ESRS S4 Consumers and end-users

ESRS S4 Consumers and end-users

Impact, risk and opportunity management

Material consumers-related impacts, risks and opportunities in relation to strategy and business model (IRO-1, SBM-3)

As a consumer brand, PUMA is dedicated to maintaining business practices that protect the health, safety, and privacy of consumers and end-users. We reach our consumers via wholesalers, online platforms selling PUMA products and our own stores. Consumers and end-users of PUMA products include athletes and individuals purchasing and using PUMA products globally. We consider our consumers within the scope of our IROs’ analysis. Interests and views of stakeholders are explained in the General information (SBM-2) section.

We do not consider that any consumers, including those working in particular contexts or undertaking particular activities may be at any risk of harm. We protect vulnerable market segments such as children and impaired audiences. Therefore, PUMA works with respect for the advertising of our children’s and impaired target groups.

PUMA sells goods to consumers via wholesalers but also via direct-to-consumer channels (own physical stores and online). We recognise the potential impacts of our data processing activities on consumers and end-users’ privacy and consent spheres. Breaches of privacy regulations could lead to a negative impact on any consumer, such as the leaking of private information. Such breaches could also lead to fines by market authorities.

Policies related to consumers and end-users (S4-1)

PUMA commits to respecting Human Rights across its global value chain, including consumers. We will also uphold Human Rights to ensure ethical advertisement and shopping experiences to avoid discriminatory behaviour, ensure consumers are safe when using PUMA products and respect consumers’ data privacy rights in the locations where we conduct our business. We have established regular testing for product safety and grievance mechanisms that allow consumers and Human Rights defenders to report any potential issues without fear.

PUMA’s Human Rights Policy aligns with several internationally recognised standards, including the UN Guiding Principles on Business and Human Rights, the ILO’s Declaration on Fundamental Principles and Rights at Work, and the OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector. Any cases of non-compliance are documented and addressed through the SpeakUp platform which is publicly available on PUMA’s website. No cases of involving violations of Human Rights involving consumers have been reported during the reporting year. In the case of a severe Human Rights violation, PUMA would search for an adequate and tailored remedy together with the affected parties the same way it handles Human Rights topics in the supply chain, which is explained in the ESRS S2 Workers in the value chain section. The Management Board is responsible for the approval and overall implementation of this policy. PUMA’s Human Rights Officer oversees the policy.

PUMA promotes physical activity through diverse communication channels, adhering to an Ethical Marketing Policy that avoids exploitation, appropriation, and stereotyping. We work with multicultural models and ambassadors to reflect our diverse audience. Our campaigns ensure safety and positivity, especially for children and impaired groups, who participate voluntarily with guardian approval and PUMA’s supervision. Advertising is directed at caregivers, not vulnerable segments. Adherence to this policy is monitored regularly by the marketing team through a content approval process. The most senior person responsible for the implementation of the policy is PUMA’s VP Brand and Marketing.

To address potential neglected product safety features PUMA established a Product Safety Policy and RSL Implementation Manual for chemical management to layout the requirements, process, roles and responsibilities, and procedures in managing product mechanical and chemical safety. The documents are developed based on global product safety legislation and industrial best practice to ensure products do not pose a safety risk to consumers and end-users. The Management Board is responsible for the approval and implementation of these policies which are reviewed annually to benchmark and incorporate the latest requirements and best industrial practice.

In terms of potential data breaches, PUMA has established Data Privacy Policies that govern the collection, processing, storage, and sharing of personal data. These policies are designed to protect the rights of consumers and end-users and are regularly updated to reflect changes in legislation and best practices. PUMA’s privacy policy outlines how the company collects, uses, stores, and protects personal data. The policy is published on PUMA’s corporate website and the local e-com pages of our subsidiaries and it is monitored by local teams. The most senior person responsible for the implementation of the policy is PUMA’s General Counsel.

These policies have been in place for several years and there have not been any changes during the reporting year. Consumers have not been directly involved in the design of these policies.

Engagement with consumers and end-users about impacts (S4-2)

PUMA actively tracks its consumers brand perception through various methods, including brand and sustainability perception surveys. These tools help PUMA understand how consumers view PUMA’s overall brand image and its products. For instance, PUMA's brand tracker includes questions on product and marketing-related features, allowing the company to gauge consumer agreement. These insights are considered by different business units and sourcing teams.

