The Code of Conduct of MBA-Solutions GmbH is an important document for all partners and suppliers of MBA-Solutions. It stipulates that all parties involved in their global supply chains must protect human rights and the environment in accordance with internationally recognised standards. The aim of this document is to promote responsible business practices and to prevent or minimise negative impacts on human rights and the environment in supply chains.

MBA Solutions and its partners, including suppliers, intermediaries and HR departments, are required to sign the Code of Conduct. Both the German and English versions of this document are legally binding and apply immediately. You are also bound by the terms and conditions of purchase, which are sent with every order. When a supplier accepts an order, he also accepts the MBA Solutions Code of Conduct.

It is the responsibility of the signatories to integrate the Code of Conduct into their business practices and to ensure that it is adhered to.

The Code of Conduct defines minimum standards for ethical and responsible behaviour by MBA Solutions' business partners. National and international laws form the basis for this. The Code of Conduct is essential for direct and indirect business relationships.

We consider pregnant women, people with a migration background and people with disabilities, among other groups, to be particularly vulnerable. Our suppliers are obliged to publish their policies in relation to these groups. On the other hand, child labour is strictly prohibited in our supply chain, to which suppliers must commit.

We expect our suppliers to comply with all applicable environmental laws, regulations and standards and to implement an effective system to identify and eliminate potential environmental hazards.

If this is still incomplete or has gaps at the start of business, our suppliers undertake to ensure that gaps are closed and remedial action is taken, insofar as the legal possibilities in the production countries allow. We plan, promote and monitor the continuous improvement process.

This applies in particular to:

- We prohibit the use of ZDHC MRSL chemicals above the tolerance level throughout the supply chain. This means that these chemicals may not be used in our production, regardless of the testing of the end product. The current list of MRSL chemicals is always applied.

- Proper and responsible handling of hazardous substances and other chemicals and waste, including disposal;

- Efforts to reduce or avoid waste and minimise emissions/pollutants from operations (e.g. waste water, exhaust air, noise, greenhouse gases), but also from traffic and means of transport to the factories.

- Responsible and economical use of water

- Conservation of natural resources, for example through measures to save water, chemicals and other raw materials;

- Promoting the use of circular and other climate and environmentally friendly technologies, processes, raw materials and products;

- endeavours to increase energy efficiency and the proportion of green or renewable energies in energy consumption at our company locations.

MBA Solutions may request verification documents that demonstrate compliance with national and international legislation. In addition, environmental activities must be discussed and it must be demonstrated that appropriate measures are in place to prevent, mitigate and remedy negative impacts.

Comprehensive chemical management must be implemented especially in wet production facilities and can be verified by OEKO-TEX® STeP.

No child labour, protection of young workers

Suppliers undertake

- Not employ, directly or indirectly, children under the minimum legal age for completion of compulsory education, which shall not be less than 15 years, unless the exceptions recognised by the ILO apply.

- Children must be protected from all forms of exploitation.

- Adolescents shall not work at night and shall be protected from working conditions that are detrimental to their health, safety, morals and development, without prejudice to the specific expectations set out in this principle

Suppliers shall:

- Not engage in, or be complicit through business partners in, any form of slavery, forced labour, bonded labour, indentured labour, human trafficking or involuntary labour, including state-imposed forced labour

- Adhere to international principles of responsible recruitment, including the "employer pays" principle, and require their recruitment partners to do the same when directly or indirectly hiring all workers, especially members of vulnerable groups such as temporary and migrant workers. At a minimum, this includes: workers are not charged recruitment fees and costs, clear and transparent employment contracts, freedom of workers from deception and coercion, freedom of movement and no retention of identity documents, access to free, comprehensive and accurate information, freedom to terminate the contract, change employers and return safely, access to free dispute resolution and effective remedies.

- progressively compensate workers for the harm they have suffered within a reasonable timeframe and within the framework of the same international principles when historical or actual non-compliance with the principles is established.

Suppliers shall respect the right of workers to organise and bargain collectively, without distinction as to gender. They must ensure that all workers are adequately represented, regardless of gender, and that there is no discrimination based on union membership. Furthermore, they must not prevent employee representatives and recruitment agencies from accessing the workplace. Even in countries where trade union activities are restricted, they must respect the principle of free choice of representatives, without discrimination, violence or harassment. It is important to take care of vulnerable groups, including pregnant women, migrants, minorities and people with disabilities, and to respect their rights. MBA-Solutions promotes an inclusive working environment and condemns any form of discrimination in employment based on characteristics such as origin, health, disability, gender, sexual orientation, age, political opinion, religion or belief.

