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The Code of Ethics and corporate policies are one of the pillars of the Moncler Group’s corporate governance system and govern the decisions and conduct of the Moncler and Stone Island brands and of their employees towards their stakeholders.
In 2021, following the entry of Stone Island into Moncler, an analysis of the two Brands’ Codes of Ethics was carried out and confirmed their alignment in terms of values and principles; this will lead to the definition of a Group’s Code of Ethics.
The Codes of Ethics currently adopted by Moncler and Stone Island encompass the set of values that both Brands recognise, share and promote, in the belief that conduct inspired by the principles of diligence, honesty and loyalty is an important driver of economic and social development. Employees and collaborators are required to act with honesty, passion and integrity and to build relationships with stakeholders based on mutual trust, so that growth is guided by the principle of shared value.
The Codes apply to all employees, suppliers, contractors, consultants, partners and external collaborators of the two Brands and are available in Italian and English, as well as in Romanian for the Moncler document.
The Codes are periodically updated in order to align them with international best practices and to integrate them with sustainability issues. In particular, in 2021 the “Respect for human rights” and “Addressees” sections of Moncler’s Code of Ethics were updated. Both Codes are inspired by the main existing national and international regulations and standards on corporate social responsibility, corporate governance, human rights and the environment, such as the United Nations’ Universal Declaration of Human Rights, the Charter of Fundamental Rights of the European Union, the decent work standards set out in the ILO (International Labour Organisation) conventions and the OECD (Organisation for Economic Cooperation and Development) Guidelines for Multinational Enterprises. The Codes of Ethics refer to the key principles set out in both the Supplier Code of Conduct and the Anti-Corruption Policy, both of which have been adopted at Group level since July 2021. The new Group’s Code of Ethics will also refer to other company policies, which will also be reviewed in light of the integration, including: the Environmental Policy, the Health and Safety Management Policy and the Group’s policies on taxation, the management of human and financial resources, and asset protection.
The Codes of Ethics, which are uniformly applied in every country where Moncler and Stone Island operate, consist of a set of principles and guidelines that inspire the way in which the Brands operate every day and guide the behaviour of employees and others who work with the Brands in various ways in performing their activities and responsibilities. The Codes are brought to the attention of employees using the most appropriate means and in accordance with local customs. The documents are available on the company intranet and Internet sites. An online training programme on the contents of the Code of Ethics is regularly provided for all Moncler employees, including temporary and part-time employees, in order to ensure a proper understanding and virtuous behaviour consistent with the requirements of the Code of Ethics, while Italian Stone Island employees are trained on these issues through a specific module dedicated to the Code within the 231 Model course.
Together with the Anti-Corruption Model, the Codes of Ethics are a fundamental and integral part of the Organisation, Management and Control Models adopted by Moncler and Stone Island pursuant to Legislative Decree 231/2001. Both Models take the form of a set of principles and rules of conduct, operating procedures and disciplinary codes, aimed at preventing corporate crimes and ensuring ethical conduct of all those who operate on behalf of Group companies, in compliance with the principles of legitimacy, fairness and transparency.
Compliance with the Codes of Ethics and the Model is monitored by the appropriate supervisory and control bodies of the respective Brands, through specific audits and investigations, which may also take place on the basis of reported behaviour not in compliance with the principles of conduct required by Moncler and Stone Island. The results of verifications may lead to disciplinary actions which, depending on the severity of violation, may also lead to the termination of employment.
The Supervisory Body, which is the entity responsible for supervising the adequacy and compliance of the Organisation, Management and Control Model and its inspiring principles in Italy, is a collegial body consisting of three members of a mixed composition, both internal and external to the company, two of whom have accounting and legal expertise, and by the head of the Group Internal Audit function. This body holds a high position in the Company’s organisation, reporting directly to the Board of Directors of the company to which it belongs, in order to guarantee autonomy from all forms of potential interference.
