WHISTLEBLOWING, CODE OF ETHICS, MODEL 231 AND POLICIES part 1

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..

GLOBAL RECRUITMENT POLICY

In Ferragamo, our people are our most valuable asset. The Global Recruitment Policy is designed to guide our hiring practices worldwide, ensuring that we attract and retain individuals who embody our Company values. Our goal is to build a diverse, inclusive, empowered and talented workforce that drives Ferragamo's continued success.

RESPONSIBLE MARKETING AND COMMUNICATION POLICY

The Ferragamo Group has always placed great importance on upholding values such as transparency, honesty, accountability, responsibility, correctness and dignity, which are an integral part of its way of operating. These principles are reflected in the Responsible Marketing and Communication Policy and  embody the ethical dedication and commitment of its business philosophy in compliance with the relevant laws and regulations.

RESPONSIBLE LOBBYING POLICY

Ferragamo, in the context of entrepreneurial and economic dynamics and requirements, has among its primary values that of business ethics, through which it transmits a message of loyalty, fairness and respect that applies to the entire Group and represents a point of reference in the social reality in which it operates.
The purpose of the Responsible Lobbying Policy of the Ferragamo Group is to provide the principles and guidelines of responsible, clear and transparent lobbying aimed at representing the Group's instances, positions and legitimate interests to institutions.

RESPONSIBLE SOURCING COMMITMENT

The Ferragamo Group commitment to quality, elegance, and innovation is complemented by a dedication to ethical sourcing practices, ensuring that every product reflects our values of craftsmanship and integrity. The design and production processes are managed in-house by expert teams, including stylists, materials researchers, and pattern makers. The Group is committed to carefully control the quality of raw materials and finished products. For this reason, a Responsible Sourcing Commitment has been developed to reflect the Group's commitment to promoting the values of creativity, innovation and craftsmanship excellence.

SUSTAINABILITY POLICY

The Sustainability Policy establishes a framework of Guiding Principles on the social and environmental responsibility of the Ferragamo Group to be adopted in its daily operations and reflected in the Group’s Sustainability Plan available on the Ferragamo Sustainability website.