Code of Conduct

Chilli Ideas S.R.L. – Code of Conduct
Effective date: 1 November 2026

1. Purpose and scope

This Code of Conduct sets out the standards of behaviour that Chilli Ideas S.R.L. ("Chilli Ideas", "we") applies in its business. It applies to all our employees, managers and collaborators, and to the companies under common control with Chilli Ideas when they work on our projects. We expect our suppliers, manufacturers, subcontractors and logistics partners to respect equivalent standards when they work with us or on our behalf.

This Code complements our Human Rights Policy, our Anti-Discrimination Policy and our Grievance Mechanism. Where a client's own supplier code applies to a project, we comply with it as well; if the two differ, the stricter rule applies.

2. Compliance with the law

We comply with the laws and regulations that apply to our business in every country where we operate or deliver products, including those on trade, tax, competition, labour, product safety, environment and data protection. When the law and this Code differ, we follow the higher standard.

3. Anti-bribery and anti-corruption

We do not offer, promise, give, request or accept bribes, kickbacks or any improper advantage, directly or through third parties, to or from public officials or private persons. We do not make facilitation payments. Commissions and payments to intermediaries must correspond to real, documented services and be recorded accurately.

4. Gifts and hospitality

Business gifts are our profession, which is why we apply clear rules to our own behaviour. Gifts and hospitality offered or received by our team must be modest, occasional, transparent and never intended to influence a business decision. We do not offer gifts or hospitality during a tender or negotiation with the people deciding on it, and we respect our clients' own gift policies. Anything that goes beyond a symbolic value must be approved in advance by management and recorded.

5. Conflicts of interest

Our people must avoid situations where personal or family interests conflict with the interests of Chilli Ideas or of our clients. Any actual or potential conflict, including a financial interest in a supplier or a relationship with a supplier proposed to a client, must be disclosed in writing to management and, where our contracts require it, to the client.

6. Fair competition

We compete on the merits of our ideas, quality, service and price. We do not agree prices, bids, territories or customers with competitors, and we do not exchange competitively sensitive information with them. Where we work with clients who compete with each other, we keep their information separate and confidential.

7. Confidentiality and data protection

We protect the confidential information of our clients, suppliers and partners, including designs, artwork, prices, launch plans and volumes, and use it only for the project for which it was shared. We process personal data in line with the EU General Data Protection Regulation (GDPR) and applicable national law, apply appropriate security measures and share personal data only when necessary and lawful.

8. Intellectual property and brand use

We respect the trademarks, logos, designs and copyrights of our clients and of third parties. We use a client's brand only as authorised by that client, and we do not reproduce third-party trademarks or protected designs without confirmation that the necessary rights have been obtained.

9. Human rights and working conditions

We respect internationally recognised human rights, as set out in our Human Rights Policy, and require the same from our supply chain. In particular:

• no forced, bonded, prison or trafficked labour, and no retention of workers' identity documents or deposits;
• no child labour; young workers are protected from hazardous work, night work and work that interferes with their education;
• wages and benefits at least at the legal minimum, paid on time, and working hours within legal limits, with overtime that is voluntary and properly compensated;
• respect for workers' freedom of association and right to collective bargaining, as allowed by local law;
• no discrimination, harassment or abuse of any kind, in line with our Anti-Discrimination Policy;
• safe and healthy workplaces, with appropriate training and protective equipment.

10. Responsible sourcing and supplier standards

We select manufacturers and service providers based on quality, reliability, ethical standards and cost. We communicate this Code to our suppliers and expect them to comply with it and to apply equivalent standards to their own subcontractors. Where appropriate, we request social compliance information, audit reports or certifications, and we may refuse or end a relationship with a supplier that does not meet these standards or does not correct issues within a reasonable time. We are transparent with our clients about the origin of products when our contracts require it.

11. Product safety and quality

As importer and distributor of branded products in the European Union, we take responsibility for the products we place on the market. We work to ensure that products comply with applicable EU and national requirements, including general product safety, chemical restrictions (such as REACH), toy safety and CE marking where relevant, food-contact rules and labelling, and that the necessary technical documentation and test reports are available. We take prompt action, including withdrawal or recall, if a product is found to be unsafe.

12. Environment

We aim to reduce the environmental impact of the products and services we deliver. We comply with applicable environmental and packaging rules, consolidate shipments where possible, and offer clients more durable, recycled or responsibly sourced alternatives. We encourage our suppliers to reduce waste, emissions and the use of hazardous substances.

13. Trade compliance

We comply with customs, import, export control and sanctions rules. We declare goods correctly, keep accurate origin and customs documentation, and do not do business with sanctioned persons or in breach of applicable trade restrictions.

14. Accurate records and anti-money laundering

Our books, invoices and records accurately reflect our transactions. We do not create false or misleading records, and we cooperate with legitimate audits by clients and authorities. We do not accept or make payments that could be linked to money laundering or other illegal activity.

15. Speaking up and non-retaliation

Employees, suppliers, clients and any other person can report a concern about a possible breach of this Code or of the law, openly or anonymously, through our Grievance Mechanism or by e-mail to hello@chilli-ideas.ro (please mark the subject "Confidential"). Reports are treated confidentially and acknowledged within 48 hours. We do not tolerate retaliation of any kind against anyone who raises a concern in good faith.

16. Responsibility and review

Management is responsible for implementing this Code, making it known to our team and suppliers, and providing training where needed. Breaches may lead to disciplinary measures or to the end of a business relationship. This Code is reviewed periodically and published on our website.

Geanina Ioan
CEO, Chilli Ideas S.R.L.
Bucharest, 1 November 2026