by designated supervisory bodies through audits and spe- cific checks, which may also take place based on reported behaviour that does not comply with Moncler s standards of conduct. Audit findings may lead to disciplinary actions; depending on the severity of the case, these also lead to termination of employment. The Supervisory Body in Italy oversees the adequacy of and compliance with the Organi- zation, Management and Control Model and its underlying principles. It is a collegial body consisting of three members: two external professionals with accounting and legal exper- tise and the head of the Group s Internal Audit division. The Supervisory Body holds a high position in the Company s organizational structure and reports directly to the Board of Directors to ensure its independence from any form of potential interference or conditioning.
In 2018, Moncler s Organization, Management and Con- trol Model was updated to include the offences of illicit bro- kering, exploitation of labour, racism and xenophobia, as well as new regulations on whistleblowing and some chang- es concerning private-to-private corruption. In 2020 it was further updated to include tax crimes, smuggling, influence trafficking, and sports fraud.
Employees in Italy attended an online course on the contents of the model and the new regulations that have been added.
The audits performed in 2020 by the Internal Audit division on the Group s Italian companies focused on key corporate processes (payments, purchases, services and consulting, product shortages, quality control, chargebacks to suppliers, sales, receipts, credit management, recruit- ing, etc.) and on the main sensitive areas identified by the model. With regard to international subsidiaries, in 2020 the Internal Audit division audited Group companies in the Unit- ed States, Canada, Korea, Japan, China and Hong Kong SAR, Turkey, France, the United Kingdom, Germany, and Romania, focusing on the adequacy of internal control and financial reporting procedures, in order to identify and/or prevent any potential cases of fraud. Regarding the management of store operations (receipts and sales management, stock manage- ment, protection of corporate assets, and theft prevention), in 2020 the Internal Audit division was unable to audit any stores due to the restrictions on movement in light of the COVID-19 pandemic, though this normally takes place each year on stores selected for their revenues, risk indices, and geographical diversification in order to verify and make im- provements to operational and control procedures.
A Group-wide whistleblowing system has been in place since 2016, devised to ensure the proper management and timely verification of any reported breaches of rules, reg- ulations, and/or internal procedures, the adoption of ap- propriate measures, and the anonymity of whistleblowers. Moncler considers the reporting of particular instances of non-compliance with the Code of Ethics whether by em- ployees or external entities to be a serious matter. Any employee reporting a concern in good faith regarding sus- picious, alleged or actual breaches of the Code of Ethics is protected by Moncler against any form of retaliation, dis- crimination or penalization, without prejudice to statuto- ry obligations in force or to the rights of the Company or people falsely or mistakenly accused of misconduct. Since 2018, to further consolidate the internal whistleblowing procedure and in compliance with applicable laws, Mon-
cler has adopted a dedicated web platform and telephone lines managed by a specialized, independent third party to handle and record any reports from employees, sup- pliers, clients, and counterparties of all Group companies. Since 2019, the web platform has been available in French, German, Turkish, and Arabic as well as Italian, English, Chi- nese, Japanese, and Korean, and telephone operators speak the language of each country where Moncler has stores. The platform ensures full compliance with international privacy regulations (processing of sensitive and personal data) and in October 2020 some changes were made to the disclosure and consent procedure regarding the data of the individuals named in reports. Whistleblowers can choose to remain anonymous; in this case, all communication be- tween the whistleblower and Moncler takes place using the report s unique identification code.
The introduction of the platform went hand in hand with a review of the whistleblowing procedure, which was sent to all Group employees and is available on the company intranet. The Group s whistleblowing channels are managed by the Head of Internal Audit, who is responsible for report- ing what has been charted and monitored through those channels directly to the Board of Directors.
In 2020, three reports were received through the whis- tleblowing system that were deemed relevant and worthy of investigation. In the first case, further to investigations, an American Store Manager was dismissed for mismanagement of personnel. In the second case as well, the issue was po- tential mismanagement of staff, but since investigations and further review did not show inappropriate conduct, the man- ager was not disciplined. The third case concerned alleged violations of the receipts management procedure by the staff of a store in Asia. This matter is still being investigated.
In 2017 Moncler began to develop a Group Anti-Cor- ruption Model, later approved by the Board of Directors, which is based on a targeted risk assessment and regula- tory review of corruption offences in countries selected on the basis of sales revenues and the Corruption Perceptions Index. This allowed Moncler to identify the areas at the- oretical risk of corruption, the internal controls in place, and those requiring improvement, and to define a Group Anti-Corruption Policy.
Specifically, the policy defines: (i) regulatory monitoring responsibilities; (ii) the methods for non-compliance man- agement and reporting; and (iii) specific measures to control corruption risk.
The Company annually updates this risk assessment to review the corruption risk profiles. Based on this assess- ment, the following areas have been identified as theoret- ically exposed to a risk of corruption: interactions with government agencies; interactions with suppliers and external consultants; interactions with agents and intermediaries; interactions with joint venture partners and directors; donations, sponsorships and gifts; human resources management. For each of these areas, principles of conduct and guidelines are set out both in the Anti-Corruption Policy and in the Group s Code of Ethics. Policies and procedures concerning the Anti-Corruption Policy have been disseminated world- wide throughout the Group, and ad hoc training is routinely provided to all employees through the e-learning platform.
49CONSOLIDATED NON FINANCIAL STATEMENT 202048 RESPONSIBLE BUSINESS MANAGEMENT