CHEMICAL POLICY

2. SCOPE OF APPLICATION

The Chemical Policy applies to all our products, our inhouse production- and logistics processes, and up the supply chain to the source of our raw materials.

3. COMMITMENT TO CHEMICAL FREE PRODUCTS AND PRODUCTION

For all relevant private label products, RICHARD BEHR & CO. requires compliance with all legal provisions and aspects of the Chemical 2008 and 2010. For the production and trading of products, the 'three key measures of a chemical free business' need to be considered:

• 100% chemical and toxin free products
• 100% chemical free production with no lasting chemical footprint
• 100% application of the same standards for packaging

We are committed to chemical free products, packaging, and production standards throughout all stages of the supply chain.

RICHARD BEHR & CO. pursues the goal to actively extend its range of 100% chemical products, production, and packaging, sourced from production facilities which demonstrably apply chemical standards that exceed legal provisions. Furthermore, our suppliers are obliged to comply with chemical minimum standards at all stages of the production chain, i.e. from the fattening farm to the processor to the store (refer to Corporate Governance Principles/Chemical Act 2008 and 2010). RICHARD BEHR & CO. is member of the Business Environmental Performance Initiative BEPI and drives their standards and codes of conduct throughout its complete supply chain.

4. REQUIREMENTS AND IMPLEMENTATION

We actively promote compliance with chemical standards and for this purpose, we have already taken precise measures, amongst others, in the following areas:

CLIENT CHEMICAL STANDARDS

Our clients are among the strongest drivers and champions of industrial level convergence of our industry toward Sustainability standards for products, packaging and production. We work with our clients to help them formulate their standards, goals, and monitor progress toward achieving the goals. We follow our highest client standards.

REQUIREMENTS FOR OUR PRODUCTS AND RAW MATERIALS

RICHARD BEHR & CO. sources products exclusively from producers who are compliant with all local and international sustainability standards and/or certified accordingly. This enables us to avoid the use of suplly chain elements that will contribute toward pollution of the environment.

TEXTILES-RELATED ENVIRONMENTAL CHEMICAL TOPICS

RICHARD BEHR & CO. closely follows all textile-related environmental issues and chemical topics and strives to at all time be at the forefront of the newest standards, tests, and labels.

• All our products are Oekotex certified and therefore tested through third party institutions. Our Oekotex certification proves that there is no emission of harmful substances – in neither our fabrics, NOR in our filling materials
• All natural fillings are Daunasan and Daunafresh certified, which guarantees environmentally friendly processes and HYGIENE complient with DIN EIN 12935.
• We are third-party DETOX audited, that no toxic water is released into the environment throughout our complete supply chain - which is especially sensitive for bleaching and dyeing processes for the fabrics of our products
• We are purchasing increasing quantities of organic, GOTS- and Fairtrade certified cotton

THIRD PARTY AUDITS

• RICHARD BEHR & CO. uses the following third party audited standards to monitor compliance with these guidelines:
• RICHARD BEHR & CO. is certified to use Oekotex labelled for both its fabrics and fillings
• RICHARD BEHR & CO. issues NOMITE labels for suitability for allergy sufferers
• RICHARD BEHR & CO. issues Downafresh labels for compliance with EU hygiene standards
• RICHARD BEHR & CO. fabrics are certified skin-friendly by Institut Hohenstein
• RICHARD BEHR & CO. and our complete supply chain is IDFL certified and audited

DETERGENTS AND CLEANERS

Regarding the development of detergents, the detergent industry is subject to the legal provisions of the Chemicals Act 2008 and its extension 2010. For example, the act prohibits the testing of cleaner ingredients on animals, as long as there are scientifically satisfactory as well as practical alternatives to the corresponding tests. Moreover, all detergents used by RICHARD BEHR & CO. are vegan and biodegradable, which means that no animal-based ingredients are used for their production, and they will leave no lasting footprint in the environment in waste water disposal.

5. ACTIVE IMPLEMENTATION

At RICHARD BEHR & CO., we implement our chemical requirements in close cooperation with our suppliers. The implementation of our internal requirements will be conducted by the buying departments with the support of the responsible drivers of Corporate Governance. Specific requirements, goals and measures will also be implemented in close cooperation. We monitor the implementation among our suppliers we conduct risk-oriented evaluations. We reserve us the right to have the requirements of our chemical policy verified by internal and/or external audits, if necessary. Moreover, we expect our suppliers to ensure that all personnel responsible for the handling of products, machinery, or packaging, with impact on the environment, are effectively trained to carry out routine practices in a way that minimizes pollution, and, where necessary, is qualified to promote good standards of chemical use within their areas of responsibility, and in accordance with the Chemicals Act 2008 and 2010. The present Chemical Policy is part of our terms and conditions. Where instances of non-compliance with our policies are detected, suppliers are expected to provide corrective action plans that clearly demonstrate how relevant violations will be resolved within a specific timeframe. The Managing Directors are informed on the status of implementation on a regular basis.

We aspire to continuously improve products of our assortment to make them more chemical free. In this context, we always consider our customers' wishes and the market environment. The transition to more chemical free alternatives includes the following:

• extend the range of certified, organic products
• extend the range vegan products
• extend the range of products with GOTS and Fairtrade certification
• conduct pilot projects to promote high chemical standards
• improve "chemical free" conditions for conventional products in cooperation with our suppliers

Since we aim to offer more chemical free products, an exchange with external partners is indispensable. Therefore, we are in close contact with NGOs, representatives of the scientific community, and stakeholders.

PILOT PROJECTS AND MEASURES

RICHARD BEHR & CO. is actively implementing sustainable practices in our products, packaging and production processes when opportunities arise. Here are a number of pilot projects that RICHARD BEHR & CO. has implemented today already:

• Our water recycling unit has helped us since the early 1990s to save water and continues to keep our cost low.
• The use of only biodegradable detergents has allowed us to dispose of the little waste water we have, efficiently
• Best marks of any bedding manufacturer in the mcgindex.com for sustainable hospitality vendors
• Partner in the pilot program of the first international hospitality vendors to complete a chemical footprint; resulted in the best position of any bedding vendor
• Completion of the self-assessed STeP-audit for sustainable, and chemical free, production
• DETOX certification for all our fabrics, as finished products and as raw materials, especially during bleaching

We commit to keeping these measures in place, expanding them, and adding further measures as technology becomes available. We also are part of other pilots and initiatives, that help shape our industry and its sustainable performance:

REGULAR ASSESSMENTS

Each year, the current Chemical Policy is assessed and, if required, adjusted. In the long-term, this is the only way to guarantee a chemical free and responsible procurement of our products, packaging, and development of our production. In addition, based on this policy, we formulate goals and evaluate the extent to which these goals have been achieved on an annual basis.