1. PURPOSE

Regarding the supply chain: In order to fulfill our social responsibility, JACK WOLFSKIN has committed to acting sustainably and responsibly. As part of our business operations, we place particular emphasis on respecting human rights and protecting the environment. This includes ensuring fair, safe, and healthy working conditions throughout our global supply chain. To promote these goals, we have established a Code of Conduct that must be adhered to by all our contractual partners.

In terms of content, the Code of Conduct aligns with the requirements of the "Code of Labour Practices" of Fair Wear (a multi-stakeholder initiative of which JACK WOLFSKIN is a member). We regularly monitor compliance with these standards through independent and internal audits, continuously striving to improve their implementation in cooperation with our suppliers.

An essential tool in this regard is the complaints procedure described below. It enables us to identify human rights and environmental risks along our supply chain at an early stage and to remedy violations.

Regarding general business activities of JACK WOLFSKIN: Integrity and compliance with laws and internal rules enjoy the highest priority at JACK WOLFSKIN. JACK WOLFSKIN expects all employees across all business areas and levels to act responsibly, honestly, and in full compliance with applicable rules. This forms an integral part of our corporate culture and serves as the foundation for our strong reputation, the trust of our business partners, the well-being of all staff, and sustainable economic success.

Crucial to effective compliance is the early detection and processing of violations in order to eliminate them immediately and, if necessary, readjust existing systems. This requires the heightened vigilance of all employees and their willingness to report suspicions.

To this end, JACK WOLFSKIN has implemented a modern whistleblower system that enables confidential reporting, opens dedicated reporting channels, and ensures transparent, swift, and objective investigation.

The implementation of this whistleblower system comes with the expectation that it will be used responsibly; the whistleblower system is not a general "suggestion box" or grievance wall, and must be used exclusively to report actual or suspected violations. Whistleblowers make a vital contribution to the early detection, remediation, and ultimate prevention of breaches; they thus play a decisive role in protecting the company.

Whistleblowers need not fear any disadvantage as a result of making a report and are protected against retaliation or threats thereof. Reports may also be submitted anonymously. To this end, these guidelines summarise the core procedural rules of the JACK WOLFSKIN whistleblower system and set out binding requirements for the protection of whistleblowers.

2. SCOPE OF APPLICATION

The complaints procedures serve to receive reports of human rights and environmental risks as well as breaches of duty arising from economic activity within our own business operations [Speak Up Now] or those of a supplier [Fair Wear Complaints Procedure].

To achieve this, we operate two independent systems:

• SPEAK UP NOW (speakupnow.integrityline.com)
• Fair Wear Complaints Procedure (Fair Wear Complaints Procedure V2.0)

SPEAK UP NOW:

The opportunity to report identified or suspected violations is open not only to employees, interns, or relatives of employees, but explicitly also to employees of JACK WOLFSKIN’s business partners and other individuals who have a direct or indirect connection to JACK WOLFSKIN. The system described below applies equally to all incoming reports.

Furthermore, the complaints procedure is accessible to individuals who are not directly affected. This includes, for example:

• Employees of direct and indirect suppliers
• Business partners (e.g. customers)
• Trade unions and non-governmental organisations (NGOs)
• Other third parties (e.g. local residents near company sites)

Fair Wear Complaints Procedure:

The opportunity to report identified or suspected violations is primarily open to:

• Employees and their legitimate representatives at JACK WOLFSKIN's manufacturing partners (garment, footwear, and equipment production facilities)
• NGOs
• Other stakeholders (including media representatives) concerned with the implementation of labour standards at suppliers of Fair Wear members.

Information regarding the complaints system is displayed on posters in all production facilities. In addition, production partners are requested to actively inform and regularly train their staff on the option of submitting complaints to Fair Wear’s independent system.

JACK WOLFSKIN employees who visit production sites regularly verify whether these posters are displayed. As part of routine audits, checkers confirm whether factory workers are aware of the complaints mechanism. Where this is not the case, training sessions are initiated with the help of Fair Wear or JACK WOLFSKIN staff in the local language to ensure full comprehension among factory workers.

