MBA-Solutions GmbH is a German service provider in the field of merchandise products, based in Troisdorf.

We aim not only to provide our customers with good service and quality, but also to make a valuable contribution to the sustainable development of the countries and regions in which we operate.

We are committed to our social responsibility and corporate due diligence, regardless of whether we operate economically in Germany, Europe, or other parts of the world.

The Policy Statement reflects the common understanding of socially responsible corporate action in the German textile and fashion industry. It also serves as a framework for companies to individually align their decisions and measures, and takes into account the concerns of small and medium-sized suppliers and their challenges in an increasingly global and networked economy.

We act in accordance with universally recognized values and principles such as integrity and legality, and particularly observe internationally recognized human rights and labor standards, as set out in our Policy Statement.

We are committed to our due diligence.

We share the goals and content of the Policy Statement and will, within the scope of our respective legal and actual possibilities, make all suitable and reasonable efforts to continuously comply with this voluntary commitment at all our company locations, both domestically and abroad.

If existing national regulations conflict with the content of the Policy Statement or if the domestic context makes it impossible to fully comply with them, we will seek ways to uphold the requirements of the Policy Statement as much as possible.

We respect human dignity and observe internationally recognized human rights, with reference to:

In all our business activities, we always strive neither to cause nor contribute to human rights violations. We expect the same from our business partners. Where necessary and possible, we support our production partners in this regard.

We treat our employees and suppliers with appreciation; this particularly includes the workers, without whose help we could not produce any products and who are significantly involved in our success.

We are committed to our due diligence and expect the same from our suppliers. The goal is to strengthen the rights of those affected.

MBA-Solutions avoids working with companies that are not certified.

To identify adverse impacts on human rights, labor conditions, and the environment, we maintain open, transparent communication with customers, employees, and suppliers, and provide assistance wherever possible. In return, we expect transparent information from our suppliers and a serious effort to jointly resolve problems and improve situations.

In connection with due diligence, we constantly strive to improve purchasing practices. This means: agreements with customers for longer lead times, less price pressure, less pressure on producers, and thus influencing a reduction of overtime in the supply chain. We are always aware of the problems that arise in the supply chain when deadlines are shifted, too many changes occur, and extreme pressure is built up.

Further documents:

We require our suppliers and their suppliers to comply with and enforce human rights WITHOUT restrictions. Any violation can lead to the termination of the business relationship. The Code of Conduct is another document that supplements our Policy Statement and is an integral part of our supplier contract. This applies to every order without being sent with every order process. By confirming the order, the supplier individually confirms acceptance of the Code of Conduct, regardless of a general acknowledgment signature.

We oblige our suppliers to demand and comply with this from all sub-supplier companies. Corresponding certification documents must be submitted.

We conduct risk analyses regarding the social and environmental requirements of our company, which refer to various frameworks already mentioned. Our risk analysis focuses exclusively on risks that may arise in our supply chain and identifies suitable risk management measures.

In this context, however, we also record external problems that occur worldwide and are not only related to our own supply chain. We do not tolerate such problems within our supply chain. Any discovery of a legitimate complaint or incident in this regard will ultimately lead to the termination of the business relationship if the supplier does not take immediate remedial action, as we pursue a zero-tolerance policy in this area. We have identified such most serious problems as follows:

In the case of child labor, the problem should be identified and differentiated at the national level to take targeted measures. This includes cooperation with non-governmental organizations such as UNICEF and SOS Children's Villages to get children off the streets and out of factories and to promote educational projects. The replacement of children by adults in factories and the strengthening of children's and human rights through training are also planned. In the event of serious environmental problems and non-compliance with sustainability standards, a thorough examination of the problem is planned to take appropriate measures.

Based on our risk analysis, the high-priority risks are: A) political changes worldwide and an increase in disputes, B) price and time pressure from customers, C) high overtime. These risks are given special consideration in our purchasing decisions, supplier selection, supplier evaluation, training, and remedial measures.

Political conflicts worldwide extend the delivery process by weeks and double freight prices; in addition, there is a shortage of freight containers. Incalculable environmental risks such as earthquakes and floods also arise. Political and environmental disasters can ruin companies within a very short time.

As an SME, MBA-Solutions cannot exert real influence on the political situation and conflicts worldwide. However, we place our orders in such a way that political unrest has less impact. For comparatively short delivery times, we prefer orders from Turkey. For orders with long lead times, we generally place them in the Far East, of course taking into account due diligence, sustainability, and price.

