es function. Four of these, emerged through the whistleblowing system: in three cases, they concerned inappropriate manage- ment of the work team and client relationship and in one case to discrimination in the handling of the team; following the investi- gations, for three out of four cases no breach of the Code of Ethic s principles and values emerged and, therefore, no disciplinary ac- tion was taken. In one case, the investigation is not yet complete. With regards to the remaining 16 cases, addressed to the Human Resources function, from the investigations, 16 cases of breach to the Code of Ethics emerged of which: twelve referring to be- haviour not in line with Group s business and/or conduct princi- ples and four to discrimination; three cases led to the termination of employment while for the others, disciplinary actions were im- plemented. See also page 114.
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 as- sessment and a regulatory analysis of corruption offences in the countries in which the Group operates, selected on the basis of the sales revenues and Corruption Perception Index. This result- ed in identification of the areas of theoretical corruption risk, ex- isting internal controls and those to be enhanced and formulation of a Group Anti-Corruption Policy.
In particular, the Policy lays down: (i) regulatory monitor- ing responsibilities; (ii) management and reporting of cases of non-compliance; and (iii) specific measures to control corrup- tion risk.
The Company updates this risk assessment annually to review the corruption risk profiles identified. On this basis, the following ar- eas 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 joint ventures business partners and directors management of donations/sponsorships/gifts and samples human resources management.
Principles of conduct and operating rules are set for each of these areas both within the Anti-Corruption Policy and the Group s Codes of Ethics. In Moncler s case, the policies and procedures for the Group s Anti-Corruption Model have been disseminated and shared globally, and the same will occur in Stone Island in 2022. An ad hoc training is also regularly provided to all employ- ees in Italy through the e-learning platform.
The Internal Audit function periodically carries out on-site audits at Group companies in order to verify the adoption of con- trols 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 assignments, acquisition and management of public grants and financing, employee recruitment, supplier management, pay- ments, expenses and entertainment costs.
During these audits, the various departments involved are made aware of the importance of complying with the protocols. Audit results are shared with the Control, Risk and Sustainability Committee and the Supervisory Bodies of the Moncler brand and Stone Island brand. In 2021, no cases of corruption were reported.
SUPPLIER CODE OF CONDUCT The Supplier Code of Conduct was adopted at Group level in 2021. This Code outlines the Company s expectations in relation to the main areas of the responsible sourcing and is composed of six sections that establish binding rules for: Labour and Human Rights, Occupational Health and Safety, Environment, Animal Health and Welfare, Safety and Quality of Products and Services, Corporate Ethics and Protection of Intellectual Property. Moncler requires its suppliers and subcontractors to comply with the prin- ciples set forth in the Supplier Code of Conduct and is also com- mitted to train on and raise awareness of these provisions, both within its internal departments and among suppliers, through
meetings at corporate offices or at suppliers premises. The Group also regularly conducts audits throughout the supply chain to ver- ify compliance with the principles contained in the Code of Con- duct. See also pages 140-144.
Since 2017 Moncler has also been publishing an annual Modern Slavery Act in order to transparently communicate its ap- proach to the management of human rights. In particular, the doc- ument describes the measures taken to ensure the absence of any forms of modern slavery, forced labour and human trafficking internally and along its supply chain as required by Section 54 of the UK Modern Slavery Act 2015.
2.2 RISK MANAGEMENT
ENTERPRISE RISK MANAGEMENT MODEL The Group has an integrated Enterprise Risk Management (ERM) model inspired by international best practices, involving the en- tire organisation and governance bodies, each within its sphere of competence. According to the field s guidelines and best prac- tices, the main objective of ERM activities is to ensure optimal identification, measurement, management and monitoring of company risks.
The ERM model considers the main types of risk that may compromise the achievement of strategic objectives, harm the company s assets and compromise the value of the Moncler and Stone Island brands or the companies reputation. It is integrat- ed in, and functional to, the relevant decision-making processes.
The risks identified may be internal or external to the Group. In particular, external risks are linked to the industry and market context, as well as to the perception of all stakeholders of how the Group operates. The enterprise risk management model classi- fies risks into four categories: Strategic Risk Business Risk Compliance Risk Financial Risks.
Strategic risks may refer to changes in the business or the inad- equate response to changes in the competitive environment and the Company s business development activities. Sustainability risks may also be included in this category.
Business risks are those related to the sector in which the Group operates, the business operations, its organisational structure, information systems and Group s control and reporting processes.
Compliance risks, in general, are those related to non-com- pliance, in the conduct of the business, with national and interna- tional laws and regulations applicable to the business activity, as well as to the Code of Ethics and internal procedures.
Financial risks are those related to the Group s financial management, specifically related to the risk of: liquidity, exchange rates, interest rates and financial counterparties in financial and commercial transactions.
In the case of internal risks, the aim of the ERM model is to manage risk through specific prevention and control systems integrated into the corporate processes, aimed at avoiding or transferring the risk, at reducing the probability of occurrence or, in the event of occurrence, containing its impact. In the case of external risks, the aim of the ERM model is to monitor risks and mitigate the impact if such risks occur, for example through in- surance policies.
The risk assessment activity identifies all risks and risk owners responsible for managing the risk and the correspond- ing control system, as well as for implementing or improving the mitigation actions. The risks, the assessment of the internal con- trol system covering them and the related mitigation actions are included in the Risk Register, which is periodically updated with the risk owners on the basis of an annual plan approved by the Board of Directors with the support of the Control, Risks and Sus- tainability Committee. The proposed plan is periodically updated to include any new elements of risk and/or to reflect a possible in- crease in the probability of occurrence or in the impact.
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