FLATTERED – CODE OF CONDUCT

1. ABOUT FLATTERED

Flattered was founded in 2013 and designs products with a vision of creating classics. The products are of the highest quality regarding craftsmanship, materials, and comfort.

The products are manufactured in Europe for Flattered. Flattered occasionally collaborates with local production agents to identify factories that best meet its requirements and to ensure quality and lead times. Europe is its largest market, selling products through an online store, external retailers, and various marketplaces.

It is of the highest priority that Flattered both acts and responsibly manufactures products. Our definition of being responsible is acting according to the UN Global Compact's ten principles covering the following four main areas: human rights, labour conditions, the environment, and anti-corruption.

2. TO WHOM DOES THE CODE APPLY?

To conduct our business responsibly, this code first applies to Flattered and all our co-workers and sets out our requirements and the basic principles that guide our daily business (section 4).

Secondly, this code applies to all our partners who have a business relationship with Flattered by supplying goods and/or services, acting on Flattered's behalf, or collaborating with Flattered. Such as suppliers, agents, and distributors (section 5). Flattered believes that an integrated code, covering both our requirements on all business carried out within Flattered and our expectations on all business carried out on behalf of Flattered by our business partners, is the best way to work with responsibility in an integrated way.

3. WHAT DOES THE CODE CONTAIN?

The code outlines the minimum standards that Flattered requires all its co-workers and business partners to comply with and applicable laws and regulations in all jurisdictions where we do business. Should any local practice or custom contradict the standards set out in the code, such local practice or custom shall be disregarded unless such practice or custom is explicitly permitted or required by local written law. If such cases are identified, the CEO shall immediately be informed.

Flattered works to foster compliance with international guidelines regarding human rights, labour conditions, the environment, bribery and anti-corruption. The code is inspired by relevant international frameworks such as the UN Global Compact, its underlying conventions, and the OECD Guidelines for Multinational Enterprises. Regarding respect for human rights, the principles laid down in the UN Guiding Principles on Business and Human Rights have been considered.

4. "THE FLATTERED WAY"

This section of the code clarifies how Flattered and all our co-workers should work and act to ensure that we conduct our business sustainably and responsibly.

4.1 A RESPONSIBLE MEMBER OF THE SOCIETY

A shared understanding of international rules: Flattered supports and respects the protection of internationally proclaimed human rights and labour conditions and is doing its utmost to ensure that Flattered is not complicit in human rights abuses or abuses of labour conditions.

Equal opportunities for all co-workers; co-workers with the same qualifications, experience and performance receive equal pay for equal work concerning their relevant peers. Flattered recognises diversity's benefits in recruiting and dealings with all co-workers.

Safe and healthy working environment: Flattered provides a workplace where all co-workers are comfortable voicing their concerns and reporting unethical behaviour.

Internships for long-term learning: Flattered always seeks extraordinary people who are passionate about retail and fashion. Therefore, our internship program offers a glimpse into the industry in a fun, informal work environment.

Fair competition: Flattered and our co-workers compete vigorously but fairly for business opportunities. Our co-workers do not discuss market allocation, information exchange, production and sales quotas, or bid rigging with competitors.

Zero tolerance of corruption and bribery: Flattered does not tolerate any form of corruption, extortion, or bribery, including kickbacks and improper offers for payments to or from our co-workers or organisations. Flattered's co-workers do not directly or indirectly offer, promise, grant, or authorise giving money or anything of value to someone to unduly influence the recipient in performing professional duties or to obtain any other unlawful or unethical benefit.

Privacy: Flattered respects the privacy of all individuals. In the course of its business, Flattered handles personal information about employees, business partners and customers. All personal information is used in compliance with applicable data protection and privacy laws.

Marketing: Flattered shall promote a healthy body ideal and lifestyle in applicable marketing material.

4.2 ENVIRONMENTAL APPROACH

High-quality, long-life products: Flattered aims to reduce the negative environmental impact of its products throughout their life cycles. Flattered's business model is based on a timeless design and high-quality materials that promote responsible consumption.

Responsible materials: Flattered aims to source as much as possible from tanneries that have been gold-rated by the Leather Working Group, meaning they have met the best environmental standards. Flattered is conscious of the drawbacks of leather and is constantly assessing alternatives. However, Flattered currently considers leather the best option due to its enduring qualities.

The use of chemicals: Flattered promotes the substitution principle and aims to minimise the use of chemicals in its products.

