53 RESPONSIBLE BUSINESS MANAGEMENT52 RESPONSIBLE BUSINESS MANAGEMENT MONCLER GROUP 2022
INDEPENDENT ESG RATINGS AND ASSESSMENTS
In 2022 Moncler has been confirmed for the fourth year in a row in the Dow Jones Sustainability World and Europe indices, achieving the highest score (91/100) of the Textiles, Apparel & Luxury Goods sector in the 2022 S&P Global Corpo- rate Sustainability Assessment* (as of 14 February 2023).
In the 2022 CDP** Climate Change Questionnaire, the Group confirmed the leadership level with a score of A- for transparency and actions to mitigate climate change risks.
In 2022 Moncler also obtained an AA score from MSCI ESG Research***, which provides sustainability ratings for listed international companies and some private companies by evaluating them on their exposure to industry specific ESG risks and their ability to manage those risks in comparison to sector peers.
Moncler also ranked second in the Specialised Retail sector in the ESG Overall Score ranking of Moody s ESG Solutions, with a score of 62/100, achieving the Advanced level.
In January 2023, Moncler again obtained the Sustainalytics Industry Top-Rated Badge and Regional Top-Rated Badge. Sustainalytics is a leading ESG and corporate governance rating and research firm that supports inves- tors in developing and implementing responsible investment strategies.
CODE OF ETHICS 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 the conduct of the Moncler and Stone Island brands and of their employees towards their stakeholders.
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 knowledge that conduct inspired by the principles of diligence, honesty and loyalty is an important driver of economic and social development. Employees and partners are re- quired to act with honesty, passion and integrity and to build rela- tionships with stakeholders based on mutual trust, so that growth is guided by the principle of shared value.
The Codes are periodically updated in order to align them with the international best practices and to integrate them with emerging sustainability issues. Both Codes are inspired by the main existing national and international regulations 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 Europe- an Union, the decent work standards set out in the ILO (Internation- al Labour Organisation) conventions and the OECD (Organisation for Economic Cooperation and Development) Guidelines for Multi- national Enterprises. The Codes of Ethics evoke the key principles set out both in the Supplier Code of Conduct and Group s policies, including the Anti-Corruption Policy, Environmental Policy, Human Rights Policy1, the Occupational Health and Safety Policy, the tax policy and HR management policy, as well as the financial and as- set protection policies.
The Codes of Ethics apply to all employees, suppliers, con- tractors, consultants, partners, and external collaborators of the two Brands, and apply in a consistent manner across all countries where Moncler and Stone Island operate. The documents are avail- able in Italian and English, as well as in Romanian for the Moncler Code of Ethics, and set out the principles and guidelines that in- spire the way in which the Brands operate every day and guide the behaviour of employees and others who work with them in various ways in performing their activities and responsibilities. The Codes are brought to the attention of employees in the most appropriate manner, in accordance with local customs. The documents can be freely downloaded from the company s intranet and internet sites. An online training programme on the contents of the Code of Ethics is regularly provided for all Moncler employees, including tempo- rary and part-time employees, in order to ensure a proper under- standing 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, Manage- ment 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 proce-
dures and disciplinary codes, aimed at preventing the commission of offences and ensuring ethical conduct by those who operate on behalf of Group companies, in compliance with the principles of le- gitimacy, fairness and transparency.
Compliance with the Codes of Ethics and the Model is moni- tored by the appropriate supervisory and control bodies of the two Brands, through specific audits and investigations, launched on the basis of reports of conduct not in compliance with the principles of conduct required by Moncler and Stone Island. The results of veri- fications may lead to disciplinary actions which, depending on the severity of violation, may lead to the termination of the professional or business relationship.
The Supervisory Body, which is the entity responsible for su- pervising the adequacy and compliance of the Organisation, Man- agement and Control Model and its inspiring principles in Italy, is a collegial body consisting of three members of a mixed composition of professionals, 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 is placed at the top of the Company s organisation, reporting directly to the Board of Direc- tors of the Company to which it belongs, in order to guarantee au- tonomy from all forms of potential interference.
The Moncler and Stone Island Organisation, Management and Control Models are periodically updated in the light of regu- latory and organisational changes. In particular, in 2022 a risk as- sessment was carried out to update the models, incorporating new offences such as offences involving payment instruments other than cash and offences against cultural heritage.
In the control activities carried out by the Internal Audit func- tion, which operates at Group level, in 2022 with regard to the Ital- ian companies of Moncler and Stone Island, checks were carried out on significant corporate processes (payments, purchases, ser- vices 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 the Group s foreign subsidiaries, in 2022 the Internal Audit function carried out checks and tests on the ade- quacy of the internal control system and financial reporting proce- dures for companies operating in Korea, Japan, the United States and Türkiye, including to identify and/or prevent potential fraudu- lent conduct.
As part of management of store operations (management of receipts and sales, management of stock, protection of compa- ny assets and prevention of theft), the Internal Audit department draws up a thorough annual plan of audits at stores. Stores are generally selected according to criteria of significance of revenues, risk indicators and geographical diversification. During the year, the function continuously monitored the inventories, missing prod- ucts detected during product handling and at the warehouses and compliance with the sales procedure. In particular, for Stone Island stores in Italy and the United States, ad hoc audits were carried out in 2022 on the correct implementation of store procedures follow- ing the migration of the sales management system already imple- mented at Moncler stores.
In addition, in order to ensure compliance with the principles and rules of conduct set out in the Code of Ethics, there are var- ious compliance audits, including, for example, ethical and social audits along the supply chain, periodic checks carried out to ob- tain social and environmental certification, third-party audits on in- formation systems and analyses by external laboratories qualified to verify the chemical compliance of products with Company stan- dards and applicable legislation.
For both Moncler and Stone Island, a whistleblowing system is in place at the Group level, with the aim of accurately manage and quickly detect any illegal and disrespectful conduct reported by employees or external parties with regard to internal rules, regu- lations, procedures and values, and take 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 penalisation. The platform makes it possible for the whistleblower to choose ano- nymity: in this case, communications through the platform between the whistleblower and the Group, via Web or dedicated telephone lines, take place solely through a unique code identifying the report.
* S&P Global is a leading global rating, benchmark and analytics company, according to economic, social and environmental responsibility criteria.
** CDP is a non-profit organisation that manages the main environmental re- porting platform and assesses companies on a scale from A to E.
*** MSCI ESG Research provides in-depth research, assessment and analysis on business practices related to environmental, social and governance issues to offer institutional investors insights to identify risks and opportu- nities that traditional methods of investment may overlook. The rating scale ranges from AAA (leader) to CCC (laggard).
1 Adopted in February 2023.