Suppliers Code of Conduct

1. Purpose and Scope

At Eataly, we believe that respect for human rights, the environment, health and safety, quality and identity is the foundation of a sustainable, ethical, and inclusive business.

Eataly’s Suppliers’ Code of Conduct (the “Code”) sets Eataly’s minimum requirements for all suppliers of goods and services, including their own suppliers/subcontractors and temporary-work agencies (collectively “Suppliers”), throughout the entire production and supply chain (e.g. cultivation, transformation, packaging and labeling, finished product production, etc.).

It applies to all tiers involved in the production chain and in any service for Eataly, including cultivation, transformation, processing, packaging, and labeling, logistics, etc.

The trust we have earned from our consumers and stakeholders rests on the integrity and responsibility that guide our everyday decisions. Our Suppliers play a vital role in sustaining this trust and in shaping our shared success, which is why we expect all those working with Eataly to uphold the highest standards of ethics, integrity, and business conduct.

We require all Suppliers acting on Eataly's behalf and/or providing goods or services to Eataly to comply with this Code, read together with the other policies of Eataly, including the Code of Ethics, the Organizational Control and Management Model pursuant to Legislative Decree no. 231/2001 (“231 Model”), the Human Rights Policy, the Sustainability Policy, and any technical specifications or disciplinary standards adopted by Eataly and applicable to the specific supply chain in which the Suppliers operate (together the “Eataly Policies”).

Suppliers must adopt adequate internal policies and measures/procedures, including appropriate monitoring systems, to ensure compliance with the Eataly Policies and to ensure that their own suppliers and subcontractors comply with equivalent principles.

Where legal or regulatory provisions govern the same aspects as this Code, the higher standard shall apply where legally possible. Where Eataly technical supply-chain specifications or disciplinary standards apply, such specifications establish additional specific requirements and prevail as minimum standards for operators in the relevant supply chain.

2. Legal Compliance and Reference Standards

Suppliers shall comply with all applicable laws and regulations in the countries where they operate and where goods/services are delivered, including food safety, employment, health and safety, environment, data protection, competition/antitrust, sanctions/export controls and anti-corruption.

Eataly expects alignment with internationally recognized standards and principles, including:

• the Universal Declaration of Human Rights

• the International Labour Organization Core Conventions and Declaration (the “ILO Convention”)

• the International Covenants on Civil and Political Rights and on Economic, Social and Cultural Rights

• the UN Guiding Principles on Business and Human Rights

• OECD Guidelines for Multinational Enterprises

• UN Global Compact Principles

• UN Sustainable Development Goals (SDGs)

• EU Corporate Sustainability Reporting Directive (CSRD), where applicable with reference to the relevant Eataly Group entity.

This Code shall be interpreted consistent with Eataly policies, where applicable. When legal and international standards differ, Suppliers shall follow the higher standard where legally possible.

3. Human Rights and Fair Labour

Suppliers must conform to the following standards:

(i) Prohibition of any form of forced labour, slavery, and human trafficking:

• Suppliers shall strictly prohibit all forms of forced or compulsory labour, including bonded, indentured, prison or slave labour, and any form of human trafficking, in line with ILO Conventions No. 29 and No. 105. Suppliers shall take appropriate steps to prevent, identify, and address any risk of forced labour in their operations and supply chain, and must inform Eataly if migrant or prison labour is used under a legal framework;

(ii) Prohibition of illegal, clandestine, or undeclared labour:

• Suppliers shall employ only individuals who are legally entitled to work and must verify their employment eligibility through valid documentation. Work should be performed under a legitimate and recognized employment relationship, in accordance with applicable national laws and regulations;

(iii) Prohibition of the exploitation of workers and their state of need, prohibition of requesting money or deposits from workers:

• employment must always be based on free choice, with workers having the right to resign or leave their job with reasonable notice;

(iv) Freedom of resignation and movement; prohibition ofretaining personal documents:

• all workers must have the right to work freely and enjoy freedom of movement without coercion, threats, or retention of personal documents (e.g., identity card, residence permit, etc.);

(v) Prohibition of child labour below the minimum legal working age in the country where the Supplier operates and prohibition of assigning minors to dangerous or inappropriate work:

• Suppliers shall not employ, directly or indirectly, individuals below the minimum legal age for employment, in accordance with ILO Conventions No. 138 and No. 182. Where young workers are lawfully engaged, their work must not endanger their health, safety, or development, nor interfere with their education. The Supplier shall take appropriate measures to prevent and address any risk of child labour in its operations and supply chain;

(vi) Prohibition of discrimination of any kind (e.g., based on gender, ethnicity, religion, disability, age, sexual orientation, etc.) and the principle of equal opportunity, fair treatment, and inclusion at workplaces:

• Suppliers shall treat all employees with dignity, respect, and integrity, ensuring fair and equal treatment in all employment practices. Discrimination on any grounds, as defined in ILO Convention No. 111, as well as any form of harassment, abuse, or intimidation, is strictly prohibited. The Supplier shall also respect employees’ privacy and ensure that any security personnel act in accordance with these same principles. Workers must be treated with dignity and respect;

