Business Partners
Code of Conduct

On the right track
Our identity is inspired by simple founding values that have always guided us “on the right track”.
As an ecosystem of iconic cycling brands, our purpose is fostering positive change by connecting humans with the outside world.
Consequently, we envision a future in which an ever-growing number of sensitive and environmentally conscious people will choose the bike as their main way of getting around, exercisingand experiencing nature.
To pursue this vision, our daily commitment is to develop, produce and market saddles, components and accessories for different kinds of bicycles and cyclists, focusing on research, technology and style to improve the cycling experience and lead the global cycling revolution.
In full adherence with our corporate principles, we want to share with our people and business
partners the values that guide our actions and decisions, responsibly, inside and outside ourorganization:

TOGETHERNESSWe act in concert with our surroundings and people. We see ourselves as part of a system that
goes beyond the single elements of our organization.

TIME
We believe we need to take back control of time. A dimension that allows us to slow down, observe,reflect, and accelerate, when necessary, with a renewed awareness.

FRICTION
We believe the friction between different ideas and points of view is key to generating innovation—just like the friction between the road and the bike wheels is essential for moving forward.

MOMENTUM
We put impetus and enthusiasm in everything we do, to lead those who are brave enough to follow
it, and build the momentum it needs to reach the finish line.

BALANCEThe secret to bike riding lies in balance. We actively work to find a balance between profit, respect
for the environment and the wellbeing of people and communities.

Dear Business Partner,
as Selle Royal Group, we believe that by partnering with all the actors of our value chain we can foster
positive change within our planet and our society.
Working with responsibility and respect towards people, planet, and communities has been part of ourcompany DNA since its origins. Today we want to build a more collaborative path and a formal governance that will allow us to evolve together, following the UN’s Sustainable Development Goals.
The Code of Conduct is a first step in this direction. It’s a document that recaps the fundamental principles that, as a company with brands and facilities around the world, we ask our business partners toread, understand, and respect. In the future, we will ask you to participate in surveys and audits that willallow us to evaluate your performance in the areas highlighted by the Code of Conduct and to cooperate in the corrective action plans that will be deemed necessary to improve it. Any future review of thisdocument will be promptly communicated to you.
The Code of Conduct was written following the social standards of our industry, including the Code ofConduct by the World Federation of Sporting Goods Industries (WFSGI) whose principles are based on
the Universal Declaration of Human Rights, relevant Conventions of the International Labour Organization (ILO), and internationally accepted occupational health and safety standards.
As a multidimensional and international organization, we are aware of the difficulties that might arise as
we start formalizing our Code of Conduct. However, we believe this is the first, essential step to create ashared vision of continuous improvement, to make sure that we are “on the right track”, together.

CALL TO COMMITMENT
We are kindly asking you to:1) Read our Business Partner Code of Conduct carefully2) Add any meaningful notes
4) Sign the commitment on these standards and principles
5) Ensure that your business partners, as well as their business partners also comply with this BusinessPartner Code of Conduct
6) Cooperate and provide all reasonable support in audits and investigations we may organize in thefuture, as well as cooperate in corrective action plans within a reasonable timing
7) Send us back a signed copy of this document to your company contact, within the communicateddeadline

Business Partner Code of Conduct
PeopleWe strive for…

1) REGULAR EMPLOYEMENT CONDITIONS• All your workers must have a written contract that adheres to local laws and practices, they are entitled to receive written and understandable information about their employment conditions in respect towages before they begin employment.
• All workers must have a wage that meets or exceeds the national legal minimum wage or the minimum wage set by the collective bargaining agreements in their respective countries. In any event, thewage should always be enough to meet basic needs and provide some discretionary income. Only legally mandated deductions from wages are allowed, and you are required not making deductions fromworkers’ wages for disciplinary purposes.
• All workers must have benefits as required by law or contract, including holidays, sick and maternity
leave, and statutory severance. You are required not imposing excessive probation periods or relying
heavily on subcontractors, temporary workers, agency workers, or apprentices.
• Unless in exceptional business circumstances, your workers shall not be required to work more than
60 hours (including overtime) per week or the local legal requirement, whichever is less. Overtime work
must be voluntary. All your workers must be granted at least 24 consecutive hours of rest within every
seven-day period.

2) DIVERSITY, EQUITY AND INCLUSION• All your workers and staff members must be treated with dignity and respect. No one should be
subjected to physical, verbal, sexual, or psychological harassment, intimidation, violence, or abuse.
• Hiring, compensation, training, promotion, termination, and retirement shall not be based on discriminatory factors such as race, caste, national origin, religion, age, disability, gender, marital status, sexual
orientation, union membership, or political affiliation. Eventual foreign or domestic migrant workers shallbe treated equally with local employees.
• All your workers have the right to join or form trade unions of their choice and to bargain collectively,
regardless of their position or status. You must respect the activities of trade unions and their organi-zational functions and, if the law restricts any right of freedom, you must facilitate the development ofalternative means. Workers’ representatives must not be discriminated against and should have accessto perform their representative functions in the workplace.
• You should promote initiatives of vulnerable groups inclusion, even above the law requirements.
• You should promote an open context of listening, wellness, development and engagement of your people, aimed at the continuous improvement, also through formal or certificated tools/actions.

