Moncler Group | Annual Report 2024 Board of Directors’ Report 272 Moncler Group | Annual Report 2024 Board of Directors’ Report 273

[S4 SBM–3] Material impacts, risks and opportunities

and their interaction with strategy and business model

1

Registration Evaluation Authorisation

and Restriction of Chemicals

2

National Standard of the Peoples

Republic of China

3

Japanese Industrial Standards

The theoretical risks associated with clients, identif ied in the

double materiality analysis, concern issues related to client data

management and protection as well as compliance with applicable

laws for products intended for sale (the assessments did not take

into account the mitigation actions implemented by the Group).

The management and protection of client data represent

a strategic element of Moncler Group’s operations and its

trust-based relationship with stakeholders, as the collection, storage

and use of data play a crucial role in key business processes,

including the personalisation of the of fer and client relationships

management both in-store and online. Specif ically, the assessments

conducted showed that non-compliance with the regulations

on data management and protection applicable in the various

countries where Moncler and Stone Island operate, could

represent a potential risk for the Group both in terms of sanctions

and reputation.

Another theoretical risk that emerged from the analysis

concerns potential non-compliance with applicable regulations

related to products compliance intended for sale in the selling

country/State, especially with reference to the use of potentially

harmful chemical substances. The evolution of applicable

regulations in terms of product compliance, such as the REACH

regulation1 in Europe, the Chinese GB requirements2 and the

Japanese JIS3 requirements, requires careful monitoring and

adaptation when necessary. Non-compliance could result in

consequences not only in economic terms, with direct losses

due to restrictions on distribution, sanctions, product recalls

or sales bans, but also in terms of reputation, undermining the

perception of the brand as a symbol of quality, sustainability

and responsibility.

[S4–1] Policies related to consumers and end-users

Data management and protection

The Moncler Group, in line with the principles set out in the Code

of Ethics and the Human Rights Policy (see also pages 263; 302),

recognises and protects the right to privacy of its clients, as well

as employees, collaborators, suppliers and partners. The Company is

committed to using and processing personal data collected in the

countries where it operates in compliance with applicable regulations,

such as EU Regulation 2016/679 General Data Protection Regulation

(GDPR). To this end, Moncler and Stone Island have adopted internal

procedures, tools and guidelines, including the Data Protection

Master Policy, which provides rules and instructions for the

processing of personal data (of clients, employees and third parties),

data retention periods, and identif ies and def ines the individuals

involved in the process, their respective roles and responsibilities;

the register of personal data processing activities; the procedure

for assessing the impact on personal data protection (Data Protection

Impact Assessment — DPIA); the procedure for the management

of data breaches; the regulation on the use of IT tools by employees;

and the information technology systems capable of ensuring

an increasingly high level of security.

These documents, processes and tools are regularly monitored

and, if necessary, updated to ref lect any new regulations or rules,

as well as changes in the Group’s organisational structure or

technological developments. Privacy-related responsibilities lie

with the Board of Directors.

Product compliance

In line with the provisions of the Code of Ethics, the Group

is committed to ensuring that products meet client expectations

and comply with the regulatory requirements of the specif ic

markets in which they are sold.

In accordance with the Supplier Code of Conduct (see also

page 263), the Group contractually requires its manufacturing

partners to operate in compliance with applicable international

legislation regarding chemicals and performance.

In particular, partners are contractually bound to adhere to

the guidelines outlined in the Compliance Specif ications, which

detail the main compliance requirements of both Brands for their

suppliers and sub-suppliers, including dye houses, laundries and

embroideries. The Specif ications are updated periodically, taking

into account international regulations as well as voluntary

parameters and commitments undertaken by Moncler and

Stone Island, which include the Group’s Manufacturing Restricted

Substances List (MRSL) and Product Restricted Substances List

(PRSL). These def ine both the substances that suppliers and

sub-suppliers must monitor in the various production phases and in

the products/materials, and the related reference parameters to be

respected to prevent and/or mitigate the risk of any critical issues

related to the products. In addition, for Moncler, the Specif ications

include the Manual of Performances which outlines performance

and physical-mechanical requirements. For more information on

PRSL and MRSL, see also page 191.