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

We claim to not only supply 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 our corporate duty of care, regardless of whether we operate in Germany, Europe or other parts of the world.

The declaration of principles reflects the common basic understanding of socially responsible corporate behaviour in the German textile and fashion industry. At the same time, it serves as an orientation framework to which the companies can individually orientate their decisions and measures, and also 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 generally accepted values and principles such as integrity and legality and, in particular, observe internationally recognised human rights and labour standards as set out in our Declaration of Principles.

We are committed to our duty of care.

We share the objectives and content of the Declaration of Principles and will make every appropriate and reasonable effort within the scope of our respective legal and actual possibilities to fulfil the voluntary commitment on an ongoing basis at all our company locations in Germany and abroad.

If existing national regulations contradict the contents of the declaration of principles or the national context makes it impossible to comply with them without restriction, we will look for ways to fulfil the requirements of the declaration of principles as far as possible.

We respect human dignity and respect internationally recognised human rights with reference to:

In all our business activities, we always endeavour to neither 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 endeavour.

We treat our employees and our suppliers with respect, including in particular the workers without whose help we would not be able to manufacture products and who play a key role in our success.

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

We maintain open and transparent communication with customers, employees and suppliers to identify adverse effects on human rights, the labour situation and the environment and provide assistance wherever possible. In return, we expect transparent information from our suppliers and a serious endeavour to work together to remedy problems and improve situations.

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

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 a further document that supplements our Declaration of Principles and forms part of our supplier contract. This applies to every order without being sent with every order process. With the order confirmation, the supplier also individually confirms acceptance of the Code of Conduct, irrespective of a general signature of acceptance.

We require our suppliers to demand this from all subcontractors and to comply with it. Corresponding certification documents must be submitted.

We carry out risk analyses with regard to the social and environmental requirements of our company that refer to various frameworks already mentioned. Our risk analysis focuses exclusively on risks that may occur 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 context will ultimately lead to termination of the business relationship if the supplier does not take immediate remedial action, as we have a zero-tolerance policy in this area. we have identified such serious issues as follows:

• Child labour

• Serious environmental pollution/pollution and non-compliance with sustainability standards.

In the case of child labour, the problem is to be identified and differentiated at national level in order to take targeted measures. This includes working with non-governmental organisations such as Unicef and SOS Children's Villages to get children off the streets and out of factories and to promote educational projects. There are also plans to replace children with adults in factories and to strengthen children's and human rights through training. In the event of serious environmental problems and non-compliance with sustainability standards, a detailed examination of the problem is planned in order to take appropriate measures. Details can be found under the link:

Based on our risk analysis, the high priority risks are: A) Political changes around the world and increase in disputes B) Price and time pressure from customers C) High overtime.

The political conflicts in the world (e.g. the attacks on cargo ships in the Red Sea by the Huthi rebels), which extend the delivery process by weeks and double freight prices, as well as a shortage of freight containers.

In addition, there are unpredictable environmental risks such as earthquakes and flooding.

Political and environmental disasters can ruin companies within a very short space of time.

As an SME, MBA-Solutions cannot really influence the political situation and conflicts worldwide. However, we place our orders in such a way that political unrest has less impact. With comparatively short delivery times, we favour orders from Turkey. We generally place orders with long lead times in the Far East, naturally taking due diligence, sustainability and price into account.

Short lead times, price pressure and poor forecasting with resulting order adjustments in design or delivery time result in high overtime. We therefore ask our customers to give us a reasonable lead time and to avoid orders with short lead times. On the other hand, when confirming orders, we ask our customers not to make any changes to the design or material after production samples have been approved in order to avoid excessive overtime. However, price is still an important factor in our business today. We offer a sustainable option with every normal quotation. Our product managers/marketing managers are constantly trying to convince customers to buy certified products. (Remedial action: see LINK 3, risk analysis based)

We do not tolerate child labour and observe the applicable legal minimum age for admission to employment. In any case, we do not employ persons under the age at which compulsory schooling ends under the law of the place of employment or under the age of 15.

We expect our contractual partners to have appropriate means of determining age in order to prevent child labour. If child labour is detected, all necessary measures must be taken immediately to focus on the welfare, protection and development of the child.

The rights of young workers under the age of 18 must be respected; they may only be employed if it is ensured that the working and employment conditions neither pose a risk to their health, safety or morals nor are detrimental to their development.

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

Our suppliers guarantee that no involuntary labour, forced labour or any form of slavery takes place, including in the lower supply chains. All forms of labour must be voluntary.

