E T H I C A L S O U R C I N G P O L I C Y

KLOTHING LIMITED

What we require of every brand we list, wherever they make it

Our marketplace welcomes every brand that meets our standard. That openness only means something if the standard is real. This Policy is the standard.

PART A — PURPOSE, SCOPE AND STANDARDS

1. Purpose

1.1 KLOTHING LIMITED (NZBN 9429052132117) operates a curated head-to-toe marketplace serving New Zealand and Australia, with planned expansion into further markets.

1.2 Our brand philosophy is Product, Price and Quality. Quality that is verified at source is meaningless if the source is exploitative. This Policy is how we make that verification cover people, animals and the environment as well as workmanship.

1.3 This Policy exists to prevent, identify and address adverse human rights, labour, environmental and animal welfare impacts connected to the goods we sell.

2. Scope

2.1 This Policy applies to every brand, supplier, manufacturer, agent, importer and licensor that supplies goods listed on klothing.co.nz or sold by us in person (each a Supplier), and to our own-brand production.

2.2 It applies to every category we sell: clothing and apparel; headwear and caps; footwear; accessories and leather goods; watches; jewellery and precious stones; fragrance and grooming; and eyewear.

2.3 It applies at every tier we can reach. Suppliers must apply equivalent requirements to their own subcontractors, homeworkers, labour agents and raw material sources, and must not subcontract production without disclosing it to us.

2.4 It applies globally. Where local law sets a lower standard than this Policy, this Policy applies. Where local law sets a higher standard, local law applies. Where the two genuinely conflict, the Supplier must tell us and we will seek a resolution that upholds the higher protection for workers.

3. The standards we align to

3.1 This Policy is built on internationally recognised instruments rather than a standard of our own invention, so that a Supplier in any country can recognise what is being asked of them.

3.2 We also comply with, and require Suppliers to comply with, applicable modern slavery and forced labour law, including the UK Modern Slavery Act 2015, the Australian Modern Slavery Act 2018, the United States Uyghur Forced Labor Prevention Act and Tariff Act forced labour provisions, the EU Corporate Sustainability Due Diligence and Forced Labour Regulation regimes as they take effect, and any New Zealand modern slavery legislation once enacted.

PART B — OUR SUPPLIER CODE: LABOUR AND HUMAN RIGHTS

Every Supplier must meet each of the following. These are requirements, not aspirations.

4. Employment is freely chosen

4.1 There is no forced, bonded, indentured, trafficked or prison labour. No worker is compelled to work through threat, debt, deception or coercion.

4.2 No worker pays a fee to obtain or keep a job. Recruitment fees and related costs are borne by the employer, in line with the ILO employer-pays principle. Where a worker has already paid a fee, it must be reimbursed.

4.3 No employer retains a worker's identity documents, passport or wages as a condition of employment. Workers are free to leave after reasonable notice.

4.4 Particular care is required with migrant, contract and agency labour, and with any production in a region subject to a credible finding of state-imposed forced labour. Suppliers must disclose to us any production or raw material input from such a region.

5. No child labour

5.1 No person under 15 is employed, or under the local minimum working age or compulsory schooling age if higher.

5.2 No person under 18 performs hazardous work, night work, or work that interferes with their education, in line with ILO Convention 138 and 182.

5.3 Where child labour is found, the child's welfare comes first. The Supplier must remove the child from the workplace, support their return to education, and continue to support the family. Immediate dismissal without remediation is not an acceptable response and is itself a breach of this Policy.

5.4 Suppliers must keep verifiable age records for every worker.

6. Wages, hours and terms

6.1 Wages meet or exceed the legal minimum or the prevailing industry benchmark, whichever is higher, and are paid on time, in full, in legal tender, and directly to the worker.

6.2 We support progress towards a living wage that meets basic needs and provides discretionary income, and we will work with Suppliers who are moving towards one.

6.3 Deductions as a disciplinary measure are not permitted. All deductions must be lawful and disclosed.

6.4 Regular working hours do not exceed 48 per week. Overtime is voluntary, paid at a premium rate, and does not exceed 12 hours per week. Total hours do not exceed 60 per week other than in exceptional, short-term and documented circumstances.

6.5 Workers receive at least one day off in every seven-day period, and their legal entitlement to leave, rest breaks and public holidays.

