S4 Consumers and end-users

S4 Consumers and end-users

Impact, risk, and opportunity management

Material consumer-related impacts, risks, and opportunities (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 followed the same process to identify and assess material IROs for consumers and end users as outlined in the General information (IRO-1) section. This regularly updated process involves mapping relevant consumer topics (such as health, safety, privacy, and inclusivity), screening external developments relating to consumer topics, and engaging with customers via stakeholder dialogue.

Insights from this process inform and adapt PUMA’s strategy and business model, leading to updates in policies, product safety standards, and consumer initiatives, while ongoing monitoring and stakeholder feedback support the strategy to remain responsive to emerging risks and opportunities.

Material impacts affect consumers who rely on accurate product information for safe use, including sports enthusiasts and vulnerable groups such as children. Digital consumers face privacy risks from data collection, while marginalised or financially vulnerable individuals may be more exposed to non-inclusive or misleading communication. These consumer-related risks are integral to our strategy and business model: compliance with chemical safety standards protects product integrity and market access; safeguarding consumer data ensures trust and e-commerce growth; and transparent, credible communication maintains consumer confidence and brand reputation.

T.74 Material consumer-related impacts, risks and opportunities (IRO-1, SBM-3)

Value chain location ■□□ Upstream □■□ Own operations □□■ Downstream

Time horizon ❶⑤⑩ Short-term ①❺⑩ Medium-term ①⑤❿ Long-term

Time horizon is indicated for potential impacts. If the impact is actual, marked with ●

Material topic

Material impacts, risks, and opportunities

Horizon

Location

Example (mitigation) measures

Health and safety of consumers

POSITIVE IMPACTS

 

 

 

Promotion of physical activity: Promoting physical activity through sport has a positive impact on people by supporting healthier lifestyles, improving physical and mental well-being, and fostering social inclusion through team sports

□□■

• Leveraging sports for health and activity: Leverage PUMA’s core connection to sports and its brand strategy to promote active, healthy lifestyles through products and partnerships

• Setting policies and standards: Ensuring compliance with product safety regulations and maintaining clear product recall procedures to protect consumers

• Business responsibility strategy: Ensure compliance with legal responsibilities as an importer by monitoring product safety and regulatory requirements across all sourcing regions

NEGATIVE IMPACTS

 

 

Health and safety impacts: Health and safety issues may arise from isolated incidents or from inappropriate product design, material selection, or chemical use

❶❺❿

□□■

FINANCIAL RISKS

 

 

Stricter regulations: Stricter chemical regulations may result in higher compliance costs, potential fines for non-compliance, and limitations on market access due to restrictions on certain substances

①⑤❿

□□■

Information-related impacts for consumers

NEGATIVE IMPACTS

 

 

 

Personal information misuse: Privacy concerns resulting from excessive data collection, especially in regions with weak data protection, can negatively impact consumers by exposing them to identity theft, financial fraud, and misuse of personal information. This can lead to a loss of trust and emotional distress

①❺❿

□□■

• Setting policies and standards: Implementing global data privacy policies and procedures to ensure secure handling of consumer information

• Information Security Committee: Meeting to discuss the latest statuses, risks, and developments with regard to the information security-related topics

• Protection measures: Introduce privacy protection measures to strengthen consumer trust and confidence in online purchases

FINANCIAL RISKS

 

 

Reputational and regulatory risks: Consumer privacy breaches pose financial risks through potential compensation claims, regulatory fines such as under the EU’s General Data Protection Regulation (GDPR), and reputational damage. As digital operations grow, failure to implement effective privacy management can lead to non-compliance, legal action, and even restrictions on business activities

①⑤❿

□□■

Responsible marketing

NEGATIVE IMPACTS

 

 

 

Non-inclusive communication: Any form of communication that unfairly targets or excludes individuals based on characteristics like race, gender or age can harm consumers by undermining their mental well-being and sense of inclusion

①⑤❿

□□■

• Responsible marketing policy: Implement inclusive communication guidelines to ensure marketing and messaging respect all demographics and promote diversity

• Internal review: Establish internal review processes for all public-facing content to ensure compliance with legal and ethical standards

FINANCIAL RISKS

 

 

Reputational and regulatory risks: Ambiguous product descriptions, unclear reviews, and greenwashing can mislead consumers, result in legal penalties, and increase return rates and loss of trust, ultimately harming brand reputation and increasing operational costs

①❺❿

□□■

Strategy

PUMA’s approach for consumers and end users emphasises product safety, data protection, and responsible consumption. We apply safety and chemical management standards, regularly test products for compliance with industry standards, and maintain data privacy policies to safeguard consumer information.

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

PUMA strives to act in accordance with laws and ethical standards, treating consumers fairly and with respect. We are committed to respecting human rights across our value chain, including consumers, as indicated in PUMA’s Human Rights Policy, which refers to international standards such as the UN Guiding Principles on Business and Human Rights and is available on our website for our stakeholders. PUMA aims to avoid discrimination in advertising and shopping experiences, help ensure product safety for consumers, and protect data privacy in every market.

