THE NEW MONCLER INVESTOR RELATIONS APP IS NOW AVAILABLE

Moncler’s Code of Ethics (hereinafter also the Code) 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 represents the set of values that 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. 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.

In 2017, a comprehensive update was carried out on the Code to align it with the best international practices and to better integrate sustainability issues and anti-corruption guidelines. The Code of Ethics reflects the main regulations, guidelines, 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 Organisation) conventions, and the OECD (Organisation for Economic Co- operation and Development) Guidelines for Multinational Enterprises. The Code of Ethics also includes the key principles set out in the Supplier Code of Conduct adopted by the Group and in the 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. The Code 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 also 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 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 the 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 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 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 profession- als 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 and reports directly to the Board of Directors to ensure its independence from any form of potential interference or conditioning.
In 2017, an assessment of risks and corporate processes was conducted, with results to be used in early 2018 to update Moncler’s Model in accordance with new offences recently introduced under Legislative Decree 231/2001, regarding illicit brokering, the exploitation of labour, racism, and xenophobia, as well as new regulations on whistleblowing and some changes concerning corruption between private individuals. Following the assessment, there were no instances requiring significant corrective measures.

In 2017, an assessment of risks and corporate processes was conducted, with results to be used in early 2018 to update Moncler’s Model in accordance with new offences recently introduced under Legislative Decree 231/2001, regarding illicit brokering, the exploitation of labour, racism, and xenophobia, as well as new regulations on whistleblowing and some changes concerning corruption between private individuals. Following the assessment, there were no instances requiring significant corrective measures.

The audits performed in 2017 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, credit management, recruiting, etc.) and on the main ‘sensitive’ areas identified by the Model. With regard to international subsidiaries, in 2017 the Internal Audit division audited Group companies in the United States, Korea, Japan, China, and Hong Kong, 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 2017 the Internal Audit division audited 49 stores, selected on the basis of turnover, risk level, and geo- graphic diversification. The audits made it possible to verify and make improvements to existing operating and control procedures.

In 2017, 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 reported breaches of rules, regulations, and/or internal procedures, the adoption of appropriate measures, and the anonymity of whistleblowers. In late 2017, to further consolidate the internal whistleblowing procedure and in compliance with recent legislation on whistleblowing, Moncler launched a study for the adoption of a dedicated web platform and ad hoc telephone lines – to be managed by a specialised and independent third party – to manage and record any reports from employees, suppliers, clients, and counterparts of all Group companies. The new system is expected to be operational by mid-2018.
In 2017, only one report was received through the whistleblowing system, which was timely analysed, assessed, and managed through an ad hoc audit carried out at the production site of a foreign supplier. The audit did not confirm the allegations of the report received, nor did it reveal any breaches of the Codes adopted by Moncler and made binding also for suppliers.

Therefore, no specific action was taken against the supplier in question.
In this regard, the Group has adopted a Supplier Code of Conduct since 2016. It addresses Moncler’s expectations regarding responsible sourcing, 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. Moncler requires its suppliers and subcontractors to comply with the binding principles set forth in the Supplier Code of Conduct, and conducts regular audits across the supply chain to verify compliance. The Group is also committed to carrying out relevant training and awareness activities among internal departments and suppliers alike.

SEARCH MONCLERGROUP.COM: