Code of Ethics

Protection of employee personal data

We have always recognized the value of our employees’ data, and as such, we respect and protect their privacy. To this end, all employees of ACBC benefit from the following rights:

1. Fair and transparent information before any new processing of data, and prior consent if appropriate.
2. Right to object to processing of data if there is a legitimate interest.
3. Right to access and correct data.
4. Right to data privacy as their data will be visible only by a restricted number of people.
5. Right to have their personal data deleted after they have left the company.
6. Reasonable use of social networks and personal websites We encourage staff to be ambassadors of ACBC. However, only the individuals duly authorized to do so within the Company may communicate on its behalf. Talking about the Company is permissible, but not on behalf of ACBC. Every employee represents the professional values of the Company in the public and private sphere, including on social networks and personal websites. We therefore have an obligation to act with integrity and professional discernment when we express our views on subjects that are directly or indirectly connected to the Company, in order to preserve ACBC’s image and reputation. We must ensure that there is no possible confusion between our opinions and personal interests and those of ACBC. For this reason, employees acting under their real identity, or whose identity is associated with their place of work on social networks and discussion forums, must mention that they are acting on their own behalf and that their views do not reflect the image or the stance of ACBC on the topics addressed.

   
   OUR CUSTOMERS AND CONSUMERS

   Honesty, safety and quality

   We provide our customers and consumers with the very best professional service to ensure that they are satisfied and to earn their trust. Through its Houses, the Group designs and markets products or services that comply with current standards and regulations in terms of quality, safety, industrial and intellectual property rights, and provides transparent, reliable, and fair high-quality information. Our public relations and advertising are based on honesty and fairness, and always keep customer and consumer safety in mind.

   Protection of personal and confidential data

   Our customers retain the power to make decisions about the information that they entrust to us, and we ensure that the confidential nature of their private data is preserved by respecting the commitments we have made to them and in accordance with applicable laws. We respect the right of individuals to retrieve, correct or erase data, and use back-up devices (both physical and digital) for the data collected. The Company recognizes the value of the data that its customers and contacts have entrusted to it. Operating in the Luxury sector, ACBC possesses customer data with a potentially high market value. Being aware of the risk of data breaches, the Company has focused not only on complying with the General Data Protection Regulation, but also ensuring that it provides the best possible protection for its customers’ data.

   Our Business Partners and Our Competitors

   We are committed under all circumstances to fair and equitable business relationships. ACBC publicizes its ethical principles which must guide the conduct of business by its employees, as well as by its business partners, particularly in regard to compliance with laws and regulations, the prevention of any form of corruption, including influence- peddling, and conflicts of interest.

   ACBC strictly prohibits corruption in any form whatsoever, including influence-peddling, and intends to prevent it by complying with the anti-corruption laws applicable in each country in which the Company is present, in particular: French legislation (as amended by the Sapin II law), Italian law, the Foreign Corrupt Practices Act of the USA and the Corruption Act of the United Kingdom. ACBC exercises zero tolerance in regarding all forms of corruption. Active corruption consists of illegally offering or promising an advantage to a person at any time, whether directly or indirectly, which is aimed at inciting that person to act or refrain from acting. The concept of passive corruption refers to the situation of the person corrupted. Corruption is subject to criminal penalties, whether the person corrupted works in the public or private sector. Offering an advantage means offering anything of value (money, of course, but also for example vouchers various kinds of invitation, gifts, donations, job promises, reimbursement of travelling expenses, etc.). As far as “influence-peddling” is concerned, this consists of offers, promises, donations, gifts or advantages of any kind offered directly or indirectly to a person for themselves or for another person, to encourage them to abuse, or because they have abused, their real or assumed influence for the purpose of obtaining distinctions, jobs, contracts or any other favorable decision from a public authority or public administration. We ban facilitation payments throughout the Group, which means the payment of an unofficial sum of money with the aim of facilitating, guaranteeing, or speeding up the execution of an administrative decision. Financing of political organizations, unions, cultural or charitable organizations in the name of or on behalf of the Group for the purpose of obtaining material, commercial or personal advantage, whether direct or indirect, is also totally prohibited.

   Free competition

   Competition law is intended to guarantee that all companies engage in fair competition to offer high- quality products and services at the best prices. We believe in free, open and fair competition, a factor in economic and social progress in terms of prices and the quality and scope of the offer, in the interests of the consumer. We intend to comply strictly with regulations applicable to competition in all markets where the Company operates.

   Commitments by our suppliers and subcontractors

   Respect for human rights and fundamental freedoms are ACBC’s core ethical commitments and must be upheld by all of its employees and stakeholders. To this end, our Code of ethics draws on major international references on ethics and human rights. ACBC is therefore committed to regularly assessing its main suppliers, providing support and advice to them (training programs, development of skills, sharing good practices, among other) to ensure that they comply with its Code of ethics and Suppliers’ Charter.

   ACBC has further set out Sustainability Principles which are systematically communicated to every supplier with which the Group has a contractual relationship; these restate all the fundamental principles and guidelines that complement and specify the major principles of the Suppliers’ Charter.

