Code of Conduct

We believe in an honest and fair business where all employees are treated equally.

Our Code of Conduct is an outline of our expectations of our partners. As an international brand, we expect our partners to follow all the laws and regulations set out by their governing regions. We build relationships with our suppliers through trust and communication. The Code of Conduct is a way of ensuring our partners know what we expect from them.

Below you can read our Code of Conduct.

Contents

• Our Brand

• Our Approach to Social Compliance

• Code of Conduct Development

• Who is the Code of Conduct for?

• Management Systems

• Validity

• Laws

• Zero Tolerance List

• Expectations of our Suppliers

• Monitoring

• Failure to comply

• Commitment

Code of Conduct

Our Brand

Pas Normal Studios is a Copenhagen-based brand of contemporary, technical cycling clothing. The concept of Pas Normal Studios is to create technically perfect apparel combined with visionary aesthetics. Through innovative designs, brand collaborations, and sourcing of new production methods, Pas Normal Studios strives to bring out collections that define modern cycling in a different context.

Our Values

As with any club, it is all about coming together and sharing a passion. In this case, our relentless desire to ride bikes. What started as a local Copenhagen phenomenon has evolved into international group rides across six continents.

Our mission is to provide high-end, technically perfect cycling apparel combined with visionary aesthetics through honest, fair, and transparent business.

Cycling has the potential to create lasting and meaningful positive change for communities and the environment. We have a responsibility to promote this sport in the best way possible. We aim to become an industry leader in sustainable practices and reporting. We want to ensure that everyone involved with Pas Normal Studios is safe, healthy, and working responsibly.

Our Approach to Social Compliance

Our Code of Conduct (Code) outlines the expectations we hold of our suppliers. As an international brand, we require our suppliers to follow all laws and regulations set out by their governing regions. We build relationships with our suppliers through trust and communication. The Code is a way of ensuring that our suppliers know what we expect of them.

We believe in upholding honest and responsible practices when it comes to sourcing our products and services that are critical for the success of our company, protecting our brand, and advancing better social and environmental conditions in global supply chains. Therefore, we expect all our products to be produced under humane and responsible conditions and in respect of international social, environmental, and ethical standards and laws. This commitment to responsibility has implications for how we source our products. Therefore, we believe in cooperation and dialogue with our suppliers on compliance with this Code.

Code of Conduct Development

The Code specifies the ethical requirements with which the suppliers to Pas Normal Studios must comply. The following provisions derive from international declarations, conventions, and frameworks such as the Universal Declaration of Human Rights, the Core Conventions of the International Labour Organization (ILO), the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the UN Global Compact’s 10 Principles, and the United Nations Convention Against Corruption.

Who is the Code of Conduct for?

This Code applies to all entities (suppliers) engaged in a commercial relationship with Pas Normal Studios that supply finished goods/materials within the supply chain of our products.

This Code applies to the primary supplier facility as well as:

• subcontractors;

• home workers; and

• employees employed directly and indirectly by our suppliers, including contractors, seasonal, temporary, and part-time workers.

Management Systems

As a supplier of Pas Normal Studios, we expect a commitment by the supplier to the development of all aspects of the organization, including facilities, welfare, and education. This commitment should be implemented through appropriate management systems that can support the development and implementation of this Code.

Validity

This Code has a two-year validity from the date of signature, after which we will request suppliers for a renewal of commitment. We reserve the right to update this Code; suppliers are bound by the latest version of this Code as found on our website.

Laws

Any supplier with a commercial relationship with Pas Normal Studios is obligated to ensure that the conditions of this Code are respected and applied according to local laws and regulations.

Zero Tolerance List

The Code includes below a list of zero-tolerance issues. The presence of these issues will result in the immediate cancellation of all orders at the expense of the supplier, and the immediate termination of any relationship and contracts.

• Corruption or attempted bribery of Pas Normal Studios staff/auditor

• Use of forced labour in any form

• Use of prison labour

• Use of child labour

• Failure to pay minimum wage

• Inhumane, harsh treatment and physical punishment

• Lacking or inadequate fire- and emergency safety

• Overall health and safety conditions leading to unacceptable risk to workers

• Severe environmental negligence and pollution

Any evidence or suspicion of these issues must be communicated to us via the email address: impact@pasnormalstudios.com

Expectations of our Suppliers

Community Engagement

We strongly encourage the development of a sense of community within our company. We expect our suppliers to encourage and foster a positive and inclusive community in the workplace. We also expect suppliers to encourage employees to become involved with charity commitments and initiatives.