Suppliers undertake to

- ensure that workers are not required to work more than 48 standard hours per week, without prejudice to the specific expectations set out below. recognise exceptions specified by the ILO

- interpret applicable national legislation, industry benchmark standards or collective labour agreements within the international framework set by the ILO and promote working time practices that allow workers a healthy work-life balance

- only exceed the number of hours described above in the exceptional cases defined by the ILO, in which case overtime is permitted

- that overtime is only worked in exceptional cases and on a voluntary basis and is remunerated with a supplement of at least 125% of the standard rate. Overtime must not lead to a significantly higher probability of work-related risks and must not exceed the limits set out in national legislation. We recommend a maximum of 12 hours per week, no more than two hours per day. However, regional laws take precedence

- grant their employees the right to rest breaks every working day and the right to at least one day off in seven days, unless exceptions are stipulated in collective agreements. Occupational health and safety (OHS)

Suppliers agree to:

- Comply with at least the wages required by state minimum wage laws or industry standards approved based on collective bargaining (whichever is higher). Wages relate to standard working hours

- Wages and salaries are paid regularly, punctually, in equal amounts and in full in legal currency. Partial payment in the form of benefits in kind is only accepted in accordance with ILO guidelines

- the wage gap is accurately assessed and progressively worked towards the payment of a living wage that provides an adequate standard of living for workers and their families. (Wage gap analysis was prepared and continuously updated by MBA Solutions).

- the skills, responsibilities, seniority and education of workers are reflected in their wage levels

-when a wage rate is set for production, quota or piecework, workers are enabled to earn at least a wage that meets or exceeds applicable legal minimum wages, industry standards or collective bargaining (where applicable) within normal working hours

- ensuring that workers from all genders and categories, such as migrant and local workers, receive equal pay for equal jobs and skills

- deductions are only made under the conditions and to the extent stipulated by law or collective agreement

- employees receive the social benefits granted by law, e.g. without any negative impact on their salary, seniority level, position or promotion prospects. Reasonable working hours

Suppliers are required to submit payrolls on request in order to carry out a GAP analysis. This serves to find out to what extent suppliers are already paying living wages. MBA Solutions is working towards implementing living wages in the supply chain.

Suppliers are committed:

We comply with national and international occupational health and safety standards and ensure a safe and healthy working environment to promote health and safety.

working environment in order to maintain the health and safety of our employees, protect third parties and prevent accidents, injuries and work-related illnesses.

In close communication with our suppliers, they ensure the implementation of occupational health and safety by applying a health and safety management approach appropriate to their company with the aim of preventing accidents and maintaining the health of workers. This includes protective equipment on the machines, protective clothing where necessary.

Suppliers commit to:

- ensure that their recruitment process and employment relationships do not create insecurity and social or economic vulnerability for their workers

- ensure that work is carried out on the basis of a recognised and documented employment relationship established in accordance with relevant national laws, customs or practices and international labour standards, whichever is the higher protection.

- provide workers with understandable information in their own language prior to commencing employment and ensure that they are aware of their rights, obligations and working conditions, including working hours, remuneration and payment terms, in their own language

- Provide decent and, where appropriate, flexible working conditions that also support workers, regardless of their gender, in their role as parents or carers, including migrant and seasonal workers whose children may be left behind in their hometowns.

- Not to exploit employment relationships in a way that is wilfully inconsistent with the purpose of the Act. This includes, in particular, apprenticeship or training programmes where there is no intention to teach skills or create a regular employment relationship, seasonal or contingent work where it serves to undermine worker protection, labour-only contracts and the substitution of contracts.

- Not to use subcontracting in a way that undermines workers' rights. No debt bondage, forced labour or human trafficking.

Suppliers undertake:

- Not to engage in corruption, extortion or embezzlement or any form of bribery - in particular the promise, offer, giving or acceptance of any improper financial or other inducement,

- develop and implement appropriate internal controls, programmes or measures to prevent and detect corruption, extortion, embezzlement or any form of bribery, based on a company-specific risk assessment

- keep information about its activities, structure and performance up to date and accurate and disclose it in accordance with applicable regulations and industry benchmark practices to improve the transparency of its activities

- not to falsify information or participate in the falsification of information or misrepresentation in the supply chain

- communicate awareness of the policies, controls, programmes and measures against unethical behaviour to employees and promote compliance within the company through training and communication

- collect, use and otherwise process personal data (including that of employees, business partners, customers and consumers within its sphere of influence) with reasonable care. The collection, use and other processing of personal data must comply with privacy and information security laws and regulatory requirements. Integration and implementation conditions

Respect, dignity, human rights

Suppliers commit to:

- treat all workers and employees with respect and dignity

- ensure that workers are not subjected to any form of violence, harassment, inhuman or degrading treatment in the workplace, threats of violence and abuse, including corporal punishment, verbal, physical, sexual, economic or psychological abuse, mental or physical coercion or other forms of harassment or intimidation.

