CALIDA : Code of Conduct

Code of Conduct

CALIDA GROUP

December 5th, 2018

CALIDA GROUP Code of Conduct

1

Table of Contents
Contents ............................................................................................................................................................................................	2
1.	Introduction ...........................................................................................................................................................................	3
2.	Human rights.........................................................................................................................................................................	5
3.	Human Capital ......................................................................................................................................................................	8
4.	Environment, health and safety issues ........................................................................................................................	9
5.	Business ethics ...................................................................................................................................................................	11
6.	Data privacy ........................................................................................................................................................................	14
7.	Stakeholder and community engagement.............................................................................................................	15
8.	Governance of the Code of Conduct ........................................................................................................................	16

CALIDA GROUP Code of Conduct

2

1. Introduction

Preamble

The CALIDA GROUP is a global player specializing in clothing with its brands CALIDA, AUBADE, MILLET, EIDER, LAFUMA Outdoor, LAFUMA MOBILIER and OXBOW. CALIDA GROUP believes in and is committed to a behavior that supports and foster sustainability, in all areas of our business. The CALIDA GROUP has a responsibility to the people and communities in the areas where we operate. People whose work contributes to the success of our company should not be deprived of their basic human rights or be forced to suffer physically or mentally from their work. CALIDA GROUP and its employees and partners have the duty to ensure that all business is conducted with integrity and with fair and ethical conduct. The purpose of this our CALIDA GROUP Code of Conduct is to outline our expectations and commitments in relation to all these topics.

For whom is the Code of Conduct

Our Code of Conduct will be distributed to, and complied with, by all employees.

Our Code of Conduct applies also to all partners, specifically suppliers both under a direct contract and further upstream.

Commitments

CALIDA GROUP is committed to and supports the:

• UN Universal Declaration of Human Rights and connected UN Conventions.
• ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy.

This Code of Conduct is further based on:

• Modern slavery acts (UK, Australia)
• ILO core conventions. These are:

1. No. 87: Freedom of Association and Protection of the Right to Organize Convention,

1948

1. No. 98: Right to Organize and Collective Bargaining Convention, 1949 o No. 29: Forced Labour Convention, 1930
   o No. 105: Abolition of Forced Labour Convention, 1957
   o No. 138: Minimum Age Convention, 1973
   o No. 182: Worst Forms of Child Labour Convention, 2000
   o No. 111: Discrimination Employment and Occupation Convention, 1958
   o No. 100: Equal Remuneration Convention, 1951

CALIDA GROUP Code of Conduct

3

Legal compliance

This document does not replace national legislation. The overall obligation is to comply with all laws and regulations.

If any of the content herein is in conflict with local legislation, then local legislation will supersede. Situations may occur for which there are no specific guidelines. In such cases behavior in the spirit of the Code should be maintained.

Guidance and whistleblowing

In case of uncertainty, concern, complaint, or a report of violation, an employee's immediate manager, the person nominated for the local mechanism for referral, or if there is no such local function, the nominated person for the Code of Conduct at CALIDA GROUP headquarters should be contacted. As much as possible, an employee's information will be treated confidentially, and no employee will be discriminated against for reporting in good faith, violations of the policy.

Implementation

The business functions within CALIDA GROUP is responsible for the implementation in their respective business function.

Monitoring and review

CALIDA GROUP will follow up and monitor the implementation of the Code of Conduct. Any inconsistencies or nonconformances will be handled immediately. The Code of Conduct and the implementation measures will be reviewed and updated periodically. The results of the review will be communicated internally and publicly.

CALIDA GROUP Code of Conduct

4

2. Human rights

CALIDA GROUP is committed to combatting modern slavery and upholding human rights in its own operations and in its supply chain and to follow all international, applicable standards.

CALIDA GROUP conducts risk assessments in order to identify and manage modern slavery and human rights risks in the supply chain and adopts the necessary programs to manage human rights risks. Reporting on human rights impacts takes place regularly in the annual sustainability reports of the CALIDA GROUP divisions.

CALIDA GROUP expects of all business partners that they adhere and implement this Code of Conduct in their own businesses.

In all cases of non-compliance with this Code of Conduct, CALIDA GROUP will act and seek to remediate the situation.

Child labor

CALIDA GROUP recognizes the rights of every child to be protected from economic exploitation and from doing work that is likely to be hazardous to the child's physical, mental or spiritual health, harmful to their moral or social development, or interfere with their education.

A child in this context is a person younger than 16 years of age. Some countries apply the definition of "young workers" to persons above the minimum age, but below a specified age, which means that there might be legal restrictions regarding the type of activities that they are allowed to perform. In any case should young workers be especially protected from hazardous operations or excessive work hours or any other situation that might harm their wellbeing or development.

Children under the age of 16 must not be employed. An exception is persons employed as trainees once they have completed their compulsory school education. Holiday jobs for children and youth who have not reached the minimum age of employment must be remunerated and such remuneration is to be paid specifically for this purpose.

Forced or bonded labor

CALIDA GROUP does not employ nor accept any form of forced or bonded labor, prisoners or illegal workers.

CALIDA GROUP Code of Conduct

5