In 2018 the Organisation, Management and Control Models of both Moncler and Stone Island were updated to include offences of illicit brokering and the exploitation of labour, racism and xenophobia, as well as the new rules on whistleblowing and some changes concerning private-to-private corruption. In 2021 they were further updated with the inclusion of tax and smuggling crimes and those relating to the trafficking of illicit influences and sports fraud, for all Group companies for which the preparation of a Model is required or strongly recommended. In addition, in light of the integration, for the Stone Island Model, updates on changes related to the organisational and governance context were also included.
The audit carried out in 2021 by the Internal Audit function, which operates at Group level, with regard to the Italian companies Moncler and Stone Island, focused on significant corporate processes (payments, purchases, services and consultancy, missing products, quality control, charge-backs to suppliers, sales, receipts, credit management, recruiting, etc.), as well as on the main areas identified as “sensitive” within the Model. With regard to Moncler’s international subsidiaries, during the year the Internal Audit function carried out audits and tests on the adequacy of the internal control system and financial reporting procedures for companies operating in the United States, Korea, Japan, China, Turkey, and France, in order to identify and/or prevent potential fraudulent conduct. The business will also be extended to significant international Stone Island companies starting from 2022.
In the management of operations at stores (receipts and sales management, stock management, protection of corporate assets and prevention of theft), in 2021 the Internal Audit division, due to the restrictions and limitations on movement as a result of the Covid-19 pandemic, was not able to audit any stores, though this normally takes place each year on selected stores according to criteria of significance of revenues, risk indicators and geographical diversification. However, in line with the objective of verifying and strengthening existing operating and control procedures, during the year activities were carried out to constantly monitor inventories, missing products detected during the handling phase and at warehouses and compliance with the sales procedure.
In addition, in order to ensure compliance with the principles and rules set out in the Code of Ethics, various audits are carried out. These include, for example, ethical and social audits along the supply chain, periodic checks aimed at obtaining social and environmental certification, third-party audits of information systems and analyses carried out by external and qualified laboratories to verify the chemical compliance of products with Company standards.
For both Moncler and Stone Island, a whistleblowing system is in place at the Group level, with the aim of managing properly and verify timely any illegal and disrespectful conduct – reported by employees or external parties – not in compliance with internal rules, regulations, procedures and values, and taking appropriate steps, while ensuring the anonymity of the whistleblower. Any employee who, in good faith, reports an alleged or actual anomalous violation of the Code is protected from retaliation, discrimination or penalization. The platform makes it possible for the whistleblower to choose anonymity: in this case, communications through the platform between the whistleblower and the Group take place solely through a unique code identifying the report.
However, this is without prejudice to the legal obligations and the protection of the rights of the Companies or of persons accused wrongly and/or in bad faith. In order to further strengthen the internal process of whistleblowing and in compliance with the relevant regulations, in 2021 Stone Island also adopted the Moncler web platform and ad hoc telephone lines – managed by a specialised third party and available at all times globally – to manage and record reports from employees, suppliers, clients and counterparties of all Group companies. The web platform is available in Italian, English, Chinese, Japanese, Korean, French, German, Turkish, Arabic and, starting from 2021, also in Romanian, while the telephone operators speak the language of all the countries where the Group has stores. The platform ensures, full compliance with international privacy regulations (processing of sensitive and personal data).
The whistleblowing procedure, updated during 2021, was circulated to all employees and is available on the company intranet of the two Brands. All Group employees, through an ad hoc email, and human resources managers of the Moncler Regions, through one-to-one meetings or video conferences, were made aware of the importance of whistleblowing and reporting methods.
The management of the Group’s whistleblowing channels is entrusted to the Head of Internal Audit, who is responsible for reporting what was tracked and monitored through these channels directly to the Board of Directors at least every six months.
In particular, once a report is received through whistleblowing channels the Head of Internal Audit receives and promptly analyses all the information; if the issue raised is very serious or complex, the Head of Internal Audit has the task of starting an investigation immediately, also requiring the support of other corporate functions, including Legal, Human Resources, ICT and Sustainability, as well as of competent external consultants, in order to conduct investigations and controls aimed at understanding what happened. Where appropriate in relation to the seriousness of the incident, immediate measures are put in place and they can also lead to termination of employment.
