CODE OF ETHICS AND CONDUCT
1
OUR ETHICAL PRINCIPLES IN THE CONDUCT OF BUSINESS
And I Wonder makes sure to behave honestly and responsible manner.
Taking an ethical approach to business, in all circumstances, is a guarantee of business continuity. Our success and sustainable development in our markets depend on the trust of our customers, employees, partners, business partners and local communities. This trust is built over time and must be earned every day. Ethics in a business environment encompasses several issues that can sometimes seem contradictory. This is especially true for a company that aims to operate on multiple continents, in countries with different cultures at different stages of economic development.
However, these differences can be structured around some simple but powerful shared principles that should guide our actions in a spirit of responsibility and common sense. The And I Wonder Code of Ethics and Conduct was drawn up in 2021 following the creation of the first internationalization plan. Its ambition is to be updated regularly and follows a dual ambition:
– Establish the company’s ethical principles in a simple and methodical way.
– Address all company employees and, above and beyond them, all our partners and partners.
The ethical principles we all share are:
• act with integrity and a sense of responsibility.
• comply with laws and regulations.
• respect the dignity and rights of each individual.
• act with respect for the environment.
• use the company’s assets and resources in the interest of the business and its partners.
• encourage our employees to engage with the community and sustainability initiatives.
• respect commercial confidentiality.
The application of ethical principles in our daily lives can generate questions, which must be constantly encouraged and reinforced through example, in-depth knowledge of the subjects, training and the right to question.
In addition to the Code of Ethics and Conduct, which is the basis and frame of reference for, And I Wonder ethical business conduct, there are other documents in constant development with which it is essential to be familiar and which must be correctly applied. It is, therefore, the responsibility of each individual to deepen their knowledge of the issues that concern them, based on their specific responsibilities, through reading the documents that complement the Code, namely the Compliance Manual and respective policies and procedures.
Likewise, the company will provide each employee with a catalogue of mandatory training courses on business, services and in the future also on ethics developed for all employees and partners worldwide.
Every And I Wonder employee should be familiar with the Code and its principles, and ask questions before acting, especially if have any questions about their conduct, be aware, ask for help if do not know how to resolve the ethical dilemma, and report any problem or violation of the Code.
We are committed to preventing and penalizing any violation of the company’s Code of Ethics and Conduct and to implement all necessary corrective actions.
2
OUR PRINCIPLES OF BUSINESS PRACTICE AND BEHAVIOR IN RELATION TO OUR MAIN PARTNERS.
And I Wonder considers important to remember and clarify the principles of practice and behaviour shared by all of us, and expected of each individual in relation to the different audiences and stakeholders with which we regularly act or occasionally contact.
This concerns the:
– the company’s employees,
– our customers and consumers,
– shareholders,
– our business partners and our competitors,
– the environment,
– society in general.
COMPANY EMPLOYEES
Management: a key role in respecting our ethical rules and promoting a culture of integrity.
In order to help all employees, succeed in their roles in accordance with the company’s ethical rules, principles and conduct, the Management have a specific responsibility to embody the company’s ethical values and principles, giving the personal example and ensuring that the Code of Ethics and Conduct is properly applied and respected by the teams.
They are guarantors of the disclosure of the company’s main messages and good practices. They must be up front and fully available to listen and support their teams in case of doubt or ethical dilemma, encouraging them to freely express their doubts and concerns.
Integrity, loyalty, and responsibility
We have an obligation to act with integrity, loyalty and a sense of responsibility. In particular, we will ensure that we do not get involved in situations that may be fraudulent (corruption, conflicts of interest, misappropriation of assets, fraudulent reporting of information, etc.) or malicious.
In general, in our daily actions associated with our professional activities, in our usual workplace or on business trips, we strive to respect the company’s ethical principles, safeguarding the company’s interests and image.
