pg. 5

"Steps planned for 2020

Our progress

In 2020, we conducted a detailed human rights gap assessment across the entire Zalando business with a human rights risk consultancy.

We developed roadmaps based on a human rights due diligence cycle for the entire business and corresponding plans for implementation in the supply chain. We also launched a risk assessment pilot to assess the human rights risk profile of suppliers."

...

"Third-party brands

Launch of brand assessment tool to first phase of brands

Pilot with selected brands to identify specific needs when it comes to assessment

Continue close partnership with SAC and Higg Co to ensure robustness of assessment tool and data tracking

In 2020, we rolled-out a mandatory sustainability assessment on the basis of the Sustainable Apparel Coalition’s (SAC) Higg Brand & Retail Module (BRM). Brand partners have to complete the sustainability self-assessment on a yearly basis, in addition to agreeing to our Code of Conduct and Ethical Sourcing Standards."

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."