FLATTERED – CODE OF CONDUCT

1. ABOUT FLATTERED

Flattered AB was founded in 2013, and designs products with a vision to create classics. The products are of the highest quality in terms of craftsmanship, materials and comfort.

The Products are manufactured in Europe on behalf of Flattered. Flattered works sometimes with local consults who help Flattered to find the most accurate factories for Flattered’s requirements and who help to ensure quality and lead times. Europe and Asia are Flattered’s biggest markets and the products are sold via Flattered’s own e-store, Tmall and via external retailers.

It is of highest priority that Flattered both act and manufacture products in a sustainable way. Our definition of being sustainable is to act in accordance with UN Global Compact’s ten principles covering the following four main areas; human rights, labour conditions, the environment, and anti-corruption.

Our core values form the basis of our business and guide us in all business decisions. This code turns our values into principles that guide us in our daily business.

• We are a humble and positive team with a family spirit.
• We are passionate and determined, and we never settle for "good enough."
• We are early adopters, we embrace new ways of doing things, and we learn by doing.
• We deliver WOW through the purchase experience.

2. TO WHOM DOES THE CODE APPLY?

With the purpose of conducting our business in a sustainable way, this code firstly applies to Flattered and all our staff and sets out the requirements we have, and the basic principles that guide us in our daily business (section 4).

Secondly, this code also applies to our suppliers (section 5). Flattered believes that an integrated code, covering both our requirements on our own business and our expectations on our suppliers, is the best way to work with sustainability in an integrated way.

3. WHAT DOES THE CODE CONTAIN?

The code outlines the minimum standards that Flattered requires its staff and expects its suppliers to comply with in addition to applicable laws and regulations. Should the code be in violation with national laws or regulations, the law shall always be complied with and prevail. 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 environmental and anti-corruption. The code is inspired by relevant international frameworks such as UN Global Compact and its underlying conventions, and the OECD Guidelines for Multinational Enterprises. In relation to the respect of human rights, the principles laid down in the UN Guiding Principles on Business and Human Rights have been taken into account.

The code is divided into two main sections, the first (section 4) is directed towards Flattered and its staff and the second towards Flattered’s suppliers (section 5).

4. “THE FLATTERED WAY”

This section of the code clarifies how Flattered and all our staff should work and act to ensure that we conduct our business in a sustainable and responsible way.

4.1 A RESPONSIBLE MEMBER OF THE SOCIETY

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 make sure that Flattered is not complicit in human rights abuses or abuses of labour conditions.

Equal opportunities for all staff; staff with the same qualifications, experience and performance receive equal pay for equal work with respect to their relevant peers. Flattered recognizes the benefits of diversity in recruiting and in dealings with all staff.

Safe and healthy working environment; Flattered provides a working environment where all staff are comfortable voicing their concerns and reporting any unethical behaviour.

Internships for long-term learning; Flattered is always on the lookout for extraordinary people who are passionate about retail and fashion. Therefore, we have an internship program that offers a glimpse into the industry in a fun, informal work environment.

Fair competition; Flattered and our staff compete strongly but fairly for business opportunities. Our staff do not engage in discussions with competitors regarding market allocation, information exchange, production and sales quotas, or bid rigging.

Zero toleration of corruption and bribery; Flattered does not tolerate any form of extortion and bribery, including improper offers for payments to or from members of the staff, or organizations. Flattered’s staff do not directly or indirectly offer, promise, grant, or authorize the giving of money or anything of value to someone in order to unduly influence the recipient in the performance of professional duties or in order to obtain an improper business advantage.

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, in applicable marketing material, promote a healthy body ideal and a healthy lifestyle.

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 the idea of a timeless design and the use of high quality materials that promotes a sustainable consumption.

Sustainable materials; Flattered aims to increase its use of sustainable materials for example by continuing to develop cooperation with organic tanneries.

The use of chemicals; Flattered promotes the substitution principle and aims at minimizing 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 suppliers by supplementing goods in a conscious way. Flattered only work with ISO certified transporters.

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

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

Waste management; Flattered maintains a high proportion of sorted municipal waste and strives to reduce the total amount of waste. Hazardous waste is managed so that the risk of negative environmental impact is minimized. Product samples and defect products are sold at the second hand market in order to prolong the life-time of the product. We are also investigating how we could help customers recycle worn out products in the future.

4.3 IMPLEMENTATION AND COMPLIANCE

The code is intended to guide Flattered and all our staff on how to act with integrity and good judgment at all times. The implementation and observance of the code is the responsibility of the CEO. Flattered monitors compliance through periodic reporting to the board. The subject is a recurring topic on the agenda at board meetings. Flattered encourages all staff to raise any integrity concerns that may arise. If violations of the code are detected, this shall immediately be communicated to the CEO who have the responsibility to inform the board. All concerns will be investigated. No reprisal of any kind is tolerated against justified complainants. Any staff violating the code may be subject to disciplinary action.

5. WORKING WITH SUPPLIERS

This section of the code clarifies the expectations Flattered has on its suppliers. Flattered aims to produce its products as responsibly and sustainably as possible and facilitates a continuous dialogue with its suppliers on this issue. Flattered visits its suppliers on a regular basis to build a long-term business relationship

Flattered expects its suppliers to conduct their business in a good, sustainable and reliable way and to comply with all applicable rules and regulations. Flattered also expects its suppliers to act in accordance with 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 kind of 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 in accordance with minimum wages and to provide benefits including holidays in accordance with applicable rules and regulations. Over-time hours are consensual and compensated and all wages and over-time compensation are timely paid – all in accordance with 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 means 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 free to (iv) express normal behaviour, and be free from (v) fear and distress.

• provide information of the origin of traded materials such as leather and wool and to 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.

• minimize and mitigate any harmful effects that its operation’s and / or its products may have on the environment, especially with regard to 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 accept corrupt practices, including giving and/or receiving bribes, and

• promote compliance with the above mentioned principles to its suppliers.

5.1 IMPLEMENTATION AND COMPLIANCE

Flattered strives to work together with its suppliers to improve performance and compliance. It is the responsibility of the supplier to ensure that it, and its suppliers, comply with the code. The supplier must immediately inform Flattered of any non-compliance. Flattered reserves the right to make visits to the suppliers and to have access to facilities, staff, books and records relevant observance of the requirements in this code. If a visit reveals less than full compliance, the supplier must take corrective measures without delay. If the supplier fails to comply with the code, and if improvements are not made within an agreed period of time, Flattered reserves the right to terminate the business relationship.

6. ADOPTION AND UPDATES

The code has been adopted by Flattered’s board and will be reviewed annually and updated when needed. We highly appreciate if you as a stakeholder take contact with 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