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CODE OF ETICHS

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 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 made to the Code to align it with international best practices and to better integrate sustainability issues and anti-corruption guidelines. 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 Organisation) conventions, and the OECD (Organisation for Economic Cooperation 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 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. Since 2018, an online training programme was launched for all employees to ensure a correct understanding and 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 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 adequacy 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 and reports directly to the Board of Directors to ensure its independence from any form of potential interference or conditioning. In 2018, Moncler’s Organisation, Management and Control Model was updated with the new offences relating to 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, a further update of the Model is expected, to include new tax offences as well as those relating to the illicit traffic of influence and sports fraud. Italian employees were trained, through an online course, on the contents of the Model and the new regulations that have been introduced. The audits performed in 2019 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 2019 the Internal Audit division audited Group companies in the United States, Korea, Japan, China, Hong Kong SAR, Taiwan, Turkey, France, Switzerland, the United Kingdom, Germany, Austria, Russia, Kazakhstan, the United Arab Emirates and Romania, focusing on the adequacy 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 2019 the Internal Audit division audited 50 stores, selected on the basis of turnover, risk level, and geographic diversification. The audits made it possible to verify and make improvements to existing operating and control procedures. The objectives of the audits also include the assessment of compliance with the main provisions and company rules included in the Code of Ethics. 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 has been in place since 2016, and is 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. Since 2018, to further consolidate the internal whistleblowing procedure and in compliance with legislation on whistleblowing, Moncler has adopted 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. In 2019, a new communication was sent to all Regions to ensure proper report management in the context of the breach of laws and rights related to human rights. Since 2019, the web platform has been available in Italian, English, Chinese, Japanese and Korean, as well as in French, German, Turkish and Arabic, while telephone operators speak the language of all the countries in which Moncler has stores. The platform ensures, inter alia, full compliance with international regulations in the field of privacy (processing of sensitive and personal data) and the anonymity of whistleblowers: in this case, communication via a platform between whistleblowers and Moncler only takes place using the unique identification code of the report.

The introduction of the platform went hand in hand with a review of the whistleblowing procedure, which was therefore sent to all Group employees and is available on the company intranet.

During 2019, two reports were received through the whistleblowing system that were deemed relevant and worthy of investigation and analysis. In the first case, as a result of the inquiry carried out with the collaboration of several company departments, one employee was dismissed from the Company as a breach of company procedures was ascertained; in the second case, no disciplinary action was taken as only inappropriate work team management was discovered, which resulted in the Company carrying out an awareness raising activity with the interested party.

Starting from 2017, Moncler has developed a Group Anti-Corruption Model based on a targeted risk assessment and regulatory review of corruption offences in some of the countries in which the Group operates, selected on the basis of sales revenues and the Corruption Perception Index.

This allowed the Company 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 identified corruption risk profiles. Based on this assessment, the following areas were identified as theoretically exposed to a risk of corruption:

 

• relations with Public Administrations;

• relations with suppliers and external consultants;

• relations with agents and intermediaries;

• relations with business partners for joint ventures and directors;

• management of 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.

 

The Internal Audit function 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 expenses. In 2019, no cases of corruption were reported.

Finally, Moncler has adopted a Supplier Code of Conduct since 2016. It addresses the Company’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, 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 is also committed to carrying out relevant training and awareness activities among internal departments and suppliers alike, through meetings at corporate sites or at supplier premises. The Group also conducts regular audits across the supply chain to verify compliance with the principles in the Code of Conduct. See also pages 114-118. The Supplier Code of Conduct will be updated in 2020 to integrate and strengthen the principles of responsible supply chain management. In addition, during 2019 Moncler published the Modern Slavery Act to make its approach to managing the issue of human rights public in a transparent way. In particular, the document describes the measures taken to ensure, as required by the UK Modern Slavery Act 2015 – Section 54, the absence of any form of “modern slavery, forced labour and human trafficking” internally and along its supply chain.

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