Moncler - Annual Report 2024

Moncler Group | Annual Report 2024 Board of Directors’ Report 304 Moncler Group | Annual Report 2024 Board of Directors’ Report 305

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.

Compliance

The Moncler Group, as described above, operates based

on the highest ethical principles of transparency, integrity and

loyalty, formalised in the Moncler and Stone Island Codes

of Ethics, fully complying with the applicable laws in the countries

where it operates, while concentrating ef forts on building

relationships of trust with its stakeholders.

In conf irmation of the above, during 2024 no f inal decisions

re handed down against the Group companies in any of the

following areas: unfair competition and antitrust; product health

and safety; product labelling; marketing, including advertising,

promotion and sponsorship; disputes impacting the community;

environment; or intellectual property.

Animal welfare

Animal welfare is an area of particular attention for the

Moncler Group. As outlined in the Supplier Code of Conduct

and conf irmed within the Raw Material Manual, all partners

are required to comply with current animal health and welfare

regulations and to adhere to strict protection standards

covering every phase of animal treatment.

In particular, suppliers must ensure compliance with the “Five

Freedoms” for farm animal welfare: freedom from hunger

and thirst; freedom from physical and thermal discomfort; freedom

from pain, injury and disease; freedom to express species-specif ic

behaviors; and freedom from fear and distress.

The Code requires suppliers to take all necessary measures

to protect the behavioural, biological and emotional needs

of animals, safeguard biodiversity in sourcing ecosystems, and

provide the provenance of animal-derived materials.

The Group is also committed to not using materials derived

from endangered species according to the CITES Convention

(Convention on International Trade in Endangered Species of Wild

Fauna and Flora).

Down

Down is one of the most important raw materials for Moncler

All suppliers are not only required to meet the highest quality

tandards but also to act responsibly and with full respect for

animal welfare

To protect animal welfare Moncler requires and verif ies

that its down suppliers comply with the strict requirements

laid down in the Moncler Technical Protocol called DIST Down

Integrity System Traceability available on the page dist

moncler.com, and verif ies that they do so. The DIST Protocol, f irst

implemented in 2015, regulates methods of breeding white

geese, the traceability, and technical quality of down. Moncler

only purchases down that has obtained DIST-certif ication.

Among the basic requirements that must be respected across

the entire supply chain include the following:

•down must be exclusively sourced from farmed white geese

and as a by-product of the food chain;

•no form of live-plucking or forced feeding is permitted.

The protocol, drafted taking into consideration the peculiarities of the

Moncler’s supply chain, is the result of open and constructive

dialogue within the scope of a multi-stakeholder forum set up in 2014,

which considered the expectations of the various stakeholders

to ensure a scientif ic and holistic approach to the topic of animal

welfare and product traceability. The forum, chaired by a professor

of Management at the Ca’ Foscari University of Venice with

specif ic knowledge and expertise in sustainability issues, consists

of Moncler people, experts from the Department of Veterinary

Medicine of the University of Milan, the Polish National Institute

of Animal Husbandry Koluda Wielka, Compassion in World

Farming (a non-governmental organisation dedicated to the welfare

of farm animals), representatives from certif ication and

consulting companies (SGS, Control Union, IDFL and KPMG),

and, starting in 2023, following the inclusion in the DIST

protocol of specif ic modules on human rights and environmental

compliance, representatives of the International Labour

Organization. From the belief that dialogue is a source

of improvement, Moncler organized the eleventh multi-stakeholder

forum in February 2025. At the forum, the results of the

certif ication process and any future developments were discussed.

The DIST Protocol assesses animal welfare from

an innovative perspective. In addition to the traditional approach

that focuses on the environment in which the animal lives

(in

terms of availability of food and water, adequate space for

movement, etc.), the Protocol, in line with the European

Commission guidelines also assesses welfare by carefully

observing the animal through the socalled AnimalBased

Measures ABMs1 ABMs allow a direct assessment of an animals

condition by observing how geese respond to the dif ferent

factors of the environment in which they live outcome approach

The DIST Protocol features nine ABMs including among

other those designed to identify unusual behaviours or aspects

such as plumophagia2 dislocated or broken wings feather

irregularities and abnormal beak colour These situations can

be associated with environments in which welfare

of geese is compromised by various factors including high animal

density inadequate diet lack of pasture or inappropriate

animal management

AnimalBased Measures are indicators

that can be directly observed on

animals and that assess their actual

conditions in relation to their ability to

adapt to specif ic farming environments

These measures include physiological

pathological and behavioural indicators

Plumophagia is an abnormal behaviour

in avian species that consists of pecking

the feathers of another bird or tearing

them with the beak