Moncler - Annual Report 2024

Moncler Group | Annual Report 2024 Board of Directors’ Report 304 | ’

evel – 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 phone 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 regulations (processing of sensitive and personal data).

In 2024, the updated whistleblowing procedure was

communicated

to the entire company population via dedicated

newsletters and made available on the company intranet. The

regional human resources managers were made aware of the

importance of whistleblowing and reporting procedure through

one-to-one meetings or video conferences. In addition, the

mandatory course on the Code of Ethics includes a section dedicated

to the use of the whistleblowing channel.

Anti-corruption

The Group adopts an Anti-Corruption Model, approved by the

Board of Directors based on a targeted risk assessment

and a regulatory analysis of corruption of fences in the countries

in which the Group operates, selected on the basis of the

Corruption Perception Index of the country and the value of the

invoice generated by the company in the country. This allows

for the identif ication of areas theoretically at risk of corruption

and the internal controls that are either in place or need to be

strengthened. The Group’s Anti-Corruption Policy also def ines

the guiding principles and controls that the Group’s employees,

partners and counterparties are required to follow to prevent

incidents of corruption.

In particular, the Policy def ines: regulatory monitoring

responsibilities; management and reporting of cases of non-

compliance; and specif ic measures to control corruption risk.

The following areas were identif ied as theoretically

exposed

to risk of corruption: relationships with public administration;

relationships with suppliers and external consultants; relationships

with agents and intermediaries relationships with business

partners for joint ventures and directors management of donations

sponsorshipsgifts and samples and human resources management

For each of the abovementioned areas principles of conduct

and operating rules have been formulated in both the

AntiCorruption Policy and in the 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 Groups AntiCorruption

Model have been circulated and shared globally In addition all

Group employees are regularly of fered specif ic training on active

and passive corruption In particular a new elearning platform

training programme was introduced in 2024 aimed

at s

trengthening the culture of integrity and implementing

ef fective anti-corruption measures, thus helping to mitigate

potential risks and maintain high ethical standards.

The Internal Audit function periodically conducts out

-site audits at Group companies in order to verify the adoption

of controls to mitigate corruption risk in the areas identif ied

s most at risk. In particular, audits are carried out annually

on marketing costs, sponsorships, donations and gifts,

management of consultants and professional service, employee

recruitment, supplier management, payments, expenses

and entertainment costs.

During these audits, the various departments involved are

informed of the importance of complying with the established

ntrol protocols. Audit results are shared with the Control, Risks

and Sustainability Committee and the Supervisory Bodies

of Moncler and Stone Island. At least every six months, the Board

of Directors receives and assesses the results of the audit

activities carried out by the Group Internal Audit function, also

through the Control, Risks and Sustainability Committee,

which is an internal Board committee.

No cases of either active or passive corruption were

ascertained in 2024, in line with 2023.

The Moncler Group manages relationships with political parties

and their representatives based on the highest principles

of transparency and ethics. Also in 2024, the Moncler Group did

not make any contributions to political parties, lobbying

activities or any other activities beyond those with associative

purposes. The political commitments and contributions

made by the Group’s employees are considered personal and

entirely voluntary.

Regarding lobbying activities, the Group mainly operates

through industry associations, without excluding the residual

possibility of directly interacting with institutions, always

in accordance with the principles described above, to ensure that

the activities and decisions taken are aligned with the Group’s

Environmental Policy.

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