3. DEFINITIONS

• Reasonable suspicion: Exists when there are sufficient factual indications suggesting that a violation has occurred. Sufficient factual indications exist if, from the whistleblower's perspective, there is a plausible possibility of a breach.
• Violations: Refers to any breaches of statutory provisions, internal guidelines, and compliance principles occurring in connection with or on the occasion of an activity performed for JACK WOLFSKIN (see Section 5: Subject Matter of Reports).
• Information on violations: Refers to actual knowledge of breaches or, at the very least, reasonable suspicion supported by concrete facts.
• Reports: Notifications containing information about (potential) violations submitted to the reporting units of "SPEAK UP NOW" or the "Fair Wear Complaints Procedure".
• Whistleblowers: Any individuals who have obtained information on violations in connection with their professional activities or through other means and proceed to report them.
• Persons concerned: Individuals who are implicated or adversely affected by a submitted report.
• Retaliation: Actions or omissions related to professional activities that are triggered as a reaction to a report and result in (or may result in) an unjustified disadvantage or detriment to the whistleblower.

4. PROTECTION OF WHISTLEBLOWERS

SPEAK UP NOW:

Whistleblowers who report violations in good faith and with reasonable cause will be protected. For this purpose, the following protection mechanisms in particular are implemented:

• Duty of Confidentiality:The identity of whistleblowers will remain strictly confidential. Without their explicit consent, their identity may only be disclosed to persons responsible for receiving reports or taking follow-up action. The same applies to the identity of persons concerned or any third parties named in the report, unless disclosure is strictly necessary as part of an internal investigation or for taking follow-up measures.The duty of confidentiality does not apply to whistleblowers who intentionally or through gross negligence report incorrect or false information. Exceptions to confidentiality also apply where public authorities or courts demand disclosure; in such cases, the whistleblower will be informed prior to the disclosure of their identity, unless the respective authority or court explicitly notifies JACK WOLFSKIN that doing so would compromise ongoing investigations or judicial proceedings.
• Protection against Retaliation:Whistleblowers are protected from any form of retaliation. Discrimination, hostility, or other detrimental treatment directed at whistleblowers are strictly prohibited, as are threats or attempts thereof, and will be subject to disciplinary action under employment law. If a whistleblower experiences such impairments and turns to the responsible reporting unit, investigating office, or works council, immediate support will be provided.This protection does not apply to individuals who intentionally or through gross negligence make false reports; such cases may result in labor law sanctions, criminal prosecution, and claims for damages.
• Exemption from Liability for Obtaining Information:JACK WOLFSKIN will not hold whistleblowers liable for procuring or accessing the reported information, provided that the procurement or access itself did not constitute a criminal offense (e.g. trespass, unauthorized data interception). Nor will the whistleblower be held responsible for disclosing the information, provided they had reasonable grounds to believe that the disclosure was necessary to uncover a violation.

Fair Wear Complaints Procedure:

Whistleblowers who report violations in good faith are protected. To this end, Fair Wear has implemented the following safeguards:

• Duty of Confidentiality:Confidentiality regarding the whistleblower's identity is maintained by Fair Wear staff. Their identity may only be disclosed within Fair Wear unless consent is given. The same applies to the identity of persons concerned or others named in the report.Anonymised summaries describing the complaint and the respective supplier facility are shared simultaneously with all Fair Wear members who source goods from that facility. Fair Wear members are then called upon to address the situation with factory management in cooperation with Fair Wear’s Complaints Handler to formulate and implement a solution.
• Protection against Retaliation:Whistleblowers are protected from retaliation. Disadvantages, harassment, or other adverse actions against whistleblowers—including threats or attempts—are strictly forbidden and subject to disciplinary action. Should a whistleblower report such impairments to Fair Wear, immediate support will be provided by JACK WOLFSKIN.

5. SUBJECT MATTER OF REPORTS

SPEAK UP NOW:

The whistleblower system is intended exclusively for reporting actual or suspected violations of applicable law, as well as significant breaches of the Code of Conduct or other internal policies of the JACK WOLFSKIN Group. A breach is deemed "significant" if it poses safety, liability, or reputational risks for JACK WOLFSKIN.

For minor breaches of the Code of Conduct or internal rules, employees should seek dialogue with their direct supervisor. Furthermore, the whistleblower system is not intended for day-to-day interpersonal grievances with colleagues or line managers; channels such as the works council are available for these matters.