Our suppliers ensure that employees do not have to hand in any personal documents (e.g. passports) or pay any employment deposits in order to get the job. All employees receive a briefing on the guidelines and the associated 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 complaints management portal on our website).

2.3 Diversity / Discrimination

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 on the basis of national and ethnic origin, social background, health status, disability, sexual orientation, age, gender, political opinion, religion or belief.

We comply with the statutory or applicable collectively agreed provisions on working hours, including overtime, rest breaks and holidays. In any case, we ensure that overtime is compensated or remunerated at least in accordance with the statutory or collectively agreed regulations; it is ordered in exceptional cases and exclusively on a statutory, collectively agreed or contractual basis. We also expect this from our suppliers.

The supplier shall comply with all nationally applicable laws and binding industry standards on working hours, overtime, breaks and paid holidays.

In our risk analysis, we have identified overtime as a key risk in our supply chain, where we have taken mitigating actions such as no changes to design and material after production sample approval and a buffer time of 3 weeks to our production lead time.

We, MBA-Solutions, as well as our suppliers commit ourselves to comply with the following points:

To pay at least the legally required wages or industry specific standards according to collective labour agreements, whichever is higher. Wages are paid regularly, punctually and in full in the legal currency; benefits in kind are only acceptable in accordance with ILO specifications. A living wage is aimed for, which enables an adequate standard of living, based on a constantly 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 a fair wage within regular working hours. Equal pay for equal work regardless of gender and origin. Deductions are only made in accordance with statutory or collectively agreed requirements. Social benefits are granted without any negative impact on salary, seniority, position or promotion opportunities. Suppliers must provide wage lists on request in order to carry out a GAP analysis and promote the implementation of living wages in the supply chain.

MBA Solutions GmbH places great importance on ensuring a living wage for all employees involved in their contracts. To this end, they have conducted a thorough salary analysis and communicated with key suppliers to address any deviations. Their "Vision 2030: Sustainability Programme" requires key suppliers to increase salaries by at least 10% annually in order to reach the living wage standard by 2030. This is supported by cooperation with the Textiles Partnership. Progress will be reviewed every two years and suppliers who adhere to the programme will receive an additional order volume as recognition. The details of the strategy can be found at the link below:

We respect the right of employees to freedom of association and assembly as well as the right to collective bargaining and collective bargaining, insofar as

this is legally permissible and possible in the respective country of employment. If this is not permissible, we seek appropriate compromises.

Our suppliers recognise these rights and encourage workers to participate in elections for trade union representation without threat, insofar as the political conditions of the country allow.

We comply with national and international occupational health and safety standards and ensure a safe and healthy working environment in order 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 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 devices on the machines, protective work clothing where necessary.

We emphasise particularly vulnerable groups in our supply chain. Among other things, we take into account 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 policies, but also want to see the policies of our suppliers in relation to these and other groups and ask/encourage them to change their policies (if applicable).

The protection and preservation of the natural foundations of life concerns and obliges us all. With this in mind, we conduct our business activities with due consideration for ecological aspects and are committed to the goal of a global climate-neutral future.

We expect our suppliers to comply with all applicable environmental laws, regulations and standards and to implement an efficient 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 :

the professional and responsible handling of hazardous substances and other chemicals as well as waste, including disposal;

We observe the principles for the protection of animals and biodiversity and organise our business activities accordingly.

The keeping and utilisation of animals must comply with the applicable legal animal welfare requirements and be species-appropriate. The Washington Convention on International Trade in Endangered Species of Wild Fauna and Flora 11 must be complied with.

We explicitly oblige our suppliers to comply with animal protection laws and not to torture or injure animals, cause them to suffer in unacceptable animal transports, keep them in non-species-appropriate conditions or otherwise abuse animals.

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

We behave fairly and respectfully towards our business partners and customers. We respect the different legal, economic, social and cultural backgrounds and circumstances of the countries and regions in which we operate. We always base our business activities on universally recognised ethical values and principles, including integrity and respect for human dignity.

We are in favour of free and fair global trade and comply with the laws and regulations of the countries and regions in which we do business.

We expect our suppliers to do the same and to comply with applicable competition and antitrust laws.

Where our products and services affect the interests of consumers, 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 relevant statutory consumer protection provisions.

As part of our information and sales measures, we take consumer interests into account by applying fair business, marketing and advertising practices and promoting consumer education. We pay particular attention to the interests of children, senior citizens, 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. Of course, Tier 2 or Tier 3 suppliers are not counted as subcontractors, but as supply chain processes.

