Moncler - Annual Report 2024

Moncler Group | Annual Report 2024 Board of Directors’ Report 302 Moncler Group | Annual Report 2024 Board of Directors’ Report 303

This section, in accordance with the European Sustainability

Reporting Standards (ESRS) on business conduct (ESRS G1),

describes the corporate culture, the Company’s values, as well

as the Codes and policies that guide behaviours and principles

to be followed in business management, with particular reference

to the topics identif ied as relevant in the double materiality

analysis, namely relationships with suppliers and attention to animal

welfare (the assessments did not take into account the mitigation

actions implemented by the Group).

In addition, to ensure continuity with what was reported

in previous years’ Consolidated Non-Financial Statements, issues

such as corruption prevention, contributions to political parties,

and lobbying activities are also addressed, even though they were

not identif ied as relevant.

Code of Ethics

The Code of Ethics and corporate policies are one of the pillars of the

Group’s corporate governance system and regulate the way

the Moncler brand, the Stone Island brand and their respective

employees, partners, clients and shareholders operate.

The Codes of Ethics of Moncler and Stone Island encompass

the set of values both Brands recognise, share, and promote,

acknowledging that conduct inspired by the principles of diligence,

honesty and loyalty represents a signif icant driver of economic

nd social development. Employees and partners are required to act

with honesty, passion and integrity and to build relationships

with stakeholders based on mutual trust so that growth is guided

by the principle of shared value

he Codes establish clear behavioural norms for recipients

regulating various aspects including relations with employees

suppliers clients and authorities respect for human rights

protection of intellectual and industrial property conf idential

information and privacy respect for fair competition

proper

administrative and f inancial management environmental

protection anticorruption and antimoney laundering measures

and the responsible use of corporate assets and the management

of conf licts of interest contributions and sponsorships

The Codes of Ethics apply to all employees suppliers contractors

consultants partners and external collaborators of the two

Brands and apply in a consistent manner across all countries

where Moncler and Stone Island operate. In case of non-compliance,

disciplinary measures and/or sanctions will be applied

up to and including termination of the existing employment

contract or business relationship.

The Board of Directors is the competent body to decide on the

adoption and subsequent amendments to the Code of Ethics,

as well as being involved in managing any ethical issues of particular

relevance. The Head of the Corporate Af fairs & Compliance

Function, as part of the second-level control, monitors the proper

conduct of the Group’s operations in compliance with relevant

legal and regulatory constraints, internal procedures and values

of the Code of Ethics This role also ensures the management

of corporate compliance aspects Human Resources and the

Function Managers on the other hand actively support

staf f training and awarenessraising ensuring that all employees

understand and respect the provisions of the Code of Ethics

The Codes are periodically updated to align with international

best practices and further integrate them more with emerging

sustainability and business conduct topics 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 International Bill

of Human Rights of the United Nations the Universal Declaration

of Human Rights and the Charter of Fundamental Rights of the

European Union the decent work standards set out in the

[G1–1] Policies and practices on business conduct

and corporate culture

conventions of the International Labour Organization (ILO), and

the OECD (Organization for Economic Cooperation and

Development) Guidelines for Multinational Enterprises of the

Organization for Economic Cooperation and Development.

The Codes of Ethics also refer to the key principles outlined in the

Supplier Code of Conduct. The Group’s corporate policies,

including the Anti-Corruption Policy, Environmental Policy, Human

Rights Policy, Health and Safety Management Policy, etc., are

considered an integral part of the Codes.

The Codes are made available to employees through the most

appropriate means, in accordance with local customs, and

are available in Italian and English, as well as in Romanian for

the Moncler Code of Ethics. The documents can be freely

ownloaded from the company’s intranet and internet sites.

An online training programme is regularly provided to all

Monc

ler employees, including temporary and part-time employees,

to ensure correct understanding and virtuous behaviour

consistent with the requirements of the Code, while Stone Island

employees in Italy are trained on these topics through a specif ic

module within the 231 Model course.

Organisation, management and control model

he Codes of Ethics together with the Anti-Corruption Model,

are a fundamental and integral part of the Organisation,

Management and Control Models adopted by Moncler and

Stone Island pursuant to Legislative Decree 231/2001.

Both Models consist of a set of principles and rules of conduct,

operational procedures and disciplinary codes, aimed

at preventing the commission of of fences and ensuring ethical

behaviour by those who operate on behalf of Group’s companies.

The Organisation, Management and Control Models

of both

Moncler and Stone Island are periodically updated in light

regulatory and organisational changes. In particular,

for Moncler in October 2023 and for Stone Island in February

2024, the Models were updated with the integration of new

of fences such as crimes relating to payment instruments other than

cash and crimes against cultural heritage as well as the

adoption of EU developments regarding the management of the

whistleblowing channel The body responsible for overseeing

the adequacy of and compliance with the Organisation Management

and Control Model and its guiding principles is the Supervisory

Body The Supervisory Body works in coordination with

the Groups Internal Audit function which reports directly to the

Board of Directors and operates with complete autonomy without

responsibility for operational areas Internal Audit conducts

checks on various compliance issues including privacy taxation

health and safety labour law aspects and anticorruption

measures to verify compliance with the principles of the Code

of Ethics In 2024 the Internal Audit function with regard to

its au

diting activities on the Groups Italian companies continued

to carry out several checks on signif icant corporate processes

(payments, purchases, services and consultancy, quality control,

charge-backs to suppliers, sales, receipts, credit management,

payroll management, etc.), as well as on the main areas identif ied

as “sensitive” within the Model. With regard to the Group’s

foreign subsidiaries, during the year the Internal Audit function

carried out checks and tests on the adequacy of the internal

control system and f inancial reporting procedures for companies

operating in Chinese mainland, South Korea, Japan, the United

ates, Canada and France, including to identify and/or prevent

potential fraudulent conduct. As part of management of store

oper

ations (management of receipts and sales, managemen

f stock, protection of company assets and prevention

of theft),

the Internal Audit function draws up an annual plan

of audits at stores. Stores are generally selected according to criteria

f revenues signif icance, risk indicators and geographical

diversif ication. During the year, the function monitored inventories,

missing products detected during product handling

and at the warehouses and compliance with the sales procedure.

Whistleblowing system

At Group level, a whistleblowing system is in place with the aim

of ef fectively managing and quickly detecting any illegal

and unethical conduct and action that do not comply with the

rules, regulations, internal procedures, and value principles,

and adopting the appropriate measures while ensuring the

anonymity of the whistleblower. Any stakeholder, whether

nternal or external to the Group, who, in good faith, reports

an anomalous behaviour, alleged or actual violation of the Code

is protected from retaliation, discrimination or penalisation.

In particular, once a report has been received through the

histleblowing channels, the Head of Internal Audit promptly

analyses all the information and responds to the whistleblower;

the issue raised is very serious and/or complex, the Head

of Internal Audit is tasked with starting an immediate

investigation, also requesting support from other corporate

functions such as Asset Protection Legal Compliance Human

Resources ICT and Sustainability as well as from competent

external consultants in order 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 termination of the contract

with the employee other staf f member or supplier involved The

whistleblower is notif ied of the closure of the investigation

in traceable form via an IT platform At least every six months

the Internal Audit function reports to the Board of Directors

on the cases investigated

The Moncler Group has provided whistleblowers with an

ad hoc

web platform and phone lines which are managed

by a specialised third party and available at all times at the global