Diversity and Inclusion

We endorse a diverse working environment regarding skill, age, cultural heritage, nationality, sexuality, and gender. We praise all diversity and encourage its development in every part of our business. We expect our suppliers to provide a working environment where all employees feel included, respected, and are free to celebrate diversity.

Equal Employment Policy

We expect our suppliers to ensure that men and women receive the same pay for doing the same task.

Equal Pay

We expect our suppliers to comply with local laws and regulations relevant to wages, working hours, and employee benefits. Suppliers should not defer, delay, or withhold wages legally due to their employees. Overtime hours should be voluntary and fully compensated based on prior arrangements.

Discrimination

We endorse a working environment free from harassment, discrimination, and victimization. We believe in the equal treatment of each individual before, during, and after employment. No individual should be discriminated against due to their gender, identity, appearance, race, religion, age, or any other factor. We expect our suppliers to ensure that employees are not subject to any form of discrimination.

Harassment and Violence

We believe in a zero-tolerance approach towards physical harassment, sexual harassment, psychological harassment, violence, verbal abuse, or bullying. We expect our suppliers to ensure their employees are treated with respect and dignity. Suppliers must ensure employees are not subject to or threatened by abuse of any kind, violence, or harassment.

Child Labour

We expect our suppliers to not employ anyone: under the legal minimum age of employment; under the minimum age for completing compulsory education in that country; or under the age of 18 for work which may negatively impact their health, safety, or morals.

Contracts and Terms of Employment

We expect our suppliers to respect and protect their employees in line with national and international laws and regulations. Our suppliers must inform employees of the terms of employment in their own language regarding wages, hours, and holidays. The working week of an employee must not exceed the local allowance set by the governing body of the country. All overtime must be consensual, and compensation must be paid accordingly. Overtime must not be requested regularly by the employer.

Anti-bribery, Corruption, and Presentation of False Information

We do not tolerate the making or receiving of corrupt payments or bribes in any form. We expect our supplier to ensure that all applicable anti-corruption laws, rules, and regulations are followed. Suppliers must immediately inform Pas Normal Studios if they suspect bribery in any form.

Freedom of Association, Right to Presentation of False Information

We expect our suppliers to allow employees to join trade unions or other types of employee organizations. We expect suppliers to allow employees to engage in collective bargaining and retain the right to strike. We encourage communication between employees and their managers and representatives to resolve disputes and create a more positive and safe working environment for all.

Human Rights

We expect our suppliers to respect the rights of employees and comply with all human rights and relevant labour legislation and regulations.

Health and Safety

We expect our suppliers to provide a safe and healthy workplace for employees to minimize the risk of accidents and injury. We expect suppliers to be proactive when dealing with issues regarding health and safety. As a minimum requirement, all suppliers must abide by local laws and regulations regarding health and safety. We encourage suppliers to promote well-being and ensure employees have support available if they wish to use it.

Living Conditions/Dormitories

We expect our suppliers to provide housing to employees, ensure the standard of the accommodations meet the employee's needs, and are clean and safe.

Maternity Rights/Parental Leave

We expect suppliers at a minimum to comply with local laws regarding maternity, paternity, parental leave, and special leave arrangements. We encourage suppliers to support employees with caring responsibilities and health requirements by offering flexible hours.

Forced or Bonded Labour

We expect our suppliers not to take part in forced or bonded labour. Human trafficking is prohibited. Suppliers must monitor any suppliers assisting the employment of employees, ensuring they are following all local laws and not engaging in forced or bonded labour or human trafficking. All employees must be free to leave their roles with reasonable notice.

Notice Period, Dismissal, and Disciplinary Action

We expect our suppliers to respect the rights of employees to terminate their employment with reasonable notice. We believe all employees should receive all earned salaries and wages.

Overtime Pay

We expect our suppliers to compensate employees for any overtime worked. Overtime must be voluntary and not completed regularly. Suppliers must ensure employees agree on the payment for overtime and must not be pressured or forced into accepting terms.

Working Hours and Rest Breaks

We expect our suppliers to follow regular and overtime hours allowed by the law of the country of employment. We require our suppliers to ensure employees work the hours agreed in advance. We expect our suppliers to ensure employees can take breaks during the working day and have the right to discuss with their manager if they feel stressed, tired, or overworked. We expect our suppliers to ensure employees are paid annual leave.

