53 ReSPOnSIBLe BUSIneSS MAnAGeMenT52 ReSPOnSIBLe BUSIneSS MAnAGeMenT MONCLER GROUP 2023

wrongly and/or in bad faith. The Moncler Group has provided whis- tleblowers with an ad hoc web platform and telephone lines man- aged by a specialised third party and available at all times at the global level 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 telephone operators speak the language of all the countries where the Group is present through its network of stores. The platform en- sures, inter alia, full compliance with international privacy regula- tions processing of sensitive and personal data. In 2023, the Group updated the whistleblowing procedure in the light of the changes in Italian legislation that transposed the european directive aimed at providing greater protection of whistleblowers against retaliato- ry behaviour. This update was immediately circulated to the entire corporate population in a dedicated newsletter. The whistleblowing procedure is available on the two Brands company intranet. In ad- dition, the human resources managers of the Moncler Regions were made aware of the importance of whistleblowing and how to report it through one-to-one meetings or video conferences.

Management of the Group s whistleblowing channels was entrusted to the head of Internal Audit, who was responsible for re- porting what was tracked and monitored through these channels directly to the Board of directors at least every six months.

In particular, once a report has been received through whis- tleblowing channels, the head of Internal Audit receives and promptly analyses all the information and responds immediately to the whistleblower; if the issue raised is very serious or complex, the head of Internal Audit has the task of starting an immediate inves- tigation, also requesting the support of other corporate functions, including Asset Protection, Legal, Compliance, Human Resources, ICT and Sustainability, as well as competent external consultants, in order to conduct investigations and controls aimed at under- standing what happened. Where appropriate in relation to the seri- ousness of the incident, immediate measures are put in place, up to termination of the contract with the employee or other staff mem- ber. The whistleblower is notified of closure of the investigation in traceable form via an IT platform.

during the year, five reports considered significant and wor- thy of analysis and investigation were received through the whis- tleblowing system. In four cases, on the basis of the outcome of the investigation, it was decided not to proceed at a disciplinary level. Rather, awareness-raising activity was carried out on the individ- uals concerned by the corporate Human Resources (HR) depart- ment together with HR colleagues from the Regions involved: three of these cases relate to reports of alleged inappropriate behaviour by team managers towards colleagues, while one case relates to a report of inappropriate management of the sales and store man- agement procedures by a store manager. The fifth case, instead, in- volved internal thefts and violations of sales procedures by the staff of a store. Following the investigations carried out, the employment relationship with the individuals involved was terminated.

In addition, through communications addressed to the Hu- man Resources department, 17 reports were received3 regarding potential violations of the Code of ethics that upon investigation were determined to be actual violations of the Code of ethics: eight cases of internal theft of certain products from stores, four cases of inappropriate behaviour towards colleagues or clients, three cases of harassment and/or violent behaviour and two cases of discrim- inatory behaviour. In nine cases, the employment relationship was terminated and, in the remaining cases, other disciplinary actions were taken.

ANTI-CORRUPTION MODEL In 2021 a Group-wide Anti-Corruption Model was adopted, ap- proved by the Board of directors and based on a targeted risk assess- ment and a regulatory analysis of corruption offences in the countries in which the Group operates, selected on the basis of the sales reve- nues and Corruption Perception Index of the country. This resulted in the identification of areas of theoretical corruption risk, of the existing internal controls and those to be enhanced, and in the formulation of a Group Anti-Corruption Policy setting out the guiding principles and controls that Group employees, partners and other counterparts are required to implement to prevent corruption incidents.

3 The 2023 Consolidated non-Financial Statement sets out all the cases that led to a report of violations in all areas of the Code of ethics, including human rights violations.

In particular, the Policy defines: (i) regulatory monitoring responsi- bilities; (ii) management and reporting of cases of non-compliance; and (iii) specific measures to control corruption risk.

The Group updates this risk assessment annually to review the cor- ruption risk profiles identified. On this basis, the following areas have been identified as potentially exposed to corruption risk:

relations with the public administration; relations with suppliers and external consultants; relations with agents and intermediaries; relations with business partners for joint ventures and directors; management of donations/sponsorships/gifts and samples; human resources management.

For each of the above-mentioned areas, principles of conduct and operating rules have been formulated in both the Anti-Corruption Policy and in the Codes of ethics, as well as in the policies govern- ing behaviour to be held when carrying out activities relating to the areas mentioned above. The policies and procedures of the Group s Anti-Corruption Model have been circulated and shared globally. An ad hoc training is also regularly provided to all employees in Ita- ly through the e-learning platform.

The Internal Audit function periodically carries out on-site au- dits at Group companies in order to verify the adoption of controls to mitigate corruption risk in the areas identified as most at risk. In particular, annual audits are carried out on sponsorships, donations and gifts, management of consultants and professional assign- ments, acquisition and management of public grants and financing, employee recruitment, supplier management, payments, expenses and entertainment costs.

during these audits, the various departments involved are made aware of the importance of complying with the established control protocols. Audit results are shared with the Control, Risks and Sustainability Committee and the Supervisory Bodies of the Moncler brand and Stone Island brand. At least every six months, the Board of directors receives and assesses the results of the au- dit activities carried out by the Group Internal Audit function. no cases of corruption were reported during 2023, in line with 2022.

SUPPLIER CODE OF CONDUCT The Supplier Code of Conduct, adopted at Group level, outlines the Company s expectations in relation to the main areas of the respon- sible sourcing process and is composed of six sections that estab- lish binding rules for: Labour and Human Rights, Health and Safety, environment, Animal Welfare, Quality and Safety of Products and Services, Business ethics and Protection of Intellectual Property. Moncler requires its suppliers and sub-contractors to strictly com- ply with the principles set forth in the Code of Conduct and also commits to train and raise awareness of these provisions, both with- in its internal departments and among suppliers, through meetings at corporate sites or at suppliers premises. The Group also regular- ly conducts third-party audits throughout the supply chain to verify compliance with the principles contained in the Code of Conduct. See also pages 131-139.

Moncler has also been publishing an annual Modern Slav- ery Statement in order to transparently communicate its approach to the management of human rights. In particular, the document describes the measures taken to ensure, as required by the law of the United Kingdom Modern Slavery Act 2015 Section 54 and the law of California, the absence of all forms of modern slavery, forced labour and human trafficking within its direct scope and along its supply chain.

ENTERPRISE RISK MANAGEMENT MODEL The Group has an integrated enterprise Risk Management (eRM) model inspired by international best practices, involving the en- tire corporate organisation and governance bodies, each within its sphere of competence. According to the field s guidelines and best practices, the main objective of eRM activities is to ensure optimal identification, measurement, management and monitoring of com- pany risks.

The eRM model considers the main types of risk that may compromise the achievement of strategic objectives, harm the

RISK MANAGEMENT