During the year, 20 reports1 of potential violations of the Code of Ethics were received through the whistleblowing system and the communications addressed to the Human Resources function. Four of these, emerged through the whistleblowing system: in three cases, they concerned inappropriate management of the work team and client relationship and in one case to discrimination in the handling of the team; following the investigations, for three out of four cases no breach of the Code of Ethic’s principles and values emerged and, therefore, no disciplinary action was taken. In one case, the investigation is not yet complete. With regards to the remaining 16 cases, addressed to the Human Resources function, from the investigations, 16 cases of breach to the Code of Ethics emerged of which: twelve referring to behaviour not in line with Group’s business and/or conduct principles and four to discrimination; three cases led to the termination of employment while for the others, disciplinary actions were implemented.
In 2021 a Group-wide Anti-Corruption Model was adopted, approved by the Board of Directors and based on a targeted risk assessment and a regulatory analysis of corruption offences in the countries in which the Group operates, selected on the basis of the sales revenues and Corruption Perception Index. This resulted in identification of the areas of theoretical corruption risk, existing internal controls and those to be enhanced and formulation of a Group Anti-Corruption Policy.
In particular, the Policy lays down: (i) regulatory monitoring responsibilities; (ii) management and reporting of cases of non-compliance; and (iii) specific measures to control corruption risk.
The Company updates this risk assessment annually to review the corruption risk profiles identified. On this basis, the following areas have been identified as potentially exposed to corruption risk:
• relations with the public administration
• relations with suppliers and external consultants
• relations with agents and intermediaries
• relations with joint ventures business partners and directors
• management of donations/sponsorships/gifts and samples
• human resources management.
Principles of conduct and operating rules are set for each of these areas both within the Anti-Corruption Policy and the Group’s Codes of Ethics. In Moncler’s case, the policies and procedures for the Group’s Anti-Corruption Model have been disseminated and shared globally, and the same will occur in Stone Island in 2022. An ad hoc training is also regularly provided to all employees in Italy through the e-learning platform.
The Internal Audit function periodically carries out on-site audits at Group companies in order to verify the adoption of controls to mitigate corruption risk in the areas identified as most at risk. In particular, annual audits are carried out on sponsorships, donations and gifts, management of consultants and professional assignments, acquisition and management of public grants and financing, employee recruitment, supplier management, payments, expenses and entertainment costs.
During these audits, the various departments involved are made aware of the importance of complying with the protocols. Audit results are shared with the Control, Risk and Sustainability Committee and the Supervisory Bodies of the Moncler brand and Stone Island brand. In 2021, no cases of corruption were reported.
Supplier Code of Conduct
The Supplier Code of Conduct was adopted at Group level in 2021. This Code outlines the Company’s expectations in relation to the main areas of the responsible sourcing and is composed of six sections that establish binding rules for: Labour and Human Rights, Occupational Health and Safety, Environment, Animal Health and Welfare, Safety and Quality of Products and Services, Corporate Ethics and Protection of Intellectual Property. Moncler requires its suppliers and subcontractors to comply with the principles set forth in the Supplier Code of Conduct and is also committed to train on and raise awareness of these provisions, both within its internal departments and among suppliers, through meetings at corporate offices or at suppliers’ premises. The Group also regularly conducts audits throughout the supply chain to verify compliance with the principles contained in the Code of Conduct.
Since 2017 Moncler has also been publishing an annual Modern Slavery Act in order to transparently communicate its approach to the management of human rights. In particular, the document describes the measures taken to ensure the absence of any forms of “modern slavery, forced labour and human trafficking” internally and along its supply chain as required by Section 54 of the UK Modern Slavery Act 2015.
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1 The 2021 Consolidated Non-Financial Statement sets out all the cases that led to a report of violations in all areas of the Code of Ethics, including human rights violations.