Code of Ethics

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  1. INTRODUCTION

  2. SCOPE

  3. GENERAL PRINCIPLES

  4. RULES OF CONDUCT

    4.1 Principles and Rules of Conduct for the Members of Corporate Bodies

    4.2 Principles and Rules of Conduct for the Personnel and the Persons Who Perform Activities in the Interest of the Woolrich Group

    4.3 Conflict of Interest

    4.4 Rejection of any Form of Corruption, either Active or Passive

    4.5 Relations with Suppliers, Contractors, Third Parties with which the Companies enter into Agreements

    4.6 Relations with customers

    4.7 Confidentiality

    4.8 Diligent Use of the Company’s Assets

    4.9 Financial Statements and other Corporate Documents

    4.10 Health and Safety at Work

    4.11 Anti-Money Laundering

    4.12 Use of Information Systems

    4.13 Respect for the Environment

    4.14 Accounting Controls and Transparency

    4.15 Protection of the Corporate Capital and of Creditors

    4.16 Principles and Rules of Conduct for Third Party Recipients

  5. COMMUNICATION, DISSEMINATION, MONITORING AND UPDATING OF THE CODE OF ETHICS

    5.1 Communication and Dissemination of the Code of Ethics

    5.2 Reporting of the Violations of the Code of Ethics

    5.3 Violation of the Code of Ethics and Sanctions

    5.4 Monitoring and Updating of the Code of Ethics

INTRODUCTION

1.1 This code of ethics (the “Code of Ethics”) is one of the key corporate governance documents of the companies (the “Companies” and each of them individually the “Company”) belonging to the Woolrich group (the “Woolrich Group”), as it contains the ethical principles deriving from a heritage of common personal and corporate values, which the Woolrich Group follows in performing its business activities. In fact, the Code of Ethics is intended to be a guide and a support for every director, manager and other employee of the Woolrich Group in order to enable him/her to pursue the Group’s mission in the most effective manner possible.

1.2 The Woolrich Group is an international group operating in the sector of industrial manufacturing of apparel, footwear and accessories in general and of their wholesale and retail sale. The mission of the Woolrich Group is focused on growth and creation of value through manufacturing and marketing of high quality products in due compliance with the applicable regulations. The Woolrich Group runs its business in a socially responsible, impartial and ethical manner, adopts fair and correct practices in the management of the employment relationships, guarantees the employees