55 RESPONSIBLE BUSINESS MANAGEMENT54 RESPONSIBLE BUSINESS MANAGEMENT MONCLER GROUP 2022
However, this is without prejudice to the legal obligations and the protection of the rights of the Companies or of people accused wrongly and/or in bad faith. The Moncler Group has provided whis- tleblowers with an ad hoc web platform and telephone lines man- aged by a specialised third party and available at all times at the global level for recording and managing reports from employees, suppliers, clients and counterparties of all the Group companies. The Web platform is available in Italian, English, Chinese, Japanese, Korean, French, German, Turkish, Arabic and Romanian, while the telephone operators speak the language of all the countries where the Group is present through its network of stores. The platform ensures, inter alia, full compliance with international privacy regu- lations (processing of sensitive and personal data). In early 2023, the Group planned a timely update of the rules for whistleblowing management in light of the changes occurred in Italian legislation transposing the European Directive aimed at providing greater pro- tection of whistleblowers against retaliatory behaviour.
The whistleblowing procedure was circulated to all employ- ees and is available on the two Brands company intranet. All Group employees, through an ad hoc email, and human resources manag- ers of the Moncler Regions, through one-to-one meetings or video conferences, were made aware of the importance of whistleblow- ing and reporting methods.
Management of the Group s whistleblowing channels was entrusted to the head of Internal Audit, who was responsible for re- porting what was tracked and monitored through these channels directly to the Board of Directors at least every six months.
In particular, once a report has been received through whis- tleblowing channels the Head of Internal Audit receives and promptly analyses all the information; if the issue raised is very se- rious or complex, the Head of Internal Audit has the task of start- ing an immediate investigation, also requesting the support of other corporate functions, including Legal, Human Resources, ICT and Sustainability, as well as competent external consultants, in or- der 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, up to termina- tion of the contract with the employee.
During the year, although no significant reports were received through the whistleblowing system, 13 reports2 were received through communications addressed to the Human Resources de- partment regarding potential violations of the Code of Ethics that upon investigation were determined to be actual violations of the Code of Ethics: three cases of internal theft of certain products from stores, nine cases of inappropriate behaviour towards colleagues or customers and one of discriminatory behaviour. In five cases, the employment relationship was terminated and in the others disci- plinary actions were implemented.
ANTI-CORRUPTION MODEL In 2021 a Group-wide Anti-Corruption Model was adopted, ap- proved by the Board of Directors and based on a targeted risk as- sessment 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 of the coun- try. This resulted in the identification of areas of theoretical corrup- tion risk, of the existing internal controls and those to be enhanced, and in the formulation of a Group Anti-Corruption Policy setting out the guiding principles and controls that Group employees, partners and other counterparts are required to implement to prevent cor- ruption incidents.
In particular, the Policy lays down: (i) regulatory monitoring re- sponsibilities; (ii) management and reporting of cases of non-com- pliance; 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 business partners for joint ventures and directors management of donations/sponsorships/gifts and samples human resources management.
For each of the above-mentioned areas, principles of conduct and operating rules have been formulated in both the Anti-Corruption Policy and in the Group s Codes of Ethics, as well as in the policies governing behaviour to be held when carrying out activities relating to the areas mentioned above. The policies and procedures of the Group s Anti-Corruption Model have been circulated and shared globally. An ad hoc training is also regularly provided to all employ- ees in Italy through the e-learning platform.
The Internal Audit function periodically carries out on-site au- dits 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 assign- ments, 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 established control protocols. Audit results are shared with the Control, Risk and Sustainability Committee and the Supervisory Bodies of the Moncler brand and Stone Island brand. At least every six months, the Board of Directors receives and assesses the results of the au- dit activities carried out by the Group Internal Audit function. No cases of corruption were reported during 2022.
SUPPLIER CODE OF CONDUCT The Supplier Code of Conduct, adopted at Group level, outlines the Company s expectations in relation to the main areas of the respon- sible sourcing process and is composed of six sections that estab- lish binding rules for: Labour and Human Rights, Health and Safety, Environment, Animal Welfare, Quality and Safety of Products and Services, Business Ethics and Protection of Intellectual Property. Moncler requires its suppliers and sub-contractors to strictly com- ply with the principles set forth in the Code of Conduct and also commits to train and raise awareness of these provisions, both with- in its internal departments and among suppliers, through meetings at corporate sites or at suppliers premises. The Group also regular- ly conducts third-party audits throughout the supply chain to verify compliance with the principles contained in the Code of Conduct. See also pages 134-138.
Since 2017 Moncler has also been publishing an annual Modern Slavery Statement in order to transparently communicate its approach to the management of human rights. In particular, the document describes the measures taken to ensure, as required by the laws of the United Kingdom and the California Modern Slav- ery Act 2015 Section 54 , the absence of all forms of modern slavery, forced labour and human trafficking within its direct scope and along its supply chain.
2 The 2022 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.