• Suppliers shall prohibit any form of violence, threats/intimidation, degrading behavior, harassment or abuse;

(vii) Fair wages and benefits:

• Suppliers shall provide all employees with fair and legal compensation, including wages, benefits, and overtime, in compliance with national laws, applicable collective agreements, or industry standards. Remuneration must be sufficient to meet employees’ basic needs and those of their dependents, and no unlawful deductions, discrimination, or unfair practices shall be applied;

(viii) Working hours and work-life balance:

• Suppliers shall respect employees’ rights to rest, leisure, and a balanced work-life schedule, in compliance with applicable laws, collective agreements, and International Labour Organization standards. Working hours, breaks, leave, and overtime must be fair, voluntary, and appropriately compensated, with at least one day off after six consecutive working days;

(ix) Respect of freedom of association and collective bargaining pursuant to the applicable national/regional laws:

• Suppliers shall respect employees’ rights to freely form, join, and participate in trade unions, and to engage in collective bargaining, in accordance with applicable laws and International Labour Organization standards. Discrimination, intimidation, or retaliation related to union membership or activities is strictly prohibited, and the Supplier must take measures to prevent and address such practices;

(x) Remediation and Grievance Procedures:

• Suppliers shall take appropriate steps and measures to put in place an effective remedy mechanism to ensure human rights concerns and issues along their supply chain can be addressed.

Suppliers shall implement a documented human rights due diligence process proportionate to the risks of their respective sector and countries of operation.

This human rights due diligence process shall include and cover the following: mapping and assessment of salient risks across the supply chain; prevention and mitigation measures; periodic monitoring of effectiveness; grievance mechanisms and effective remedy for adverse impacts identified; and stakeholder engagement, paying special attention to vulnerable and migrant workers.

Upon request, the Supplier shares evidence of the process and improvement plans with Eataly.

4. Health, Safety and Working Conditions

Suppliers must conform to the following standards:

• provide a safe, healthy, and hygienic workplace for all employees, to avoid accidents at work and occupational diseases. At a minimum, this includes access to potable drinking water, proper lighting, ventilation, temperature control, sanitation, personal protective equipment, and adequately equipped workstations. Facilities must also be designed, constructed, and maintained in compliance with all applicable laws and regulations;

• identify, prevent, and mitigate risks and implement appropriate safety measures;

• provide training and necessary and adequate working tools and PPE (Personal Protective Equipment);

• comply with applicable laws and collective agreements regarding health and safety at work.

5. Local Communities and Indigenous Peoples

Where Suppliers work with local communities or indigenous peoples, as defined by the UN Declaration on the Rights of Indigenous Peoples, Suppliers must seek their free, prior, and informed consent and ensure human rights. Eataly expects Suppliers to evaluate and manage the impacts of their operations on local communities, prioritize sourcing from local partners where feasible, and promote inclusive development and fair economic conditions, with the goal of fostering positive and lasting relationships with the communities they serve.

6. Food Safety and Quality

Eataly has defined a strategy aimed at protecting product quality and identity, supply chain traceability and transparency, in particular:

• Quality: continuous controls on processes and products, rigorous food safety standards, and selected ingredients.

• Traceability and transparency: clear information on raw material origin, production methods, and supply chain journey to the consumer.

• Cultural identity: safeguarding Made in Italy and artisan knowledge, with respectful adaptation to local contexts.

• Supply chain support: long-term relationships and logistical-commercial support to enable producers and artisans to grow sustainably.

Eataly cooperates with its Suppliers to pursue the aforementioned objectives and implement best practices.

Suppliers must conform to the following standards:

• comply with all applicable product quality and food safety laws and Eataly technical specifications;

• maintain segregation to avoid commingling with non-conforming product;

• maintain effective quality and safety systems;

• notify Eataly promptly about any safety or quality concern;

• ensure full traceability of raw materials, intermediates and finished products;

Eataly has the right to determine further standards with reference to specific supply chains to which Suppliers must adhere. Suppliers shall comply with material restrictions and product safety requirements set by applicable laws and regulations. They must ensure that key personnel are informed of, and trained in, proper product safety practices.

7. Environmental Protection and Sustainability

Suppliers shall comply with all applicable environmental laws, regulations, and Eataly specifications, implementing measuresto reduce emissions, and managing waste responsibly.

Chemicals must be managed responsibly and restricted substances are to be avoided in order to ensure safe handling, storage, and disposal.

Packaging should follow sustainable design principles, minimizing material use and promoting recycling. Operations should promote circularity: reduce, reuse, and recycle materials.

Suppliers shall implement measures to reduce energy consumption and adopt energy efficiency strategies, including the use of renewable energy sources, sustainable fuels, and optimized, fuel-efficient logistics operations.

Continuous improvement of environmental performance is expected, with appropriate documentation maintained and made available upon request.