Reports should notably be made in cases involving:

• Corruption / Bribery
• Breaches of antitrust and competition laws, particularly procurement regulations
• Verbal, non-verbal, physical, or sexual harassment, bullying, discrimination, or workplace violence
• Breaches of employment law, occupational health and safety regulations, or human rights violations
• Fraud (e.g. fraud, breach of trust)
• Theft, damage, embezzlement, or misuse of corporate assets
• Breaches of proper accounting, financial reporting, and auditing standards
• Breaches of tax and social security laws
• Infringements of intellectual property rights
• Breaches of data protection regulations
• Breach of trade secrets, business secrets, and other confidential information
• Breaches of environmental laws, environmental duties, or significant waste of natural resources
• Conflicts of interest
• Other significant breaches of applicable law or internal JACK WOLFSKIN regulations

Fair Wear Complaints Procedure:

This system is strictly intended for actual or suspected violations of applicable laws and breaches of the Code of Conduct. The complaint hotline acts primarily as a fallback mechanism when internal grievance procedures within manufacturing plants fail, are inadequate, or when the complainant lacks confidence in the local system.

Reports should be lodged concerning contracts and payments, or other conditions posing severe health risks to workers or a high risk of long-term non-compliance. High priority is given to Code of Conduct violations that pose an immediate risk to life or health, which are fast-tracked under strict Fair Wear monitoring. These include:

• Fire and building safety hazards
• Child labour
• Wages below the statutory minimum wage
• Any other emergency situations posing immediate risk to worker safety

While freedom of association issues—such as union suppression, unfair dismissals, or retaliation against labor leaders—represent major risks for factory staff, they often require more structured, long-term remedies involving extended processes.

6. SUBMISSION OF REPORTS

Reporting Channels & Process

SPEAK UP NOW:

Whistleblowers can submit reports either to the internal reporting unit set up for each group company or to the competent public authority acting as an external reporting channel. Employees remain free to report concerns directly to supervisors, HR, the works council, or the legal department, and are protected against retaliation under both whistleblower legislation and general statutory laws.

JACK WOLFSKIN encourages all employees to submit reports internally first to ensure the fastest possible investigation and swift remediation of violations.

Reports to the internal reporting unit can be submitted at any time via the web-based reporting system SPEAK UP NOW at:

👉 speakupnow.integrityline.com

Submissions via SPEAK UP NOW are encrypted and secure. Whistleblowers can request a personal meeting with a representative of the reporting unit via the portal. Dedicated reporting channels have been established for each participating group company via a drop-down menu.

(An overview of external public reporting channels will be added here once fully established by the authorities.)

Reports are made via an input mask in SPEAK UP NOW and are currently available in English and German, with additional languages to follow. Documents or voice messages can be uploaded as needed.

Reports must always be truthful, objective, unbiased, and contain sufficient detail to enable an initial assessment and investigation. Anonymous reporting is supported. Whistleblowers should ensure that information is clear, concrete, and understandable; otherwise, investigation measures cannot be initiated.

SPEAK UP NOW offers whistleblowers (including anonymous reporters) the option to set up a secure electronic mailbox for ongoing protected communication. Setting up this mailbox is strongly recommended to facilitate necessary follow-up questions.

Fair Wear Complaints Procedure:

Complaints can be lodged with local Fair Wear complaint offices or directly with Fair Wear in Amsterdam via phone, written submission, oral report, email to complaints@fairwear.org, or through social media and messaging applications in selected countries.

Where Fair Wear or a member brand acts on media reports to launch an investigation, Fair Wear will attempt to contact affected workers to include them as complainants. If impossible, local stakeholders will be consulted.

Involved workers can choose whether to remain anonymous throughout the process. If anonymity is requested, Fair Wear guarantees that identities will not be disclosed to the factory or brand. However, to process the complaint, Fair Wear requires complainant cooperation for follow-up assessments and retaliation checks.

Regardless of anonymity choices, published Fair Wear reports never contain personally identifiable data.

If a complainant chooses not to share contact details, Fair Wear will work with the brand using alternative diagnostic tools—such as off-site worker interviews or audits—to identify the issue. This applies especially to immediate health and safety hazards.

7. PROCESSING OF REPORTS

SPEAK UP NOW:

Responsibility for Receiving Reports

The internal reporting unit established for the respective group company is responsible for receiving and processing reports. All submissions via SPEAK UP NOW are automatically routed here.

The internal reporting units are operated by lawyers from the law firm CMS Hasche Sigle ("CMS") based in Germany, under contract by the group companies. CMS ensures that potential conflicts of interest are strictly ruled out.