Cases of non-compliance with human rights principles can be reported through SpeakUp platform. No cases involving violations of human rights related to consumers were reported during the reporting year. If the investigation confirms a violation or a potential risk of violation of the law or PUMA policies, PUMA shall take all the appropriate remedial steps and measures to prevent, end, or minimise such violations or a potential risk of violation immediately in accordance with the severity and the principle of proportionality.

PUMA promotes physical activity through diverse communication channels, adhering to a publicly available Ethical Marketing Policy that avoids exploitation, appropriation, and stereotyping. We work with multicultural models and ambassadors to reflect our diverse audience. PUMA aims to create campaigns that foster a safe and positive environment, particularly for children and individuals with impairments, who participate voluntarily with guardian approval and under PUMA’s supervision. Advertising is not directed at vulnerable market segments (such as children) but at their carer. The implementation of the policy is monitored by the Marketing team through their content approval process into which the principles covered in the policy have been integrated. The most senior person responsible for the implementation of the policy is PUMA’s VP Brand and Marketing.

PUMA has developed a Product Safety Policy and an RSL Implementation Manual for chemical management, outlining requirements, processes, and responsibilities for managing product safety. These documents are based on product safety legislation and industry standards and are updated as needed in response to regulatory changes and developments. The Management Board oversees the approval and implementation of these policies.

PUMA has put in place policies to protect both information security and data privacy. The Information Security Policy is designed to help prevent unsafe actions by anyone using PUMA’s IT systems, with oversight from the Information Security team. The Privacy Policy explains how personal data is collected, used, stored, and protected, and is available on PUMA’s corporate website and local e-commerce pages. Local teams monitor compliance and the General Counsel is responsible for overseeing the Privacy Policy’s implementation. To address the risks relating to artificial intelligence (AI), PUMA has an AI Framework under which it does not allow sensitive consumer data to be fed into AI systems without proper security measures to avoid risking data breaches. The Management Board has overall responsibility for information security, data privacy, and data protection. It has established an Information Security Committee consisting of delegates from different business units and departments including Legal, Sourcing, People & Organisation, Finance, Product, Brand & Marketing, and IT. The committee meets quarterly and updates the Management Board on the latest statuses, risks, and developments related to the topic.

In the event of a data breach, PUMA has a response plan in place that includes immediate containment of the incident, notification of affected individuals and relevant authorities, and a thorough investigation to prevent recurrence. In the case of a breach, the Data Protection Officer is informed. Within 72 hours, they notify the data protection authority, and, if necessary, based on the nature of the breach, report on the impact on customers and the measures taken to mitigate the incident.

Engagement with consumers and end users on 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 perception quarterly. These insights are taken into consideration by different business units and sourcing teams. Vice President Brand & Marketing is responsible for the brand perception-related engagement.

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

Additionally, we provide grievance mechanisms for consumers to report any concerns without fear.

Remediation of negative impacts for consumers who raise concerns (S4-3)

To get direct input 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 feedback is received from consumers or end-users, the customer service team processes the feedback and directs it to the relevant parties. Any issues related to product safety are forwarded to the Product Compliance team for investigation. Complaints concerning product safety follow the process set out in the Product Quality claim of our internal guidelines. The Product Compliance team is responsible for arranging a root cause analysis with PUMA’s product teams and suppliers. A corrective action plan is then submitted to address the issue and help prevent similar problems from occurring in the future. In 2025, no product safety recalls have been received during the reporting period.

PUMA collects personal data from customers, employees, and partners through channels such as online forms, purchases, and customer service interactions. This data is used for purposes including order processing, enhancing customer service, marketing activities, and fulfilling legal obligations. We respect the rights of our consumers 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 through our Data Privacy Policy which can be found on PUMA’s corporate website and PUMA e-commerce. In 2025, three data privacy complaints were received during the reporting period, and all have been resolved.

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 concerns raised are treated confidentially and respect the right to privacy and data protection. Consumers can use the telephone to raise concerns anonymously; other channels such as email and chat cannot be anonymised.

For issues like misuse of confidential information which can be reported through SpeakUp, PUMA is committed to ensuring protection against retaliation as part of our Complaints Procedure. For other topics, there are not yet any specific policies in place to protect individuals from retaliation when using channels to raise concerns or voice needs. We can assess that communication channels are used by consumers, we receive their concerns and questions, and depending on the scale of the request, the timeframe for resolving them varies. We require external service providers to answer all inquiries received via telephone and email.

Actions on material impacts on consumers (S4-4, MDR-A)

PUMA is committed to ensuring the well-being of its consumers and end-users. Our approach to remediation and any cases during in 2025 is reported in the Remediation of negative impacts for consumers who raise concerns (S4-3) section. PUMA aims to ensure its own practices do not cause negative impacts by adhering to a strict Code of Conduct and a Code of Ethics and conducting annual internal audits to maintain high ethical standards. As explained in the General information (IRO-1) section, these topics are transferred into ERM.