6.6 Every worker receives written terms of employment in a language they understand before starting work.

7. Freedom of association

7.1 Workers may join or form a trade union of their choosing and bargain collectively, without discrimination, harassment, retaliation or interference.

7.2 Where the law restricts freedom of association, the Supplier must facilitate parallel means of independent and free association and bargaining, and must not obstruct them.

8. No discrimination, harassment or abuse

8.1 There is no discrimination in hiring, pay, training, promotion, discipline or termination on the basis of race, colour, ethnicity, national or social origin, caste, sex, gender identity, sexual orientation, pregnancy, marital status, age, disability, religion, political opinion, union membership or health status.

8.2 Pregnancy testing, contraception requirements and virginity testing as conditions of employment are prohibited.

8.3 There is no physical, verbal, sexual or psychological abuse, harassment, intimidation or threat, and no corporal punishment or unlawful disciplinary deduction.

8.4 Suppliers must maintain a functioning, confidential and non-retaliatory grievance mechanism accessible to every worker, including agency and migrant workers.

9. Health and safety

9.1 Workplaces and any employer-provided accommodation are safe, hygienic and compliant with applicable law.

9.2 Suppliers must assess and control risk, provide appropriate personal protective equipment free of charge, maintain unobstructed and unlocked fire exits, provide fire detection and suppression, run documented evacuation drills, and provide access to clean drinking water, sanitation and first aid.

9.3 Building and electrical safety must be certified where the law requires it. We will not accept production in a building known to be structurally unsound.

9.4 Workers handling chemicals, dyes, solvents, adhesives, polishing compounds or fragrance concentrates must receive training, ventilation, protection and health monitoring appropriate to the exposure. Sandblasting of denim is prohibited.

9.5 Serious workplace incidents connected to goods supplied to us must be reported to us within five working days.

PART C — ENVIRONMENT AND CHEMICALS

10. Environmental requirements

10.1 Suppliers must hold current environmental permits, comply with applicable environmental law, and manage discharges to air, water and land responsibly.

10.2 Wastewater from wet processing must be treated before discharge. Untreated discharge to waterways is a red line under clause 20.

10.3 Suppliers must manage waste, minimise landfill, and handle hazardous waste lawfully.

10.4 We encourage measurement and reduction of energy, water and greenhouse gas intensity, and we prefer Suppliers who can evidence it.

10.5 Materials must not be sourced from illegal deforestation or from land converted from primary forest. This applies particularly to leather, wood-based fibres including viscose and rayon, and natural rubber.

11. Restricted substances

11.1 Products must comply with the chemical restrictions applying in the market of sale, including EU REACH and applicable New Zealand, Australian and other national standards.

11.2 We require compliance with a restricted substances approach consistent with the ZDHC Manufacturing Restricted Substances List, including restrictions on azo dyes releasing carcinogenic amines, formaldehyde, chromium VI, cadmium, lead, nickel release, phthalates, PFAS and APEOs.

11.3 Products in contact with skin, and jewellery in particular, must meet applicable nickel release and lead content limits.

11.4 Fragrance and grooming Products must conform to IFRA standards and applicable cosmetic regulation, and must carry accurate allergen declarations.

PART D — MATERIALS: ANIMALS, METALS AND STONES

12. Animal-derived materials

12.1 Animal-derived materials must come from animals treated in accordance with the Five Freedoms. Suppliers must be able to identify the species and country of origin.

12.2 Where a species is listed under CITES, the Supplier must provide valid permits before we will list the Product.

13. New Zealand wool, merino and possum merino

13.1 New Zealand possum merino is a fibre we actively promote, and this clause sets out why we consider that promotion defensible, how we verify it, and the limits we place on ourselves when describing it. It is written to be read alongside clause 19, which governs how we talk about everything we sell.

The fibre and why it exists

13.2 The common brushtail possum is an introduced species in New Zealand and a declared pest. It damages indigenous forest canopy and preys on native birds, eggs and invertebrates, and it is controlled under the Biosecurity Act 1993 and successive national predator control programmes.

13.3 Fibre recovered from that control programme is a by-product of conservation work. Possums are not farmed, bred or kept for fibre in New Zealand. This is the substantive reason we are willing to list a fur-bearing fibre at all, and it is the only basis on which we will do so. The prohibition on fur in clause 12 is not displaced by this clause: we do not list possum pelts, trim or fur products, only spun fibre blended into yarn.

