The LVMH Group Has Recently Issued a New Code of Conduct in Order to Address the Challenges in an Ever-Changing Environment Whil

The LVMH group has recently issued a new Code of Conduct in order to address the challenges in an ever-changing environment while upholding Ethics and Governance objectives. Bulgari is part of the LVMH group, shares its values and actively participates in building the foundations for its lasting success.

Bulgari is a byword for excellence. Its authenticity, combined with the ability to evolve while also remaining true to its core values, are the qualities that determine its success. In the luxury goods market, brand leadership of this level is only possible thanks to the constant search for perfection: our creations are so highly coveted because they realize a dream and bring excitement into the lives of those who own them, thanks to their extraordinary quality.

Today, as never before, leadership is strongly linked to credibility. Our clients and stakeholders fully rely on the fact that this dedication to excellence is reflected in extremely high standards of behavioral integrity and business practices at Bulgari. Compliance with the standards of the Responsible Jewellery Council is a concrete example of our commitment.

Bulgari has decided to fully adopt the new LVMH Code of Conduct, whose every word it shares and whose principles are in total harmony with the commitments made by the company and the values that have guided it over the years. Adherence to the LVMH Code of Conduct is an opportunity and an incentive to further strengthen all the operating guidelines and systems that we have developed over the years, guaranteeing coherence between business values and activities.

Bulgari is committed to guaranteeing compliance with the principles set out in the LVMH Code of Conduct and ensuring that they are implemented and disseminated. The personal contribution of each individual is essential to bringing the LVMH Code of Conduct to life in day-to-day activities and determining the success of our company over time.

Jean-Christophe Babin Chief Executive Officer Code of Conduct

Code of Conduct TABLE OF CONTENTS

6 FOREWORD

8 INTRODUCTION

10 ACTING RESPONSIBLY AND WITH SOCIAL AWARENESS

12 PROVIDING A FULFILLING WORK ENVIRONMENT AND VALUING TALENTS

15 COMMITMENT TO PROTECT THE ENVIRONMENT 17 WINNING THE TRUST OF CUSTOMERS

18 WINNING THE CONFIDENCE OF SHAREHOLDERS

21 ACTING WITH AND COMMITMENT TO INTEGRITY IN THE CONDUCT OF BUSINESS

25 IMPLEMENTATION AND COMPLIANCE FOREWORD

Successful companies stand the test of time.

LVMH knows this well. Our Maisons excel in nurturing the value of their brands, continually strengthening their appeal with bold innovation while respecting their unique and prestigious heritage. This is what inspires the success of the Group and guarantees our future.

The success of LVMH also depends on respect for the shared rules, practices and principles that guide the day-to-day conduct of our business activities everywhere in the world in terms of ethics, social responsibility and respect for the environment.

LVMH has articulated and encouraged respect for these shared rules, practices and principles. Since its founding, the LVMH Group has ensured that: these practices reflect the highest standards of integrity, responsibility and respect for stakeholders; employees enjoy a work environment in which they can express their talent and apply their skills and expertise; our Maisons define and adapt their production processes, habits and behaviors to pursue continuous improvement in addressing the environmental issues we face; we contribute to the development of the regions and communities where we do business; we provide resources and competencies to support public interest initiatives and corporate philanthropy, and promote access to the arts and culture for a broad public.

We make these commitments to ourselves and to our stakeholders. They are reflected in the signature by LVMH and its Maisons of fundamentalinitiatives – such as the United Nations Global Compact in 2003 – and by the adoption of internal codes of practice and charters that provide a benchmark for all our Maisons. These include an Environmental Charter introduced in 2001 and the Supplier Code of Conduct in 2008. We adopted the initial version of our Code of Conduct in 2009, formally setting out simple yet fundamental principles that

6 LVMH . Code of Conduct

inspire the Group in the conduct of its businesses and guide each of us in the exercise of our responsibilities.

This updated version of our Code of Conduct is both more explicit and more extensive for several reasons.

Because we must update our common framework to better address the diversity of continually evolving national contexts, métiers and cultures.

Because we must ensure compliance with all applicable treaties, laws and regulations, particularly in the areas of human rights and basic freedoms, health and safety, environment and ethics.

And because it is essential that these principles be applied thanks to concrete and effective means and an appropriate organizational structure.

This Code of Conduct has been signed by the members of the Executive Commit- tee and by the CEOs of the LVMH Maisons. Each of the signatories thus makes a formal commitment to respect this Code and to guarantee its application and dissemination.