Short lead times, price pressure, and poor forecasting with resulting order adjustments in design or delivery time lead to high overtime. Therefore, we ask our customers to grant us a reasonable lead time and to avoid orders with short lead times. We also ask our customers not to make changes in design or material after the production sample has been approved, to avoid excessive overtime. However, price is still an important factor in our business today. We offer a sustainable option with every normal offer. Our product and marketing managers constantly try to convince customers to buy certified products.

We do not tolerate child labor and observe the applicable statutory minimum age for admission to employment. In any case, we do not employ persons below the age at which compulsory schooling ends under the law of the place of employment, nor persons under 15 years of age.

We expect our contractual partners to have appropriate means of age verification to prevent child labor. Should child labor be identified, all necessary measures must be initiated immediately, focusing on the child's well-being, protection, and development.

For persons under 18 years of age, the rights of young workers must be observed; they may only be employed if it is ensured that the working and employment conditions do not pose a risk to their health, safety, or morality, nor are detrimental to their development.

We reject all forms of forced or compulsory labor, including any form of debt bondage, serfdom, slavery or slave-like practices, human trafficking, or other involuntary labor and services that are incompatible with internationally recognized labor and social standards, and expect the same from our contractual partners.

Our suppliers ensure that no involuntary labor, forced labor, or any form of slavery occurs, including in lower supply chains. All forms of work must be voluntary.

Our suppliers ensure that employees do not have to hand over personal documents (e.g., passports) or deposit any employment fees to get the job. All employees receive an introduction to the policies and related rights and obligations. Any form of punishment, psychological and/or physical, as well as other forms of human trafficking, are prohibited and must be reported immediately if they become known (see complaint management portal on our website).

We promote a work environment that enables inclusion and values the diversity of our employees. We are committed to equal opportunities and reject any form of discrimination or unjustified unequal treatment in employment, for example, due to national and ethnic origin, social background, health status, disability, sexual orientation, age, gender, political opinion, religion, or worldview.

We adhere to the statutory or applicable collective bargaining provisions on working hours, including overtime, rest breaks, and annual leave. In any case, we ensure that overtime is compensated or remunerated at least in accordance with statutory or collective bargaining regulations; its arrangement is exceptional and exclusively based on statutory, collective bargaining, or contractual grounds. We also expect this from our suppliers.

The supplier complies with all nationally applicable laws and binding industry standards on working hours, overtime, breaks, and paid annual leave:

In our risk analysis, we have identified overtime as a major risk in our supply chain and have taken remedial measures, such as no changes to design and material after the production sample has been approved, and a buffer time of 3 weeks to our production lead time.

We, MBA-Solutions, and our suppliers commit to complying with the following points:

We pay at least the legally mandated wages or industry-specific standards according to collective agreements, with the higher value applying. Wages are paid regularly, punctually, and in full in legal currency; in-kind benefits are only acceptable according to ILO guidelines. A living wage is strived for, enabling an adequate standard of living, based on a continuously updated wage gap analysis by MBA-Solutions. Wages should reflect the skills, responsibility, seniority, and training of employees. Employees should have the opportunity to earn an adequate wage within regular working hours. Equal pay for equal work applies regardless of gender and origin. Deductions are made only according to legal or collective bargaining requirements. Social benefits are granted without negative effects on salary, seniority, position, or promotion opportunities. Suppliers must provide wage lists upon request to conduct a gap analysis and promote the implementation of living wages in the supply chain.

MBA-Solutions GmbH attaches great importance to ensuring a living wage for all employees involved in its orders. For this purpose, we have conducted a thorough salary analysis and communicated with key suppliers to address discrepancies. Our "Vision 2030: Sustainability Program" requires key suppliers to increase salaries by at least 10% annually to reach the living wage standard by 2030. This is supported by cooperation with the Textile Alliance. Progress is reviewed every two years, and suppliers adhering to the program receive additional order volume as recognition.

Further documents:

We respect the right of employees to freedom of association and assembly, as well as the right to collective and wage bargaining, as far as this is legally permissible and possible in the respective country of employment. If this is not permissible, we seek appropriate compromises.

Our suppliers recognize these rights and promote the ability of workers to participate in elections for trade union representation without threat, as far as the political conditions of the country allow.

We observe national and international occupational health and safety standards and ensure a safe and health-promoting work environment to maintain the safety and health 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 an appropriate approach to health and safety management for their company with the aim of preventing accidents and maintaining the health of workers. This includes protective devices on machines and protective work clothing where necessary.

We attach importance to particularly vulnerable groups in our supply chain. Among other things, we consider the protection of pregnant women, people with a migration background, and people with disabilities. They must be protected from any kind of discriminatory treatment. We regularly visit our suppliers to check the status of implementation of our measures for these groups. We do not only rely on our strategies but also want to see our suppliers' strategies regarding these and other groups and urge or encourage them to change their strategies (if applicable).

