Moncler SpA

Lobbying Governance

AI Extracted Evidence Snippet Source

**9. MONITORING OF THE POLICY**

The Board reviews the Policy at three-yearly intervals to ensure that it is up to date with changes in legislation, regulations and the Code applicable from time to time and with national and international best practices. The Policy will also be reviewed should events and changes, either internal or external to the Group, make this necessary or appropriate.

If significant changes are necessary, the CEO, in agreement with the other Responsible Directors, will formulate a proposal to the Board, except in the case of changes required by mandatory rules, for which he may act autonomously, informing the Board of any changes made to the Policy at the next convenient meeting.

https://www.monclergroup.com/wp-content/uploads/2025/03/engagement-policy-2025-final-eng.pdf

The Codes of Ethics of Moncler and Stone Island and the Group's Supplier Code of Conduct, as well as the Environmental Policy, contain a section, where the Group explicitly ask suppliers to actively manage their environmental impact for example promoting the use of renewable energy and reducing GHG emissions in line with a science-based approach. By requiring the suppliers to be compliant with the above-mentioned Codes and policies, the Group encourages partners to apply environmental best practices and to embrace a culture of respect for the environment by behaving responsibly and contributing to its protection. This will lead in the end to an increasing alignment in the responsible business practices applied by the Group and its partners."
"The Chief Corporate Strategy and Communications Officer together with the Sustainability Unit monitor, on a constant basis, the alignment of the commitments of these associations with those of the Group and update the Control, Risks and Sustainability Committee. The Chief Corporate Strategy and Communications Officer and the CSO take part to trade associations meetings and ensures a complete alignment with Moncler Group's climate strategy in engagement activities. In addition to this, Moncler Group has defined a Sustainability Plan with 5 strategic pillars, including a specific one on Act on Climate & Nature, in which it has defined a set of measurable objectives for the coming years that will guide the decisions and development of the entire Group. The Group's Sustainability Plan includes environmental impact reduction targets such as maintaining carbon neutrality, recycling fabric scraps, making widespread use of lower impact nylon and cotton compared to the Group's conventional options, wool certified Responsible Wool Standard (RWS), and eliminating single-use virgin plastics. To ensure that the Group's daily strategies are always in line with the ambitious objectives, the MBO system, is linked to the targets of the Sust. Plan. To ensure the observance of commitments made, the Sustainability Unit asks for regular progress reports on projects, and updates the CCRS accordingly. The plan is updated each year to report on the status of projects underway, and to set new targets for continuous improvement. See pg. 54-56 of the attached \"Consolidated Non Financial Statement 2022\".

https://www.monclergroup.com/wp-content/uploads/2024/05/CDP-CLimate-Change-2023.pdf

Moreover, Moncler developed and adopted an anti-corruption model that provides, among other things, for the regulatory review of corruption offences in the countries in which the Company operates, identifying the areas and business processes most at risk of corruption. More specifically, an anti-corruption policy was therefore implemented by each company of the Moncler Group, regulating the responsibilities for monitoring regulatory changes, risk controls, training, audit activities, management, and the reporting of any cases of non-compliance. [...] Moncler has also adopted an anti-corruption model, which includes, among other things, a regulatory reconnaissance of corruption offenses in the countries in which the Company operates, identifying the areas and business processes most at risk of corruption. Specifically, an anti-corruption policy is applied, adopted by each Moncler Group company, which defines responsibilities for monitoring changes in regulations, controls to guard against risk, training, audit activities, and management and reporting of cases of non-compliance.

https://www.monclergroup.com/wp-content/uploads/2016/07/CORPORATE-GOVERNANCE-REPORT-2023-ENG.pdf

Moreover, Moncler developed and adopted an anti-corruption model that provides, among other things, for the regulatory review of corruption offences in the countries in which the Company operates, identifying the areas and business processes most at risk of corruption. More specifically, an anti-corruption policy was therefore implemented by each company of the Moncler Group, regulating the responsibilities for monitoring regulatory changes, risk controls, training, audit activities, management, and the reporting of any cases of non-compliance. [...] The Company also adopted the procedure on the internal dealing regulations referred to in art. 19 of the MAR, last amended on 25 July 2018 to regulate the disclosure requirements in respect of the Consob and the public related to the fulfilment by the "relevant persons" and "persons closely associated to them", identified in the Market Abuse Regulation, of transactions involving financial instruments issued by the Company.

https://www.monclergroup.com/wp-content/uploads/2016/07/draft-ENG-CORPORATE-GOVERNANCE-REPORT-2022.pdf

Relations between the Moncler Group and political parties and their representatives are guided by the highest principles of transparency and ethics, as stated in the Codes of Ethics of both Brands. In 2023 the Moncler Group did not make contributions to political parties, lobbying activities or any other activities beyond those with associative purposes. The political commitments and contributions made by the Group's employees are understood to be personal and entirely voluntary. [...] The Chief Marketing & Corporate Strategy Officer is responsible for effective application of these principles and periodically updates, together with the Sustainability Unit, the Control, Risks and Sustainability Committee. The Sustainability Unit also has to monitor, on a constant basis, the alignment of the commitments of these associations with those of the Group. Moncler believes this alignment is essential to the collective achievement of the challenging goals that these associations set themselves and is committed to proactively promote its environmental ambitions in the event of any misalignment with the associations of which it is a member may emerge.

https://www.monclergroup.com/wp-content/uploads/2024/05/2023-Consolidated-non-Financial-Statement.pdf

Moreover, Moncler developed and adopted an anti-corruption model that provides, among other things, for the regulatory review of corruption offences in the countries in which the Company operates, identifying the areas and business processes most at risk of corruption. [...] More specifically, an anti-corruption policy was implemented, applicable to each company of Moncler Group, which regulates the responsibilities for monitoring regulatory changes, risk controls, training, audit activities, management, and the reporting of any cases of noncompliance.

https://www.monclergroup.com/wp-content/uploads/2025/03/2024-report-on-corporate-governance-and-ownership-structure-1.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]At Moncler Group the person that is in charge for corporate relations (Chief Corporate Strategy and communication Officer) has also the responsibility of a department within which lies the Sustainability Unit, led by the CSO, and takes part to trade associations meetings. This ensures a complete alignment with Moncler Group's climate strategy in engagement activities.
In addition to this, Moncler Group has defined a Sustainability Plan with 5 strategic pillars, including a specific one on Act on Climate Change, in which it has defined a set of measurable objectives for the coming years that will guide the decisions and development of the entire Company. Moncler Group's Sustainability Plan includes environmental impact reduction targets such as maintaining carbon neutrality, recycling fabric scraps, making widespread use of lower impact nylon, cotton, wool certified Responsible Wool Standard (RWS), and eliminating single-use conventional plastics.
To ensure that the Company's daily strategies are always in line with the ambition objectives, the MBO system, is linked to the targets of the Sustainability Plan To ensure the observance of commitments made, the Sustainability Unit asks for regular progress reports on projects, and updates the Control, Risks and Sustainability Committee accordingly. The plan is updated each year to report on the status of projects underway, and to set new targets for continuous improvement.
See more details at pg. 43-44 of the attached document "Consolidated Non Financial Statement 2021".

CDP Questionnaire Response 2022