Integrity, loyalty, and responsibility
We owe our colleagues and employees respect and fair treatment, and the guarantee of a motivating work environment that respects the dignity and rights of all people, promoting development and well-being. We will promote a human resources policy that contributes to the professionalism, motivation, and professional satisfaction of all, offering training, mobility and internal promotion opportunities, and developing the employability of each one.
We provide a working environment that respects human rights and labour laws, and complies with environmental, health and safety laws and regulations in all countries in which we operate.
We prohibit child labour and force labour.
We encourage the freedom of expression of the company’s employees.
We encourage dialogue and respect the free exercise of trade union rights within the context of local laws and regulations.
A work environment free from all forms of harassment
And I Wonder does not tolerate any type of harassment, discrimination, intimidation, bullying or humiliating behaviour, whether psychological, sexual or that constitutes an abuse of power. It is the responsibility of everyone not to behave in a way that could harm the dignity and rights of others.
Harassment means any repetitive voluntary pattern of hostile, abusive or humiliating behaviour, whether in the form of verbal comments, actions or gestures that endanger a person’s dignity or psychological well-being and cause a deterioration of the work environment.
It can take many forms (degrading, offensive or obscene comments, rumour or ridicule, threats, requests to perform degrading tasks, exclusion and isolation of people, etc.).
Sexual harassment is intimidation or coercion of a sexual nature and the unwanted or inappropriate promise of reward in exchange for sexual favours. It can include a range of actions ranging from minor transgressions to sexual abuse or sexual assault.
Harassment can be subject to disciplinary penalties and, in many countries, criminal prosecution.
Non-discrimination, diversity, and equal opportunities
At And I Wonder, we believe that diversity is a source of creativity and innovation, and therefore economic performance.
We are careful to develop an inclusive approach where all differences are considered, so that everyone has the opportunity to be themselves.
Therefore, we care to spread a culture of equality at all levels of the organization and offer our teams an open and stimulating work environment, free from any discrimination, which contributes to the company’s success. We promote equal opportunity and treatment. In this context, we affirm our commitment to greater diversity and gender parity in all functions and positions, and at all hierarchical levels of the company, namely putting an end to the waste of female talent in the entire chain of command.
Non-discrimination, diversity, and equal opportunities
To ensure that our employees maintain a good balance between their work and personal lives, and to promote the well-being of everyone at work, And I Wonder seeks to facilitate a supportive, caring, and productive work environment. For this purpose, the company implements policies and mechanisms that facilitate the daily life of each one and improve the quality of life at work: remote work, parental leave, compensation days, etc.
In addition, the company has the ambition to promote awareness training on domestic violence for employees and its impact on the world of work, being convinced of its responsibility to make the business a safe and welcoming place for women.
Commercial Confidentiality
In their daily exchanges and interactions with internal or external stakeholders, all employees are committed to:
•protect commercial confidentiality, respecting signed agreements and confidentiality principles that prohibit any unauthorized disclosure.
• strictly limit the disclosure of information exclusively to interested and duly authorized persons.
• maintain and protect all confidential data for which they are responsible.
• pay special attention to written and/or verbal information posted in public spaces.
Protection of personal data of employees and partners
We always recognize the value of our employees’ and partners’ data; we respect and protect their privacy.
To this end, all company employees benefit from the following rights:
• fair and transparent information prior to any further data processing and prior consent, if appropriate,
• right to object to the data processing if there is a legitimate interest,
• right to access and correct data,
• the access to data is limited to a restricted number of people,
• right to be forgotten after leaving the company, once the necessary conditions are met.
As And I Wonder operates in the footwear industry, some of its employees may have data available with a potentially high market value. And I Wonder is aware of the risk of data breach and therefore is also committed to improving data security.
Responsible use of company assets
Each employee is committed to preventing the misuse, waste or misuse of all company resources. In particular, for all material resources (telephone, vehicle, computer, etc.), all employees undertake to comply with the usage rules they have been informed about. In the case of intangible resources (internet, e-mail, etc.), personal use can be tolerated on a one-off basis, as long as it does not impair the correct performance of professional activities.
