Code of Conduct employees

CODE OF CONDUCT, EMPLOYEES ADOPTED 2019-04-26 Last revised 2022-05-19

The CEO of Earl Holding I AB (reg. no. 559046-8566) (the “Company”1) has on April 26, 2019 adopted this Code of Conduct, Employees.

Eton Code of Conduct, Employees 1. Introduction This Code of Conduct (hereafter the “Code”) was adopted to ensure that Eton conduct business in a manner that inspires confidence and complies with legislation and best practices in the sector. The Code shall be revised annually or more often if required. The CEO is the owner of this Code. Each manager is responsible for implementing the Code within his or her area of responsibility and the CEO is responsible for informing the managers about the Code. The Code can be found on Eton’s intranet (Share point).

1.1 Scope Honesty, integrity and fair play are values on which our business practices have been based since our founding in 1928. This Code outlines principles that we commit to, defining how we behave in all situations. Compliance to this Code is mandatory for all Eton employees (regardless of employment status) and anyone acting on behalf of Eton (hereafter the “employees”).

It is the ultimate responsibility of each employee to “do the right thing” and to, if in doubt about the proper course of action, seek guidance. In short, employees are expected to use good judgment and to avoid the appearance of improper behaviour. Decisions and actions on behalf of Eton should always have Eton’s, Eton’s customers and Eton’s owners’ best interests at heart.

If ever in doubt about a course of conduct, ask yourself: • • • •

Is my action consistent with the principles of our Code of Conduct?

Is my action ethical?

Will it reflect well on me as an employee and the Company?

Would I want to read about it in the newspaper?

If the answer is “No” to any of these questions, you should revise your action. If you are still uncertain, ask for guidance from your manager.

1 Includes all subsidiaries of the company group in which Earl Holding I AB is the

parent company.

1.2 Guiding principles Eton always acts in accordance with national legislation in all countries where we operate and take appropriate measures to prevent direct or indirect violations of human rights, labor laws, environmental laws, competition laws and anticorruption laws. Eton is responsible for ensuring that all employees are familiar with national legislation and regulations relevant to their area of responsibility including legislation with extraterritorial jurisdictions, such as the UK Bribery Act, UK Modern Slavery Act, and Foreign Corruption Practice Act. We have aligned our Code with the Ten Principles of the UN Global Compact2 and applicable international agreements: the UN Universal Declaration of Human Rights3, the International Labor Organization Conventions4, the UN Convention against Corruption5 and the Rio Declaration on Environment and Development6.

To read more about which requirements we have on our suppliers. Please read our Supplier Code of Conduct.

2. Human rights and labor rights Fundamental human rights and working conditions shall be known, respected and equally applied to all employees regardless of employment status.

2.1 Equality and diversity Eton strives to be a diverse and equal workplace. This means that we support diversity and equality both operationally and within the governing and management bodies. All employees at Eton are compensated in a fair manner and Eton actively work against unjustified salary differences.

2.2 Discrimination and harassment Eton respects the personal dignity, privacy and personal rights of every employee and is committed to maintaining a workplace free from discrimination and harassment. Eton and our employees must not discriminate on the basis of origin, nationality, religion, race, gender, disability, political opinion, union affiliation, age or sexual orientation, or engage in any kind of verbal or physical harassment based on any of the above or any other reasons. Eton recruits on the basis of competence and never in a manner that is or could be perceived as discriminatory.

2 Ten Principles of the UN Global Compact 3 UN Universal Declaration of Human Rights 4 International Labour Organization Conventions 5 UN Convention against Corruption 6 Rio Declaration on Environment and Development

2.3 Working conditions A healthy work environment is essential for the well-being of our employees and thereby also important for a successful business. We take a holistic approach to health that includes physical, mental and social well-being. Eton and our employees shall work systematically and transparently on improving the working environment. It is Eton’s responsibility to inform all employees about our health and safety principles. For further information on what Eton defines as a good working environment read the Culture Audit.

It is never acceptable for employees to use or work under the influence of alcohol or drugs, which in any way could compromise your own and/or others safety and well-being.

2.4 Child labor Eton does not accept the use of children or minors under the minimum legal working age or fifteen (15) years old, whichever is higher, as labor. Employees under the age of 18 shall not carry out hazardous work, heavy work or work night shifts.

2.5 Freedom of association and the right to collective bargaining Eton respects employees’ right to join or not to join a union or worker’s association of their choice, as well as to engage in collective bargaining, in accordance with national legislation of the country in which the employee works.

2.6 Opportunities for development It is of great importance for Eton to be an attractive and stimulating workplace.

We encourage and support the continuing development of our employees.

Managers and employees have a mutual responsibility to ensure that each and every person who works for Eton has the information, knowledge and capabilities required for performing their work.

3. Environment At Eton it is important to reduce the impact of our activities on the environment.

Our environmental responsibility must be integrated in all our core activities. We shall perform our business in such a way that energy, water and raw materials are used efficiently, and waste and residual products are minimized. We always apply the precautionary principle in our assessment of substances and processes that may harm the environment.

3.1 Energy and greenhouse gas emissions For Eton it is critical to continually reduce greenhouse gas emissions and energy consumption. Eton always tries to take environmental impact into account when we choose energy resources and methods of transportation and travel. In our offices, stores, operations and travels, we prioritize energy from renewable energy resources as far as possible.

3.2 Materials and waste Our approach is to always keep waste to a minimum and recycle materials as far as possible. When Eton and our employees use or buy equipment, materials, utilities and services we strive to choose the option that is best for the environment from a long-term perspective.

3.3 Water, chemicals and hazardous substances Eton aims to work with environmental matters regarding water, chemicals and hazardous substances. We recognize that we have a high sustainability impact in our production process together with our suppliers. To read more about our environmental requirements on our suppliers, read our Supplier Code of Conduct.

