Code of Conduct

Introduction:

SKIMS BODY Inc., a Delaware corporation (“SKIMS”) has built its reputation on a commitment to producing high quality merchandise and to conducting its business in accordance with the highest ethical standards.To protect this reputation, SKIMS requires its suppliers: (i) to abide by all applicable international, federal, state, and local laws, rules and regulations governing the manufacture, assembly, inspection, packaging, storage, handling and shipment/delivery of merchandise provided to SKIMS; (ii) to agree to conduct their businesses with the highest ethical standards; (iii) to abide by the requirements of this Supplier Code of Conduct (“Code”); and (iv) not engage in any activity that results or may result in noncompliance, a conflict of interest, embarrassment or harm to SKIMS, its reputation and/or brand.If a supplier fails to comply, in any respect, with all these requirements, SKIMS may immediately and without liability terminate the Agreement.

All suppliers must always be able to demonstrate compliance with the above and below requirements at the request of SKIMS or its designated representative(s). SKIMS may at its sole discretion and at any time (without advance notice) conduct social and environmental responsibility (“SER”) audits at factories and/or facilities producing products for SKIMS.If a supplier does not have an SER program or a corporate responsibility program, SKIMS will work with such supplier to ensure that it is building its internal capabilities to monitor compliance at its facilities, but it must still comply with the requirements detailed in this Code. Please note that if differences or conflicts in our code and legal requirement arise, the highest standard shall apply.

SKIMS Code of Conduct:

The following Code of Conduct is aligned with the Fair Labor Association’s Code of Conduct and Compliance Benchmarks. It establishes the framework for our commitment to our mission and defines the minimum standards that all our employees and suppliers must meet.

SKIMS will only do business with vendors/factories that adopt and adhere to rules and conditions of employment that respect workers and, at minimum, safeguard their rights under national and international labor and social security laws and regulations.

SKIMS specially requires that all vendors/factories comply with all applicable laws and regulations relating to the exportation and importation of merchandise, including country of origin, labeling, customs classifications and valuation, and all laws prohibiting transshipment of merchandise. Where local industry standards are higher than applicable legal requirements, the higher standards apply.

Employment Relationship

SKIMS requires employers to adopt and adhere to rules and conditions of employment that respect workers and, at a minimum, safeguard their rights under national and international labor and social security laws and regulations.

Child Labor

SKIMS will not work with any vendors/factories that utilize labor under the age of 15 or under the age of completion of compulsory education, whichever is higher.

Forced Labor

SKIMS will not work with any vendors/factories that use any forced or involuntary labor, whether imprisoned, bonded, trafficked, indentured or otherwise.

Harassment & Abuse

SKIMS requires that all vendors/factories treat each employee with dignity and respect, and that they will not use corporal punishment, threats, or other forms of unlawful, physical, sexual, psychological, or verbal harassment or abuse or coercion, whether mental or physical.All our Agents/factories must implement a non-retaliation policy that allows workers to freely express their concerns about workplace conditions.

Nondiscrimination

SKIMS will not work with any vendors/factories that discriminates in their hiring and employment practices, including compensation, advancement, discipline, termination, retirement or other on the basis of race, ethnic origin, national origin, religion, age, marital status, capacity to bear children, pregnancy, HIV or any other medical status, sexual orientation, gender, political opinion, social status, legal migrant worker status, disability, or other legally protected category.

Wages and Benefits

SKIMS requires that every worker has a right to compensation for a regular work week that is sufficient to meet the worker’s basic needs and provide some discretionary income. Vendors/factories shall pay at least the minimum wage or the appropriate prevailing wage, whichever is higher, comply with all legal requirements on wages and provide any fringe benefits required by law or contract. Where compensation does not meet workers’ basic needs and provides some discretionary income, each employer shall work with SKIMS to take appropriate actions that seek to progressively realize a level of compensation that does.

Working Hours

SKIMS requires that all vendors/factories must comply with all applicable laws and regulations related to work hours, including but not limited to hours of work, overtime, maximum hours, rest day, and holidays.

The regular working hours per week shall not exceed 48 hours; other than exceptional circumstances, the total of regular and overtime hours per week must not exceed 60 hours.All overtime work shall be consensual.In addition, employees will be entitled to at least 24 consecutive hours of rest in every seven-day period. Vendors/factories must not request overtime on a regular basis and shall compensate for all overtime work at a premium rate.Vendors/factories must also provide employees with a clear written accounting statement for every pay period and must not deduct or withhold wages or benefits for disciplinary infractions.

Health, Safety & Environment

SKIMS requires that all vendors/factories provide a safe and healthy workplace setting to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of employers’ facilities.

Protection of the Environment

SKIMS requires that all vendors/factories comply with all applicable local environmental laws and regulations and adopt responsible measures to mitigate negative impacts that the workplace has on the environment.

Subcontracting

SKIMS strictly prohibits unauthorized production and requires that no Agent/factory will use any unauthorized facility for the manufacture of SKIMS merchandise or components thereof without SKIMS express prior written consent, and only after the subcontractor has entered a written commitment with SKIMS to comply with this Code of Conduct.

Freedom of Association and Collective Bargaining

SKIMS requires that all vendors/factories recognize and respect the right of employees to freedom of association and collective bargaining.

Ethical Standards

SKIMS will only work with Agents/factories that conduct their business by a set of ethical standards, which are compatible with SKIMS standards. It is strictly prohibited to offer or receive bribes, kickbacks, or any other similar unlawful or improper payments to or from our representatives, government officials, 3rd parties or any person or entity to obtain or retain business, and/or direct/shape the outcome of 3rd party QC inspections and social compliance audits.

Documentation and Monitoring

At its discretion, SKIMS, and its designated agents (including third parties) may engage in monitoring activities to confirm compliance with this Code of Conduct, including announced or unannounced on-site inspections of manufacturing facilities and employer-provided housing, reviews of books and records relating to employment matters, private interviews with employees, or certification by the Agent/factory that SKIMS Code of Conduct has been complied with. All documentation that might be needed to demonstrate compliance with this Code of Conduct shall be maintained for at least one year.

Gift Policy

SKIMS prohibits their Agents/factories the giving of any, and all gifts of any sort, no matter the value, including any type of monetary consideration, gift card, or “personal loan” to any Hybrid employee for any reason, at any time.

Security

SKIMS requires Agents/factories to maintain facility security procedures to guard against the introduction of illegal substances or non-manifest cargo into outbound shipment. All Agents/factories must cooperate with local, national, and foreign customs and drug enforcement agencies to guard against illegal shipments.