In addition, PUMA is in constant contact with its main athletic ambassadors to receive direct feedback on the PUMA products under high performance conditions. No further engagements with consumers have taken place to influence the management of potential impacts.

Remediation of negative impacts and channels for consumers and end-users to raise concerns (S4-3)

• To get valuable direct inputs from end-users regarding the brand, PUMA provides contact channels for all consumers on the PUMA website and contact information is also available on the product or product packaging. Consumers or end-users can reach out via email, telephone or social media channels to give us feedback about our products or raise complaints.

When a comment is received from consumers or end-users, the customer service team processes the request and directs it to the relevant parties. Any issues related to product safety are forwarded to the Product Compliance team for investigation and followed up by internal teams and suppliers as necessary. Upon receiving a complaint from consumers or end-users, the customer service team directs it to the appropriate parties. Complaints concerning product safety follow the Product Quality claim section under PIT – Sourcing Guidelines. The Product Compliance team is responsible for arranging a root cause analysis with the PUMA Product Line Manager, PUMA Product Development, PUMA Production team, and suppliers. This includes, but is not limited to, processes such as product design and material review, document review, and third-party testing. A corrective action plan is then submitted to ensure remediation is completed and to prevent the recurrence of similar issues. As of December 2024, no product safety complaints had been received during the reporting period.

PUMA collects personal data from customers, employees, and partners through various channels, including online forms, purchases and customer service interactions. The collected data is used for purposes such as processing orders, improving customer service, marketing, and complying with legal obligations. We respect the rights of our consumers and end-users regarding their personal data. This includes the right to access, correct, delete, and restrict the processing of their data. Consumers can exercise these rights through our dedicated data privacy email address. Consumers are also informed about all processed data by PUMA and the company’s Data Privacy Policy can be found on PUMA’s corporate website and PUMA e-commerce. As of December 2024, one data privacy complaint was received during the reporting period.

Communication channels between PUMA and consumers are managed by third-party service providers. Consumers are made aware of the available communication channels on PUMA’s corporate website and e-commerce contact section. All grievances are treated confidentially and respect the rights of privacy and data protection. Consumers can use the telephone to raise concerns anonymously, other channels such as email and chat cannot be anonymised. No specific policies regarding protection against retaliation for individuals that use channels to raise concerns or needs are in place yet. We are able to assess that communication channels are used by consumers, we receive their concerns and questions on a regular basis and depending on the scale of the request the timeframe for resolving them will vary. We require external service providers to answer all inquiries received via telephone and email.

Actions on material impacts on consumers, and managing material risks and opportunities related to consumers (S4-4, MDR-A)

PUMA is committed to ensuring the well-being of its consumers and end-users through a comprehensive approach. To prevent and mitigate material negative impacts, PUMA has implemented comprehensive safety assessments and data protective policies and continuously tracks their effectiveness. In cases of actual material impacts, PUMA provides or enables remedies to address these issues effectively depending on their scale.

PUMA ensures its own practices do not cause negative impacts by adhering to a strict code of conduct and a code of ethics and conducting regular internal audits to maintain high ethical standards. PUMA also focuses on delivering positive impacts through additional initiatives and processes, aligning them with the SDGs. Examples include employees engaging with local communities through various programs aimed at improving education, health, and well-being.

PUMA conducts an annual review of its product safety and RSL policies, aligning them with the latest global legislation and industry best practices. We engage with external organisations such as the Federation of the European Sporting Goods Industry (FESI) and the Apparel and Footwear International Restricted Substances List Management Group (AFIRM) to stay informed about the latest legislative developments in product safety and incorporate relevant requirements into our safety policies. PUMA has adopted the AFIRM RSL as the foundation for our RSL management. We also arrange annual training sessions with suppliers to update them on the latest PUMA requirements. All PUMA products must adhere to the design guidelines outlined in the PUMA Product Safety Policy to ensure they do not pose any mechanical safety risks to consumers and end-users.

