PUMA : HUMAN RIGHTS GUIDELINE FOR PUMA ENTITIES

HUMAN RIGHTS GUIDELINE

FOR THE PUMA GROUP

Activity	Organizational Unit	Date	Responsibility
Development	People & Organization	Q4 2023	D. Knoess
	Corporate Sustainability		S. Seidel
	Governance & Compliance		R. Koleva
Instruction	Management Board of PUMA SE	2023	A. Freundt
			A.L Descours
			H. Hinterseher
			M. Valdes
Distribution	CEO	2024	A. Freundt
Upload on website	Corporate Sustainability	2024	S. Seidel

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Contents
Section 1: Introduction	4
Section 2: About This Human Rights Guideline	6
Section 3: Human Rights Standards at PUMA	9
3.1.	Prohibition of Child Labor	9
3.2.	Prohibition of Forced Labor and Slavery	10
3.3.	Migrant and Refugee Employees	13
3.4.	Prohibition of Discrimination	13
3.5.	No Harassment and No Abuse	15
3.6.	Compliance with Occupational Health & Safety and Wellbeing	16
3.7.	No Illegal Use of Security Forces	19
3.8.	No Harmful Pollution	19
3.9.	Freedom of Association and Collective Bargaining	19
3.10.	Fair Wages	20
3.11.	Employment Benefits	21
3.12.	Respecting Land Rights	22
Section 4: Grievance Mechanisms	22
Section 5: Training, Engagement and Communication	23
Section 6: Human Rights Risk Management and Due Diligence	25
Section 7: Preventive Measures and Remedial Actions	26
Section 8: Documentation and Reporting	27
Section 9: Data Protection	27
Legal Disclaimer	28

The external links you can click in this Guideline are shown in orange.

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Section 1: Introduction

1.1.Introductory Remarks by CEO

At PUMA, we are convinced that we have the responsibility to contribute to a better world for generations to come. We are working towards a more just and sustainable future, accelerating positive change in the industry and the world.

All human beings are born with the right to liberty and equality, and everyone is entitled to enjoy human, economic, social, environmental, and cultural rights. We are committed to respecting Human Rights and we put it at the core of all operations. Our commitments include, but are not limited to, the right to an adequate standard of living, freedom of association, equality, a safe working environment free of discrimination or any type of forced or child- labor. We have a zero-tolerance policy against violations of fundamental Human Rights.

We aim to bring our business activities in line with the principles of sustainable development and respecting Human Rights. Our Code of Ethics expresses the expectations we have of our employees. It is an important set of values that guides the way we conduct our day-to-day business. Our Human Rights Policy endorses internationally recognized Human Rights and standards. With this Guideline, we aim to provide our employees with concrete measures to ensure Human Rights at PUMA Entities such as corporate offices, owned stores, warehouses, owned factories, and distribution and logistics centers. The standards that we set also contribute to providing the best working environment and opportunities for our employees. Over many years PUMA has gained recognition through Global Top Employer, Leader in Diversity for Europe, Great Place to Work and World's Top (50) Female-Friendly companies.

We will continue our existing efforts and consistently aim for improvements in Human Rights.

Arne Freundt

Chief Executive Officer

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1.2. PUMA's Sustainability Strategy and Human Rights

PUMA's Forever Better strategy strives to create a positive impact by integrating sustainability into all its business areas. PUMA's strategy aims to balance economic, social, and environmental dimensions towards a more sustainable business development.

The Forever Better strategy clearly addresses Human Rights. PUMA does not tolerate any child labor, forced labor, all forms of slavery, disregarding occupational health and safety obligations, disregarding freedom of association, unequal treatment, not paying adequate wages, causing pollution to air, water and soil, harmful noise emission, excessive water consumption, unlawful eviction, using security forces for harmful purposes, environmental pollution in PUMA's own operations.

PUMA stands for continuous improvement and mainstream sustainability, in an effort to create positive impact and ensure industry alignment. To learn more about our strategy and targets, please check out PUMA's Sustainability website.