- Understand the possible grounds for discrimination in their specific context and not discriminate against or exclude individuals on the basis of gender, age, religion, ancestry, birth, social background, disability, ethnic and national origin, nationality, membership of trade unions or other legitimate organisations, political affiliation or opinion, sexual orientation, family responsibilities, marital status, pregnancy, illness or other conditions that could lead to discrimination.

- Establish disciplinary measures in writing and explain them verbally to employees in terms and language they understand. The disciplinary measures must be in accordance with national laws

- ensure gender-sensitive equal opportunities and equal treatment in recruitment and employment

- verify that employees are not harassed, disciplined or penalised for reporting problems on any of the above grounds. Appropriate remuneration

The values and principles set out in this document shall be implemented throughout the life cycle of their business relationships and in close co-operation with the relevant stakeholders:

- Before entering into a business relationship, to identify and understand potential and actual rights for human rights.

- during a business relationship to conduct responsible business and to coach and support their business partners in continuous improvement.

- at the end of a business relationship to ensure a responsible transition for the business partner. Information management

- The undersigned shall maintain the required documents, such as those on the Amfori platform, with up-to-date and accurate information and instruct their employees and representatives to use this information in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation), also referred to as the EU GDPR.

- The undersigned understand that all personal data collected, used and otherwise processed within the Amfori tools and platforms or any other participating platform must comply with the EU GDPR, regardless of the geographic location where the data is collected.

- The undersigned agree that the information collected in the context of a monitoring activity, including a complaint mechanism, may be shared with third parties, provided that this is done within the legal framework, within the framework of the Amfori platform used or within the framework of another testing institute, insofar as such sharing is necessary for the provision of services by or on behalf of the same-related activities, and/or the third parties undertake to treat the information provided with the utmost respect and for the sole purpose relevant in this case. Monitoring in the supply chain

- Business partners ensure through monitoring that the MBA-Solutions Code of Conduct is observed internally and by their upstream business partners involved in the production process on the basis of continuous improvement.

- MBA-Solutions is an Amfori member, as are many of our producers and their suppliers. The business partners recognise that Amfori members may decide to include them in the monitoring activities. They agree to be audited by Amfori or by Amfori qualified third parties (e.g. audit companies, quality partners) on and off site, announced or unannounced. These activities can be carried out as part of the Amfori Monitoring Tools or the Amfori Audit Quality Programme.

As part of a monitoring activity, Business Partners agree to

Provide unrestricted access to facilities as requested by the individuals conducting the activity, including parts not originally identified in the scope of the activity, provide access to personal data about their employees and allow the individuals to collect relevant data for reporting purposes, as long as this is in accordance with national legislation and the EU GDPR, allow the individuals to collect the necessary supporting documents for the activity, in particular business documents, licences, certifications and images, allow the individuals to conduct interviews with workers on and off site while maintaining confidentiality and without interference or retaliation from management.

Requirement to subcontract:

We, MBA-Solutions, do not allow subcontracting in our supply chain as it is difficult to monitor other companies with whom we do not have a direct contract. In such cases, due diligence and human rights are often violated. Of course, Tier 2 or Tier 3 suppliers are not counted as subcontractors, but as supply chain processes.

Continuous improvement: Signatories commit to implement the MBA Solutions Code of Conduct in a holistic approach embedded in their management systems and corporate culture to ensure continuous improvement of due diligence within their organisations and supply chains on a step-by-step basis.

Collaboration: Signatories will have a greater impact on human rights and environmental impacts in their organisations and supply chains and a better chance of identifying, preventing, mitigating and remediating such impacts by working together and taking a holistic approach to due diligence. A willingness to co-operate is crucial for engagement between signatories and stakeholders at different levels, especially to achieve leverage.

MBA Solutions will support by creating relevant, meaningful and long-term partnerships.