Subcontracting, Outsourcing, and Homeworkers

We expect our suppliers to inform Pas Normal Studios of the use of subcontractors before production has begun and at the earliest date possible. Subcontracting is not permitted without permission from Pas Normal Studios: Any subcontractor must meet the standards of all other suppliers used by Pas Normal Studios.

Wages and Financial Benefits (e.g. bonuses, insurance, social security, pensions)

We expect our suppliers to pay employees, at a minimum, the minimum legal wage for the country or region. We encourage suppliers to pay a living wage. We expect suppliers to ensure wages are paid at the date agreed and in full. No deductions should be made for disciplinary measures or any measures not authorized. Suppliers must proactively ensure all workers are paid fairly and on time.

Animal Welfare

We believe that all animals should be treated fairly and with the utmost care. We only work with suppliers of animal products when we can be sure they treat their animals ethically. We expect our suppliers to work progressively to improve the well-being of all animals involved in the activity of the business by applying the most appropriate technologies and standards possible. Suppliers must adhere to local and international regulations regarding the treatment and use of animals and animal products.

Biodiversity and Conservation

We are committed to encouraging biodiversity and conservation. It is vital for protecting our environment and maintaining our quality of life. We expect our suppliers to encourage biodiversity and conservation.

Restricted Substances List

We expect our suppliers to ensure all chemicals used in our products comply with the EU’s Registration, Evaluation, Authorisation, and restriction of Chemicals (REACH) regulation. We expect suppliers to immediately inform us if they identify any chemicals not compliant with this regulation. We will then replace the chemical with an alternative material or process.

Energy and Carbon Emissions

We endorse efforts to reduce the energy use and carbon footprint of our suppliers. This includes measuring impact and creating a strategy to improve practices. We expect our suppliers to promote initiatives to reduce energy use and emissions.

Waste and Recycling

We believe in working to reduce waste within our supply chain. We expect our suppliers to identify areas where our supply chain can reduce waste. We expect our suppliers to encourage their employees to reduce waste and increase recycling efforts.

Water Effluents and Treatment

We expect our suppliers to ensure its operations do not negatively affect access to safe water for the community.

Water Usage and Footprint

We expect our suppliers to identify areas where our supply chain can reduce water use. We expect our suppliers to encourage their employees to reduce water use.

Monitoring

As a supplier of Pas Normal Studios, frequent communication and transparency are at the heart of our relationship. Communication regarding ethical and legal requirements is essential for preserving a successful relationship. Visits to facilities by representatives and staff of Pas Normal Studios will allow consistent updating and internal auditing to occur. Suppliers must also ensure access to facilities for external audits if requested.

Failure to Comply

Our suppliers are crucial to the success of our organization, and we trust them to operate responsibly. If a supplier is not aligned with our standards described in the Code, we will work with the supplier to ensure the standards are raised to at least those outlined in the Code. If the supplier can not operate under these standards, we will identify a new supplier.

This Code of Conduct has been approved and issued by the Pas Normal Studios.

Commitment

Please sign and return to your contact person at Pas Normal Studios.

• We confirm that we have received, read, and understood the Pas Normal Studios Supplier Code of Conduct and understand the importance of compliance to this Code by ourselves, our suppliers, and subcontractors.

• We commit to adhere to all provisions in the Code of Conduct and accept that Pas Normal Studios is entitled to cancel orders and terminate the business relationship in case of failure to comply.

• We also accept that Pas Normal Studios or anyone representing Pas Normal Studios is entitled to evaluate via questionnaires or on-site social audits all relevant facilities at any time, announced or unannounced, to monitor compliance with this Code.

• We confirm that we will promptly provide upon request accurate information and documentation regarding all products, manufacturing processes, assembly, and storage sites.

• We understand that open and transparent communication on all issues related to the provisions of this Code is a requirement for doing business with Pas Normal Studios. We understand that falsification of records, factory names, and certifications may cause termination of the business relationship with Pas Normal Studios.

• We understand that the Pas Normal Studios’ Supplier Code of Conduct is available on the customer’s website. It is the responsibility o Pas Normal Studios to keep ourselves up to date with the latest version.

Name of Company ..........................................

Main Address ...................................................

Date and Place ................................................

Signature ...........................................................