The Board of Directors’ Ethics and Sustainable Development Committee monitors respect for the rules and values defined in this Code of Conduct. Each Maison and its members are expected to engage with this common framework and to apply its principles. This is a key factor in ensuring our continued excellence and a pillar that allows us to thrive over the long-term.

Our future collective success depends on the ethical commitment of every individual in the Group.

Bernard Arnault Chairman and Chief Executive Officer of LVMH

7 INTRODUCTION

purpose Cultivate an entrepreneurial spirit: LVMH has an agile and decentralized organization that The LVMH Group (“LVMH” or the “Group”) com- encourages efficiency and responsiveness. It prises over 70 exceptional Maisons that create stimulates individual initiative by entrusting high quality products. LVMH is the only com- each person with meaningful responsibilities. pany active in all five major sectors of the luxury Our entrepreneurial spirit encourages both industry: Wines & Spirits, Fashion & Leather risk-taking and perseverance. It requires prag- Goods, Perfumes & Cosmetics, Watches matic thinking and an ability to motivate teams, & Jewelry and Selective Retailing. leading them to achieve ambitious objectives.

The Group’s growth and enduring success are underpinned by the values and principles that responsible people at the heart shape its culture and inspire and guide the of performance actions of all employees.

LVMH’s ambitions are anchored by three funda- LVMH employees are inspired by these values mental values shared by all members of the and embody them to guarantee the success of Group: the Group and its Maisons. These values serve as a guide for our employees in changing con- Be creative and innovative: creativity and texts, as well as in complex environments, ena- innovation are part of our DNA. Over the years, bling them to challenge themselves to innovate they have ensured our Maisons’ success and and drive growth. These values are the pillars established their legitimacy. This combination that ensure the performance and long-term of creativity and innovation is the foundation of success of the LVMH Group. our Maisons and figures at the heart of the del- icate balance required to continually renew our offering while resolutely looking to the future, an ecosystem of maisons always respecting our unique heritage;

Deliver excellence: because LVMH embodies LVMH is above all an ecosystem of Maisons that the world of craftsmanship in its most noble share a common culture of excellence and and most accomplished form, we pay meticu- dynamic creativity to satisfy the aspirations of lous attention to detail and to perfection. We their customers. never compromise on quality. From products to The organization of LVMH emphasizes the service, we cultivate our difference through this autonomy of its Maisons, recognizing the rich constant quest for excellence; diversity of the business models they have

8 LVMH . Code of Conduct

developed. The Group respects their distinctive Guidelines for Multinational Enterprises and character and development paths and acts as the United Nations Guidelines on Women’s the leader of a creative community where Empowerment. expertise and skills are carefully preserved, The LVMH Code of Conduct provides the foun- nurtured and shared. dations for our policy. The application of this Decentralized operations guarantee the auton- common base in specific areas is detailed in the omy and agility of the Maisons, allowing LVMH Environmental Charter, the Supplier Code of to remain extremely close to customers, to rap- Conduct as well as various internal guidelines idly make effective decisions, and to continually and charters. motivate our employees by encouraging them This Code of Conduct does not supersede the to show their entrepreneurial spirit. codes and charters applied by LVMH Maisons, but rather serves as a common core and source of inspiration. It brings together the fundamen- a shared ethical framework tal principles that illustrate our shared commitment and guide the way we carry out our The principles set out in this Code of Conduct day-to-day professional activities. It states the provide an ethical framework for all the actions principles that must inspire every member of of LVMH and its staff. LVMH expects exemplary the Group, as well as our partners and suppliers. behavior by its employees, fully respecting the Group’s ethical commitments.

Respect for national and international laws, regulations and decisions and the application of best practices – particularly with respect to ethics, the environment and social responsibility – are essential prerequisites for the credibility of our policy. LVMH is committed to respecting both the letter and the spirit of these key texts and to translating its values and principles into responsible behavior.