Within PUMA, dedicated teams and resources are allocated to manage the effectiveness of actions related to consumer well-being and responsible business practices. Product Compliance oversees product safety, Legal and Global Information & Cyber Security handle data protection and information security, and Brand & Marketing, including Consumer Insights & Marketing Analytics, focus on marketing strategies and consumer engagement. The yearly actions outlined below are already ongoing with a target completion year of 2030 at the latest, as part of our Vision 2030.

Health and safety of consumers

Promoting physical activity through sport has a positive impact on people by supporting healthier lifestyles, improving physical and mental well-being, and fostering social inclusion through team sports.

PUMA conducts an annual review of its product safety and Restricted Substances List (RSL) policies, adapting them to reflect the latest legislative requirements and industry standards. To remain up to date with regulatory developments, we engage with external organisations such as the FESI and the Apparel and Footwear International Restricted Substances List Management Group (AFIRM). PUMA has adopted the AFIRM RSL, a standardised list of restricted substances based on global regulations, as the foundation for our RSL management. We arrange annual training sessions with suppliers on the latest PUMA chemical management requirements. Materials used in PUMA products are expected to comply with the RSL requirements. This means that only materials that have passed the RSL testing process are considered for use in production. Materials with OEKO-TEX® 100 or bluesign® certification are not required to undergo a RSL test, as these certifications already verify compliance with strict chemical safety requirements.

All PUMA products must adhere to the design guidelines outlined in the PUMA Product Safety Policy to prevent safety risks to consumers and end-users. Children’s products and their components are required to undergo mechanical safety testing at PUMA-nominated third-party laboratories to prevent mechanical safety risks.

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 internally. As part of our due diligence process, a number of products are randomly selected from suppliers, and their materials are tested against PUMA’s RSL standards at third-party laboratories.

Information-related impacts for consumers

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 requires these providers to adhere to strict data protection standards.

In 2025, PUMA had the following IT and information and cyber security initiatives and projects:

  • Our Security Operations Centre is hosted and managed 24/7
  • The e-commerce private Bug Bounty programme has been put in place
  • The rollout of third-party cyber risk assessment is in progress
  • We prepared the Cloud Native Application Protection Platform
  • We implemented regular zero trust state reviews.
Engagement with consumers

PUMA seeks to involve consumers and end users in sustainability-related matters by engaging them in initiatives and communication efforts that invite them to share their perspectives and feedback. Voices of a RE:GENERATION aims to make PUMA’s sustainability efforts more transparent and engaging, particularly for younger generations. The programme empowers Gen Z advocates from diverse backgrounds by giving them a platform to share their perspectives and influence PUMA’s sustainability strategy and communications. These ambassadors met with PUMA’s senior management to discuss how to communicate sustainability topics in a simpler and more transparent way.

In addition to this, PUMA initiated its FOREVER.BETTER. podcast series to connect with younger audiences. With the GREEN FLAGS podcast series, the aim is to make sustainability educational and relatable. In 2025, we also launched our new podcast series Who Gives a Shirt which explores the cultural and historical pull of football shirts and takes a closer look at their environmental impact.

PUMA actively pursues opportunities to enhance the experience of its consumers by focusing on innovation and sustainability. For instance, PUMA has launched initiatives related to biodegradable shoes and apparel made from recycled materials.

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 contributes to meeting the industry RSL standards. It applies to all production activities. Performance against this target is tracked through a database where the tests are stored. Consumers have not been engaged to set up, identify opportunities, or track performance against this target. It was developed by internal stakeholders. No targets or metrics have been set for the other material IROs.

T.75 10FOR25 targets and performance

Target achievement ● Achieved ○ Partially achieved

Value chain location■□□ Upstream □■□ Own operations □□■ Downstream

10FOR25 target

Location1

Scope

Entity specific

2020 baseline

2025 achievement

 

100% of PUMA products are safe to use

□□■

PUMA, Cobra2, stichd3

0.59% RSL test failure

No product recall from authorities

Maintain RSL compliance rate above 90%

■□□

PUMA, Cobra2, stichd3

98.8%

98.2% RSL compliance rate4

1 Targets apply to all locations of the entities listed under scope. All targets apply from January 2020 to December 2025.

2 Cobra products sourced by PUMA Group Sourcing (PGS). The golf club parts sourced by Cobra PUMA Golf are excluded.

3 Includes only PUMA products sourced by stichd. Products sourced by stichd for other brands are excluded, as stichd follows each brand’s specific quality requirements.

4 For final products, 2025 RSL compliance rate reflects data from January to October from 498 Tier 1 and Tier 2 PUMA, Cobra and stichd factories. Both targets are absolute.

The RSL targets for 2025 were changed in 2021 from an RSL failure rate of less than 1% to maintaining the RSL compliance rate above 90%. This adjustment was made to allow for increased new material development and innovation, where each material is tested and, as a result, there are more failures that can occur during the development phase. No material with a failed RSL test is used for PUMA products until the failure has been corrected and the material has successfully passed the test. The RSL target is reported as a compliance rate, given as a percentage of compliant material or product out of total tested material or product). We follow up non-compliance cases with corrective action plans to remediate issues and prevent recurrence.

In 2025, as we closed out the 10FOR25 cycle, we met the targets.

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