8. Legality and Business Integrity

Eataly requires all Suppliers to respect the principle of legality, understood as compliance with applicable binding local, national, and international legislation, and utmost integrity in conducting their business.

In particular, Suppliers must:

Anti-bribery and anti-money laundering: Eataly prohibits all forms of bribery, fraud, corruption, extortion, embezzlement, and money laundering. Suppliers must conduct their business with integrity and transparency, refraining from offering, promising, or accepting any improper advantage, directly or indirectly. Any gifts exchanged must be modest, reasonable, fully transparent, and never intended to secure an undue benefit. Suppliers are also required to implement measures to prevent their operations from being used for money laundering or other illicit activities.

Conflicts of interest: Suppliers are expected to avoid any situation that may create a conflict of interest. Before entering into, and during the course of, any business or contractual relationship, Suppliers must promptly disclose to Eataly and its Group any actual or potential conflict of interest, including any economic or personal ties between the Supplier and Eataly employees or contracted professionals.

Fair and transparent commercial practices: avoid unfair trading practices with agricultural suppliers; not to engage in any practice of unfair competition, abuse of dominant position or anti-competitive agreement (including those aimed at price fixing, production limitation, market sharing, boycotts, etc.).

Privacy, Confidentiality, and Data Security: Suppliers shall handle all personal, confidential, and proprietary information in compliance with applicable data protection laws and best practices, using it solely for authorized business purposes. They must implement adequate organizational and technical measures to ensure data security, prevent unauthorized access, and protect trade secrets and intellectual property. Suppliers shall also ensure that personnel processing data are properly trained and, where applicable, maintain records of processing activities, procedures for handling data subject requests, and mechanisms to report breaches without undue delay. In cases of subcontracting, confidential information may only be shared with the prior consent of Eataly.

Documentation and Transparency: Suppliers shall increase transparency and traceability therein. Suppliers must gather and store relevant documentation (e.g. compliance documentation, health and safety documentation, contractual documentation with subcontractors) which can be requested and assessed within the Audits carried out by Eataly.

Compliance with law: Suppliers undertake to comply with applicable criminal laws and, where applicable, with Italian Legislative Decree no. 231/2001 or similar national/local law, along with Eataly’s 231 Model, and to implement organizational and control models and safeguards proportionate to the risks (e.g., anti-corruption procedures, third-party due diligence, etc.).

9. Prohibition of Subcontracting

Suppliers may not subcontract any of their obligations towards Eataly unless they have received an express and specific written authorization from Eataly.

If subcontracting is authorized, the Supplier must contractually require and verify compliance with this Code by the subcontractor, including Eataly’s right to carry out audits.

10. Monitoring, Audits, and Reporting Concerns

Eataly may also qualify its Suppliers and conduct audits, including with reference to compliance with ESG standards and environmental criteria, also in relation to animal treatment, including animal welfare where applicable to the supply chain.

Particularly, Eataly may verify Suppliers’ compliance with the Code. Eataly may request information, certifications and conduct on-site or remote audits directly or via third parties. Suppliers shall grant access to information/documentation requested and cooperate, including access to sub-tier facilities involved in Eataly products.

When conditions set out under Legislative Decree no. 24/2023 (Whistleblowing legislation) are met, Suppliers shall maintain reporting mechanisms that are confidential, accessible, multilingual (where needed), and free from retaliation, for their workers and stakeholders. Any retaliation or adverse treatment against good‑faith reporters is strictly prohibited. Suppliers shall inform workers of the existence of Eataly’s reporting channel under the Whistleblowing Policy/Speak Up Procedure. Material concerns and outcomes of internal investigations connected to Eataly products/services/reputation must be promptly communicated to Eataly.

11. Non-Compliance and Corrective Action

Where Italian laws apply, Suppliers shall inform Eataly of any violation of the Code of Conduct and the 231 Model through Eataly’s whistleblowing channel: https://report.whistleb.com/it/eatalyit

In the event of non-compliance, including findings from the audits described above, depending on the seriousness of the violation, (i) Eataly is entitled to suspend or terminate the contractual relationship; (ii) Suppliers may be required to provide a corrective action plan within timelines that will be agreed with the relevant supplier.

Breaches, or refusal to remediate, may lead to suspension or termination of the relationship and, where applicable, product withdrawal/recall.

12. Acknowledgement

Before any supply contract can be entered into by and between a potential Supplier and Eataly, Suppliers must acknowledge and accept the provisions of the Code and of the 231 Model as a binding pre-requisite.

Acceptance of an Eataly purchase order constitutes a direct acceptance of this Code.

Suppliers shall ensure their employees, consultants, agents and subcontractors are informed of and comply with this Code.

13. Updates and Revisions

This Code will be regularly reviewed and updated to incorporate insights gained from our ongoing commitment to continuous improvement. The most recent version of Eataly’s Suppliers’ Code of Conduct can be accessed on our website at www.eataly.net and www.eataly.com.