Reasonable use of social networks and personal websites
We encourage employees and partners to be ambassadors for the company. However, only persons duly authorized to do so may communicate on behalf of the company.
Talking about the company is allowed, but not on behalf of the company.
Each employee represents the company’s professional values in the public and private sphere, including on social networks and personal websites. We therefore have an obligation to act with integrity and professional judgment when expressing our views on matters that are directly or indirectly linked to the company, to preserve its image and reputation. We must ensure that there is no possible confusion between our personal opinions and interests and those of the company. For this reason, employees who act under their real identity, or whose identity is associated with their workplace on social networks and discussion forums, should mention that they act on their own and that their opinions do not reflect the image or the position of the company on the topics covered.
Ethical awareness and training
Education and ethics awareness programs will soon be available to all selected employees and partners worldwide. This program, which will be renewed according to the company’s needs and human value, gives everyone the tools to understand what is expected of them and guide their actions in full compliance with the company’s ethical, business and image principles, through scenarios specific and relevant examples. Attendance will be mandatory.
OUR CUSTOMERS AND CONSUMERS
Honesty, safety, and quality
We offer to our customers and consumers the best service to guarantee their satisfaction and trust. Through the teams, the company designs and sells products and/or services that meet current standards and norms in terms of quality, safety, industrial and intellectual property rights, and provides transparent, reliable, and fair information.
Our public relations and advertising are based on honesty and fairness having the consumer and customer safety in mind at all the time.
Protection of personal and confidential data
Our customers have the power to make decisions about the information they entrust to us, and we ensure that the confidential nature of their private data is preserved, respecting the commitments we have made to them and in accordance with applicable laws.
We respect the right of individuals to retrieve, correct or delete the data provided, when requested.
And I Wonder recognizes the value of customers data and contacts entrusted. Aware of the risk of data breaches, the company focuses not only on complying with the General Data Protection Regulation, but also on ensuring that it provides the best possible protection for its customers’ data.
To best protect itself against the risk of data breaches, the company is establishing necessary confidentiality policies inside and outside the European Union.
BUSINESS PARTNERS AND COMPETITORS
In all circumstances, we are committed to fair and equitable business relationships. The company discloses its ethical principles that should guide the conduct of business of its employees, as well as its business partners, especially with regard to compliance with laws and regulations, the prevention of any form of corruption, including influence peddling and interest conflicts.
Corruption, influence peddling, facilitation of payments
And I Wonder strictly prohibits corruption in any form, including influence peddling, and intends to prevent it by complying with applicable anti-corruption laws in each country in which operates. The company has zero tolerance in this regard.
Active corruption consists in illegally offering or promising an advantage to a person, at any time, directly or indirectly, with the aim of inciting that person to act or refrain from acting. The concept of passive corruption refers to the situation of the corrupted person. Corruption is subject to criminal penalties, whether the corrupted person works in the public or private sector. “Offering an advantage” means offering anything of value (money, of course, but also, for example, vouchers, various types of invitations, gifts, donations, promises of employment, reimbursement of travel expenses, etc.).
Regarding “influence trafficking”, these are offers, promises, donations, gifts or advantages of any kind offered directly or indirectly to a person, for themselves or for others, to encourage them to abuse their influence real or presumed for the purpose of obtaining distinctions, employments, contracts or any other favourable decision of a public authority or administration.
We prohibit facilitation payments, which means the payment of an unofficial amount of money for the purpose of facilitating, securing, or expediting the execution of an administrative decision.
The financing of political, union, cultural or charitable associations, in the name or on behalf of the company, in order to obtain direct or indirect commercial or personal sources, is also totally prohibited.
Gifts, benefits in kind, entertainment, donations and sponsorship
Each employee should ask himself if a gift, favour, or invitation, offer or offered, it is for the purpose of influencing the person who receives it.
And I Wonder employees and business partners must never promise, offer, give, solicit, or accept goods or services as gifts, services or entertainment for the purpose of gaining an advantage or exerting any influence.
