Responsible Business Conduct Policy

Pure Earth Holdings Ltd and Earthcove  |  Last updated: September 2026

Scope of This Policy

This Responsible Business Conduct Policy is held by Pure Earth Holdings Ltd (“PEH”), registered in England and Wales, Company No. 17289830. PEH is the parent company of the Pure Earth group and the holder of the group’s GOTS (Global Organic Textile Standard) certification, issued by Soil Association Certification.

This policy applies to PEH and to the Earthcove brand, operated by its wholly owned subsidiaries Earthcove Ltd (registered in England and Wales, Company No. 17439189) and Earthcove, Inc. (a Delaware corporation). In this policy, “we”, “us” and “our” refer to PEH and Earthcove.

Environmental Management Policy

Brand Ethos

At Earthcove, we create swimwear that puts health first and does better by the planet too. Our overall aim as a brand is to reduce the amount of plastic in families’ lives. Specifically, to reduce the amount of microplastics children and adults are exposed to through the swimwear they wear.

Earthcove is the world’s first GOTS certified organic cotton swimwear range, for kids, adults and schools. Every piece is made from GOTS certified organic cotton, with a maximum of 2% elastane for stretch and fit. We use natural, non-toxic materials wherever possible, right down to our care labels, which are screen printed with GOTS certified water-based ink.

Factories

To ensure a high level of ethics and supply chain transparency, all factories that we work with must have Sedex approval and must be GOTS registered. Adequate due diligence should be carried out by the company when any new supplier is considered.

Fabrics

All products made and sold by Earthcove must have a minimum natural fabric content of 98%. 100% natural and organic fabrics should always be aimed for, and any addition of synthetic fabrics must have a clear and unavoidable purpose. Synthetic fabrics may only make up a maximum of 2% of any finished fabrics used to make Earthcove products, and this includes all labels, trims and packaging.

All organic certifications for fabric used by Earthcove shall be GOTS standard, and manufacturers must supply the company with the GOTS Transaction Certificate for each production. These transaction certificates should be filed and saved by PEH for a minimum of seven years.

Product Patterns and Fabric Wastage

When designing our products, we ensure that the patterns of the fabric minimise any wastage and get the most out of every inch of material possible.

Customer Returns

All customer returns are sorted through. For hygiene reasons, swimwear is only accepted for return if it is unworn with the hygiene seal or liner intact. Any good quality items are re-sold, including through pre-loved sales at up to 75% off the original price.

End of Use, Non-Saleable Items

Any products which are not fit for resale, but are in a good condition for use, are gifted to the Cowshed Charity. Any products which are not in a usable state are gifted to charities who use the fabrics for young people’s creativity initiatives.

Reducing Waste in Sampling

Each and every Earthcove sample is used either by team members, by friends and family members, or by charity. Each spring, we organise a ‘drinks and sample grab’, a gathering designed for guests to come and choose any sample pieces they would like for their families. Any items not gifted at these events are sent to the Cowshed Charity.

Transportation

Goods shipped from overseas will primarily come via sea shipments. In the rare event that air transportation is needed (for tight timelines or global delays), carbon offsets will be done against the transportation.

Packaging and Distribution

No plastics are permitted in the packaging or distribution of Earthcove products. Each product is packaged in an organic cotton drawstring bag (instead of plastic packaging) with a biodegradable, plastic-free swing tag attached with product information and barcodes. Products shall be packaged in biodegradable boxes with biodegradable tape.

The warehouses we work with in the UK and US are aware that no plastics are permitted for Earthcove products.

Product Longevity and Sustainability

All our products are designed to last for a long time. We promote slow, conscious living rather than fast consumerism. Our organic cotton swimwear was wear tested over a full summer against synthetic swimwear, and lasted at least twice as long before sagging or bobbling.

Each item is made to a high quality and is crafted to pass the test of time, being passed on from one child to the next.