Receipt and Documentation

Submissions automatically notify responsible CMS attorneys upon arrival. Whistleblowers will receive an acknowledgment of receipt within 7 days.

All incoming reports are documented in a permanently retrievable, confidential manner within the SPEAK UP NOW Case Management System.

Where a personal meeting is requested, it will be documented via audio recording or written minutes, subject to the whistleblower’s consent. Whistleblowers are given the opportunity to review and correct the transcript before signing or electronically confirming its accuracy. Documentation is generally deleted when no longer required for legal compliance, typically 3 years after procedure conclusion.

Plausibility & Substance Check

CMS attorneys perform an initial plausibility and substantiation test to verify if the allegations are factually plausible and offer concrete indications warranting investigation.

Attorneys may contact whistleblowers via the secure mailbox to request additional information or clarify facts. Alternative in-person discussions can be arranged upon request.

• Lacking Plausibility/Substance: The review is formally closed, documented, and the whistleblower is informed.
• Plausible & Substantiated: The report is forwarded via SPEAK UP NOW to the responsible Internal Investigation Unit.

Fair Wear Complaints Procedure:

When a complaint is declared admissible, Fair Wear creates an investigation plan and requests feedback from the member brand and complainant. If the brand does not respond within 5 business days, Fair Wear proceeds with the original plan.

Two distinct scenarios apply:

• Scenario 1: Issue is already known (Audit Report / CAP)If the complaint refers to an issue identified in a recent audit and is already covered under a Corrective Action Plan (CAP) created within the last 90 days, Fair Wear requires the brand to address the issue within its existing remediation framework. No new investigation is initiated. Progress is tracked against the agreed CAP timeline and documented publicly on the Fair Wear website. Once remediation is verified with the complainant, the status updates to "Resolved". If no action occurs within the deadline, Fair Wear consults stakeholders regarding next steps.
• Scenario 2: Issue was previously undocumentedIf the issue is new, Fair Wear launches a full investigation. The investigation team collects factory and local evidence, culminating in an assessment report on whether the complaint is grounded.Fair Wear selects the investigation team (using local teams where available, or consulting member brands, local trade unions, IndustriALL Global Union, or labour NGOs). All parties must agree on the composition. In case of disagreement, Fair Wear acts as an independent arbiter to make the final selection.

Criteria for selecting investigation teams include:

• Accessibility
• Proficiency in local language(s) and English
• Expertise in labor law and standards
• Understanding of Fair Wear protocols
• Objectivity and independence

8. INTERNAL INVESTIGATION

SPEAK UP NOW:

Responsibilities

Once a plausible and substantiated report is received, the Internal Investigation Unit takes charge. These units are led by the Heads of Human Resources and Internal Audit, who maintain access to reports passed along by the reporting unit.

For serious violations requiring further fact-finding, the Investigation Unit instructs the Legal Department (the "Investigating Officers") to coordinate and conduct the investigation. All statutory requirements—including strict confidentiality and data protection laws—are strictly maintained. Investigating Officers act independently and free from conflicts of interest.

(If an Investigating Officer is personally implicated or a conflict arises, JACK WOLFSKIN will implement appropriate alternative procedures).

Course of Investigation

The objective is to determine whether the alleged violation occurred. Investigating Officers may interview involved parties, request documentation, and collect evidence within the scope defined by the report. No exploratory "fishing expeditions" are permitted.

Investigations are conducted neutrally and objectively under the presumption of innocence. Investigating Officers examine both incriminating and exonerating evidence.

Persons concerned will be informed of the investigation and their data privacy rights as soon as doing so no longer jeopardises the investigation. They will be granted the right to be heard to respond to allegations. Their statements will be factored into final evaluations. External experts (e.g. lawyers, auditors) may be appointed if necessary.

Conclusion and Follow-up Actions

An investigation concludes when:

1. Sufficient evidence confirms the violation did not occur;
2. Sufficient evidence confirms the violation did occur; or
3. Further fact-finding is impossible or disproportionate through reasonable means.

Upon completion, Investigating Officers draft a written Investigation Report detailing facts, findings, and conclusions.

If a violation is confirmed involving employees, the report is forwarded to HR and Legal to evaluate employment, civil liability, or legal measures. Recommended actions are included in the report.

Finally, the report is submitted to the Executive Board of the affected group company (and, where applicable, the management of JACK WOLFSKIN Ausrüstung für Draußen GmbH & Co. KGaA) for final decision and execution of follow-up measures.