The very fact of requesting, accepting, or encouraging gifts from existing or potential suppliers, customers or partners may lead to a conflict of interest, or even an act of corruption.
As the value of the gifts does not automatically lead to the conclusion that there is a conflict of interest or an act of corruption, each employee is invited to provide the management with evidence of transparency and vigilance as to the reason and legitimacy of the offer.
Donations and sponsorship agreements must be transparent and properly justified. Any planned donation to an organization must have been audited and approved in advance.
In case of doubt, the employee should contact their line manager and consult the applicable local procedures.
Conflicts of interest
And I Wonder employees must not put themselves in situations where their personal interests, or those of their family members or close relatives, could conflict with the interests of the company, or could impair their independence of judgment, professional integrity or image or reputation of the company. This is what we call a conflict-of-interest situation.
The following situations can give rise to a conflict of interest and should be avoided as they are contrary to the interests of the company:
• work, albeit voluntarily, for third parties with interests that may conflict with those of And I wonder.
• maintain personal, financial or commercial interests and foster situations that may interfere with the company's actions and/or decision-making.
• maintain inadequate working relationships with immediate superiors or subordinates.
• receive gifts or invitations that may influence personal judgment.
• influence the selection or choice of a service provider to promote personal interests or those of close relatives.
If an employee is faced with the risk of a conflict of interest, he/she must immediately inform his/her superior and refrain from any involvement in the company’s relations with the third party concerned, until a solution is found.
Fraud
Fraud generally refers to a deceptive act against an individual or company in order to incite the person or company to illegally provide money, goods or other important resources (such as valuable information).
Frequent examples of fraud coverage:
• falsification.
• Identity theft.
• fake or fraudulent bank transfers.
• cyber-attacks.
Any fraudulent act is reprehensible and disciplinary action may be taken.
Free Competition
Competition law aims to ensure that all companies compete fairly to offer high quality products and services at the best prices. We believe in free, open, and fair competition, a factor of economic and social progress in terms of prices and quality and supply scope, in the interest of the consumer.
We intend to strictly comply with applicable competition regulations in all markets where the company operates.
Commitments of our suppliers and subcontractors
Respect for human rights and fundamental freedoms are And I Wonder’s core ethical commitments and must be upheld by all of its employees and stakeholders. Therefore, our Code of Ethics and Conduct is based on the main international references of ethics and human rights.
We require our suppliers to comply with the law. We prohibit child labour and force labour. The company performs verification procedures and does not knowingly work with partners who do not share these essential principles within its business and in choosing its own service providers.
The company therefore undertakes to regularly assess its main suppliers; And I Wonder provides support and advice, if requested, to ensure they comply with its Code of Ethics and Conduct.
And I Wonder is reviewing and establishing Sustainability Principles that will be systematically communicated to all suppliers with whom the company has a contractual relationship.
ENVIRONMENT
We strive to contribute to tomorrow’s industry by keeping an eye on the preservation of the planet and its natural resources, and to reduce our impact on climate change and biodiversity loss, innovating to support future generations.
Measuring our impact beyond our own operations.
Sustainability is at the heart of the company’s strategy: it is a key element in the value creation process.
We encourage each day that our business model contributes to the improvement of the environment, the economy and society.
Given the above, And I Wonder is committed to measuring the impact of its activities on protecting natural capital and biodiversity, not only in the areas where it operates directly, but beyond, through its various supply chains, from production, from raw materials to the sale of goods and services offered by the company to its customers.
Reducing our environmental footprint
And I Wonder’s ambition is to create a company’s sustainable development strategy regarding environmental protection:
• Optimize resources in order to respect the environment and reduce CO2 emissions from the company’s activity;
• Implement responsible procurement standards for raw materials and production processes.
CIVIL SOCIETY
We reaffirm our commitment to human rights and intend to act as a socially responsible company wherever we operate. We will not tolerate threats, intimidation or attacks, whether physical or legal, against human rights defenders.
We respect the cultures of the countries where we stop. In particular, we want to contribute to economic and social development.
