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CODE OF ETHICS

The Code of Ethics is a pillar of Moncler’s corporate governance system. It sets out the principles that govern the decisions and conduct of both the Company and its employees towards stakeholders. The Code represents the set of values the Group identifies with, shares, and promotes, in the belief that a conduct inspired by principles of diligence, honesty, and loyalty can significantly drive economic and social growth; and in the conviction that there can be no long-term success without ethics and responsibility.
Moncler calls on all its employees and collaborators to act with honesty, passion, and integrity, and build relationships with stakeholders based on mutual trust, so that growth may be steered by the principle of shared value.
The Code of Ethics is applied uniformly across all countries in which the Group is present. It consists of a set of principles and guidelines that inspire and guide the way the Company operates each day, as well as the conduct of its employees and of those who collaborate with Moncler, in any capacity, in carrying out their tasks and responsibilities. In 2016, the Code was updated to include a specific article regarding compliance with national and European antitrust laws.

The Code of Ethics is duly shared with employees using the most appropriate means and in accordance with local standards and customs. It is available in both Italian and English, and can be downloaded from the Group’s intranet portal and corporate website. In June 2014, an online and classroom-based training programme was launched for all employees in Italy to ensure the widespread dissemination of the Code’s principles, their proper understanding, and the development of virtuous behaviours, as identified by the Code of Ethics.
The Code is also a fundamental and integral part of the Organisation, Management, and Control Model (hereinafter the Model) adopted by Moncler in accordance with Italian Legislative Decree 231/2001.
The Model sets forth the principles, rules of conduct, operating procedures, and disciplinary measures devised to prevent corporate crime and ensure the ethical conduct of all those who act on behalf of the Company, upholding the principles of legitimacy, fairness, and transparency.

Compliance with the Code of Ethics and the Model is monitored by designated supervisory bodies through audits and specific checks, which may also take place on the basis of reported behaviour that does not comply with the principles of conduct required by Moncler. Audit findings may require disciplinary actions that, depending on the severity of the case, can also lead to the termination of employment.
The Supervisory Body in Italy is tasked with supervising the suitability of and compliance with the Organisation, Management, and Control Model and its underlying principles. It is a collegial body consisting of three members – two external professionals with accounting and legal expertise and the head of the Group’s Internal Audit division. The Supervisory Body holds a high position in the Company’s organisational structure, to ensure its independence from any form of potential interference or conditioning.
In 2016, the Model was updated on the basis of more recent offences – against the environment and concerning self-laundering – introduced under Italian Legislative Decree 231/2001. Following an assessment, there were no instances requiring significant corrective measures.
The audits performed in 2016 by the Internal Audit divi- sion on the Group’s Italian companies focused on key corporate processes (payments, purchases, services and consulting, product shortages, etc.) and on the main ‘sensitive’ areas identified by the Model.

With regard to international subsidiaries, in 2016 the Internal Audit division audited Group companies in Japan, China, Hong Kong, and France, focusing on the suitability of internal control and financial reporting procedures, with the aim to identify and/or prevent any potential cases of fraud.
With regard to the management of store operations (receipts and sales management, stock management, protection of corporate assets, and theft prevention), in 2016 the Internal Audit division audited 42 stores, selected on the basis of turnover, level of risk, and geographic diversification. The audits led to the implementation of improvements to existing operating and control procedures.
In 2016, no breaches of the Code of Ethics were reported. Moncler considers the reporting of particular instances of non-compliance with the Code of Ethics – whether by employees or external entities – a serious matter. Any employee reporting a concern in good faith regarding suspicious, alleged or actual breaches of the Code of Ethics is protected by Moncler against any form of retaliation, discrimination or penalisation, without prejudice to statutory obligations in force or to the rights of the Company or people falsely or mistakenly accused of misconduct.
To this end, a Group-wide whistleblowing system was launched in March 2016, devised to ensure the proper management and timely verification of any breaches reported, the adoption of appropriate measures, and the anonymity of the whistleblower.

Three reports were received in 2016, all of which were promptly addressed, evaluated, and managed. Two of the reports led to ad hoc audits – of a business process and a retail store, respectively. The investigations did not confirm the contents of the reports, but did contribute to strengthening the internal controls and procedures managing business processes.
Moncler makes every reasonable effort to promote its Code of Ethics among its partners (suppliers, consultants, wholesalers, etc.), so as to encourage fair and transparent business conduct. To this end, Group contracts include specific clauses requiring the acknowledgement and adherence to the principles of the Group’s Code of Ethics, in addition to compliance with the laws in force in each country of reference.
In addition, in November 2016, Moncler formally approved a Supplier Code of Conduct, which suppliers and subcontractors are contractually required to comply with. The Supplier Code of Conduct addresses Moncler’s expectations regarding responsible purchasing, and consists of six sections describing the binding provisions related to: Labour and Human Rights, Occupational Health and Safety, Environment, Animal Health and Welfare, Safety and Quality of Products and Services, and Corporate Ethics and Intellectual Property Protection.

The responsible sourcing process adopted by Moncler includes training activities for internal departments and suppliers alike, as well as audits and reviews devised to verify supplier compliance with the principles of the Supplier Code of Conduct.
In 2017, the Group will develop an anti-corruption model, providing for an in-depth preliminary study of applicable laws in the main countries in which the Company operates. Such thorough analysis has already been performed in Italy, and the Group is already structured to ensure compliance with Legislative Decree 231/2001. The next countries to be surveyed will be those that (a) account for the Group’s higher percentage of turnover, and (b) rank highest in terms of risk of corruption:

China, Hong Kong, Korea, Japan, United States, France, and Romania.
The project will include a risk assessment to identify the Group’s risk profiles, in line with applicable laws, and the development of an action plan to implement more stringent controls where necessary.
It will also include the definition of a corporate anti-corruption policy and the provision of online training for all Group employees.