- Compliance with the Code: Compliance with national and international legislation is the first obligation of companies. In countries where national legislation provides a different standard of protection than the MBA-Solutions Code of Conduct, signatories will adhere to the principles that provide the highest level of protection for workers and the environment without contradicting the legal framework of the country.

- Transparency: Suppliers undertake to be transparent:

With each other, with MBA Solutions and, where applicable, with third parties involved (e.g. auditors, quality partners) and in the context of identifying, preventing and remediating adverse impacts on human rights and the environment. Signatories shall inform each other and actively inform MBA-Solutions about any critical incident and the effectiveness of actions taken in case of negative impacts on the values and principles of the MBA-Solutions Code of Conduct, (through appropriate disclosure of impacts on the supply chain and surrounding communities to shareholders, stakeholders and governments, where applicable in accordance with national legislation.

They are also consistent with our Complaint mechanism, which can be found at the link:

Complaint Mechanism at MBA Solutions GmbH

Explanatory principles: Social management system and cascade effect

- to adopt and publicly announce a written declaration on the principle of human rights. The written acceptance of an order is linked to the Code of Conduct.

- It is important to have a process- and risk-based due diligence system for business practices in production operations and at suppliers' subcontractors that is in line with the UNGPs and adapted to the company's business model. The expectations set out in this Code of Conduct should be embedded in the system.

- The endorsement of the MBA Solutions Code of Conduct by all functions at our MBA Solutions suppliers and subcontractors, as well as all your other business partners and relevant stakeholders (suppliers, raw material producers down to the cotton field and recycled material suppliers) is very important and must also be actively communicated by them.

- All relevant departments and individuals, including suppliers, subcontractors, employees in MBA Solutions and our customers, must be trained and motivated to integrate the principles of responsible and gender-equitable business and purchasing practices into the corporate culture and pass them on to their business partners. Business partners are encouraged to share the information with relevant business partners and stakeholders in the supply chain

- We require ALL of our business partners to fully comply with the MBA Solutions Code of Conduct within their sphere of influence, with the request and demand that they, including intermediaries (agencies), work towards its implementation.

- All workers in the MBA Solutions due diligence chain need to be engaged, especially the vulnerable parts of their supply chain such as homeworkers, casual labour, smallholders and temporary and migrant workers.

The challenges at these levels must be identified and work with MBA Solutions and other relevant stakeholders to achieve improvements

- It is important that everyone has sufficient corporate strategy, processes and resources (including MBA Solutions) to fulfil the responsibilities related to the MBA Solutions Code of Conduct and ensure continuous improvement in its implementation,

- Apply responsible and gender-sensitive purchasing practices. Avoid placing business partners in a position that prevents them from abusing the MBA Solutions Code of Conduct or from being able to implement it. Employee participation and protection is paramount.

- Establish responsible and gender-sensitive management practices that involve all workers and their representatives in an informed exchange of information through the due diligence process.

- Long-term goals to protect workers in accordance with the requirements of the MBA Solutions Code of Conduct must be defined.

- Specific measures, such as training, must be taken to educate workers and employees and others involved in the process so that they are sensitised to exercise their rights. Particularly vulnerable persons must be taken into account.

Where appropriate, intermediaries (e.g. agencies or workers' organisations) should play an active role in implementing these steps.

- Sufficient competences among managers, employees and employee representatives in all companies involved in the process as well as in the entire supply chain must be built up and further developed.

In order to embed the MBA Solutions Code of Conduct in the corporate culture of all those involved in the process and to promote continuous education and training at every level of the organisation, certain mechanisms must be introduced:

- effective grievance mechanisms at the operational level for individuals and communities who may be adversely affected.

- Accurate records must be kept.

- The operational level grievance mechanism must be in line with Article 31 of the UNGP. Where relevant (e.g. migrant workers, suppliers), the operational level grievance mechanism should be accessible in local languages and enable issues to be effectively addressed and resolved through partnerships and coordination across jurisdictions. Freedom of association and the right to collective bargaining.

We work exclusively with certified factories. We favour OEKO-TEX® MADE IN GREEN (OEKO-TEX® STANDARD 100 and OEKO-TEX® STeP), we want BSCI certificates (we are an amfori member ourselves), but we also accept SMETA. We also work with GOTS and GRS. There is a supplier certificate list that is regularly updated in order to request upgrades in good time.

We would like to point out that the Code of Conduct is part of our order system and automatically comes into force when an order is accepted, even without signing when an individual order is placed.

This also applies to all suppliers in the supply chain that affect our products and services to be manufactured.