Children’s products and their components are required to undergo mechanical safety testing in PUMA-nominated third-party laboratories to ensure there are no mechanical safety risks. Additionally, all products and materials must be certified under the Oekotex 100 or bluesign® standards, or tested according to PUMA’s RSL policy in nominated third-party laboratories, to ensure chemical safety.

Personal Protective Equipment (PPE), including shin guards and protective goalkeeper gloves, are tested and certified by third-party laboratories in accordance with EU PPE regulations. Products or materials that do not comply with PUMA’s requirements must be remediated before shipment. Suppliers are required to provide a corrective action plan, which is verified by the PUMA team to prevent recurrence of the issue. All corrective action plans are recorded and maintained on PUMA’s Sharepoint. As part of our due diligence process, a number of products are randomly selected from suppliers and tested against PUMA’s RSL in third-party laboratories.

PUMA involves consumers and end-users in decision-making processes related to sustainability, ensuring their voices are heard. PUMA has an initiative called Voices of a RE:GENERATION. This initiative aims to make PUMA’s sustainability efforts more transparent and engaging, particularly for younger generations. It is designed to empower Gen Z sustainability advocates from different backgrounds by giving them a platform to influence PUMA’s sustainability strategy and communication. These consumer ambassadors meet frequently with PUMA’s sustainability senior management to discuss their views on how the topic can be addressed in a simpler and honest way.

PUMA‘s FOREVER. BETTER. sustainability program helps to transparently report the positive outcomes of programs and processes and highlights the tangible benefits for consumers and end-users, reinforcing the company’s dedication to responsible business practices. PUMA actively pursues material opportunities to enhance the experience of its consumers and end-users by focusing on innovation and sustainability. For instance, PUMA has launched initiatives related to biodegradable shoes and apparel made from recycled materials, which cater to the growing demand for fashion made from certified and/or recycled materials. To manage material negative impacts, PUMA leverages its business relationships by collaborating closely with suppliers to ensure ethical practices and improve working conditions throughout its supply chain. This includes regular audits and providing training programs to help suppliers meet PUMA’s high standards.

PUMA employs technical and organisational measures to protect personal data, including encryption, access controls, and regular security audits. Personal data may be shared with third-party service providers for specific purposes, such as payment processing and shipping. PUMA ensures that these providers adhere to strict data protection standards.

In case of a data breach, PUMA has a response plan that includes immediate containment, the notification of affected individuals and authorities, and a thorough investigation to prevent future incidents. The Data Protection Officer is informed and has to investigate what happened, within 72 hours needs to decide if the data protection authority has to be informed, also depending on the individual costumer, what exactly happen, and which measures have been taken to minimise the breach.

Resources, staff and monitoring tools, are allocated to manage the effectiveness of the actions mentioned above. Product related impacts are managed by the Product Compliance team, Data Protection by the Legal team and encouragement of physical activity by the Marketing team.

During 2024, no severe human rights issues or incidents connected to consumers and/or end-users have been reported.

Metrics and targets (MDR-M, MDR-T, S4-5)

For the IROs identified as material in this chapter, PUMA has set a target focused on product safety. This target supports sustainable consumption and production and contributes to meeting the industry RSL standards. It also contributes to SDGs. It applies to global production activities, with the baseline being the products and materials used in the calendar year. The performance against this target is reported annually in PUMA’s sustainability reports and can be tracked regularly through a database. Consumers have neither been engaged to set up, identifying opportunities, nor tracking performance against this target. It was developed by internal stakeholders. No targets or metrics have been set for the other material IROs.

10FOR25 Targets (Baseline year 2020, Target year 2025)

• Ensure that 100 % of all products are safe to use and achieve a compliance rate of over 90 % for RSL testing of products and materials (upstream, global)
• In 2024, the RSL testing compliance rate was 98.9 %.

Only materials which pass an RSL test and/or are certified to comparable chemical standards such as Oekotex 100 or bluesign can be used to produce PUMA goods. The RSL compliance target has been in place for more than five years and its calculation methodology has not been modified to enable comparability. The RSL is reported as a compliance rate in percentage within the time interval of January to October from 638 factories of PUMA core and non-core Tier 1 and Tier 2. There is no extrapolation. All non-compliance cases are followed up with corrective action plans to remediate and avoid recurrence.‎