A4-Codeofconduct-ENG

Code of conduct 2025

Bel&Bo Code of Conduct • 2

Introduction At Bel&Bo, we believe fashion should be created responsibly: with respect for people, planet, and partnerships.

This Code of Conduct outlines the ethical standards that guide how we do business, from our headquarters in Belgium to every production site across the world.

It reflects our values: honesty, warmth, and a genuine closeness to the people we work with. We expect all our business partners to share these principles and to apply them throughout their own supply chains.

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Building on International Standards Our Code of Conduct is grounded in internationally recognized conventions and principles, including: •

The UN Guiding Principles on Business and Human Rights (UNGPs)

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The OECD Guidelines for Multinational Enterprises

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The International Labour Organization (ILO) Conventions

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The Fair Wear Code of Labour Practices

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Amfori BSCI and BEPI principles

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Where local laws and this Code differ, the higher standard shall always apply.

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Governance and Responsibility Bel&Bo’s due diligence process is coordinated by the Executive Board, which includes all department heads and the CEO. They are supported by the Sustainability Team, composed of our CEO, Buying Manager, CSR Manager, and our Sustainability Champions. Together, they oversee the development, implementation, and monitoring of all due diligence policies. Topical experts from other departments support them where needed.

We also work closely with trusted partners who strengthen our responsible business efforts: Amfori – providing monitoring tools and improvement support through BSCI and BEPI frameworks.

Fair Wear – helping us improve labour conditions and transparency across our supply chain.

Accord – ensuring fire and building safety in Bangladesh through independent inspections and remediation.

Fair Trade – supporting fair prices and better working conditions for cotton farmers, ensuring our cotton is grown with respect for both people and planet.

Our approach is guided by several internal policies: (see our Appendix for more information on these policies) •

Supplier Consolidation Policy

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Unauthorized Subcontracting Policy

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Responsible Exit Policy

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Animal Welfare Policy

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Responsible Sourcing Bel&Bo, responsible sourcing is built on respect, clarity, and long-term collaboration. We believe that good planning and open communication are the foundation for strong partnerships.

Sourcing Strategy Our sourcing strategy covers not only order timing, quantities, budgets, colors, and designs, but also the choice of materials and our broader sustainability ambitions.

We aim for collections that are efficient, consistent, and aligned with our responsible business vision.

Everything starts with our risk assessment, which we review each season together with all our buyers. This process helps us identify potential risks — social, environmental, and material-related — and guides our decision-making throughout the sourcing process.

Twice a year, we align our strategy across departments to ensure that every step, from design to production, contributes to a more sustainable and transparent supply chain.

Planning with Purpose Each season, we turn strategy into action: •

Coordinate closely with suppliers to ensure stability and smooth execution throughout the season.

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Hold regular meetings to review timelines and any adjustments needed.

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Share shipment and delivery schedules transparently.

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Provide ongoing updates throughout production to anticipate and address potential delays.

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Evaluating & Growing Together At the end of each season, we evaluate: •

Planning effectiveness and communication

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Product quality and CSR progress

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Pricing and responsiveness

Suppliers with strong results and few action points are prioritized for future collaborations, building trust step by step.

Clear Guidance We provide all partners with clear resources to simplify collaboration: •

Supplier Manual: delivery, labeling, and packaging instructions

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Quality Control Manual: guidance on sampling and measurements

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Technical Packs: detailed product specifications

These ensure every item meets Bel&Bo’s quality and responsibility standards and prevent misunderstandings.

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Minimum Requirements for Suppliers Bel&Bo partners with suppliers who share our commitment to quality, ethics, and sustainability. We expect fair labor practices, respect for environmental standards, and excellence in manufacturing, while fostering positive impact across the industry and communities.

Code of Conduct All suppliers must read and sign Bel&Bo’s Code of Conduct, upholding minimum standards for labor, ethics, and the environment throughout their supply chains.

Audits & Self-Assessment •

Social Audits: Producers and subcontractors in high-risk countries must undergo third-party social audits, typically annually or biennially, to assess compliance with labor rights protections. Audits may be semi- or fully announced.

