Code of Ethics

BRENDRATTI INC.

Code of Ethics & Business Conduct

Version 1.0

1. PURPOSE

Brendratti Inc. ("Brendratti," the "Company") is committed to conducting business with integrity, responsibility, transparency, and respect.

As a California corporation designing luxury resortwear inspired by the elegance of coastal living and handcrafted in Italy, our reputation is built upon the trust of our clients, employees, artisans, suppliers, investors, and communities.

This Code of Ethics establishes the principles that guide every decision we make and every relationship we build.

Compliance with this Code is required of:

• Directors
• Officers
• Employees
• Consultants
• Contractors
• Suppliers
• Manufacturing partners
• Agents
• Representatives
• Any individual acting on behalf of Brendratti.

2. OUR PURPOSE

Brendratti exists to create timeless luxury resortwear that celebrates effortless sophistication, exceptional craftsmanship, and modern elegance.

Our collections unite:

• California creativity
• Italian artisan excellence
• Sustainable luxury
• Exceptional client experiences

We believe true luxury is defined not only by beautiful products but by responsible business practices.

3. OUR VALUES

Every decision at Brendratti reflects the following principles:

Integrity

We do the right thing—even when no one is watching.

Excellence

We pursue uncompromising quality in design, craftsmanship, service, and execution.

Respect

We treat every individual with dignity, fairness, and professionalism.

Creativity

Innovation and artistic expression are fundamental to our identity.

Responsibility

We acknowledge our responsibility to people, communities, and the environment.

Transparency

We communicate honestly with our employees, partners, clients, and stakeholders.

Craftsmanship

We honor Italian artisanship while embracing modern innovation.

4. COMPLIANCE WITH LAW

Brendratti conducts business in full compliance with:

• California law
• United States federal law
• Italian law
• European Union regulations where applicable
• International trade laws
• Customs regulations
• Import/export regulations
• Labor laws
• Environmental regulations
• Anti-corruption laws

Employees are expected to understand the legal requirements applicable to their responsibilities.

No business objective justifies violating the law.

5. HUMAN RIGHTS

Brendratti supports internationally recognized human rights including:

• Universal Declaration of Human Rights
• International Labour Organization standards
• UN Guiding Principles on Business and Human Rights

We prohibit:

• Forced labor
• Human trafficking
• Child labor
• Modern slavery
• Coercion
• Abuse
• Exploitation

These standards extend throughout our supply chain.

6. DIVERSITY, EQUITY & INCLUSION

Luxury is global.

Our workforce, customers, and partners represent diverse cultures and perspectives.

Brendratti provides equal opportunity regardless of:

• Race
• Color
• National origin
• Ancestry
• Citizenship
• Religion
• Age
• Disability
• Gender
• Gender identity
• Gender expression
• Sexual orientation
• Marital status
• Veteran status
• Pregnancy
• Any legally protected characteristic.

Discrimination, harassment, retaliation, or bullying will not be tolerated.

7. RESPECTFUL WORKPLACE

Every employee deserves:

• Safety
• Respect
• Inclusion
• Professional development
• Equal opportunity

Brendratti prohibits:

• Workplace harassment
• Sexual harassment
• Intimidation
• Violence
• Retaliation
• Abuse of authority

We encourage open communication and respectful collaboration.

8. HEALTH & SAFETY

We are committed to providing safe workplaces in California, Italy, and all operating locations.

Every employee shares responsibility for maintaining:

• Safe facilities
• Healthy working conditions
• Proper equipment
• Emergency preparedness
• Compliance with occupational safety regulations

No employee should ever compromise safety for productivity.

9. ETHICAL SOURCING

Luxury begins with responsible sourcing.

Brendratti works only with suppliers who share our commitment to:

• Ethical labor
• Safe workplaces
• Fair wages
• Environmental stewardship
• Transparency
• Legal compliance

Our Italian manufacturing partners are expected to maintain the highest standards of craftsmanship and ethical production.

10. MADE IN ITALY HERITAGE

Italian craftsmanship is central to the Brendratti identity.

We proudly support:

• Traditional artisans
• Skilled manufacturing
• Authentic production
• Heritage techniques
• Responsible innovation

We accurately represent the origin of our products and comply with all applicable country-of-origin regulations.

11. PRODUCT QUALITY

Our clients expect exceptional quality.

Every Brendratti product must reflect:

• Precision
• Durability
• Luxury materials
• Superior construction
• Authenticity
• Attention to detail

Employees must never compromise product integrity.

12. ENVIRONMENTAL RESPONSIBILITY

Luxury must respect the planet.

Brendratti seeks to minimize environmental impact through:

• Responsible sourcing
• Reduced waste
• Energy efficiency
• Sustainable packaging
• Responsible logistics
• Lower carbon emissions
• Circular design practices where practical

We continuously evaluate opportunities to improve environmental performance.

