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ITEM 16B. CODE OF ETHICS

We have adopted a Code of Ethics (the “Code of Ethics”) that is applicable to all of our employees (including our executive officers) and our directors. The Code of Ethics is available to the general public on our website www.birkenstock-holding.com. Our board of directors is responsible for overseeing the Code of Ethics and is required to approve any waivers of the Code of Ethics applicable to any director or executive officer.

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