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Self-Assessment Onboarding Questionnaire: Each supplier completes a questionnaire to provide data on social and environmental practices across our supply chain.

Fair Wear Worker Information Suppliers must prominently display the Fair Wear Worker Information Sheet, which includes access to a grievance helpline. This ensures every employee can raise concerns directly, promoting transparency and safeguarding worker well-being.

Bangladesh: Accord Requirement Suppliers in Bangladesh must be members of the Accord on Fire and Building Safety to qualify for collaboration, reflecting our commitment to safe and responsible production in high-risk regions.

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Respect for People and Labour We are committed to upholding the fundamental rights of all workers in our supply chain. Our standards are aligned with ILO conventions and international best practices.

Employment is freely chosen No form of forced, bonded, or prison labour shall be used.

Workers are free to leave their jobs after reasonable notice.

No discrimination Equal opportunities for all, regardless of race, colour, gender, religion, political opinion, nationality, or background.

Freedom of association Workers have the right to form and join trade unions and to bargain collectively.

No child labour The minimum age for employment is 15 (or 14 in specific exceptions, in line with ILO standards). Young workers (15–18) must not perform hazardous tasks.

Payment of a living wage Wages shall meet at least legal or industry standards and allow workers to meet their basic needs and maintain a decent standard of living.

Safe and healthy working conditions Factories must provide a clean, safe, and hygienic work environment and comply with occupational health and safety regulations.

Reasonable working hours Working time shall not exceed 48 hours per week, with at least one day off in seven. Overtime must be voluntary and compensated.

Legally binding employment relationship All employees must have a written contract and social security entitlements according to national laws.

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Zero Tolerance Policies At Bel&Bo, certain violations are incompatible with our values and Code of Conduct. These are non-negotiable standards: any confirmed breach may result in immediate suspension or termination of the business relationship, always handled in line with our Responsible Exit Policy.

We maintain zero tolerance for: 1. Forced or bonded labour Any form of coercion, retention of personal documents, or restriction of workers’ freedom of movement.

2. Child labour Employment of anyone below the legal minimum working age or involvement of young workers in hazardous work.

3. Harassment or abuse Any physical, verbal, or psychological mistreatment, including sexual harassment or intimidation.

4. Bribery and corruption Offering, accepting, or requesting any improper advantage in relation to Bel&Bo’s business operations.

5. Unauthorised subcontracting Production outside approved facilities or the use of unregistered subcontractors.

6. Non-payment or withholding of wages Failure to pay workers their due wages in full and on time, deductions made unlawfully, or deliberate withholding of earnings as punishment or control.

7. Environmental negligence Intentional discharge of untreated wastewater, illegal disposal of hazardous waste, or deliberate violation of environmental laws.

Bel&Bo will investigate any reported violation transparently and objectively.

Suppliers are expected to cooperate fully and implement immediate corrective actions when required.

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Due Diligence in Practice Identifying and Assessing Risks Bel&Bo regularly conducts risk assessments across all sourcing countries and production sites. Each season, we review these assessments together with our buying teams to identify potential social, environmental, and governance risks.

We combine insights from audits, local expertise, international studies, and our own sourcing data to create a clear picture of where the highest risks lie. This approach helps us set priorities, focus our actions, and strengthen our responsible sourcing decisions.

Preventing and Reducing Negative Impacts Before partnering with any new factory, the minimum requirements need to be met (see page 5.)

If a non-compliance is found, we work closely with suppliers on Action Plans to ensure sustainable improvements. In rare cases where collaboration must end, we follow a Responsible Exit Procedure to minimize disruption and uphold fairness.

Tracking Implementation and Results We monitor supplier performance through audits, follow-up visits, and data reviews. Progress is tracked annually, and results feed into our continuous improvement plans.

Communicating Our Progress Bel&Bo publishes updates annually on our website, including our Social Report and policy overview. We share our progress openly, acknowledging both achievements and challenges in our journey toward responsible fashion.

Providing Access to Remedy Workers in all partner factories can raise grievances via the Fair Wear helpline, listed on the Worker Information Sheet. Every complaint is handled confidentially, investigated thoroughly, and followed up until resolution.

