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 January 1, 2025, the Ethics Committee is composed as follows:

- General Counsel: Marcello Marzo

- Chief People Officer: Camilla Maggiori

- Chief Product Officer: Giacomo (James) Ferragamo

- Internal Audit Director: Francesco Pergolini

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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

The Salvatore Ferragamo Group's core values include corporate ethics and the fostering of loyalty, fairness, and respect, both within the company and toward the partners with whom it has business relationships. In accordance with the provisions of the Code of Ethics, the Group considers collaboration with the supply chain crucial to the achievement of ethical standards and business development. To this end, the Salvatore Ferragamo Group has chosen to adopt a Supplier Code of Conduct setting out ethical principles and conduct rules that supplement the legal, regulatory, and procedural provisions governing commercial relations between the Group and its partners. Aware that responsible and sustainable business management is a necessary aim to pursue, the Code seeks to be a landmark in establishing successful relationships and shared strategies with suppliers.

INCLUSION POLICY

The Group values its human capital and is committed to fostering a management system based on fairness, integrity, and respect principles. In this regard, and in accordance with the Code of Ethics and the Sustainability Policy, an Inclusion Policy has been drafted to regulate the Group's ongoing commitment to promoting and safeguarding the values of inclusion in carrying out all 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

In a framework where pursuing social responsibility objectives is a path that is constantly being improved, the Modern Slavery Statement outlines the measures implemented by the Salvatore Ferragamo Group in order to prevent any form of “modern slavery, forced labor, and human smuggling” within its own business and supply chain, consistently with the UK Modern Slavery Act 2015 - Section 54, the California Transparency in Supply Chains Act of 2010 (SB 657), the Australian Modern Slavery Act (No. 153) 2018, and the Canadian Fighting Against Forced Labor and Child Labor 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's commitment to integrity, quality, elegance, innovation, and craftsmanship excellence is embodied in its Responsible Sourcing Commitment and is pursued also through the adoption of ethical sourcing practices, i.e., practices that foster the selection of certified, high-quality raw materials, as well as the improvement of supply chain traceability.

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.

RESPONSIBLE REORGANIZATION

The Ferragamo Group is committed to promoting social responsibility at all corporate levels, aiming at ensuring transparency, attention to stakeholders, and measures intended to reduce its impact, even when a reorganization is required.

BIODIVERSITY MANIFESTO

For the Ferragamo Group, the safeguard and promotion of biodiversity – through targeted initiatives such as the Biodiversity Manifesto – are distinctive aspects of its approach to environmental awareness and to the promotion of Made in Italy. Aware that its activities are intrinsically linked to and dependent on natural capital, the Ferragamo Group has decided to further commit itself to protecting and promoting natural resources. The Manifesto formalizes the Group's commitment in this regard, with a pledge to contribute as far as possible to safeguarding the environment through the development of strategies and initiatives aimed at minimizing environmental impacts throughout the entire value chain.