Policy on Responsible Business Conduct

Applicability

This Policy applies to: all brands under Wheat A/S, Wheat Kids Clothing UK Ltd, Wheat Fashion Ltd, Wheat Norge AS

Each entity is responsible for implementing this policy in accordance with applicable national legislation and regulatory requirements.

This policy also applies to all employees and management of Wheat A/S, suppliers, subcontractors, business partners, own operations and supply chain activities.

1. Purpose

Wheat A/S is committed to conducting business in a responsible, ethical and transparent manner.

This Policy establishes our overarching commitment to responsible business conduct across:

  • Human rights and labour standards
  • Environmental protection and climate responsibility
  • Chemical management and product integrity
  • Ethical governance and business integrity
  • Responsible sourcing and supply chain management

2. Commitment

Wheat A/S commits to operate in accordance with:

  • The OECD Guidelines for Responsible Business Conduct
  • The UN Guiding Principles on Business and Human Rights
  • The Global Organic Textile Standard (GOTS) Version 7.0
  • Applicable national and international laws

We recognise that responsible business conduct is an ongoing process and requires continuous improvement.

3. Respect for Human Rights and Labour Standards

Wheat A/S respects internationally recognised human rights, including those expressed in:

  • The Universal Declaration of Human Rights
  • The ILO Core Conventions

We commit to:

  • Prohibit child labour and forced labour
  • Prohibit discrimination and harassment
  • Respect freedom of association and collective bargaining
  • Promote fair working conditions
  • Work towards closing living wage gaps
  • Ensure access to grievance mechanisms

These commitments apply to our own operations and our supply chain.

4. Environmental and Climate Responsibility

Wheat A/S commits to:

  • Reduce environmental impact across our operations and supply chain
  • Manage chemical inputs responsibly
  • Promote responsible material sourcing
  • Support renewable energy transitions within our supply chain
  • Address water use, waste, and resource efficiency
  • Prevent environmental degradation and land grabbing

Our environmental commitments are supported by our Environmental Policy and Environmental Management System.

5. Responsible Sourcing and Supply Chain Management

Wheat A/S recognises that the textile sector carries inherent risks related to labour, environment and chemical use.

We commit to:

  • Conduct risk-based human rights and environmental due diligence
  • Assess and monitor suppliers based on severity and likelihood of harm
  • Prioritise severe human rights impacts
  • Use leverage to prevent or mitigate adverse impacts
  • Cooperate in remediation where we have caused or contributed to harm

Our Supplier Code of Conduct defines minimum expectations for suppliers.

6. Due Diligence Commitment

Wheat A/S commits to conducting ongoing, risk-based due diligence in line with:

  • OECD Guidelines for Responsible Business Conduct
  • UN Guiding Principles on Business and Human Rights
  • GOTS Version 7.0 (Section 4.1)

Due diligence at Wheat A/S:

  • Covers own operations and supply chain
  • Is proportionate to risk and business context
  • Prioritises severe human rights impacts
  • Includes stakeholder engagement
  • Is documented and monitored

Where Wheat A/S:

Has caused or contributed to adverse impacts, we shall provide or cooperate in remedy.

Is directly linked through business relationships, we shall use leverage to prevent or mitigate harm.

Due diligence does not shift responsibility to suppliers, certification bodies or other third parties. Responsibility remains with Wheat A/S.

Our Due Diligence Process Manual defines implementation procedures.

7. Ethical Business Conduct and Governance

Wheat A/S commits to conducting business with integrity, including:

  • Zero tolerance for corruption and bribery
  • Responsible lobbying practices
  • Transparency in reporting
  • Protection of confidential information
  • Respect for data privacy

These commitments are detailed in our Code of Ethics and related governance policies.

8. Responsible Business Relationships

Wheat A/S seeks to ensure that its suppliers and other business partners operate in a manner consistent with internationally recognised standards on human rights, labour rights, environmental protection and ethical business conduct.

Wheat A/S does not enter into or maintain business relationships with:

  • Entities subject to EU sanctions or trade restrictions
  • Entities credibly alleged to be contributing to forced labour, corruption, conflict financing or illegal land use
  • Entities credibly alleged to be operating in violation of international humanitarian or human rights law

Where Wheat A/S engages with suppliers or partners located in conflict-affected or high-risk areas (as identified by the European Union, OECD or other internationally recognised sources), enhanced due diligence shall be carried out prior to engagement.

Enhanced due diligence may include:

  • Independent third-party social and environmental audits
  • Verified certification schemes (e.g. GOTS, OEKO-TEX, SA8000, BSCI, WRAP, ZDHC MRSL compliance)
  • Evidence of functioning grievance mechanisms
  • Time-bound corrective action plans (CAPAs)
  • Demonstrated progress towards living wages

Engagement in such regions shall only proceed where Wheat A/S determines that risks can be adequately mitigated and that the relationship does not contribute to adverse human rights or environmental impacts.

Where violations are identified, Wheat A/S will seek remediation through time-bound corrective action plans prior to considering suspension or termination of the relationship, in accordance with OECD Due Diligence Guidance.

9. Stakeholder Engagement

Wheat A/S engages relevant stakeholders to strengthen responsible business practices, including:

  • Employees
  • Suppliers
  • Workers in our supply chain
  • Certification bodies
  • Relevant civil society stakeholders

We maintain grievance mechanisms to allow concerns to be raised confidentially.

10. Governance and Oversight

The Board of Directors holds ultimate oversight responsibility for this Policy. Executive Management is accountable for implementation. The Impact Manager coordinates operational execution and reporting.

This Policy is reviewed annually and updated as necessary.

11. Related Documents

This Policy is supported by Wheat A/S's: Code of Conduct, Code of Ethics, Human Rights Policy, JEDI Commitment, Due Diligence Commitment, Due Diligence Process Manual, Environmental Policy, Environmental Management System, Wage Policy, Grievance Procedures