Office Policies

Our team all work from home, so there is no office to consider for our environmental management. However, the team are encouraged to consider energy saving in terms of heating, electricity and transportation whenever they can. In the rare event that travel is needed for staff, it is carried out via public transport wherever possible.

Spreading the Message

Much of our brand messaging revolves around environmental management and reducing the amount of toxins and microplastics in families’ lives. So we’re constantly giving our community advice and passing on recommendations on how to live in a more eco conscious way.

Staff Environmental Impact

All our staff members have a high understanding and regard for environmental matters. We are constantly discussing this as a team, both for our personal lives and for our products and brand as a whole, to ensure we are pushing boundaries and making every product and action as environmentally responsible as possible. We will continue to strive for environmental excellence and will always make further changes wherever possible.

Ethical Business Policy

PEH and Earthcove prohibit any kind of forced labour, child labour, discrimination or use of any hazardous chemicals in any part of the business operations and supply chain.

Factories

To ensure a high level of ethics and supply chain transparency, all factories that we work with must have Sedex approval and must be GOTS registered.

Corruption and Bribery

We do not offer bribes or get involved with corruption, and all staff are required to report any incident or request of this kind immediately to their line manager for further action.

Staff

We pay all employees in line with the national living wage requirements.

Staff are encouraged to implement high levels of environmental accountability into their everyday lives, including limiting the use and purchase of any plastic products, reducing their electricity consumption where possible, and travelling by foot, bicycle or public transport over using cars whenever they can.

We have regular discussions, both internally and with our wider audience, around the harmful effects of microplastics and how to minimise the use of plastics in our everyday lives.

All staff have access to their line managers to discuss any potential grievance issues at any point in their employment. Any concerns raised by staff will be well documented and dealt with by management in a timely manner. Any affected individuals will be kept informed of the status of their complaints.

Supporting Working Mothers

We are proudly women-owned and mother-led. Our small team of mums balance family life with a shared passion for creating safer, healthier products for families. We work flexibly from home, building careers that fit around our families, in an environment that’s relaxed, creative and inspiring.

While we are inclusive in the workplace, and do not require our employees to be of any specific gender or family status, we are passionate about creating a space where women can thrive as both parents and professionals.

Social Criteria

Supply Chains

We forbid the use of slave or child labour in any part of our supply chains, and take various actions to ensure this does not happen.

We only work with Sedex approved factories and manufacturers who have a GOTS licence, as these two combined ensure a high level of transparency and accountability in all supply chains.

Staff Members

We adhere to the national living wage minimums in the United Kingdom to ensure all our staff members are paid fairly. We offer our staff a high level of flexibility to work on their own terms around family life, encouraging our staff members to first and foremost be a parent and care for their children and families.

We do not require staff members to take holiday days to care for unwell children or other childcare eventualities, giving them the flexibility to make up their hours and workload where they can.

Health and Safety

While we don’t have an office and all our staff work from home, they are encouraged to take care of their own wellbeing and mental health. They are given access to a meditation app and we have open channels of communication to discuss any concerns at any time.

We ensure the highest standards of safety for each of our products, conforming to all required safety standards and some additional non-required standards too.

If any safety concern arises with any Earthcove product, we will immediately cease the sale of the affected products and issue a product recall to customers. An action plan will be carried out to mitigate any remaining harm and prevent any identified potential future harm of any products identified to have any safety concerns.

Risk Assessment Policy for GOTS

Storage and Transport

All Earthcove products are textile products made from GOTS certified fabrics.

All our products are stored in individual packaging bags which are made from GOTS certified organic cotton.

Products are stored in boxes, organised per product, so products are not mixed up in a box. All GOTS certified products are therefore stored and transported in boxes with only GOTS certified products inside that box, negating any risks of contamination during storage or transportation.

Supplier Risk Assessments

As an entity, we receive only finished and packaged goods which are not undergoing any further processing. We therefore ask for all relevant test reports from our suppliers to ensure all relevant GOTS testing and risk assessments have been carried out on products sent to us.