Transportation of goods: Flattered's purchases are closely planned to enable transportation that is as environmentally friendly as possible. Flattered reduces the number of transports from and to our business partners by consciously supplementing goods. Flattered only works with ISO-certified transporters.

Business travels: Flattered evaluates environmental impact, time and costs when planning, booking and carrying out business travels. Flattered encourages all co-workers to choose the type of travel with the most limited environmental footprint.

Energy efficiency: Flattered strives to reduce its energy consumption at its office and utilises renewable energy sources when possible.

Waste management: Flattered maintains a high proportion of sorted municipal waste and strives to reduce the total amount. Hazardous waste is managed to minimise the risk of adverse environmental impact. Product samples and defective products are sold at second-hand markets to prolong the products' lifetime, and we encourage and help customers to do the same and recycle worn-out products.

4.3 IMPLEMENTATION AND COMPLIANCE

The code is intended to guide Flattered and all our co-workers on always acting with integrity and good judgment. The CEO is responsible for implementing and adhering to the code. Compliance is monitored by Flattered through regular reports to the board. This matter is consistently included as an agenda item in board meetings. Flattered encourages all co-workers to raise any integrity concerns that may arise. If code violations are detected, this shall immediately be communicated to the CEO, who is responsible for informing the board. All concerns will be investigated. No reprisal of any kind is tolerated against justified complainants. Any co-worker violating the code may be subject to disciplinary action.

5. WORKING WITH OUR BUSINESS PARTNERS

This section of the code clarifies Flattered's expectations of its business partners. Flattered aims to produce its products responsibly and facilitates a continuous dialogue with its business partners, particularly suppliers, on this issue. Flattered visits its business partners regularly to build a long-term business relationship.

Flattered expects its business partners to conduct their business in a good, responsible and reliable way and to comply with all applicable laws, rules and regulations. Flattered also expects its business partners to act by the following principles:

• respect and support international human rights and labour conditions and make sure that it is not complicit in human rights abuses,

• not use child labour. Child labour, as defined by the ILO, is work that deprives children of their childhood, their potential and their dignity and that is harmful to physical and mental development,

• not use forced labour or other forms of involuntary labour, including prisoners, bonded workers, illegal workers, or other non-paid workers, not hold persons in slavery or servitude and not engage in acts of human trafficking,

• not subject its employees to any discrimination, harassment, threats and/or oppression,

• uphold the right to freedom of association and collective bargaining, including the right to form and join trade unions and other worker organisations without harassment or interference,

• provide wages above or by minimum wages and benefits, including holidays, per applicable rules and regulations. Overtime hours are consensual and compensated, and all wages and over-time compensation are timely paid – all by applicable rules and regulations,

• provide a safe and healthy working environment and, when applicable, safe and healthy housing facilities for its employees,

• promote animal welfare and respect the "five freedoms" for animals under human control. The five freedoms mean that animals kept for the production of food, wool, skin, etc., should be free from (i) hunger and thirst, (ii) discomfort, (iii) pain, injury and disease, be accessible to (iv) express normal behaviour, and be free from (v) fear and distress.

• provide information on the origin of traded materials such as leather and wool and guarantee that the wool used is not a result of mulesing of merino sheep nor produced out of angora wool and that the leather used is from cattle, goats or sheep and does not origin from animals that are breed for their skins but is a by-product of the food industry.

• minimise and mitigate any harmful effects that its operation and/or its products may have on the environment, especially about emissions and waste- and water management,

• comply with all applicable chemical rules and regulations in the manufacturing of Flattered's products (as amended from time to time),

• not carry out any actions involving bribes or corruption, including financial or other advantages which are given, promised, offered, accepted, requested or received to influence the ability to make objective and fair business decisions and

• promote compliance with the principles mentioned above to its business partners.

5.1 IMPLEMENTATION AND COMPLIANCE

Flattered strives to work with its business partners to improve performance and compliance. The business partner must ensure that it and its partners comply with the code. The business partner must immediately inform Flattered of any non-compliance. Flattered reserves the right to visit its business partners and access facilities, co-workers, books and records relevant to observance of the requirements in this code. If a visit reveals less than full compliance, the business partner must take corrective measures immediately. Flattered reserves the right to terminate the business relationship if the business partner fails to comply with the code and improvements are not made within an agreed period.

6. ADOPTION AND UPDATES

Flattered's board has adopted the code, which will be reviewed annually and updated when needed. We would appreciate it if you, as a stakeholder, could contact us if you think we should clarify, improve or update this version of the code.

Gustav Lidén, CEO
Email: gustav@flattered.com
Phone number: + 46 (0) 707 882 987