1.3. Governance

PUMA's Human Rights topics are governed in the following ways:

• At the Supervisory Board level, with a Sustainability Committee which holds meetings four times a year.
• At the Management Board level, where the responsibility for sustainability is assigned to the Chief Sourcing Officer (CSO), who holds monthly meetings with the sustainability leads for corporate and supply chain sustainability in addition to regular Management Board Meetings with dedicated sustainability updates.
• At the functional level, with an Executive Sustainability Committee comprised of all Functional Heads of the company such as the Human Rights Officer, Vice Presidents for People & Organization, Retail, Logistic, Legal Affairs etc.
• At the subsidiary level, the local Executive Board is responsible for ensuring compliance with Human Rights standards.
• The Management Board of PUMA SE has appointed a Human Rights Officer to monitor the implementation of the German Supply Chain Due Diligence Act (LkSG) which requires PUMA to ensure that Human Rights are respected in its own operations and in the supply chain. The Human Rights Officer is supported by an operational organization to implement PUMA's obligations and to execute all tasks of the law on an operational level. The Human Rights Officer reports directly to the Management Board of PUMA SE at least once a year, or on an ad hoc basis.
• PUMA has a Health and Safety Committee that operates in the headquarters in Herzogenaurach and conducts quarterly meetings. This committee regularly reviews existing reports on known occupational health and safety (OHS) risks, conducts frequent health and safety inspections and exchanges documentation on health issues and risks. Members of the Health and Safety Committee are OHS-specialists, amongst others, a specialized labor physician, a health and safety technician and employee representatives.

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The Vice President People & Organization, who is part of the Health and Safety Committee, informs the Management Board of PUMA SE about relevant health and safety matters at least quarterly.

At PUMA, the variable annual performance bonus is based, in part, on the achievement of PUMA's Forever Better sustainability strategy targets, which include Human Rights. All PUMA leaders globally, from CEO to Team Head level, have clearly defined sustainability targets, including Human Rights, as part of their annual performance bonus.

1.4. Human Rights Policy

PUMA is committed to ethical and responsible corporate behavior, as well as respecting Human Rights and protection of the environment in its own operations and throughout its supply chain. PUMA has a public Human Rights Policy and pledges towards upholding Human Rights stipulated by international conventions.

In addition to the Human Rights Policy, through its Annual Reports,Sustainability Handbooks and Modern Slavery and Human Trafficking Statements, which are available on PUMA's corporate website, PUMA communicates publicly about its due diligence and how it monitors progress.

Section 2: About This Human Rights Guideline

Scope of the Human Rights Guideline

This Human Rights Guideline for the PUMA Group (hereinafter referred to as "Human Rights Guideline" or "Guideline") aims to provide our PUMA Group employees the protection of Human Rights which are in accordance with national and internationally recognized principles mentioned in PUMA's Code of Ethics and the Human Rights Policy.

This Guideline follows a top-down approach and stipulates the minimum principles regarding the protection of Human Rights and the relevant processes that must be followed and implemented by all fully consolidated PUMA Entities globally (each individually, "PUMA" or "PUMA Entity" and collectively, "PUMA Group" or "PUMA Entities") including stichd and Cobra Golf.

Depending on the specific business of each PUMA Entity, the relevant and applicable principles, requirements, controls, and measures stated in this Guideline shall be complied with and locally implemented by all PUMA Entities within their corporate offices, owned stores, warehouses, owned factories, and distribution and logistics centers.

This Guideline is binding for all PUMA Entities. In cases of conflicting requirements between this Guideline and the local regulations, the stricter regulation shall prevail, provided this is in accordance with local law. PUMA Entities shall ensure the alignment of their existing policies and procedures with this Human Rights Guideline.

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This Guideline shall be reviewed at least once a year and on an ad hoc basis if PUMA expects significant changes or increase in risk exposure throughout PUMA's own operations.

Purpose

This Guideline aims to illustrate PUMA's commitments and compliance with national and international Human Rights standards, regulatory requirements and reporting standards listed below:

International Standards endorsed by PUMA:

• The International Bill of Human Rights
• The United Nations Guiding Principles on Business and Human Rights
• The International Labor Organization (ILO) Core Conventions including ILO Conventions No. 29, 87, 98, 100, 105, 111, 138, 182
• The International Labor Organization's Declaration on Fundamental Principles and
  Rights at Work
• The United Nations Global Compact Ten Principles (of which PUMA is a signatory)
• The United Nations Women Empowerment Principles (of which PUMA is a signatory)
• The OECD Guidelines for Multinational Enterprises and Due Diligence Guidance for Responsible Business Conduct
• The OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector
• The Children's Rights and Business Principles
• The Convention on the Elimination of all Forms of Discrimination Against Women
• The International Covenant on Civil and Political Rights
• The International Covenant on Economics, Social and Cultural Rights
• The European Convention on Human Rights
• Sustainable Development Goals.

Regulations and Directives

The regulatory requirements include, but are not limited to the following:

• European Union Corporate Sustainability Reporting Directive
• German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG)
• UK Modern Slavery Act
• Australian Modern Slavery Act
• California Transparency in Supply Chains Act
• France Duty of Vigilance Law.

The Guideline aims to comply with the major reporting standards and frameworks such as Global Reporting Initiative.