The protection and preservation of natural livelihoods concerns and obliges us all. With this awareness, we conduct our business activities considering ecological aspects and commit ourselves to the goal of a worldwide climate-neutral future.

We expect our suppliers to comply with all applicable environmental laws, regulations, and standards and to implement an efficient system for identifying and eliminating 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 remedies are provided, provided that the legal possibilities in the production countries allow this. We plan, promote, and control the continuous improvement process.

This applies in particular to:

We are committed to improving the recyclability of the products we procure and continuously expanding the use of more sustainable materials in our production. We are specifically working to increase the proportion of sustainable materials such as organic cotton and recycled fibers, especially recycled polyester and recycled cotton, within our product portfolio.

Our goal was to switch at least 10% of our total production to sustainable materials by July 2026. To achieve this goal, MBA-Solutions works closely with its suppliers to analyze the availability of sustainable alternatives and identify suitable materials for our products.

Already in 2025, we were able to exceed this goal: The share of recycled materials was 6.8%, while organic cotton reached a share of 7.4%. In total, 14.2% of our total production thus consisted of more sustainable materials.

As part of our strategy to increase the share of sustainable materials in our supply chain, we offer our customers sustainable material alternatives whenever possible. Our product managers continuously encourage our customers to choose more sustainable options and support them in making responsible purchasing decisions.

We observe the principles for the protection of animals and biodiversity and align our business activities accordingly. The keeping and use of animals must comply with applicable animal welfare requirements and be appropriate for the species. The Washington Convention on International Trade in Endangered Species of Wild Fauna and Flora must be observed.

We explicitly oblige our suppliers to comply with animal welfare laws and not to torment or injure animals, not to subject them to unreasonable animal transports, not to keep them in inappropriate conditions, or otherwise abuse animals.

We pursue exclusively legitimate business goals and practices and maintain business relationships only with reputable partners.

We act fairly and respectfully towards our business partners and customers. We respect the different legal, economic, social, and cultural backgrounds and conditions of the countries and regions in which we operate. We always align our business activities with universally valid ethical values and principles, including integrity and respect for human dignity.

We advocate for free and fair global trade and adhere to the law and regulations of the countries and regions in which we operate. We expect the same from our suppliers and that they comply with applicable competition and antitrust laws.

Insofar as our products and services affect consumer interests, we have taken appropriate measures to ensure the safety and quality of the products or services we offer. We ensure that our products or services comply with the respective applicable consumer protection regulations.

In the context of information and sales measures, we consider consumer interests by applying fair business, marketing, and advertising practices and promoting consumer education. We pay special attention to the interests of children, seniors, people with disabilities, and other vulnerable consumer groups.

We 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. The agreement is currently being signed. Tier 2 or Tier 3 suppliers are naturally not considered subcontractors, but rather part of the supply chain processes.

We work exclusively with certified companies. We prefer OEKO-TEX® MADE IN GREEN, OEKO-TEX® STANDARD 100, and OEKO-TEX® STeP, desire BSCI certificates (we are an Amfori member ourselves), but also accept SMETA. We also work with GOTS and GRS. A supplier certificate list exists and is regularly updated to request upgrades in a timely manner.

We reject all forms of bribery and corruption and avoid even the appearance thereof, as is the case, for example, in the form of granting or accepting unfair advantages.

We act in accordance with applicable import and export control regulations and adhere to legal requirements for the prevention of money laundering. In return, we expect our suppliers to also comply with these laws.

We advocate for free and fair competition. We do not tolerate anti-competitive agreements and ensure that we act in accordance with applicable antitrust laws. We reject competitive advantages gained through unfair business practices. Conflicts of interest are to be avoided if they harm the business relationship and the working environment and impair objectivity.

The supplier complies with all applicable export controls, sanctions, and customs laws and regulations, including prohibitions and restrictions ("Trade Laws"). In particular, the supplier ensures that neither they, their beneficial owners, all their representatives, nor other subcontractors employed by them are listed as "Denied Parties" on any applicable sanctions lists.

We respect the personal rights of our employees, business partners, and customers and adhere to applicable legal and official requirements for the processing of personal data and information security when handling personal information.

We carefully ensure that business secrets and other confidential information of our business partners and customers entrusted to us are adequately protected against unauthorized acquisition, use, and disclosure, at least in accordance with the relevant legal provisions for the protection of business secrets.

We advocate for information security regarding data (according to GDPR) including personal data.