13.4 Suppliers must confirm that fibre is obtained from control operations conducted in accordance with the Animal Welfare Act 1999 and the trap standards approved under it, and that no trap prohibited in New Zealand has been used.

Merino and mulesing

13.5 Mulesing is prohibited in New Zealand under the Animal Welfare (Care and Procedures) Regulations 2018. Merino grown in New Zealand is therefore non-mulesed as a matter of law, not merely of supplier assurance.

13.6 For merino grown outside New Zealand, the general requirement in clause 12 applies and a supplier declaration is required. We do not extend the New Zealand regulatory position to wool that did not come from New Zealand, and we do not describe imported wool as though it did.

Licence, certification and verification

13.7 We promote a fibre, a certification or a provenance only where the brand supplying it holds the relevant licence or certification in its own name, and only where we hold a current copy of the underlying document. A supplier's verbal assurance is not evidence and is not sufficient.

13.8 Certification marks, standards marks and programme names are the property of their scheme owners and may only be used by a current licensee, within the scope of that licence. Where a mark is licensed to a manufacturer rather than to KlōTHiNG, we attribute it to that manufacturer and we do not present it as ours.

13.9 Before we publish any wool or possum merino claim we obtain, record and diarise the following. Where a field is not held, the corresponding claim is not published.

13.10 Certificates expire. We record the expiry date of every certificate we rely on, re-request it before expiry, and suspend the associated claim if a current certificate is not produced. A lapsed certificate is treated as no certificate.

13.11 We re-verify the full record in this clause at least annually, and immediately on any change of manufacturer, mill, spinner or yarn.

How we describe it

13.12 We describe what we can evidence, in the terms the evidence supports, and we attribute it. We say who certified what, under which scheme, and to whom the licence is held. We do not compress a manufacturer's certification into a general impression that KlōTHiNG itself is certified.

13.13 We distinguish clearly between: a certified fact; a manufacturer's declaration; a regulatory position that applies to a whole country; and our own preference or aspiration. These are four different things and we do not blur them.

13.14 Where a performance claim is made, such as warmth, insulation or durability relative to another fibre, it is published only with the test basis identified. A comparative performance claim without a stated test basis is not published.

13.15 Country of origin claims are made in accordance with the Fair Trading Act 1986 and Commerce Commission guidance, and fibre content and care labelling comply with the applicable consumer information standards in each market of sale.

13.16 We maintain a claims substantiation file for every wool and possum merino claim we publish, holding the evidence in clause 13.9. It is available on request to the Commerce Commission, the Australian Competition and Consumer Commission, or the equivalent regulator in any market we enter.

13.17 This discipline is what allows us to promote the fibre confidently. A claim we can prove is a commercial asset. A claim we cannot prove is a liability under clause 19.3, whatever its marketing value.

14. Precious metals, diamonds and gemstones

14.1 Suppliers of jewellery must operate due diligence consistent with the OECD Minerals Guidance and must be able to demonstrate the provenance of metals and stones.

14.2 Rough diamonds must be sourced in compliance with the Kimberley Process Certification Scheme. Polished diamonds must be accompanied by supplier warranties consistent with the World Diamond Council System of Warranties.

14.3 Laboratory-grown diamonds must be disclosed as laboratory-grown at every stage, including on the listing, invoice and certificate, in accordance with clause 16.2 of our Terms and Conditions of Supply. Non-disclosure or ambiguous description is a red line under clause 20.

14.4 Gold, silver and platinum group metals must not originate from sources financing armed conflict, and Suppliers must disclose whether metals are recycled, mined or a stated blend.

14.5 Where material is sourced from artisanal and small-scale mining, we prefer engagement and formalisation over disengagement, provided the operation is free of child labour, forced labour and mercury use in processing.

14.6 Coloured gemstones must be identified by species and treatment. Undisclosed treatment, synthetic substitution or composite material is a red line under clause 20.

PART E — HOW WE APPLY THIS POLICY

15. Onboarding due diligence

15.1 Before we list a Supplier we require: a signed acknowledgement of this Policy; disclosure of manufacturing locations at the production-unit level; disclosure of any subcontracting; the Supplier's own code, audit reports or certifications where they exist; and confirmation of category-specific requirements under Part D.

