What is this code about?
The Zalando Code of Ethics outlines the standards to which we as a company adhere. Based on fundamental values of honesty, respect, trust, and fairness, the code sets clear expectations for the professional, ethical, and responsible behavior of all employees.
We believe it is only by committing to be our best that we can build the great products our customers need, hire the great people our teams need, and reimagine fashion in a way that is truly for the good of all. Every one of us contributes to this purpose through everyday words and actions. Ultimately, it is these moments that make us who we are and who we can be in the future. The Code of Ethics does not tell us exactly what to do in every one of these situations but it does provide guiding principles. We ask you to act by the code and use good judgement.
To whom does this code apply?
The Zalando Code of Ethics applies to all of us. From new joiners to founders, everyone at Zalando is expected to know and follow the standards outlined in this document, and to remind others of it when appropriate. This includes all companies of the Zalando Group. Be aware that failure to apply this code can result in disciplinary action, and may even result in a termination of employment, irrespective of grades or roles. Please note that leaders have a special responsibility for shaping our culture and upholding our standards. We expect our leaders to be role models and take responsibility for their teams to behave according to this code. And when concerns are being raised, we expect leaders to listen carefully, take every concern seriously, protect confidentiality, and take action.
What if I have a question or concern?
If you experience inappropriate behavior, feel discriminated against or harassed, don’t assume that others already know. If you have a question, wish to discuss a sensitive situation, or observe behavior that is not in line with our Code of Ethics, please speak up. In some cases, the best approach might be to directly approach the involved colleague(s). In others, you might speak to your lead or ask a P&O business partner for advice. If you have experienced or witnessed direct or indirect discrimination, (sexual) harassment or bullying, the Equality Team is there for you via a protected system through firstname.lastname@example.org (More information regarding these cases can be found on zSolve).
For all compliance or ethical matters, you can turn to the Compliance & Business Ethics Team personally, via zSolve, or via email@example.com. If you wish to remain anonymous, you may also use the Whistleblowing tool.
We prohibit retaliation against any colleague who reports an incident in good faith or participates in an investigation of a possible violation of the law or our Code of Ethics. If you believe you have been retaliated against, please reach out to your lead or to the Compliance team. Every report is taken seriously, investigated promptly, and action will be taken where necessary.
Together We Win
We are a team and we can only win if we work together. Like any successful team, we care about each other, we always treat each other with dignity and respect, and we keep our shared goals in mind. We value our diversity and we are committed to a healthy, supportive and inclusive work environment where we all have the opportunity to reach our fullest potential, feel valued, and be our authentic selves. We are all custodians of Zalando’s culture and reputation. We have high expectations towards each other and our partners and we do hold each other accountable. Integrity and trust are the fundamental cornerstones of all our interactions. Upon these foundations we build long-term, sustainable relationships with our colleagues and with our business partners and other third parties:
We value diversity and foster an inclusive environment.
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 offer equal opportunities.
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 respect and care about our colleagues.
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.
We listen and encourage participation.
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 further increase trust with our partners.
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.
We Focus on What Matters
Each of us is part of Zalando’s success story and contributes to solving the most exciting problems in the fashion industry and to shaping our customer’s experiences. And we do so with expertise, passion, commitment, speed and a healthy level of risk-taking, in close collaboration with colleagues and partners. The principles below provide guidance to navigate in this agile environment:
We serve our customers.
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.
We create a productive and healthy working environment.
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 strive to be a safe and inclusive workplace.
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.
We avoid conflicts of interest.
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 Benefits, Gifts, Events Expenses.
We Act Like Owners
Entrepreneurship is at the heart of Zalando’s culture: we empower our employees, enable them and provide an environment in which we can contribute to our joint successes. We expect all Zalandos to follow the principles below:
We speak up, we listen, and we act.
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.
We get the most out of what we have.
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 keep confidentiality.
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 Follow the Law
We uphold the highest standard of integrity, which also includes complying with all applicable legal requirements. It is your responsibility to be informed, and while it is not possible for anyone to know every applicable law by heart, we expect you to take advantage of our Compliance training to understand the red lines, and to reach out to your lead or the Legal function directly in case of doubt. Violations of the law can lead to considerable fines, civil law claims, reputational damage, administrative or penal prosecution, or other severe disadvantages (e.g. loss of permits) for Zalando or you personally. We do not tolerate violations and will take appropriate actions. This is not limited to the areas of law described below, but we expect you to be especially diligent in these areas also to avoid unintentional breaches:
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 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 Don’ts” 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.
As Zalandos, our individual actions and words collectively shape our culture and our future. We are all custodians of Zalando’s integrity and success and are therefore accountable for our individual behavior. Everyday each of us is faced with new scenarios and new questions and it is impossible to anticipate them all. That is why we rely on principles to guide our actions - our Founding Mindset and this Code of Ethics (in specific sensitive areas, we have issued related policies for more guidance). These principles help us apply the right judgement to the situations we face now and in the future.
If you find yourself in a situation where you are in doubt about your own behavior, a simple test may help you make the right decision: Ask yourself: “How comfortable would I feel if I read about my behavior in the press or explained it to somebody else - for example, my partner or my colleagues at the next All Hands meeting?”