   ENVIRONMENT

   We endeavor to shape the fashion sector whilst remaining mindful of preserving the planet and its natural resources, and to reduce our impact on climate change and the loss of biodiversity by innovating to support future generations. Measuring our impact beyond our own operations, sustainability is at the heart of ACBC’s strategy: it is a key element in the process of value creation. Our business model aims at having a positive impact on the environment, the economy and the society. In the light of this, ACBC measures the impact of its activities on the protection of natural capital and biodiversity, not only in the areas where it operates directly, but also through its various supply chains, from the production of raw materials to the marketing of the goods and services offered by ACBC to its customers. True to its commitment to transparency and sharing, ACBC publishes the results of its EP&L (Environmental Profit & Loss Account) and makes its methods public, to encourage other organizations to follow its steps in the battle to protect the environment.

   All the Recipients are required to promptly notify the Surveillance Body of ACBC S.R.L. of any derogation, breach or suspected breach, of which they become aware, of the conduct rules referred to in the Company’s Code of Ethics, as well as of the principles of conduct and of the arrangements for the carrying out of the activities defined as “at risk” and governed by the Model.

   The reports, if addressed to the Surveillance Body of ACBC S.R.L., can be submitted by email to:

   organodivigilanza@acbc.com

   The Surveillance Body shall assess all the reports received and adopt the appropriate measures under its discretion and responsibility within its existing powers, it may hear – if necessary – the author of the report and the author of the alleged violation. The reasons of any subsequent decision shall be stated; any measures shall be applied in compliance with the provisions set forth in the Disciplinary System section.

   CODE OF CONDUCT FOR THE SUPPLY CHAIN

   Group Suppliers’ Charter

   Document approved by the Board of Directors of ACBC S.r.l. on 26/02/2019

   Suppliers’ and sub-contractors’ undertakings

   We require our suppliers to adhere to the principles laid down in the Group Suppliers’ Charter. We fight against child labor and forced labor.

   ACBC has introduced checking procedures and does not knowingly work with any partner who disregards these essential principles. ACBC and its brands will help them adopt best practices and comply with its Code of ethics. Beyond these checking procedures, we work to establish lasting partnerships with our suppliers and sub- contractors and support them through training skills and development programs and sharing good practices. Last of all, we believe in free, open and fair competition, a factor in economic and social progress.

   It is equally applicable to the prices, quality and breadth of the offer, in the interests of the consumer and the end customer. We are committed to strict compliance with the relevant regulations relating to competition within the European Union and in all markets where the ACBC operates.

   Group suppliers’ charter

   ACBC and its brands declare their commitment to comply with the provisions of the International Labour Organisation (ILO) and in particular with the conventions concerning the eradication of child labour and the abolition of slavery and forced labour. Moreover, the Group has shown its commitments as a signatory of the United Nations Global Compact and through this support emphasises its defence of the ten principles of the Global Compact since 2008.

   In the light of this, ACBC require their suppliers to commit themselves to the following basic principles which:

   • To prohibit work by children under 15 years of age, saving an ILO waiver clause permitting work by children over 14 years of age;
   • To prohibit the recourse, in whatever form, to slavery, debt bondage, or forced or compulsory labor together with products or services created by these means. The term ‘forced or compulsory labor’ covers all work or service exacted from an individual under threat of any penalty or without remuneration and for which the person has not offered himself/herself voluntarily;
   • To prohibit any type of work which, by its nature or the conditions in which it is carried out, is likely to compromise health, safety or morality;
   • To prohibit any behavior contrary to dignity at work, especially any practice contrary to social regulations and in particular concerning remuneration, working hours and working conditions;
   • To respect employees’ directly applicable right of representation and expression;
   • To prohibit discrimination, in particular racial, ethnic and gender discrimination;
   • To prohibit all forms of sexual and psychological harassment;
   • To ensure the appropriate circulation of the principles of the Charter to its employees;
   • To take appropriate measures for the effective application of the principles of the Charter to its own suppliers;
   • To faithfully warn ACBC and/or its brands of any serious difficulty in applying the Charter.
   • To comply with directly applicable environmental legislation and work to implement the three principles of the Global Compact.

   The unlawful practice of child labor or forced or compulsory labor is totally unacceptable in any commercial relationship between ACBC or its brands and a supplier. In a general way, ACBC shall ensure that any supplier is helped to improve its standards to meet the objectives stipulated in this Charter.
   

   To determine whether or not the Charter conditions are being properly observed, ACBC representatives and/or its brands, who may be accompanied by outside observers, before any contractual relationship for the supply of goods and services to ACBC, shall have unrestricted access to the administrative documents, personnel and production, and packing and transport sites pertaining to the products and/or services to be contracted. These inspections may be repeated as often as is deemed necessary.
   

   For any contractor of ACBC or its brands, compliance with the Charter shall constitute, not with standing any contractual clause, an essential condition of the commercial relationship. In the event of significant failure to comply with the Charter, ACBC or its brands shall decide what corrective measures are to be put in place, if need be, in order to permit the commercial relationship to continue.