15.2 We assess inherent risk by country, category, material and production model, and we apply proportionate scrutiny. Higher-risk combinations receive more.

15.3 We accept recognised third-party audit and certification evidence in place of duplicative auditing, including SMETA, amfori BSCI, SA8000, WRAP, Fair Wear, the Responsible Jewellery Council Code of Practices, ISO 14001 and ISO 45001, and recognised material standards such as RWS, RMS, GOTS, GRS and OEKO-TEX.

15.4 A Supplier who cannot or will not disclose where their goods are made will not be listed.

16. Ongoing monitoring, and what we do today

16.1 This clause states our current practice honestly, because a policy that overstates its programme is itself a form of misrepresentation.

16.2 We reserve the right to visit, or to have an independent party visit, any site producing goods for us, with or without notice, and to request records relevant to this Policy.

17. Non-compliance, corrective action and remediation

17.1 Our default response to a breach is engagement and correction, not immediate termination. Cutting and running usually harms workers rather than helping them.

17.2 Where a breach is identified we agree a written corrective action plan with the Supplier, with defined actions, owners and deadlines, and we verify completion.

17.3 Where a person has been harmed, remediation of that harm comes before commercial considerations. This includes back-pay of unpaid or underpaid wages, reimbursement of recruitment fees, and support for a child removed from work under clause 5.3.

17.4 Where a Supplier fails to engage, misses agreed deadlines without cause, repeats a breach, or conceals information, we will suspend listings and may terminate the relationship.

17.5 Where we terminate, we will do so responsibly, giving notice and honouring committed orders where doing so does not perpetuate the harm.

18. Speaking up

18.1 Any worker, Supplier, customer or member of the public may raise a concern about conduct connected to goods we sell, by contacting [insert ethics email] or by writing to the Director at our registered office.

18.2 Concerns may be raised anonymously. We will not retaliate against anyone raising a concern in good faith, and we require Suppliers to give the same protection. Retaliation against a person who raises a concern is a red line under clause 20.

18.3 We acknowledge every report within five working days and tell the reporter the outcome where it is possible to do so without exposing them to risk.

19. Talking about this honestly

19.1 We do not publish a sustainability, ethical or provenance claim that we cannot substantiate. Where a Supplier makes a claim, we require the evidence before we repeat it.

19.2 We use precise language. We distinguish between what is certified, what is self-declared by a Supplier, and what is our own aspiration.

19.3 This is both a values position and a legal one. Unsubstantiated environmental and ethical claims are misleading conduct under the New Zealand Fair Trading Act 1986, the Australian Consumer Law, and equivalent law in other markets.

19.4 This Policy describes our sourcing requirements. It is not a warranty about any individual Product. Product-level rights are governed by our Terms and Conditions of Supply and by applicable consumer law.

20. Red lines

20.1 The following result in immediate suspension of listings pending investigation, and termination if confirmed:

21. Governance and review

21.1 The Director of KLOTHING LIMITED owns this Policy and is accountable for it.

21.2 We review this Policy at least annually, and whenever we enter a new market, add a new category, or become aware of a material risk.

21.3 Suppliers are notified of material changes and given reasonable time to comply.

22. Contact

KLOTHING LIMITED · NZBN 9429052132117

Level 1 / 18–26 Amelia Earhart Avenue, Airport Oaks, Auckland 2022, New Zealand

Ethical sourcing enquiries and reports: [insert ethics email] · klothing.co.nz

SCHEDULE 1 — SUPPLIER DECLARATION

Every Supplier completes and signs this declaration before listing, and re-confirms it annually.

Signed for and on behalf of the Supplier: ______________________________ Name: ______________________________

Position: ______________________________ Date: ______________________________

VERSION CONTROL AND RELATED DOCUMENTS

Version 1.0 · Effective 18 August 2026 · Approved by the Director, KLOTHING LIMITED.

Related documents: Terms and Conditions of Supply (Version 1.0); Website Terms of Use (Version 1.0); Shipping and Delivery (Version 1.0); Global Privacy Policy (Version 1.0); Returns Policy.

This Policy is reviewed at least annually and published at klothing.co.nz.