External Code of Conduct 

The External Code of Conduct of Emma The Sleep Company (“Code”) is rooted in the belief that upholding high ethical standards creates a workplace where talent can thrive.   

The Code is essential for developing outstanding products, attracting top suppliers and investors, and earning our customers' trust. Emma Sleep GmbH and its subsidiaries (together “Emma”) are committed to conducting business in a socially responsible manner, adhering to the highest standards of human rights, labor principles, environmental stewardship, and ethical conduct.   

The Code and any “addendums” sent with such, apply to all Emma’s business partners, whether natural or legal persons, and to all individuals subcontracted by them (together “Partners”). Partners are contractually committed to following the Code and operating their business in accordance with it.

Workplace Culture 

Emma is committed to fostering a positive, inclusive, and respectful workplace environment where everyone can excel and reach their fullest potential. 

Emma believes in diversity, fairness, and inclusion, ensuring that everyone is treated with dignity and respect regardless of race, gender, age, religion, sexual orientation, or any other characteristic. 

Harassment, bullying, discrimination, intimidation, violence, abuse of power, or any form of inappropriate behavior is not tolerated. 

Conflicts of Interest 

A conflict of interest occurs when an individual’s private interests, financial or otherwise, compromise or have the potential to compromise the individual’s judgment, decision, or action in the workplace. 

Partners must avoid any situation where personal interests could conflict or appear to conflict with the interests of Emma. Conflicts of interest may arise from personal relationships with customers, suppliers, competitors, business partners, or colleagues, even if unintentionally. This is because personal relationships usually impact objective judgments and create biased decisions or actions. In case of unsurety or unclarity, Partners can reach out to their point of contact at Emma. 

If a conflict of interest cannot be avoided or has already occurred, Partners must immediately disclose it to their point of contact at Emma. Additionally, Partners can also make a report on Emma’s whistleblowing channel: Speak Up. 

Trust-based and open environment 

Emma is dedicated to maintaining a culture of transparency, integrity, and accountability. As such, Partners are encouraged to report any human rights violations, financial violations, criminal offenses, and violations of national and/or EU law and regulations in Speak Up. 

Reports made through Speak Up are strictly confidential and can be anonymous, to ensure that Partners feel safe in coming forward. Retaliation against anyone who reports violations is strictly prohibited. 

Emma's Speak Up team will thoroughly investigate all reports and take appropriate action to address any confirmed violations, safeguarding both the integrity of the process and the rights of all parties involved. 

Confidentiality 

Information can be a valuable asset. While doing business, Emma regularly exchanges information with Partners. Safeguarding Emma's ideas, technologies, processes, strategies, plans, financial data, internal reports, and other proprietary company information (together “Confidential Information”) is essential for managing business, maintaining competitive advantage, and complying with certain legal requirements. If Confidential Information is leaked to the general public, to competitors, or to investors, it can gravely hinder Emma. 

For this reason, Partners must only use Confidential Information strictly for legitimate business purposes. Unauthorized misuse of Confidential Information is strictly prohibited, whether inside or outside working hours. 

Likewise, Emma respects Partners’ sensitive information. Emma is committed to using only legal and ethical means to collect information regarding markets, customers, and competitors. 

Human Rights and Labor Practices 

Emma is dedicated to upholding the highest standards of human rights and labor practices across all its operations. Emma aims to create a work environment that respects the dignity and welfare of every individual, complying with all internationally recognized freedoms and rights. 

Discrimination based on race, gender, age, religion, sexual orientation, disability, or any other characteristic is strictly prohibited and should be immediately reported to Speak Up. Emma provides equal employment opportunities and fosters a diverse and inclusive workplace where Emmies can perform their responsibilities without fear of harm or harassment. All relevant labor and health and safety regulations should be complied with, and Emma expects her partners to take proactive measures to prevent workplace accidents and injuries. 

Compliance Officer 

The General Counsel  is the Compliance Officer of Emma, with suitable qualifications in corporate compliance to ensure company policies are effectively designed, implemented, and maintained. 

Besides the Speak Up channel, Partners can report any behaviors that do not align with the Code or applicable laws and regulations to the Compliance Officer via e-mail to compliance@emma-sleep.com. Retaliation against anyone who reports violations is strictly prohibited.   

Conclusion 

The Code is more than a set of rules; it embodies Emma’s commitment to integrity, respect, and excellence in everything it does. By adhering to these guidelines, Partners contribute to a positive and ethical work environment that fosters trust, innovation, and long-term success. As such, Emma expects all Partners, regardless of the business relationship, to be guided by both the letter and the spirit of the Code in their operations. 

By entering into a business relationship with Emma, Partners agree to communicate the contents of this Code to all employees, providers and subcontractors. Breaching the Code or applicable laws and regulations can gravely compromise Emma. For this reason, violations of the Code may constitute cause for Emma to immediately terminate the business relationship, including all associated agreements. 

Commitment to the Code is what makes Emma accomplish its mission and grow stronger every day. By working together and striving for excellence as one, Partners can ensure a brighter future for themselves and Emma. 

External Speak Up Guidelines 

What is Speak Up? 

At Emma we believe in fostering a culture of transparency, integrity, and accountability. Your voice matters, and we want to provide you with a safe and confidential way to bring serious concerns to Emma's attention.  Speak Up is available to Emma’s job candidates, suppliers and business partners, as well as Australian customers who may wish to report violations of competition law and/or consumer law. 

What is Speak Up for? 

Speak Up is meant for raising serious concerns, with proof or reasonable suspicion, investigating them in a confidential and unbiased manner, and acting upon such concerns, accordingly, ensuring the safety of the person reporting. Either as the Reporter or as an interviewed person, the Speak Up fully protects your identity and all the information you have disclosed. Your identity and what you have chosen to discuss with the Speak Up team will never be shared with others.       

Why is Speak Up important? 

Emma's success heavily depends on its business partners and their wellbeing. When you Speak Up, you are contributing to a safer and healthier workplace and promoting a culture of open communication. Emma needs your help to shed light on situations that could normally remain in the dark, so please always SPEAK UP! 

When should Speak Up be used? 

Serious concerns under Speak Up’s scope include: 

• Human rights violations (including, but not limited to) 
• Discrimination (race, gender, sexuality, political beliefs, and religion); 
• Harassment (sexual, verbal, physical, and psychological); and 
• Health and safety hazards. 
• Financial violations (including, but not limited to) 
• Fraud; 
• Improper use of company resources; 
• Violation of anti-money laundering laws; 
• Violation of tax laws; 
• Violation of sanction laws; 
• Bribery; 
• Embezzlement; and 
• Conflicts of interest. 
• Criminal offenses. 
• Violations of national and/or EU law and regulations. 

For Australian customers, Speak Up can also be used to report: 

• Breaches of Australian competition and consumer law. 

How does Speak Up work? 

1. Scan the applicable QR Code 

Australian Customers

Freelancers, Consultants, and Store Staff