13. ANIMAL WELFARE

Where animal-derived materials are used, they must be sourced responsibly.

Brendratti requires suppliers to comply with internationally recognized animal welfare standards.

We reject:

• Cruel treatment
• Illegal wildlife trade
• Endangered species
• Inhumane farming practices

14. CLIENT EXPERIENCE

Luxury service requires professionalism.

Employees shall:

• Treat clients with courtesy
• Protect customer privacy
• Provide truthful product information
• Deliver exceptional service
• Resolve concerns fairly
• Preserve client confidentiality

Trust is earned through consistency.

15. FAIR COMPETITION

Brendratti competes honestly.

We prohibit:

• False advertising
• Defamation of competitors
• Misrepresentation
• Anti-competitive practices
• Price fixing
• Market manipulation

Success should be achieved through innovation and excellence.

16. CONFIDENTIAL INFORMATION

Employees must safeguard confidential information, including:

• Product designs
• Collections
• Pricing
• Financial information
• Client information
• Vendor information
• Marketing plans
• Trade secrets
• Manufacturing techniques

Confidential information may only be shared on a legitimate business need-to-know basis.

17. INTELLECTUAL PROPERTY

Brendratti's creative assets are among its most valuable resources.

Employees must protect:

• Designs
• Trademarks
• Logos
• Copyrights
• Patents
• Photography
• Digital assets
• Brand identity

We also respect the intellectual property rights of others.

18. CONFLICTS OF INTEREST

Employees must avoid situations where personal interests conflict with Company interests.

Examples include:

• Undisclosed outside employment
• Financial interests in competitors
• Vendor kickbacks
• Personal relationships affecting business decisions
• Misuse of Company resources

Potential conflicts must be disclosed promptly.

19. GIFTS & ENTERTAINMENT

Business gifts must never influence business judgment.

Employees may accept or provide only modest business courtesies consistent with:

• Law
• Good business practice
• Transparency
• Company policy

Cash or cash equivalents are prohibited.

20. ANTI-BRIBERY & ANTI-CORRUPTION

Brendratti maintains zero tolerance for bribery.

Employees may not:

• Offer bribes
• Accept bribes
• Facilitate improper payments
• Influence officials unlawfully
• Provide improper advantages

We comply with:

• U.S. Foreign Corrupt Practices Act (FCPA)
• California law
• Italian anti-corruption laws
• Other applicable international regulations

21. ANTI-MONEY LAUNDERING

Brendratti conducts business only with legitimate customers and partners.

Employees must report suspicious transactions involving:

• Cash payments
• Fraud
• Sanctions violations
• Illegal financial activity
• Identity concerns

22. DATA PRIVACY

We respect the privacy of our clients, employees, and business partners.

Brendratti complies with applicable privacy laws, including:

• California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA)
• European Union General Data Protection Regulation (GDPR), where applicable
• Other applicable data protection laws

Personal information shall be collected, used, stored, and shared only for legitimate business purposes and with appropriate safeguards.

23. FINANCIAL INTEGRITY

Company records must be:

• Accurate
• Complete
• Timely
• Transparent

Employees must never:

• Create false records
• Conceal transactions
• Manipulate financial information
• Misrepresent expenses

24. SOCIAL MEDIA & COMMUNICATIONS

Employees should use good judgment when discussing Brendratti online.

Only authorized spokespersons may speak on behalf of the Company.

Confidential information must never be disclosed through:

• Social media
• Personal websites
• Public forums
• Interviews

25. SPEAK UP

Employees are encouraged to report concerns regarding:

• Ethics
• Fraud
• Harassment
• Discrimination
• Safety
• Legal violations
• Financial misconduct

Reports may be made confidentially through Company reporting channels.

Retaliation against individuals who report concerns in good faith is strictly prohibited.

26. ENFORCEMENT

Violations of this Code may result in:

• Coaching
• Corrective action
• Disciplinary measures
• Termination of employment
• Termination of vendor relationships
• Legal action where appropriate

Compliance with this Code is a condition of employment and business partnership.

27. GOVERNANCE

The Board of Directors oversees the implementation of this Code.

Management is responsible for promoting ethical leadership and ensuring that employees receive appropriate training.

The Code shall be reviewed periodically to reflect changes in law, business practices, and corporate values.

28. OUR COMMITMENT

Brendratti believes that true luxury is measured not only by exceptional design, but by the integrity with which it is created.

From our California headquarters to the ateliers in Italy, we are committed to honoring craftsmanship, 100% Made In Italy, embracing innovation, respecting people, protecting the environment, and conducting business with honesty, Integrity and excellence.

Together, we uphold the standards that define the Brendratti name.

BRENDRATTI, INC. A California S Corporation, with Corporate entity 47-2651492 under the laws in the State of California with Dun & Bradstreet entity # 028672094 filing in California and under the state laws and legal rights in California.