51 ReSPOnSIBLe BUSIneSS MAnAGeMenT50 ReSPOnSIBLe BUSIneSS MAnAGeMenT MONCLER GROUP 2023
IndePendenT eSG RATInGS And ASSeSSMenTS
In 2023 Moncler has been confirmed for the fifth year in a row in the Dow Jones Sustainability World and Europe indices, achieving the highest score (89/100) of the Textiles, Apparel & Luxury Goods sector in the 2023 S&P Global Corpo- rate Sustainability Assessment* (as of 7 February 2024).
In the 2023 CDP** Climate Change questionnaire, the Group achieved the top score (A) in CdP s worldwide ranking for its leadership in transparency and management of climate change related topics. In 2023, the Group has also been confirmed as a leading company on Supplier Engagement Leaderboard, for taking action to measure and reduce climate risk within its supply chain.
In 2023 Moncler also obtained the maximum AAA score (AA in 2022) from MSCI ESG Research***, which provides sustainability ratings for listed interna- tional companies and some private companies by evaluating them on their ex- posure to industry specific eSG risks and their ability to manage those risks in comparison to sector peers.
Moncler also ranked second in the Specialised Retail Europe sector in the ESG Overall Score ranking of Moody s ESG Solutions, with a score of 65/100, achieving the Advanced level.
In January 2024, Sustainalytics**** confirmed Moncler s Industry Top-Rat- ed Badge and Regional Top-Rated Badge for its sustainability performance.
COde OF eTHICS The Code of ethics and corporate policies are one of the pillars of the Moncler Group s corporate governance system and govern the decisions and the conduct of the Moncler and Stone Island brands and of their employees towards their stakeholders.
The Codes of ethics currently adopted by Moncler and Stone Island encompass the set of values that both Brands recognise, share and promote, in the knowledge that conduct inspired by the principles of diligence, honesty and loyalty is an important driver of economic and social development. employees and partners are re- quired to act with honesty, passion and integrity and to build rela- tionships with stakeholders based on mutual trust, so that growth is guided by the principle of shared value.
The Codes are periodically updated in order to align them with the international best practices and to integrate them with emerging sustainability issues. Both Codes are inspired by the main existing national and international regulations on corporate social respon- sibility, corporate governance, human rights and the environment, such as the United nations Universal declaration of Human Rights, the Charter of Fundamental Rights of the european Union, the de- cent work standards set out in the ILO (International Labour Or- ganisation) conventions and the OeCd (Organisation for economic Cooperation and development) Guidelines for Multinational enter- prises. The Codes of ethics evoke the key principles set out both in the Supplier Code of Conduct and Group s policies, including the An- ti-Corruption Policy, environmental Policy, Human Rights Policy2, the Occupational Health and Safety Policy, the tax policy and HR man- agement policy, as well as the financial and asset protection policies.
The Codes of ethics apply to all employees, suppliers, con- tractors, consultants, partners, and external collaborators of the two Brands, and apply in a consistent manner across all coun- tries where Moncler and Stone Island operate. The documents are available in Italian and english, as well as in Romanian for the Mon- cler Code of ethics. The Codes are brought to the attention of em- ployees in the most appropriate manner, in accordance with local practices. The documents can be freely downloaded from the com- pany s intranet and internet sites. An online training programme on the contents of the Code of ethics is regularly provided for all Mon- cler employees, including temporary and part-time employees, in order to ensure a proper understanding and virtuous behaviour consistent with the requirements of the Code of ethics, while Italian Stone Island employees are trained on these issues through a spe- cific module dedicated to the Code within the 231 Model course.
Together with the Anti-Corruption Model, the Codes of ethics are a fundamental and integral part of the Organisation, Manage- ment and Control Models adopted by Moncler and Stone Island pursuant to Legislative decree 231/2001. Both Models take the form of a set of principles and rules of conduct, operating proce- dures and disciplinary codes, aimed at preventing the commission of offences and ensuring ethical conduct by those who operate on behalf of Group companies, in compliance with the principles of le- gitimacy, fairness and transparency. 2 Adopted in February 2023.