We work exclusively with certified companies. We favour OEKO-TEX® MADE IN GREEN, OEKO-TEX® STANDARD 100 and OEKO-TEX® STeP), would like BSCI certificates (we are an Amfori member ourselves), but 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 reject any form of bribery and corruption and avoid any appearance of it, e.g. in the form of granting or accepting unfair advantages.

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

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

The Supplier shall comply with all applicable export controls, sanctions and customs laws and regulations, including prohibitions and restrictions ("Trade Laws"). In particular, the Supplier shall ensure that the Supplier itself, its beneficial owner(s), all its representatives and other subcontractors used by it are not included on any applicable sanctions list as a "Denied Party".

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

We take great care to ensure that business secrets and other confidential information entrusted to us by our business partners and customers are adequately protected against unauthorised acquisition, use and disclosure, but at least in accordance with the relevant statutory provisions on the protection of business secrets.

We are committed to information security with regard to data (in accordance with the GDPR), including personal data.

We respect the intellectual property of our business partners, customers and other third parties and ensure that sufficient precautions are taken to protect intellectual property rights when transferring expertise and technologies. We place the same demands on our suppliers.

We make suitable and reasonable efforts to communicate and comply with the contents of the declaration of principles through the Code of Conduct at all of our company's locations.

The Declaration of Principles refers to all processes and the associated documents.

The Code of Conduct, on the other hand, is our explicit instruction to suppliers and subcontractors to comply with all requirements and to provide guidance to suppliers. The producer may not place orders with suppliers. This supply chain with certificates must be proven to MBA Solutions. Suppliers (Tier 2, Tier 3 suppliers) must also comply with the MBA Solutions Code of Conduct (this also includes agencies that communicate with production and act as an interface between production and MBA Solutions.

We have set up suitable measures and processes for this (evaluation of audit reports, identification of complaints to be remedied, definition of measures and measures with subsequent request for remediation with evidence).

Somit dokumentieren wir mit Unterzeichnung eines Auftrages die gleichzeitige Anerkennung des Code of Conducts von unseren Lieferanten und fordern diese Maßnahme von unseren Lieferant für deren Zulieferer ebenso, sowie deren Umsetzung unternehmensintern in angemessener Weise. Die Unternehmensleitung informiert sich in regelmäßigen Abständen über die Umsetzung und Arbeit der zuständigen Stellen und Personen.

Wir setzen grundsätzlich auf langfristige, partnerschaftliche Geschäftsbeziehungen. Wir identifizieren und überprüfen daher unsere Vertragspartner in angemessener Weise, bevor wir eine Lieferbeziehung eingehen, z. B. durch Selbstauskunft, Lieferantenbewertung oder Ähnliches.

We reserve the right to monitor our supply partners' compliance with our expectations, e.g. by means of auditing.

If serious violations are identified, we reserve the right to take appropriate contractual consequences, including termination of the business relationship (this will only be considered in extremely rare cases of serious violations). In any case, we expect that any violations identified will be responded to with appropriate preventive or remedial measures and will respond immediately if we receive a complaint.

We communicate the contents of the declaration of principles through the Code of Conduct to our employees, business partners and other key stakeholders and train our employees on individual topics of the declaration of principles as required. We expect our employees to comply with the contents of the declaration of principles. We help our suppliers to implement certifications and communicate the requirements. We expect our suppliers to also participate in continuous training.

The contents of the Declaration of Principles also reflect our expectations of our supply partners and other contractual partners in our supply chains. In this respect, we expect them to be guided by the contents of the Declaration of Principles 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 Declaration of Principles very seriously.

In the event of reports of violations, we initiate measures for proper and confidential clarification and, if necessary, take appropriate countermeasures in the sense of remedial or preventive action.

We encourage anyone who discovers 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 tell us about their problems. Mail: complaint@mba-solutions.de. Complaints can be submitted in English or German or any other translatable language. A button for English is available in the complaints portal. However, it is recommended to write them in English or German for better understanding or to avoid misunderstandings

We have a complaints management system and a direct contact where workers, employees or other complainants can go to lodge a complaint. Here we ensure that a complaint can be made anonymously and that the person making the complaint is free from any kind of retaliation. The system can be accessed via our website and a message pops up immediately in Outlook when a complaint is raised via the website. In addition, picture posters have been installed in the factories in local languages to provide access to the complaints management system. The details of our complaints mechanism can be found under the following link

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

Troisdorf, 14.05.2024 CEO / Jochen Pütz-Kurth