4. Anti-corruption Eton must never engage in any kind of corruption. Eton will work to eliminate all forms of corruption, including but not limited to, extortion, bribery, facilitation payments, nepotism, fraud, insider trading and money laundering. Eton’s employees prone to corruption must pay specific attention to Eton’s Anticorruption policy.

4.1 Bribery A bribe occurs when a person requests, receives, offer, pay, seek or accept an offer or an improper advantage or reward in connection with his or her position, office or assignment. Employees shall not offer, accept or promise any financial or other advantage to any person or organization, in order to obtain any preferential treatment in connection with Eton’s business.

4.2 Gifts and hospitality We do not offer or accept gifts, travel, payment or hospitality to encourage or reward a decision. Always ask a manager if you are unsure whether to accept or not accept a gift or a hospitable gesture. All corporate hospitality should be characterized by cost consciousness.

4.3 Conflict of interest Dealing with business partners must be impartial and professional. A conflict of interest arises when personal relationships, participation in external activities or interest in a venture influence or could be perceived to influence business decisions. Employees must be transparent about potential conflict of interests and withdraw from decision-making that creates or could be perceived to create a conflict of interest.

4.4 Fair competition Eton is committed to promoting fair competition and an open market.

Agreements, including but not limited to price fixing, market sharing, bid rigging and output restrictions are considered as corruption and not acceptable at Eton.

5. Protection of assets and confidential information 5.1 Company assets and property All employees at Eton shall safeguard and ensure proper use of Eton’s property, including both tangible and intangible assets. Eton owns the copyright to what you have created on behalf of the Company, including but not limited to designs, patterns, art work, prototypes and IT solutions. You are not allowed to use or sell assets or property belonging to Eton for your own use and compensation except with permission.

5.2 Confidential information Confidential information consists of any information concerning Eton and the company’s business that is not public information. It includes, but is not limited to, financial data, commercial relationships, trade secrets, offers, strategies, all supplier related information, IT solutions and sensitive personnel data. You must never disclose confidential information to any person – within or outside the Company – unless the information is necessary to perform a task on behalf of Eton. All personal data stored must be handled confidentially and in line with the EU General Data Protection Regulation (GDPR)7.

6. Drugs & Alcohol Eton aims to provide a sober and drug-free working environment Abuse of alcohol, narcotics and other such drugs is unacceptable. In order to ensure a good, sober and drug free work environment Eton aims to ensure drugfree workplaces, to prevent bad health, accidents and near-misses, and to discover any abuse at an early stage.

6.1 Guidelines and principles To achieve the aim of providing a drug-free workplace the following guidelines and principles apply. Employees shall not be under the influence of alcohol or drugs during working hours. Each member of staff has a duty not to jeopardize efficiency or reduce safety and well-being in the workplace through inappropriate alcohol/drugs habits.

Alcohol is a delicate matter, a natural part of festivities to many but also cause for concern to others. Alcohol should therefore be handled with care and consideration when part of company functions. Policy rules help us maintain an orderly workplace and safe and positive work environment. When attending company functions, you’re always attending as an Eton representative. Your appearance and demeanor should therefore reflect our company values. You should always present yourself with class and dignity. Alcohol can be an accepted part of staff functions, representation, and work-related events. It should in such cases always be handled with care and good judgment. Non-alcoholic alternatives should always be available.

7 EU General Data Protection Regulation

In these guidelines alcohol and drugs means alcohol, narcotics, medicines, anabolic steroids as well as other doping agents and intoxicants.

6.2 Managerial responsibilities Managers are responsible for ensuring that staff abide by these rules. A manager’s duties include taking measures if an employee is found to be under the influence of alcohol or other drugs. Together with Human Resources, managers also have a responsibility to provide support and initiate the necessary rehabilitation.

If abuse is discovered the measures taken should aim to bring an end to the abuse while allowing the employee to remain working for the company, provided that the individual concerned actively contributes to his or her rehabilitation and takes responsibility for compliance with Eton policies.

6.3 Business entertainment Entertaining clients or associates should always be connected to business in order to be tax deductible. At internal events Eton can at times let the staff enjoy drinks served at dinner. The staff themselves should care for additional drinks. In connection with representation and entertaining clients, staff’s own consumption of alcoholic beverages should be done with care and always using best judgment.

Records and receipts of entertaining events, external and internal, should state the names of participants and the cause of the event.

6.4 Advice, support, and rehabilitation Every employee in need must be helped to find support and rehabilitation irrespective of their position in the company or where they work, in accordance with the routines for alcohol and drug abuse. The integrity of members of staff shall be respected to the utmost extent.

No employee shall be at risk of losing his or her job because of an alcohol or drug problem, provided that the individual completes treatment and rehabilitation with a view to ending abuse.

The legislation in each country must be considered.

7. Compliance By signing this document, you are confirming that you have been informed about Eton’s Code of Conduct, that you have read and understood the content of the Code and that you commit to comply with the principles. “Doing the right thing” and ensuring the highest standards of integrity is a personal responsibility that cannot be delegated.

Any failure to comply with this Code may result in disciplinary action depending on the severity of the case. This may lead to verbal warning, written warning, and in case of severe breach dismissal and, if warranted, legal proceedings or criminal sanctions.

8. Reporting illegal actions or misconduct Any breach or suspected breach towards the principles in this Code shall be emailed to Eton at csr@etonshirts.com and this shall not be used against the employee if acting in good faith. All feedback will be handled anonymously, provided that we are not obliged by law to disclose it. Employees that have questions about the Code, or who wish to give feedback regarding the Code, are welcome to send an email to: csr@etonshirts.com.

9. Associated Documents Eton Code of Conduct Eton Anti-corruption policy