This Code of Conduct is inspired by the fundamental values detailed above, as well as the Universal Declaration of Human Rights, the United Nations Global Compact, the OECD

9 ACTING RESPONSIBLY AND WITH SOCIAL AWARENESS

respecting and supporting own facilities and indirectly through its part- human rights and ners – and also to the tax revenue of local and fundamental freedoms national governments. Through cooperation with the different sectors LVMH ensures that the conduct of its busi- in which LVMH operates, the Group’s presence nesses respects individual rights and encour- encourages the development of local centers of ages the continuous improvement of social and excellence, as well as development of skills. public health conditions, which are essential to the development and protection of individual rights. building and encouraging LVMH is committed to remaining vigilant in responsible relationships identifying any potential direct or indirect neg- with partners ative impact of its activities on society in order to prevent, or if necessary, remedy any such LVMH is committed to maintaining and encour- negative impact. aging responsible and fair relationships with its partners. LVMH respects and promotes the Universal Declaration of Human Rights and adheres to LVMH supports its partners to establish and the principles of the United Nations Global respect good corporate social and environmen- Compact, as well as to the United Nations tal practices and encourages their awareness of Guidelines on Women’s Empowerment. Within the importance of these issues. In particular, its sphere of influence, LVMH supports the LVMH requires suppliers to comply with the values, freedoms and fundamental rights pro- ethical principles set out in the Supplier Code moted in these texts. of Conduct. This Code specifies requirements to be respected by its suppliers, including any subcontractors they employ, in the manage- contributing to the economies ment of their business regarding social issues of host countries (prohibition of forced labor and child labor, harassment and discrimination, measures related LVMH contributes to the economic and social to wages, working hours, the free exercise of development of the regions where it does union rights, health and safety), environmental business. issues and operational issues (notably respect for laws, customs regulations, safety and sub- LVMH contributes to job creation in the regions contracting) and measures to fight corruption where it is present – both directly through its and illicit influence. This Supplier Code of

10 LVMH . Code of Conduct

Conduct also gives LVMH the right to conduct LVMH education and youth initiatives empha- audits to ensure, as far as possible, supplier size broad access to the world’s cultural herit- compliance with these principles. age and encourage the development of tomorrow’s talents. LVMH maintains balanced commercial relations with its partners and places special emphasis The LVMH Group’s solidarity also extends to on respect for contractual agreements and humanitarian and social causes. LVMH provides terms of payment. ongoing support for medical research in France and around the world.

active solidarity and . corporate philanthropy LVMH supports its partners LVMH is committed to exemplary corporate to establish and respect social responsibility. This commitment is good corporate social and anchored in the fundamental principle of respect for people and individuals, and in mak- environmental practices. ing excellence a lever for social and profes- . sional inclusion, in solidarity with our host communities.

LVMH carries out numerous initiatives to support culture, artistic creativity, education and youth, as well as major humanitarian causes.

LVMH pursues an innovative corporate philanthropy policy designed to benefit the largest possible number of people. The different aspects of this policy reflect and promote the cultural values that unify LVMH Maisons and underpin their success.

LVMH respects the cultures of the countries where it conducts business and is committed to promoting the best of local cultures and creativity. LVMH’s social solidarity policy reflects its attachment to historic and artistic heritage.

11 PROVIDING A FULFILLING WORK ENVIRONMENT AND VALUING TALENTS

LVMH respects and promotes the principles of LVMH is formally committed to ensuring that all the United Nations Global Compact, in particu- employees enjoy their rights irrespective of skin lar the fundamental rights at work: color, sex, religion, political convictions, national or social origin, age, disability, trade union mem- elimination of discrimination with respect to bership, sexual orientation, or gender identity. employment and occupation; Particular attention is accorded to vulnerable elimination of all forms of forced and com- persons’ rights. pulsory labor;

effective abolition of child labor; promoting a work environment freedom of association and the effective that respects individuals recognition of the right to collective bargaining. Diversity inspires creativity and is an essential LVMH encourages a diversity of profiles and value for LVMH. The diversity of the Group backgrounds. This commitment is formally set reflects a strong commitment to nurturing a out in the Group’s Recruitment Code of Con- culture of inclusion that respects the individual- duct and materialized by its signature of the ity of each employee or job candidate. French Corporate Diversity Charter (“Charte de la diversité en entreprise”). LVMH prohibits all forms of discrimination in recruitment, compensation, working time, . breaks or paid vacation, maternity rights, job security, assignment of positions, appraisal, Diversity, a gender-balanced training, career development, job security and workforce and gender workplace health and safety. LVMH opposes all equality are embedded forms of physical, sexual, verbal or psychologi- in the LVMH culture. cal violence and harassment. . Gender diversity is an integral part of the LVMH culture. The Group makes equal opportunity for women and men a cornerstone of its human resources policy within the framework of an inclusive culture, and places special emphasis on developing the careers of women. LVMH ensures equitable treatment of both women and men, including on work compensation and benefits.