It is the responsibility of the Executive Board of each PUMA Entity to ensure this Guideline is implemented and followed. The implementation of this Guideline is monitored jointly by

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People & Organization, Corporate Sustainability, Compliance, Logistics and Global Retail teams. In addition, further assurance can be requested and provided by independent parties (e.g., External Audit, Internal Audit). Any feedback or suggestions for improvement are welcome.

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Section 3: Human Rights Standards at PUMA

3.1. Prohibition of Child Labor

All forms of child labor are prohibited at all PUMA Entities.

A child in this section means a person who has not reached the age of 15, or the minimum employable age mandated by the applicable law, or the age for completing compulsory education. According to the ILO, child labor means the exploitation of children through any form of work that deprives them of their childhood, their potential, and their dignity, and that harms their physical and mental development. It refers to the work that is mentally, physically, socially, or morally dangerous and harmful to children; and/or interferes with their schooling by depriving them of the opportunity to attend school; obliging them to leave school prematurely; or requiring them to attempt to combine school attendance with excessively long and heavy work. The worst forms of child labor involve children being enslaved, separated from their families, exposed to serious hazards and illnesses.

Measures and Controls
• PUMA Entities shall ensure that all its	• PUMA Entities shall ensure that the ID
employees have reached either the age of	used by new employees has not been
15; or the minimum employable age	modified or falsified. PUMA Entities only
mandated by the applicable law; or the	accept official IDs with relevant
age for completing compulsory education	signatures and stamps of official bodies.
at the location where PUMA Entities are	• Where	permissible	a copy	of this ID
conducting its business activities.	document shall be saved in each
• PUMA Entities shall not exploit children	employee's file in accordance with
under the age of 18 for any labor	applicable law. For countries which do
purposes and particularly ensure that	not issue ID cards, other documents
they do not perform activities which may	might be used to validate the age of the
cause harm to the safety, health and	employee. Examples of such documents
morals of the children. Please refer to the	include a birth certificate, a school
next section on Employment of Minors	record,	social/health	insurance
and Apprenticeship or Training Programs	documents, or other legal documents
for limitations.	stating the age and/or date of birth.
• PUMA Entities shall ensure that the age	• PUMA	Entities shall ensure	that each
of every new employee has been proven	employee file	contains	adequate
against an original and official	documentation proving their legal age.
identification (ID) card or state issued	• PUMA Entities shall always keep updated
identification number containing date of	on the minimum employable age
birth and shall ensure that the age of each	mandated by the applicable laws.
candidate is verified and documented to
ensure that no child is hired.

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Employment of Minors and Apprenticeship or Training Programs

A minor (young employee) is defined as an employee who has reached the minimum age mandated by law for employment but is under the age of adulthood (typically between 15 and 18 years). Minors can be employed by PUMA according to the restrictions of local laws.

PUMA supports Apprenticeship and Traineeship Programs for the development of skills and acquisition of future talent. Apprentice and vocational training programs shall be reserved exclusively for employees who lack necessary training or experience and therefore cannot yet be hired as regular employees. Programs shall in no way be used to undermine the implementation of every country's labor law requirement, nor legitimize modern slavery and human trafficking activities.

				Measures and Controls
• The same controls	stipulated	for	• PUMA Entities shall ensure the age of the
Prohibition of Child Labor shall be applied	apprentice, trainee or working student
by the PUMA Entities.				complies with the minimum age
• PUMA Entities shall adhere to all local	requirements outlined in this Guideline
regulations, for example working hours	and applicable laws.
restrictions for minors, including regular,	• PUMA Entities shall ensure that there is a
night, and overtime hours.			written	apprenticeship	agreement in
• Where	applicable	PUMA Entities	shall	place between the PUMA Entity and the
register	the	employee	to	the	apprentice.
correspondent government labor agency	• The agreement should state the details
and keep the documentation available for	including the start and end date of the
review.						apprenticeship (duration shall not exceed
• Where	required	PUMA	Entities	shall	the period set by local law), scope of work,
obtain a written permit from the parents	working hours (time spent on theoretical
or parents in charge and keep the	instructions count as working hours),
documentation available for review.		working conditions and remuneration.
• PUMA Entities shall protect the minors	• Where	applicable, PUMA	Entities shall
from performing heavy and dangerous	ensure that the agreement is registered
work and/or contact with hazardous	with the appropriate authorities, and the
substances.					apprentice must be provided a copy of the
						agreement.

3.2. Prohibition of Forced Labor and Slavery

3.2.1. Voluntary Labor

All forms of forced labor, as well as all forms of modern slavery are prohibited at PUMA. Employment relationships at PUMA must always be entered into on a voluntary basis and can be terminated by PUMA or the employees of their own volition in accordance with the relevant and applicable laws, regulations, and procedures.

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