, among others, the imperative respect for human rights in all our business activities. The Compliance and Sustainability teams review and update these policies on a regular basis.

● Zalando’s Code of Ethics sets out Zalando’s specific expectations towards every employee regarding social and ethical behavior. The Code of Ethics has been communicated to our employees in various languages and is publicly available on our website. We revised our Code of Ethics in 2020 to further stress topics such as anti-discrimination and anti-harassment, and to communicate our grievance channels more prominently.

● Our commitment to avoid human trafficking and forced labor in our supply chain is underpinned in our Code of Conduct for Business Partners. It was established in 2013 and last reviewed in 2017. The next review will take place in 2021. It is issued by ZALANDO SE Management Board and applies group-wide to our 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."