3) HEALTH AND SAFETY• All your workers shall be protected from workplace hazards by the employer.
• Risk assessments shall be conducted by you to identify all relevant risks, including chemical and physical hazards.
• Appropriate measures shall be taken by to mitigate such risks, including the use of proper design, engineering and administrative controls, preventative maintenance, training, and safe work procedures.
• Personnel operating machinery shall be provided with protection through appropriate design of machines, training, preventative maintenance, and personal protective equipment.
• All your workers shall receive regular health and safety training, and such training shall be recorded.
• Clean toilet facilities and safe drinking water shall be accessible to workers and, if appropriate, sanitaryfacilities for food storage shall be provided.
• A senior management representative at each of your site shall be assigned responsibility over healthand safety.

4) NO UNDER AGE LABOR• You must not hire (or allowing to work) any individual under the age of 15, or under the local minimum
school leave or employment age, whichever the higher.
• You must implement adequate policies and procedures to verify the age of your workers and preventchild labor.
• Physically demanding and hazardous work is strictly forbidden for anyone under the age of 18.

5) NO FORCED LABOR & MODERN SLAVERY• You shall not use forced labor in any form; this includes, as an example, indentured labor, prison labor,
bonded labor and other forms of forced labor or modern slavery.
• All your workers shall have free access to their identity documents.
• All your workers shall not be required to make monetary deposits or other form of compensation forfinding employment or be required to pay, also partially, recruitment fees to their employer, recruitment
agencies or any other intermediaries.
• After a reasonable notice workers are free to leave their employer.

* These standards applies to all workers, including migrant workers (both cross-country and internal),
temporary workers, agency workers, regional workers, permanent workers, and local nationals. You
are responsible for ensuring that any intermediary employers or recruitment agencies understand andcomply with the principles outlined in this Code of Conduct.

Space For NotesPlanetWe strive for…

1) ECO-DESIGN AND RESPONSIBLE SOURCING• You are expected to integrate more and more of the principles of sustainability into your business decisions,practices, product and service development.
• You are encouraged to explore responsible sourcing of natural resources or alternative options to carbon-fossil ones.
• You should commit with us to reducing the amount of packaging associated with our products, while ensuringthat the packaging that is used is recyclable and made from sustainable materials.
• You are expected to collaborate in providing us with the required certifications and/or technical documentsthat demonstrate the eco-sustainable features of your products.
• You are expected to promote a collaborative research attitude on new eco-sustainable solutions to integrate
into our business, in the spirit of continuous improvement and co-development.

2) SUSTAINABLE OPERATIONS• You are expected to reduce, minimize, and avoid pollution or other negative environmental effects of youractivities, facilities, and services throughout the entire product life cycle. This includes, but is not limited to,
raw material sourcing, production, transport, use, disposal, and recycling.
• You are encouraged to track your CO2 emissions and set up an improvement action plan, to participate in
our commitment of net zero within 2050.
• You are encouraged to further reduce our carbon footprint; you should also consider using renewable energy
generation or renewable energy contracts, whenever possible.

3) END OF LIFE AND CIRCULAR ECONOMY• We expect you to comply with all relevant laws and regulations related to waste management and disposal.
This includes ensuring that hazardous waste is properly handled and disposed of in accordance with theapplicable laws and regulations.
• You are expected to implement waste reduction strategies and properly disposing of waste materials, andalso to explore sustainable waste management options such as composting, biodegradable packaging, andthe use of eco-friendly materials.
• You should commit with us to minimizing waste by reducing, reusing, and recycling materials whenever possible.

Space for notes

Participation
We strive for…

1) COMMUNITIES• In your daily business, you should act to create value for your stakeholders, including suppliers, customers,employees, shareholders, and the wider community in which your company is active.
• Our business partners should embrace our vision to promote social and economic development throughprojects and activities, including supporting local initiatives and organizations, promoting education and skills
development, and investing in infrastructure and facilities that benefit the wider community.

2) STAKEHOLDER ENGAGEMENT ON ESG• A development on Environmental Social and Governance goals can only succeed with true engagement fromall our stakeholders. You are required to start a path of stakeholder engagement, including all the key ones inyour ESG path.

Space for notesGovernance1) BUSINESS INTEGRITY AND LEGAL COMPLIANCE• You are expected to conduct business on the basis of sincere, fair, and transparent principles; principles thatare properly implemented and supervised.
• You are expected to comply with national and other applicable laws, with special reference to anti-trust,anti-bribery, and anti-competitive behavior. Where the provisions of law and these criteria address the same
subject, you should apply that provision which affords the greater protection.
• We expect you not to tolerate any form of bribery, corruption, or fraud - with respect to government officials orcommercial parties. Gifts, favors, or forms of entertainment to influence business decisions are also not tolerated.
• You should take a proactive approach towards identification, monitoring, and understanding of applicablelaws, regulations, and customer requirements, as well as a proactive approach towards informing and training
your employees on actions that are or could qualify as non-compliant.

2) CONFIDENTIALITY, CYBERSECURITY, AND PRIVACY• Our trade secrets, personal and other confidential information must be respected at all times, taking all necessary measures to safeguard them.
• You should implement a cybersecurity strategy and plan to guarantee data protection and business continuity.
• You are required to comply with applicable privacy and data protection laws and regulations.

Space for notes

COMPANY NAMECOMPANY REFERENCE CONTACT
Full Name
EmailSTAMP AND SIGNATURE
For acknowledgement and commitmentof a legal representative of the company

Phone