12 LVMH . Code of Conduct

LVMH takes initiatives to recruit, develop and safety. It works towards protecting employees retain talents that respect gender diversity. It in the framework of their professional activities has set up programs including mentoring and from exposure to hazardous materials or situa- active support for talented women. tions and reporting potential hazards.

LVMH promotes the development of young LVMH internal regulations detail workplace talents through partnerships with schools and health and safety rules. They are communicated universities, local communities and asso to employees. ciations. LVMH takes measures to ensure a healthy bal- LVMH encourages the employment and reten- ance between professional and private life for tion of older employees through initiatives its employees. such as training, flexible work hours and work- LVMH respects the right of its employees to be ing conditions and prevention of physically dif- involved in political activities and/or associa- ficult tasks. Senior employees are actively tions in a private capacity. Employees must encouraged and valued through mentoring ensure that these private activities do not programs designed to preserve and transmit involve or jeopardize the fulfillment of their their skills. responsibilities or damage the reputation of LVMH is resolutely committed to the profes- their employer. sional integration of people with disabilities and LVMH is committed to respecting applicable actively supports their training and recruitment regulations in its host countries when it gathers, through specific initiatives and dedicated processes or transfers the personal data of partnerships. employees or job candidates.

encouraging a work environment offering a stimulating that is safe and which and motivating work environment respects private life for employees LVMH takes measures to ensure the health and LVMH seeks to attract, recruit and develop the safety of its employees and ensures that all its most talented people and offers a fulfilling activities comply with applicable workplace work environment that encourages relation- health and safety laws and regulations in all its ships between colleagues based on trust. host countries. LVMH is committed to imple- menting best practices in the area of workplace

13 LVMH actively develops the skills of its employ- promoting dialogue ees through an extensive range of training pro- with employee grams and by promoting internal mobility, both representatives geographic and functional. The Group is strongly committed to the transmission of skills LVMH respects employees’ right to freely and the cultural heritage represented by arti- express views and opinions formulated within sanal and creative professions. the framework of a constructive dialogue.

LVMH encourages its employees to continually LVMH respects the right of employees to freely focus on quality in the execution of their work. and voluntarily join organizations to promote Managers place priority on leading by example and protect their professional interests. and ensuring an effective balance between ini- LVMH encourages positive dialogue with tiative and limits dictated by the professional employee representatives and cooperation skills and responsibilities of the people who with trade unions, as well as the respect and report to them. consideration for employee representatives in Employees are expected to cooperate with col- each country where the Group is present. leagues and ensure impartiality and mutual respect in their inter-personal relations.

Employees may not make discriminatory, defamatory or harassing remarks when dis- cussing their colleagues, managers or employer. In particular, this includes communication on social networks to be in compliance with the guidelines set out in the internal Social Media Charter.

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COMMITMENT T O P R O T E C T THE ENVIRONMENT

Protecting the environment is both an impera- preserving natural resources tive and a source of progress. and integrating the environmental dimension into products In all countries where it has a presence, LVMH strictly complies with applicable environmental The long-term success of LVMH Maisons and laws, regulations and standards. LVMH strives their products depends directly on protecting to exceed legal and regulatory norms as an and respecting natural resources. exemplary corporate citizen to address environmental issues that concern everyone. Through Products created by LVMH Maisons are made its Maisons, employees and partners, LVMH from natural and often rare and exceptional actively contributes to defining and implement- materials. The design and manufacture of lux- ing more virtuous practices in all of its business ury products require not only innovation, crea- sectors, in particular through a precautionary tivity and excellence in execution, but also approach. environmental performance.

These commitments were formalized in the The LVMH Group has since its founding per- Environmental Charter adopted in 2001 and petuated values rooted in the unique heritage applied by all LVMH Maisons: of its Maisons, continually anticipating and adapting production processes and behaviors Aim for a high level of environmental perfor- to better address the many environmental mance; challenges we face. Foster a collective commitment;

Control environmental risks; a commitment supported Design high-quality products by integrating by concrete, environmental innovation and creativity; effective tools Pursue commitments beyond the company. LVMH takes concrete initiatives to protect the environment, fight climate change and preserve . natural resources. The Group seeks to actively Protecting the environment drive continuous improvement of environmental conditions to benefit its customers, employ- is both an imperative ees and the broader community, and deploys and a source of progress. the suitable human and financial resources. .

15 This commitment is embodied by the LIFE Environmental priorities and objectives are an program – LVMH Initiatives For the Environ- integral part of the strategic plans at each ment – which has been incorporated by all Maison. The Maisons must prepare medium- LVMH Maisons to structure their initiatives and and long-term plans to ensure continuous focus them on nine shared priority areas and improvement, accompanied by indicators to objectives: measure performance.