Compliance with the Codes of ethics and the Model is monitored by the appropriate supervisory and control bodies of the two Brands, through specific audits and investigations, launched on the basis of reports of conduct not in compliance with the principles of conduct required by Moncler and Stone Island. The results of verifications may lead to disciplinary actions which, depending on the severity of violation, may lead to the termination of the professional or busi- ness relationship.
The Supervisory Body, which is the entity responsible for su- pervising the adequacy and compliance of the Organisation, Man- agement and Control Model and its inspiring principles in Italy, is a collegial body consisting of three members of a mixed composition of professionals, both internal and external to the company, two of whom have accounting and legal expertise, and by the head of the Group Internal Audit function. This body is placed at the top of the Company s organisation, reporting directly to the Board of direc- tors of the Company to which it belongs, in order to guarantee au- tonomy from all forms of potential interference.
The Moncler and Stone Island Organisation, Management and Control Models are periodically updated in light of regulatory and organisational changes. In particular, in 2023 the models were updated with the addition of new offences such as offences relat- ing to payment instruments other than cash and offences against cultural heritage, as well as the transposition of new eU directive related to the management of the whistleblowing channel.
In the control activities carried out by the Internal Audit func- tion, which operates at Group level, in 2023 with regard to the Group s Italian companies, checks were carried out on significant corporate processes (payments, purchases, services and consultancy, miss- ing products, quality control, charge-backs to suppliers, sales, re- ceipts, credit management, payroll management, etc.), as well as on the main areas identified as sensitive within the Model. With regard to the Group s foreign subsidiaries, in 2023 the Internal Audit function carried out checks and tests on the adequacy of the internal control system and financial reporting procedures for companies operating in Chinese mainland, South Korea, Japan, the United States and the United Kingdom, including to identify and/or prevent potential fraud- ulent conduct.
As part of management of store operations (management of receipts and sales, management of stock, protection of company assets and prevention of theft), the Internal Audit function draws up a thorough annual plan of audits at stores. Stores are generally se- lected according to criteria of significance of revenues, risk indica- tors and geographical diversification. during the year, the function continuously monitored the inventories, missing products detect- ed during product handling and at the warehouses and compliance with the sales procedure. In particular, for Stone Island stores in Ita- ly and in the United States and in Japan, ad hoc audits were carried out in 2023 on the correct implementation of store procedures fol- lowing the migration of the sales management system already im- plemented at Moncler stores.
In addition, in order to ensure compliance with the principles and rules of conduct set out in the Code of ethics, there are var- ious compliance audits, including, for example, ethical and social audits along the supply chain, periodic checks carried out to ob- tain social and environmental certification, third-party audits on in- formation systems and analyses by external laboratories qualified to verify the chemical compliance of products with company stan- dards and applicable legislation.
For both Moncler and Stone Island, a whistleblowing system is in place at the Group level, with the aim of accurately manage and quickly detect any illegal and disrespectful conduct reported by employees or external parties with regard to internal rules, regu- lations, procedures and values, and take appropriate steps, while ensuring the anonymity of the whistleblower. Any stakeholder, whether internal 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. The plat- form makes it possible for the whistleblower to choose anonymi- ty: in this case, communications through the platform between the whistleblower and the Group, via Web or dedicated telephone lines, take place solely through a unique code identifying the report.
However, this is without prejudice to the legal obligations and the protection of the rights of the Companies or of people accused
* S&P Global is a leading global rating, benchmark and analytics company, according to economic, social and environmental responsibility criteria.
** CdP is a non-profit organisation that manages the main international envi- ronmental reporting database. Its assessments are taken into great ac- count by the financial community to guide investment decisions. To assess the more than 21,000 companies participating in its annual Climate Change questionnaire, CdP uses a detailed, independent methodology, as- signing a score from A to d, on the basis of completeness of information, awareness, risk management and best practices implemented, such as set- ting ambitious and meaningful targets.
*** MSCI eSG Research provides in-depth research, assessment and analysis on business practices related to environmental, social and governance issues to offer institutional investors insights to identify risks and opportu- nities that traditional methods of investment may overlook. The rating scale ranges from AAA (leader) to CCC (laggard).
**** Sustainalytics is a leading eSG and Corporate Governance rating and research firm that supports investors in developing and implementing re- sponsible investment strategies.