Zalando Code of Ethics

We create a company as diverse as the customers we serve. Leveraging this richness of perspectives makes us better at delivering on our promises towards our customers and partners and at supporting each other. We actively seek out different perspectives, increase diversity in decision making, and create an inclusive workplace that allows everyone to feel safe being their authentic self at work.

We constantly strive to make Zalando better, not bigger. We hire and promote based on merit and qualification only. We have zero tolerance for any types of discrimination on the basis of ethnicity, gender, religion or conviction, disability, age, or sexual identity, or any other characteristics.

We treat each other and our business partners with dignity and respect and we care about each other’s well-being. We are tolerant and honest with each other. We will not accept any bullying, offensive language, discrimination or harassment and we will take appropriate actions to protect our colleagues from all forms of harmful behavior. We have zero tolerance for cases of sexual harassment or inappropriate behavior against individuals or groups. We expect everyone to be aware when behavior is unwanted and unwelcome, and act accordingly. As Zalandos, we all take responsibility for our own respectful and ethical behavior - internally and externally.

To make the best decisions, we encourage constructive and inclusive debate. We actively listen and are willing to learn from each other, irrespective of position, background, age or experience. We support direct dialogue between leaders and all employee groups. We offer formats for feedback and participation for all Zalandos.

We collaborate and build long-term relationships with our partners and third parties, adhering to the highest standards of integrity. We continue to earn our partners’ trust through our focus on win-win-win outcomes (for customers, partners and Zalando). We are humble, honest, and reliable, and we actively seek feedback and try to understand what drives our partners.

Everything starts with the customer, and our customers’ trust is crucial to Zalando’s success. By acting responsibly, we protect our customers’ and stakeholders’ trust in Zalando and thereby the foundations of our business success as well as Zalando’s reputation. We handle customer data with the utmost care. Everyone must ensure that all of Zalando’s products are safe and comply with our Quality Management standards. We flag potential issues immediately and escalate quickly to those who need to know.

At Zalando, we have high ambitions and strive every day to rise to the challenge and give our best. We celebrate our collective success alongside each other’s professional and personal highlights. In these celebratory moments, we remain mindful and respectful of each other’s cultural backgrounds, personal beliefs, and individual choices.

We will not accept any behavior that might endanger yourself or others, which impairs performance, violates the law, or risks reputational damage for Zalando. We believe that being under the influence of alcohol when working is incompatible with this commitment. Therefore, drinking alcohol on Zalando premises during office hours is prohibited. In all other work-related situations, we expect everyone to apply judgement when consuming alcohol by, for instance, being mindful of colleagues who might still be working and of the amount of alcohol consumed. We will not accept anyone being intoxicated on Zalando premises or while conducting business activities. In addition, we have zero tolerance for any possession, consumption, or distribution of illegal drugs on Zalando premises, at Zalando events, or in any work-related context, such as business trips.

When you are in a situation in which competing loyalties could cause you to pursue personal benefit for you, your friends, or your family at the expense of Zalando, you may be faced with a conflict of interest. Examples of conflicts of interest are personal investments or business interests, conflicts arising from secondary employment, or personal relationships to vendors. Gifts, invitations or other courtesies from business partners can also lead to a conflict of interest, this is why we limit the value of business gifts and only allow appropriate entertainment. More information can be found in the Group Policy on Benefits, Gifts, Events & Expenses.

Romantic relationships between colleagues can also lead to conflicts of interest, and can require re-arrangements, i.e. change of roles or teams within Zalando. Per default, a romantic relationship within a reporting line will be presumed to be an inherent conflict of interest. Any abuse of power resulting from such a relationship will not be tolerated.

All of us should avoid conflicts of interest or situations that could be perceived as such, for example by delegating a task or decision to another colleague. If the conflict cannot be avoided, we expect you to disclose the situation to your leader or another trusted person. If you accidentally entered such a situation, or if you are in doubt, your leader or your Compliance & Business Ethics colleagues can help. More information can be found in our Group Policy on Benefits, Gifts, Events & Expenses.

We encourage and expect you to speak up and participate - share your ideas, suggestions, concerns, and comments - and in turn to listen to your colleagues. Constructive feedback and truth-seeking debate is what we are striving for, as it makes us a better company now and in the future.

All of us should act in Zalando’s best interest and carefully manage all of Zalando’s resources. This applies to Zalando’s financial resources and to all other assets, such as equipment provided by Zalando. It also applies to intangible assets such as data, our reputation, and our intellectual property rights.
Furthermore, in developing business relationships, we strive for the best deal and to work with business partners whose reliability, service and quality level, ethical standards and sustainability efforts match our level of ambition and care. We apply our Investment Principles when deciding on how to allocate resources. We take risks, but we are never reckless. We understand our risks and manage them intelligently.

We want to default to transparency and so we communicate openly and share often. But we are extremely conscious of our responsibilities to all our stakeholders and work diligently to secure business assets and information, especially data protected under the law and sensitive information under antitrust law. We only share company information if we are certain we may. We always comply with the processes on data and information security. We expect you to ask for advice with the Privacy & Technology Law team whenever you are in doubt.

We don’t accept any form of corrupt practices including, but not limited to, extortion, fraud, or bribery. We expect you to comply with the law and our internal policies to avoid even the appearance of corrupt practices, e.g. gifts may not be accepted unless permitted by, and business courtesies to government officials are restricted under our Group Policy on Benefits, Gifts, Events & Expenses.

Each employee is responsible to ensure that Zalando’s high standards of data protection are respected without exception. The Data Privacy and Confidentiality Principles provide guidance for all employees when handling data. We also train employees and have policies such as Bring Your Own Device (BYOD) and Use of Electronic Communication Media and IT setting out best practice, guidance and information for all employees, to ensure that we maintain our standards.

As a company operating on various European market, Zalando is subject to national and European antitrust regulations, which are not always easy to maneuver and provide for potentially substantial consequences in case of violations. Therefore, compliance with antitrust laws and related regulations is vital for Zalando and breaches will not be tolerated. To this end, we offer trainings, workshops and guidance in our “Do’s and Dont’s” with regard to antitrust, which must be respected. Only compliant firms will be fully able to capture business opportunities in Europe, in particular due to the dynamic development of antitrust rules for platforms and tech/data companies.

As we are a listed company, Zalando is subject to capital market regulations. Information is available for all employees with a focus on those on the insider list to comply with all applicable rules through insider training sessions. Further information can be found in our Group Policy Insider Compliance.

Zalando complies with all legal and regulatory liabilities for taxation in every country in which we operate. We continuously improve our Tax Compliance Management System to ensure that the right culture, principles, processes, organization and communication are in place to fulfill all given obligations. We offer guidance and expect you to comply with the tax requirements or to reach out to the Tax Team in case of any doubts or questions.