We respect the intellectual property of our business partners, customers, and other third parties and ensure that adequate precautions are taken to protect intellectual property rights during the transfer of know-how and technologies. We place the same requirements on our suppliers.

We undertake suitable and reasonable efforts to communicate and comply with the contents of the Policy Statement through the Code of Conduct at all our company locations. The Policy Statement refers to all processes and related documents.

The Code of Conduct, on the other hand, is our explicit instruction to the supplier and sub-supplier to comply with all requirements and to provide guidance for sub-suppliers. The producer is not allowed to subcontract orders to sub-suppliers. This supply chain with certificates must be proven to MBA-Solutions. For sub-suppliers (Tier 2, Tier 3 suppliers), compliance with the MBA-Solutions Code of Conduct also applies (this also includes agencies that communicate with production and are the interface between production and MBA-Solutions).

For this purpose, we have established appropriate measures and processes (evaluation of audit reports, identification of complaints to be remedied, definition of measures and request for remedy with proof).

Thus, by signing an order, we document the simultaneous recognition of the Code of Conduct by our suppliers and demand this measure from our suppliers for their sub-suppliers as well, as well as their internal implementation in an appropriate manner. The company management regularly informs itself about the implementation and work of the responsible departments and persons. The management reviews the progress of human rights and environmental due diligence processes at least once a year. In particular, the results of the risk analysis, supplier evaluations, audit reports, complaints, training, remedial measures, progress on living wages, and the proportion of sustainable materials are evaluated. Appropriate goals and KPIs are defined for the responsible functions and taken into account in the performance evaluation of at least one member of the management.

We fundamentally rely on long-term, cooperative business relationships. We therefore identify and review our contractual partners in an appropriate manner before entering into a supply relationship, e.g., through self-disclosure, supplier evaluation, or similar. The results of the risk analysis and prioritization are taken into account in relevant decision-making and strategy processes. This particularly concerns the procurement and purchasing strategy, the selection of new suppliers and production countries, the evaluation of existing suppliers, the decision on sustainable materials, scheduling, price negotiations, and the termination or continuation of business relationships. For new products, materials, or production countries, MBA-Solutions checks potential human rights and environmental risks in advance.

Further documents:

We reserve the right to control the compliance with our expectations towards our supplier partners, e.g., by means of auditing.

If serious violations are found, we reserve the right to take appropriate contractual consequences, including the termination of the business relationship (this will only be considered in extremely rare cases of serious violations). In any case, we expect that identified violations will be responded to with appropriate measures for prevention or remedy, and we ourselves react immediately if a complaint is received by us.

We communicate the content of the Policy Statement through the Code of Conduct to our employees, business partners, and other key stakeholders and train our employees on individual topics of the Policy Statement as needed. We expect our employees to comply with the content of the Policy Statement. We assist our suppliers in implementing certifications and convey the necessities. We expect our suppliers to also participate in continuous training.

MBA-Solutions annually determines the training needs of relevant employees, especially in the areas of purchasing, product management, design, sustainability, and management. The training needs are based on risk analysis, audit findings, complaints, regulatory developments, and practical challenges in the supply chain. Relevant employees are trained on industry-specific risks such as overtime, child labor, chemical management, living wages, vulnerable groups, and responsible purchasing practices.

The content of the Policy Statement also reflects our expectations of our supplier partners and other contractual partners in our supply chains. We therefore expect them to align themselves with the content of the Policy Statement and the Code of Conduct or to apply a comparable code of conduct, and encourage them to demand this expectation from the contractual partners in their supply chain.

We take any violation of the Policy Statement very seriously. In the event of reports of violations, we initiate measures for proper and confidential clarification and, if necessary, take appropriate countermeasures in terms of remedy or prevention.

We encourage anyone who detects violations of the provisions of this Code of Conduct to report them to us. We also encourage workers in the factories to write to us and describe their problems. Email: complaint@mba-solutions.de. Complaints can be submitted in English, German, or any other translatable language. A button for English is available in the complaint portal. However, it is recommended to write them in English or German for better understanding and to avoid misunderstandings.

We have a complaint management system and a direct contact point to which workers, employees, or other complainants can turn to complain. Here we ensure that a complaint can be submitted anonymously and that the person complaining is free from any kind of retaliation. The system is accessible via our website, and a message appears immediately in Outlook when a complaint is received via the website. In addition, picture posters have been installed in the factories in local languages to facilitate access to the complaint management system.

We encourage suppliers to submit innovative ideas that contribute to further social, economic, or ecological improvements. We promote open, transparent exchange with our customers, employees, suppliers, and all stakeholders on a partnership basis.