Applicability 

This Policy applies to: all brands under Offspring A/S, Wheat Kids Clothing UK Ltd, Wheat Fashion Ltd, Wheat Norge AS 

Each group entity is responsible for implementing this Policy in accordance with applicable national legislation and regulatory requirements. 

 

1. Purpose 

This Code of Ethics sets out the principles and standards of conduct that guide how Offspring A/S operates, makes decisions, and behaves as a company. It reflects our commitment to acting responsibly, transparently, and with integrity in all aspects of our business. 

The Code of Ethics supports a respectful workplace, responsible governance, and compliance with applicable laws and regulations. It applies to all employees, management, and board members of Offspring A/S, as well as to relevant business partners where applicable. 

 

2. Values and ethical principles 

Offspring A/S is committed to: 

  • Acting with integrity, honesty, and fairness 

  • Respecting human rights and individual dignity 

  • Providing a safe, inclusive, and respectful workplace 

  • Complying with applicable laws, regulations, and standards 

  • Taking responsibility for the social and environmental impacts of our business 

  • Encouraging openness, accountability, and continuous improvement 

 

3. Compliance with laws and regulations 

Offspring A/S complies with all applicable local, national, and international laws and regulations in the countries where we operate. Employees and management are expected to understand and follow relevant legal requirements related to their roles, including labour law, health and safety, data protection, competition law, and anti-corruption regulations. 

 

4. Respectful workplace and equal treatment 

We are committed to providing a workplace based on respect, equality, and inclusion. 

Offspring A/S does not tolerate discrimination, harassment, or abusive behaviour based on gender, age, ethnicity, religion, disability, sexual orientation, gender identity, or any other protected characteristic. All employees are expected to treat colleagues, customers, suppliers, and partners with respect and professionalism. 

 

5. Health, safety, and wellbeing 

The health, safety, and wellbeing of employees is a priority at Offspring A/S. 

We work to provide safe and healthy working conditions and encourage a culture where risks are identified, reported, and addressed. Employees are expected to follow health and safety procedures and to contribute to a safe working environment. 

 

6. Anti-corruption, gifts, and business integrity 

Offspring A/S has a zero-tolerance approach to bribery, corruption, fraud, and unethical business practices. Employees, management, and business partners must not offer, give, solicit, or accept bribes, kickbacks, facilitation payments, or any improper advantages of any kind. 

 

7. Gifts and hospitality 

Gifts and hospitality must be modest, reasonable, infrequent, and appropriate to the business context. Cash or cash-equivalent gifts are never permitted. Any gifts or hospitality that could create a conflict of interest or the appearance of undue influence must be declined or disclosed to management. 

All business transactions must be accurately recorded in the company’s books and records. 

 

8. Conflicts of interest 

Employees and management must avoid situations where personal interests could conflict with the interests of Offspring A/S. 

Any actual or potential conflicts of interest must be disclosed promptly to management so they can be assessed and managed appropriately. 

 

9. Data protection and confidentiality 

Offspring A/S respects privacy and handles personal and confidential information responsibly. 

Employees must comply with applicable data protection laws, including GDPR, and ensure that personal data, confidential business information, and intellectual property are protected from unauthorised access or misuse. 

 

10. Whistleblowing and grievance mechanisms 

Offspring A/S encourages employees and relevant stakeholders to raise concerns about unethical behaviour, misconduct, or violations of this Code of Ethics. 

Reports can be made without fear of retaliation. Retaliation against anyone who raises a concern in good faith is strictly prohibited. 

Reporting channels, confidentiality safeguards, investigation procedures, and timelines are defined in Offspring A/S’s Whistleblower Policy, which applies alongside this Code of Ethics. 

 

11. Responsible business conduct and supply chain 

We expect our business partners and suppliers to act responsibly and ethically. 

Supplier expectations related to labour rights, human rights, environmental protection, and business integrity are defined in Offspring A/S’s Supplier Code of Conduct and related policies. 

 

12. Environment and climate  

Offspring A/S’s environmental and climate commitments are defined in the E nvironmental and Climate Policy and are implemented through the  Environmental Management System (EMS). All employees are expected to act in accordance with these commitments within their areas of responsibility. 

 

13. Responsibilities and enforcement 

Management is responsible for ensuring that this Code of Ethics is implemented, communicated, and enforced. 

Violations of this Code of Ethics may result in disciplinary action in accordance with applicable law and internal procedures. 

 

14. Review and updates 

This Code of Ethics is reviewed regularly and updated as needed to reflect changes in legislation, business activities, and best practices. 

 

15. Related documents 

Offspring A/S’s Environmental and Climate Policy 

Offspring A/S’s Environmental Management System (EMS) 

Offspring A/S’s Policy on Responsible Business Conduct 

Offspring A/S’s Supplier Code of Conduct 

Offspring A/S’s Human Rights Policy