Appendix

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Appendix 1 Supplier Consolidation Policy Purpose Bel&Bo aims to maintain a manageable number of production locations to ensure the effective implementation of responsible business practices. By focusing on long-term relationships, we seek to strengthen our leverage and ability to drive positive change across our supply chain.

Policy 1. Order Consolidation Suppliers are encouraged to consolidate Bel&Bo orders into as few production locations as possible.

Reducing the number of locations allows for better monitoring, improved efficiency, and streamlined administrative processes for both Bel&Bo and our suppliers.

2. Monitoring & Oversight All production locations must be monitored to ensure compliance with Bel&Bo’s responsible sourcing and quality standards.

This monitoring includes administrative, social, and environmental oversight.

3. Prioritization of Existing Locations Bel&Bo prioritizes existing production locations over onboarding new suppliers.

New suppliers or production locations are accepted only as a last resort when existing capacity or capabilities cannot meet demand.

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Appendix 2

Unauthorized Subcontracting Policy Purpose Bel&Bo values transparent, long-term partnerships. We are committed to ensuring all production occurs at approved locations and maintaining the highest ethical standards in the industry. Partners who do not share our commitment to preventing unauthorized subcontracting may see their collaboration phased out.

Approved Production Locations •

Products must be supplied from the sites specified in the order confirmation.

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Deviations from approved production locations are not permitted without prior agreement from the buying department.

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While subcontracting is common in the apparel industry, only approved locations are allowed to safeguard safe, fair labor practices and acceptable working conditions.

Transparency & Communication •

All changes to approved production locations must be communicated and approved before production begins.

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Our order administration system is maintained to ensure accurate, up-to-date tracking of production sites.

Detection of Unauthorized Subcontracting •

Bel&Bo’s CSR, sourcing, and quality teams monitor production closely, particularly in high-risk countries.

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Detection methods include document reviews, on-site observations, and thirdparty audits.

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Any unauthorized subcontracting is addressed immediately to maintain compliance with our ethical standards.

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Appendix 3 Responsible Exit Policy Purpose Bel&Bo values transparency, integrity, and ethical practices in all supplier relationships. This policy ensures any termination of a supplier relationship is handled responsibly, minimizing disruption and upholding fairness.

All decisions are guided by our risk assessment, reviewed each season with our buying teams, and by our zero tolerance standards.

Scope This policy applies only when: •

Bel&Bo has more than 2% leverage with the supplier, and

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The termination is initiated by Bel&Bo.

When leverage is below 2%, the impact of ending the relationship is deemed insignificant for the supplier.

Exit Steps 1. Assessment & Justification •

Review performance, quality, legal, and ethical factors.

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Consider alternatives before deciding to terminate.

2. Notification •

Inform the supplier in writing promptly, explaining the reasons.

3. Supplier Impact •

Evaluate potential layoffs or closure and ensure compliance with severance laws.

4. Communication •

Maintain clear communication, address concerns, and coordinate the transition.

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Notify Fair Wear if needed.

4. Phase-Out Plan •

Where necessary, work with the supplier to define a phase-out plan with a clear timeline.

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Gradually reduce orders to give the supplier time to find new customers.

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Appendix 4 Animal Welfare Policy Purpose Bel&Bo is committed to the highest standards of animal welfare throughout our supply chain. We prioritize ethical sourcing and ensure that all materials of animal origin are produced responsibly, with respect for animal well-being, environmental sustainability, and legal requirements.

Standards and Requirements 1. Responsible Sourcing •

All animal-derived materials must come from sources that uphold recognized animal welfare practices.

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Practices that cause unnecessary harm, suffering, or stress to animals are strictly prohibited.

2. Traceability •

Suppliers must provide clear information about the origin of animal-derived materials from farm to final product.

3. Prohibited Practices •

No sourcing from animals subjected to cruel practices, including liveplucking, mulesing without anesthesia, or inhumane transport or slaughter.

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No materials sourced from endangered species or non-compliant farms.

3. Monitoring and Compliance •

Bel&Bo reserves the right to audit suppliers, including site visits and documentation reviews, to ensure adherence to this policy.

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Non-compliance may result in corrective actions or termination of the business relationship.