The Group has always been highly attentive to privacy issues. In addition to improving the privacy section of its Code of Ethics, it has completed preliminary work to adapt its compliance model to the new European regulation which came into force in May 2018, including by adopting a specific policy and carrying out awareness-raising activities among all employees. In 2020 it conducted a follow-up check on the measures taken to improve the internal control system fol- lowing a compliance audit on the issue of client data privacy. See also page 196.
As regards corruption prevention measures, Moncler has developed and adopted an Anti-Corruption Model whose pro- visions include the regulatory review of corruption offences in countries where the Company operates, identifying the areas and business processes most at risk of corruption. An Anti-Corruption Policy was therefore implemented by each company of the Moncler Group, governing the responsibilities for monitoring regulatory changes, risk controls, training, au- dit activities, management, and the reporting of any cases of non-compliance. See also pages 49-50.
Moncler s main social risks are those that affect consum- ers, namely, product safety and counterfeiting. To protect the health and safety of its clients, Moncler requires all its suppliers to operate in full compliance with the most strin- gent international regulations on hazardous and potentially hazardous chemical substances, and regularly conducts strict tests on the chemical composition and physical and mechan- ical properties of its products. Suppliers are also required by contract to comply with the guidelines of the Product Restricted Substances List (PRSL), updated in 2020, which outlines the most stringent standards for the use of certain substances. The proper implementation of these guidelines is verified through tests on the chemical composition of raw ma- terials at independent specialized laboratories, at the request of the supplier and/or Moncler itself. Furthermore, the Group ensures comprehensive monitoring of this risk through an ad hoc corporate function, the Operations Compliance De- partment. See also pages 154-157. Protecting clients and the Brand also means a long-term commitment to fight coun- terfeiting. In this area Moncler has implemented a number of management and prevention tools including: creating an Intellectual Property and Brand Protection department; developing detailed procedures; working with law enforce- ment, customs, and other luxury brands; providing supplier training and auditing; and using anti-counterfeit labels on all its products. See also pages 134-137.
Finally, Moncler is strongly committed to animal welfare, and requires strict compliance in this regard with its Supplier Code of Conduct. For this reason, Moncler demands and ver- ifies that all down suppliers comply with the strict require- ments of its proprietary DIST (Down Integrity System & Trace- ability) Protocol. With the support of specialized independent bodies, the Group conducts regular audits to ensure that ani- mals are treated humanely. See also pages 121-122.
For an overview of the different types of risks to which Moncler is exposed, and for further information on this sub- ject, see the Board of Directors Report in the 2020 Annual Report.
57CONSOLIDATED NON FINANCIAL STATEMENT 202056 RESPONSIBLE BUSINESS MANAGEMENT