principles set out in both the Supplier Code of Conduct and the Anti-Corruption Policy, both of which have been adopted at Group level since July 2021. The new Group s Code of Ethics will also re- fer to other company policies, which will also be reviewed in light of the integration, including: the Environmental Policy, the Health and Safety Management Policy and the Group s policies on taxa- tion, the management of human and financial resources, and as- set protection.
The Codes of Ethics, which are uniformly applied in every country where Moncler and Stone Island operate, consist of a set of principles and guidelines that inspire the way in which the Brands operate every day and guide the behaviour of employees and others who work with the Brands in various ways in perform- ing their activities and responsibilities. The Codes are brought to the attention of employees using the most appropriate means and in accordance with local customs. The documents are available on the company intranet and Internet sites. An online training pro- gramme on the contents of the Code of Ethics is regularly provid- ed for all Moncler employees, including temporary and part-time employees, in order to ensure a proper understanding and virtu- ous behaviour consistent with the requirements of the Code of Ethics, while Italian Stone Island employees are trained on these issues through a specific module dedicated to the Code within the 231 Model course.
Together with the Anti-Corruption Model, the Codes of Eth- ics are a fundamental and integral part of the Organisation, Man- agement 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 procedures and disciplinary codes, aimed at preventing corpo- rate crimes and ensuring ethical conduct of all those who operate on behalf of Group companies, in compliance with the principles of legitimacy, fairness and transparency.
Compliance with the Codes of Ethics and the Model is mon- itored by the appropriate supervisory and control bodies of the respective Brands, through specific audits and investigations, which may also take place on the basis of reported behaviour not in compliance with the principles of conduct required by Moncler and Stone Island. The results of verifications may lead to disci- plinary actions which, depending on the severity of violation, may also lead to the termination of employment.
The Supervisory Body, which is the entity responsible for supervising the adequacy and compliance of the Organisation, Management and Control Model and its inspiring principles in Italy, is a collegial body consisting of three members of a mixed composition, 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 holds a high position in the Company s organisation, reporting directly to the Board of Di- rectors of the company to which it belongs, in order to guarantee autonomy from all forms of potential interference.
In 2018 the Organisation, Management and Control Mod- els of both Moncler and Stone Island were updated to include of- fences of illicit brokering and the exploitation of labour, racism and xenophobia, as well as the new rules on whistleblowing and some changes concerning private-to-private corruption. In 2021 they were further updated with the inclusion of tax and smuggling crimes and those relating to the trafficking of illicit influences and sports fraud, for all Group companies for which the prepara- tion of a Model is required or strongly recommended. In addition, in light of the integration, for the Stone Island Model, updates on changes related to the organisational and governance context were also included.
The audit carried out in 2021 by the Internal Audit function, which operates at Group level, with regard to the Italian companies Moncler and Stone Island, focused on significant corporate pro- cesses (payments, purchases, services and consultancy, miss- ing products, quality control, charge-backs to suppliers, sales, receipts, credit management, recruiting, etc.), as well as on the main areas identified as sensitive within the Model. With regard to Moncler s international subsidiaries, during the year the Inter- nal Audit function carried out audits and tests on the adequacy of the internal control system and financial reporting procedures for companies operating in the United States, Korea, Japan, China,
Turkey, and France, in order to identify and/or prevent potential fraudulent conduct. The business will also be extended to signifi- cant international Stone Island companies starting from 2022.
In the management of operations at stores (receipts and sales management, stock management, protection of corporate assets and prevention of theft), in 2021 the Internal Audit division, due to the restrictions and limitations on movement as a result of the Covid-19 pandemic, was not able to audit any stores, though this normally takes place each year on selected stores according to criteria of significance of revenues, risk indicators and geograph- ical diversification. However, in line with the objective of verify- ing and strengthening existing operating and control procedures, during the year activities were carried out to constantly monitor in- ventories, missing products detected during the handling phase and at warehouses and compliance with the sales procedure.
In addition, in order to ensure compliance with the prin- ciples and rules set out in the Code of Ethics, various audits are carried out. These include, for example, ethical and social audits along the supply chain, periodic checks aimed at obtaining social and environmental certification, third-party audits of information systems and analyses carried out by external and qualified labo- ratories to verify the chemical compliance of products with Com- pany standards.
For both Moncler and Stone Island, a whistleblowing system is in place at the Group level, with the aim of managing properly and verify timely any illegal and disrespectful conduct reported by employees or external parties not in compliance with inter- nal rules, regulations, procedures and values, and taking appro- priate steps, while ensuring the anonymity of the whistleblower. Any employee who, in good faith, reports an alleged or actual anomalous violation of the Code is protected from retaliation, dis- crimination or penalization. The platform makes it possible for the whistleblower to choose anonymity: in this case, communications through the platform between the whistleblower and the Group 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 persons accused wrongly and/or in bad faith. In order to further strengthen the internal process of whistleblowing and in compliance with the relevant regulations, in 2021 Stone Island also adopted the Mon- cler web platform and ad hoc telephone lines managed by a spe- cialised third party and available at all times globally to manage and record reports from employees, suppliers, clients and coun- terparties of all Group companies. The web platform is available in Italian, English, Chinese, Japanese, Korean, French, German, Turkish, Arabic and, starting from 2021, also in Romanian, while the telephone operators speak the language of all the countries where the Group has stores. The platform ensures full compliance with international privacy regulations (processing of sensitive and personal data).
The whistleblowing procedure, updated during 2021, was circulated to all employees and is available on the company in- tranet of the two Brands. All Group employees, through an ad hoc email, and human resources managers of the Moncler Regions, through one-to-one meetings or video conferences, were made aware of the importance of whistleblowing and reporting methods.
The management of the Group s whistleblowing channels is entrusted to the Head of Internal Audit, who is 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 is received through whistleblow- ing channels the Head of Internal Audit receives and prompt- ly analyses all the information; if the issue raised is very serious or complex, the Head of Internal Audit has the task of starting an investigation immediately, also requiring the support of oth- er corporate functions, including Legal, Human Resources, ICT and Sustainability, as well as of competent external consultants, in order to conduct investigations and controls aimed at under- standing what happened. Where appropriate in relation to the se- riousness of the incident, immediate measures are put in place and they can also lead to termination of employment.
During the year, 20 reports4 of potential violations of the Code of Ethics were received through the whistleblowing sys- tem and the communications addressed to the Human Resourc-
4 The 2021 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.
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