system itself as per the indications and guidelines de- fined by the Board of Directors in collaboration with the Control, Risks, and Sustainability Committee;
the Head of the Group Internal Audit division, tasked with verifying the performance and suitability of the ICRMS and coordinating the ERM process;
the Board of Statutory Auditors, which oversees the ef- fectiveness of the ICRMS.
ENVIRONMENTAL, SOCIAL AND COMPLIANCE RISKS
With operations in countries around the world, Moncler firmly believes that respect for people, human rights and the environment, and compliance with applicable laws, are prerequisites for responsible business management. To this end, it is committed to implementing the necessary policies, carrying out due diligence activities and appropriate checks, and providing training and information to minimize any risks related to these issues. These risks are described in Moncler s Enterprise Risk Management model, along with their respec- tive probability of occurrence and level of impact.
As regards our people, the main risks associated with hu- man resources management include, in particular, the reliance on key figures and the difficulty to retain and develop talent. In this regard, the Company follows a performance appraisal system that covers the entire workforce and considers both soft and hard (technical) skills. The system is designed to lev- erage and develop individual skills in the medium and long term, define succession plans, and nurture the best talent. The Group has also developed an incentive plan to facilitate the retention of managers and key personnel. See also pages 87-89. With the aim of creating a more attractive work envi- ronment, Moncler has implemented a welfare plan in Italy, the United Kingdom, and South Korea, as well as specific employ- ee wellbeing initiatives at the production site in Romania and in other Regions. See also pages 87-90.
The risk of human rights violations against the employees of Group companies is considered solely at a theoretical risk level, owing to the level of protection ensured by various laws and/or collective labour agreements, the working standards set out in Moncler s Code of Ethics, and the oversight activ- ities in place at the corporate offices. Furthermore, Moncler has adopted a Group-wide Personnel Recruitment Policy to ensure a robust personnel selection and recruitment process while guaranteeing equal opportunities. In 2020, a Diversity and Inclusion Committee was formed in order to reinforce the values of inclusivity and diversity, inside and outside Moncler. The Company provides a whistleblowing system so anyone can report alleged misconduct. See also page 49.
Moncler s business model entails the manufacture of its products through its own production site in Romania and through façon manufacturers and finished product suppli- ers in Italy and abroad. In addition, the Company purchases raw materials and services from a large number of suppliers worldwide. Moncler s variety of partners and geographical scope have led it to invest heavily in preventing and moni- toring risks associated with possible human rights violations along the supply chain, with a particular focus on sub-con- tractors, specialized workshops, and the main logistics op-
erators. Moncler conducts regular audits, also through certi- fied specialized firms, on the supply chain s compliance with applicable laws and the principles set out in the Code of Ethics and the Supplier Code of Conduct. The two Codes set binding standards of conduct for suppliers, failing which col- laboration may be terminated. Moreover, the Group is com- mitted to raising awareness of responsible sourcing princi- ples among its partners through specific training activities. See also pages 116-121; 124-127.
Moncler pays particular attention to the environmental aspects of its business, although its most significant environ- mental impacts are indirect. One of the strategic drivers of the Sustainability Plan Moncler Born to Protect is the fight against climate change, demonstrating the priority Moncler places on preventing and mitigating such risks. In this regard, the Group has joined the Science Based Targets initiative de- fining greenhouse gas emissions reduction targets that are consistent with the United Nations commitment to limit the maximum global temperature rise compared to pre-in- dustrial levels. In general, Moncler sets out rules, processes and control procedures to manage any environmental risks associated with its suppliers through the Code of Ethics and Supplier Code of Conduct. Compliance with the binding pro- visions contained in these documents is monitored through environmental audits carried out by specialized third parties. As regards its direct environmental impacts, Moncler imple- ments numerous initiatives to minimize them by following an Environmental Policy and an Environmental Management System, defining public commitments and targets to reduce energy consumption, and engaging its employees in reducing paper, toner and energy consumption and promoting waste sorting. Moncler s corporate offices, logistics hub in Castel San Giovanni (Piacenza, Italy), and production site in Romania are certified to ISO 14001. See also page 164.
Moncler has also adopted a Group-wide Compliance procedure to: (i) disseminate the meaning of compliance at Moncler; (ii) define the areas of application; (iii) establish the general compliance principles adopted by Moncler; (iv) define employee roles and responsibilities; and (v) provide guidelines based on the pillars of the Group Compliance Programme, which is regularly updated.
From the outset, the Group s Compliance unit has been engaged in activities aimed at strengthening the monitoring and management of compliance risk, starting from the areas considered to be most sensitive, such as those related to an- titrust, health and safety, privacy, and anti-corruption issues.
Moncler also considers the promotion and protection of employee health, safety, and wellbeing to be a key value and a top priority. For this reason, an effective management sys- tem compliant with the international OHSAS 18001 stand- ard was first implemented globally at all offices and stores (excluding shop-in-shops) and at logistics and production sites. It was then updated to the more recent and complete ISO 45001 standard. The system provides not only for the application of uniform management rules, detailed in the Health and Safety Management Policy, reinforced in 2020 by the adoption of an anti-COVID protocol, but also for periodic checks at all of the Group s workplaces. Bolstered by training and awareness activities targeting Moncler personnel and suppliers, the management system plays a crucial role in the Group s strategy to mitigate the risk of accidents on the job. See also pages 98-101.
55CONSOLIDATED NON FINANCIAL STATEMENT 202054 RESPONSIBLE BUSINESS MANAGEMENT