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Moncler’s Code of Ethics and corporate policies are one of the four pillars of its corporate governance system. They govern the decisions and conduct of both the Group and its employees towards stakeholders.
The Code of Ethics consists of a set of values that the Group identifies with, shares, and promotes, in the belief that conduct inspired by principles of diligence, honesty, and loyalty can significantly drive economic and social growth. 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 shared value.
The Code of Ethics applies to all of the Group’s employees, suppliers, contractors, consultants, partners, and external collaborators and is available in three languages (Italian, English and Romanian).
In 2017, a comprehensive update was made to the code to align it with best international practices and to better integrate sustainability issues and anti-corruption guidelines. In 2021 it will again be revised. The Code of Ethics reflects the main regulations and standards in force at national and international level 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 ILO (International Labour Organization) conventions, and the OECD (Organization for Economic Cooperation and Development) Guidelines for Multinational Enterprises. The Code of Ethics also includes the key principles set out in the Group’s Supplier Code of Conduct and in Company policies, including the Anti-Corruption Policy, 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 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. It 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. An online training programme is routinely provided to all employees to ensure the correct understanding and development of good conduct consistent with the Code of Ethics.
The code is also a fundamental and integral part of the Organization, Management and Control Model adopted by Moncler in accordance with Italian Legislative Decree 231/2001 on corporate liability. That model sets forth the principles, rules of conduct, operating procedures, and disciplinary code 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 with the Organization, Management and Control Model is monitored by designated supervisory bodies through audits and specific checks, which may also take place based on reported behaviour that does not comply with Moncler’s standards of conduct. Audit findings may lead to disciplinary actions; depending on the severity of the case, these also lead to termination of employment. The Supervisory Body in Italy oversees the adequacy of and compliance with the Organization, 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 organizational structure and reports directly to the Board of Directors to ensure its independence from any form of potential interference or conditioning.
In 2018, Moncler’s Organization, Management and Control Model was updated to include the offences of illicit brokering, exploitation of labour, racism and xenophobia, as well as new regulations on whistleblowing and some changes concerning private-to-private corruption. In 2020 it was further updated to include tax crimes, smuggling, influence trafficking, and sports fraud.
Employees in Italy attended an online course on the contents of the model and the new regulations that have been added.
The audits performed in 2020 by the Internal Audit division on the Group’s Italian companies focused on key corporate processes (payments, purchases, services and consulting, product shortages, quality control, chargebacks to suppliers, sales, receipts, credit management, recruiting, etc.) and on the main “sensitive” areas identified by the model. With regard to international subsidiaries, in 2020 the Internal Audit division audited Group companies in the United States, Canada, Korea, Japan, China and Hong Kong SAR, Turkey, France, the United Kingdom, Germany, and Romania, focusing on the adequacy of internal control and financial reporting procedures, in order to identify and/or prevent any potential cases of fraud. Regarding the management of store operations (receipts and sales management, stock management, protection of corporate assets, and theft prevention), in 2020 the Internal Audit division was unable to audit any stores due to the restrictions on movement in light of the COVID-19 pandemic, though this normally takes place each year on stores selected for their revenues, risk indices, and geographical diversification in order to verify and make improvements to operational and control procedures.
A Group-wide whistleblowing system has been in place since 2016, devised to ensure the proper management and timely verification of any reported breaches of rules, regulations, and/or internal procedures, the adoption of appropriate measures, and the anonymity of whistleblowers. Moncler considers the reporting of particular instances of non-compliance with the Code of Ethics – whether by employees or external entities – to be 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 penalization, without prejudice to statutory obligations in force or to the rights of the Company or people falsely or mistakenly accused of misconduct. Since 2018, to further consolidate the internal whistleblowing procedure and in compliance with applicable laws, Moncler has adopted a dedicated web platform and telephone lines – managed by a specialized, independent third party – to handle and record any reports from employees, suppliers, clients, and counterparties of all Group companies. Since 2019, the web platform has been available in French, German, Turkish, and Arabic as well as Italian, English, Chinese, Japanese, and Korean, and telephone operators speak the language of each country where Moncler has stores. The platform ensures full compliance with international privacy regulations (processing of sensitive and personal data) and in October 2020 some changes were made to the disclosure and consent procedure regarding the data of the individuals named in reports. Whistleblowers can choose to remain anonymous; in this case, all communication between the whistleblower and Moncler takes place using the report’s unique identification code.
The introduction of the platform went hand in hand with a review of the whistleblowing procedure, which was sent to all Group employees and is available on the company intranet. The Group’s whistleblowing channels are managed by the Head of Internal Audit, who is responsible for reporting what has been charted and monitored through those channels directly to the Board of Directors.
In 2020, three reports were received through the whistleblowing system that were deemed relevant and worthy of investigation. In the first case, further to investigations, an American Store Manager was dismissed for mismanagement of personnel. In the second case as well, the issue was potential mismanagement of staff, but since investigations and further review did not show inappropriate conduct, the manager was not disciplined. The third case concerned alleged violations of the receipts management procedure by the staff of a store in Asia. This matter is still being investigated.
In 2017 Moncler began to develop a Group Anti-Corruption Model, later approved by the Board of Directors, which is based on a targeted risk assessment and regulatory review of corruption offences in countries selected on the basis of sales revenues and the Corruption Perceptions Index. This allowed Moncler to identify the areas at theoretical risk of corruption, the internal controls in place, and those requiring improvement, and to define a Group Anti-Corruption Policy.
Specifically, the Policy defines: (i) regulatory monitoring responsibilities; (ii) the methods for non-compliance management and reporting; and (iii) specific measures to control corruption risk.
The Company annually updates this risk assessment to review the corruption risk profiles. Based on this assessment, the following areas have been identified as theoretically exposed to a risk of corruption:
• interactions with government agencies;
• interactions with suppliers and external consultants;
• interactions with agents and intermediaries;
• interactions with joint venture partners and directors;
• donations, sponsorships and gifts;
• human resources management.
For each of these areas, principles of conduct and guidelines are set out both in the Anti-Corruption Policy and in the Group’s Code of Ethics.
Policies and procedures concerning the Anti-Corruption Policy have been disseminated worldwide throughout the Group, and ad hoc training is routinely provided to all employees through the e-learning platform.
The Internal Audit department carries out periodic on-site audits at Group companies to verify the adoption of controls to mitigate the risk of corruption in the areas most at risk. In particular, annual audits focus on sponsorships, donations and gifts, the management of consulting and professional assignments, the acquisition and management of public grants and financing, the recruitment of employees, supplier management, payments, expenses, and entertainment costs. The various departments subject to these audits are made aware of the importance of complying with all protocols. The results of the audits are shared with the Control, Risks and Sustainability Committee and with the Supervisory Body. In 2020, no cases of corruption were reported.
Lastly, in 2020 Moncler revised its Supplier Code of Conduct in order to supplement and strengthen its responsible sourcing principles and add rules in case of pandemics. The Supplier Code of Conduct consists of six sections with binding provisions regarding 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. Moncler requires its suppliers and subcontractors to comply with the principles set forth in the Supplier Code of Conduct, and is committed to carrying out relevant training and awareness activities among internal departments and suppliers alike, through meetings at corporate offices or supplier premises. The Group also conducts regular audits across the supply chain to verify compliance with the principles in the Code of Conduct. In particular since 2017, Moncler has published an annual Modern Slavery Act to make its approach to human rights entirely transparent and public. The document describes the measures taken to ensure the absence of any form 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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