Sustainability policy

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SUSTAINABILITY POLICY

ADOPTED 2023-10-18

Revised 2024-06-22

The Board of Directors of Earl Holding I AB (reg. no. 559046-8566) (the “Company”1) has on 2024-06-22 adopted this Sustainability Policy to govern the Company’s strategic Sustainability governance.

1. Background and purpose

Eton Shirts sustainability policy sets out the direction for the company’s sustainability strategy. We have a holistic approach to sustainability: to us, it is every choice we make, that is the better choice. As a company we want to take our responsibility and contribute to a more sustainable development.

Eton shirts sustainability policy sets the framework for our sustainability agenda and strategy.

2. Procedure statement

We have developed this sustainability policy in order to clearly state to our internal and external stakeholders our ambitions and actions. Our approach is to actively work on reducing our impact on the climate and environment as far as possible within the scope of our business as well as creating good conditions for people throughout our full value chain, by respecting human rights, global and local employment laws and regulations.

Our goal to be Net zero by 2050 is guiding our climate impact reduction strategy, which sets out our key steps to futureproofing Eton. We will work towards ensuring safe work and labor rights free from harassment and discrimination in our supply chain, both in our own business practice and with our suppliers. We also commit to advocating inclusion & diversity. Through our business practices we ensure that we contribute to prosperity in all markets we are active in.

As guidance on how to be in line with our ambitions and goals we commit to:

• We will comply with the laws and regulations that relates to our own business as well as our supply chain.

• We will actively work on reducing our GHG emissions in our business-related travelling.

• Our company car policy states that our company cars should be either fully electric or hybrid electric.

• We collaborate with suppliers and partners that are sharing the same sustainability ambitions as we have. Alternatively support our suppliers in their transformational journey.

• We should always honor the option with the lowest impact for a similar product or service provider.

• Employees must undergo environmental training and specialization in the sustainability field, if applicable.

• We will actively work on reducing our climate & environmental footprint in our supply chain.

• We will aim towards a circular business model in all our operations.

• The longevity of our products is of outmost importance, and we commit to always produce products of high quality with a long lifespan.

• We align our Code of Conduct with the UN Global Compact and its applicable international agreements: the UN Universal Declaration of Human Rights and the International Labour Organization Conventions etc.

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

• Animal Welfare is of outmost importance to us. Materials used for our products must not originate from vulnerable or endangered species as specified in the Convention of International Trade in Endangered Species (CITES). All parties involved, handling the animals and the materials, must follow national and international legislation.

• THE FIVE FREEDOMS; recommendations on animal welfare set out by the World Organization by Animal Health (OIE), should be the guiding principles on all farms used in the production of fibre origin from animals used for Eton products.

• 1. Freedom from hunger, malnutrition and thirst by ready access to fresh water and a diet to maintain full health and vigor

• 2. Freedom from heat stress or physical discomfort by providing an appropriate environment including shelter and a comfortable resting area

• 3. Freedom from pain, injury and disease by prevention or rapid diagnosis and treatment

• 4. Freedom to express normal patterns of behavior by providing sufficient space, proper facilities, and company of the animal's own kind

• 5. Freedom from fear and distress by ensuring conditions and treatment which avoid mental suffering.

• All wool must be mulesing free wool.

• Before signing a new supplier, they need to be vetted by using our Sustainability tender questionnaire.

• All our suppliers contributing to our products need to sign, understand and commit to our “Code of conduct Suppliers” before entering partnership with us.

• All Eton staff need to read and approve our Code of conduct Employees when they join the company.

• 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.

• We will actively work to reduce all our waste across our operations and for the waste generated follow the EU Waste Framework Directive’s The waste hierarchy.

Compliance of this policy is done through trainings provided to all employees on an annual basis. Compliance is also monitored as a part of the annual risk assessment and management procedure.

The sustainability policy will be monitored, evaluated, and revised yearly to ensure it’s up to date. The staff at the company have the sustainability policy easily accessible at the local SharePoint server and will be kept up to date on news and rules & regulations in the sustainability field.

3. Relevant entity/BU

This Policy applies Group wide to all BU/Entities.

4. Roles and responsibilities

Our strategy and sustainability goals are overseen by the Board of Directors and the CEO. Eton’s Head of Sustainability is responsible for the overall sustainability direction and strategy. Development of the strategy, goals and targets in close collaboration with the different functions globally and collaborates closely with our CEO. Supporting daily, informing and educating our Eton team regularly.

The Chair of Eton’s Board of Directors is responsible for Eton’s impact on human rights, the environment and climate. The Head of Sustainability provides the Board with a deep Dive analysis of Eton’s status and future steps and upcoming developments at least twice yearly.

The Board of Directors is the approver of this Policy.

The Group CEO is the owner of this Policy. The Group CEO shall implement and maintain this sustainability policy and commit to continual improvement of the environmental management system to enhance environmental performance.

5. Exceptions

There are no exceptions from the policy.

6. Monitoring of compliance

Through our yearly sustainability reporting we track our environmental impact as well as our progress towards set goals of reducing our emissions. We will follow up with all departments on their progress. We commit to continually improve our environmental management system to mitigate and decrease our environmental impact.

In close collaboration, regular on-site visits, and in dialogue with our business partners2 we ensure that human rights are upheld and not violated. Regularly ESG compliance audits are performed by either a 3rd party auditing firm or by our own team. We analyze and evaluate the results, and if there’s room for improvement we engage with the business partner. We have a whistle blowing function in place, and are following up on this with our suppliers.

2 Business partners is defined as our suppliers contributing to the creation of our products.

The compliance of our Anti-corruption policy is executed through trainings provided to all employees on an annual basis. Compliance is also monitored as a part of the annual risk assessment and management procedure.

The policy is reviewed on a yearly basis.

Yearly full company meeting with an Eton shirts sustainability update and outlook.

7. References

Anti-corruption Policy

Code of Conduct (internal)

Code of Conduct (external) Code of Ethics (external) Car Policy

The Eton Principles our policy for Performance, Quality, Flammability and Chemical Restrictions

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