WHISTLEBLOWING, CODE OF ETHICS, MODEL 231 AND POLICIES

WHISTLEBLOWING

Salvatore Ferragamo S.p.A. and all Ferragamo Group Companies have always been committed to promoting a corporate culture inspired by ethics and legality. 
Reports of legal breaches - and in particular reports of Significant Breaches - as defined in the Group Whistleblowing Policy - may, through adequate enforcement and prevention measures, help to promptly find and deal with critical issues and risks to which all organizations are potentially exposed, including Companies within the Ferragamo Group. 
By establishing and encouraging the informed use of their internal reporting channels, the Ferragamo Group Companies aim to prevent and combat unlawful behavior or behavior contrary to the principles and rules set out in their organizational models, codes of ethics and company policies, protecting the confidentiality of whistleblowers and other protected subjects, safeguarding them from the risks of possible retaliation in full compliance with all applicable legal provisions.
Salvatore Ferragamo Group has adopted a web platform operated by an external company, which specializes in internal reporting systems for companies. Therefore, data are neither transferred nor managed via the servers of Ferragamo or of the other Ferragamo Group Companies. This ensures that reports cannot be traced, data is always protected and only members of the Ethics Committee have access to it. 

Effective from November 15, 2024, the Ethics Committee is composed as follows:

- General Counsel: Marcello Marzo

- Chief People Officer: Camilla Maggiori

- Chief Transformation and Sustainability Officer: Giacomo (James) Ferragamo 

- Internal Audit Director: Francesco Pergolini

- Group Planning & Control, Risk Director & Tax Risk Officer: Paolo La Morgia

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CODE OF ETHICS

Corporate ethics is a top priority for Salvatore Ferragamo in its business dynamics and demands, conveying a message of loyalty, fairness and respect regarding the entire Group, and constituting a reference point in its business environment.
The Code of Ethics sets forth the ethical principles and general guidelines that, along with legal, regulatory and contractual rules, characterize the organization and activities of Salvatore Ferragamo S.p.A and its subsidiaries. The Board of Directors of Salvatore Ferragamo S.p.A approved the last amendment to the Code of Ethics on 6 March 2024.

MODEL 231

Legislative Decree No. 231/2001 («Decree») has introduced an administrative liability of entities regime into the Italian legal system, in particular, as regards certain types of criminal offences perpetrated in their interest or to their advantage, by top executives or by persons under the latter’s management or supervision.
To ensure that the criminal offences under the Decree are prevented, Salvatore Ferragamo has adopted its own organization, management and control model («Model»).  The Board of Directors approved the last amendment to the Model on October 28, 2024.
The Board of Directors of Salvatore Ferragamo has set up a Supervisory Body, which has independent decision-making and control powers, and which is in charge of supervising the implementation of and compliance with the Model, and of fostering its continuous update.

ANTI-CORRUPTION POLICY

Salvatore Ferragamo is committed to fight corruption and reject it in any form and way it may occur. For this reason, Salvatore Ferragamo has decided to undertake a project in order to identify and prevent every corruption case by adopting an Anti-Corruption Policy applicable to employees and to all those who operate on behalf of Group companies.

SUPPLIER CODE OF CONDUCT

Corporate ethics and the promotion of the values of loyalty, fairness and respect, both within the Company and towards the partners with whom it relates to and engages with in commercial relationships, are key values for the Salvatore Ferragamo Group. Consistent with the provisions of its Code of Ethics, and within a framework of integration of social responsibility in daily business operations, the Group considers the collaboration with the supply chain fundamental to achieve the highest ethical and sustainable business development standards.
To this end, the Group has decided to adopt a Supplier Code of Conduct, which sets forth the ethical principles and rules of conduct that, along with the legal, regulatory and procedural norms, must characterize the commercial relations between the Group and its partners.
With the awareness that a responsible and sustainable management of the business is a necessary direction at every level of the supply chain, this Code aims at being a reference point for the definition of positive relationships and common strategies with our suppliers.

INCLUSION POLICY

The Group attributes great importance to its human capital and is committed to guaranteeing that the management of its people is based on the principles of fairness, integrity and respect. For this reason, in line with the statements of the Code of Ethics and the Sustainability Policy, an Inclusion Policy was adopted, formalizing the Group’s commitment to the promotion and the protection of the values of inclusion in the performance of all the business activities.

SA8000 SOCIAL ACCOUNTABILITY

Consistent with the provisions of the Group’s Code of Ethics and its Sustainability Policy, the SA8000 Policy of Salvatore Ferragamo S.p.A. affirms the corporate commitment to achieve the highest ethical and sustainable business development standards, respecting and instilling SA8000 related principles in the corporate environment, in compliance with the applicable laws and the main international agreements on human and labour rights. The Policy for Combating Child Labour aims at formalizing further the corporate commitment on this topic and prevent minors’ exposure to risky or dangerous situations for their development as well as their physical and mental health.

MODERN SLAVERY STATEMENT

Within a framework of social responsibility the Modern Slavery Statement describes the measures taken by the Salvatore Ferragamo Group to ensure the absence of any form of “modern slavery, forced labor and human trafficking” within its organization and outside along its own supply chain, in compliance with the UK “Modern Slavery Act 2015 – Section 54”, the California “Transparency in Supply Chains Act of 2010 - SB 657” and the Australian Modern Slavery Act (No. 153) 2018 and by the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act 2023.

TAX STRATEGY

Ferragamo Group’s tax strategy is inspired by the principles set forth in the Code of Ethics and defines the objectives and values adopted by all entities of Ferragamo Group for the management of the tax variable, as well as the guidelines for their actual implementation.
The tax strategy is aimed at promoting the diffusion of the values of honesty, integrity and compliance with the tax legislation, thus favoring the development of cooperative and transparent behaviors towards the local tax authorities and third parties.
On 7 September 2021 the Board of Directors of Salvatore Ferragamo S.p.A. approved the Global Tax Strategy of Ferragamo Group and the Tax Strategy of Salvatore Ferragamo S.p.A..