Integrate environmental performance of Beyond environmental factors linked directly to products throughout their life cycle since the its business activities, LVMH also helps protect design stage; the environment by forging partnerships with business groups, public authorities and NGOs. Secure access to strategic raw materials by Guided by the LIFE program, LVMH and its Mai- protecting biodiversity; sons work in a spirit of cooperation with stake- Guarantee material and product traceability holders to make a positive contribution to best compliance; practices and address environmental issues throughout the entire value chain. Promote environmental and social responsibility of suppliers and work with them to ensure best-in-class environmental standards across . our supply chain; LVMH takes concrete Protect critical know-how; actions to protect Reduce greenhouse gases emissions of our the environment activities and promote the use of renewable and always strives energy; to exceed legal and Improve the environmental performance of regulatory requirements. our production sites and stores; . Increase the lifetime and “reparability” of products;

Establish procedures to address environmental issues raised by customers and stakeholders.

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WINNING THE TRUST OF CUSTOMERS

sustaining product quality respecting privacy and safety Understanding customer needs and expecta- LVMH is committed to ensuring the health and tions is essential in order to provide them with safety of its customers by applying the precau- the products they seek and deliver a personal- tionary principle in the design and production ized customer experience. of its products. LVMH and its Maisons take measures to act LVMH continually strives to offer customers the with complete transparency in compliance with highest possible product quality thanks to applicable regulations concerning protection of research and innovation, exacting standards in customers’ personal information. In particular, selecting materials, and in the use of expert LVMH Maisons provide their customers with skills in its different sectors. clear information concerning the personal information they provide, and take measures to pro- The Group takes special care in the production tect the confidentiality of this information. and sourcing of these high-quality materials to seek to assure the sustainability of its resources, LVMH and its Maisons do not sell customers’ as well as respect for the principles promoted personal information and do not send com- by LVMH in this Code of Conduct. mercial messages to customers without their prior consent.

responsible . communication LVMH takes measures to act LVMH provides its customers with clear and with complete transparency accurate information concerning production with regards to the protection methods, as well as the impact and correct usage of its products. LVMH strives to refrain from mak- of personal information ing misleading statements or claims concerning and to scrupulously ensure its products and how they are produced. respect of its customers’ privacy. LVMH recognizes the social impact of its prod- . ucts and their image and is therefore committed to the highest levels of vigilance regarding its marketing and advertising information, by promoting responsible practices.

17 WINNING THE CONFIDENCE OF SHAREHOLDERS

defining and respecting Code of Conduct and other codes and charters shareholder rights resulting from this Code.

The rights of LVMH shareholders are protected by law and by the corporate governance princi- ensuring the quality ples that cover the operation of the Group. and transparency of financial information The Board of Directors of LVMH has adopted a Charter that sets out, among other things, its LVMH accurately reflects its operations in its composition, duties, operating procedures and financial statements. responsibilities. LVMH provides information on its performance The Board of Directors of LVMH has three com- with complete independence and transparency. mittees whose composition, duties and operat- In addition, the Group completes certain ques- ing procedures are set out in the company’s tionnaires from independent ratings agencies internal rules: where there is no risk of conflict of interest. The Performance Audit Committee, whose LVMH is committed to ensuring the simultane- main duties are to ensure that the Group’s ous, effective and complete dissemination of accounting procedures comply with applicable financial and extra-financial information that is standards. It reviews the corporate and consol- relevant, accurate, precise and trusted, and to idated financial statements and ensures effec- the publication of this information in a timely tive execution of internal control and risk manner and in a format consistent with previ- management procedures within the Group; ous publications. The Nominations and Compensation Com- Only a limited number of designated persons mittee issues proposals concerning the com- within the Group are authorized to provide pensation for senior executives and issues information to financial markets. opinions on candidates and compensation for key positions, in compliance with applicable legislation and governance principles; preventing insider trading The Ethics and Sustainable Development Committee, whose main duties are to ensure “Insider information” is any specific information compliance with the individual and collective that is not publicly available that directly or values that constitute the cornerstone of the indirectly concerns one or more issuers of LVMH Group’s operations, as detailed in this financial instruments or one or more financial

18 LVMH . Code of Conduct

instruments and which, if it were made public, To mitigate the risk of unintentional dissemina- could significantly impact the price of the tion of insider information, employees with financial instruments concerned or any deriv- access to such information are required to ative financial instruments linked to them. respect complete confidentiality and are pro- Employees with access to such information are hibited in particular from mentioning this infor- prohibited from directly or indirectly buying or mation in any communications channels that selling the issuer’s shares (or financial instru- unauthorized persons might consult or in any ments linked to these securities) or to have place where they risk being overheard. If such transactions executed by a third party employees have any doubts as to whether until such information is made public. information is considered “insider information”, they must contact their management or any The Group implements procedures to assess other authorized person (Finance or Legal whether information should be qualified as departments). insider information or not, and to determine whether this information can be communicated or used, and whether it must be made public. protecting the group’s resources

. The Group takes every possible measure to LVMH provides protect its assets and resources, including its intellectual property rights. The Maisons deploy information on its an anti-counterfeiting strategy based on pre- performance with vention, cooperation and communication.

complete independence Each employee is responsible for protecting and transparency. the heritage and resources of LVMH to avoid . any loss, improper use, damage or waste. These resources include equipment, property, financial resources and any other Group asset.

Employees are expected to use the Group’s resources responsibly and for professional, legal and appropriate purposes in order to achieve the objectives set within the framework of their duties, with the goal of contributing to the development of the Group’s businesses.

19 Employees must be vigilant in protecting LVMH requires that its employees demonstrate against waste or abusive use of resources, fair and equitable behavior. Each of them is particularly in taking advantage of benefits responsible for protecting the reputation of accorded. Resources and assets are made LVMH, its employees and its partners, and must available to employees on a temporary basis refrain from any denigration of competitors. and remain the property of the Group. In particular, LVMH expects its employees to be extremely vigilant in the statements they The LVMH Group has established internal publish on the Internet, particularly in making guidelines concerning the protection of certain that their remarks reflect only their resources which employees are also expected personal views, in compliance with the internal to follow. Social Media Charter. Employees are expected Occasional personal use of communications to show restraint, respect for others and to resources (e-mail, internet, etc.) is acceptable guarantee confidentiality and professional as long as it does not interfere with an employ- secrecy. ee’s duties, does not generate any additional costs for the company, complies with applicable legislation, and does not negatively impact the business interests of LVMH.

The use of information technology resources is in particular subject to compliance with the rules and principles set out in the internal LVMH Information Systems Security Charter.

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ACTING WITH AND COMMITMENT TO INTEGRITY IN THE CONDUCT OF BUSINESS

LVMH requires that its employees and partners There is active corruption when the corruptor act with exemplary integrity. Failure to comply initiates the corrupt act. There is passive cor- with regulations can expose the Group – as ruption when the corrupt act is performed at well as employees themselves – to criminal the initiative of the corrupted person. sanctions. In addition to possible legal pro- As for the concept of influence peddling, it ceedings, employees who fail to respect these applies to a situation in which a person illicitly internal rules and guidelines are subject to dis- uses their real or supposed influence in order ciplinary sanctions. to obtain certifications, employment, contracts or any other favorable decision for a third party from a public authority or administrative office fighting against all forms in exchange for a benefit. of corruption Influence peddling is also qualified as “active” The concept of “act of corruption” – the legal or “passive” depending upon who initiates the definition of which varies depending upon the action. applicable legal framework – generally includes LVMH applies a zero-tolerance policy concern- any act through which a person (“the cor- ing corruption and influence peddling and rupted”) solicits or accepts a gift, a promise or implements measures to prevent, identify and any type of benefit for themselves or for a third sanction any instances of corruption or influ- party in exchange for performing, failing to ence peddling within the scope of its activities. perform or delaying the performance of an action within the scope of their responsibilities, Internal guidelines communicated to employ- duties or mandates, to the benefit of a third ees precisely illustrate the types of behavior party (“the corruptor”). that are strictly prohibited and which may be characterized as corruption or influence ped- Gifts, promises or any type of benefit may con- dling. For example, they include: sist of direct benefits – payment of cash, provi- sion of goods or services, discounts, free paying or accepting bribes or hidden com- execution of work, etc. – or indirect benefits missions, regardless of whether they are paid such as hiring a relative or friend, paying a debt directly or indirectly; for someone, etc. facilitating payments (payment of small Corruption may involve a person acting in a sums to public officials in order to speed or private capacity (private corruption) or in a guarantee the execution of an action as part of public capacity (public corruption). the normal conduct of business).

21 More broadly, any payment to a third party adopting a reasonable policy must be in exchange for a service and corre- concerning gifts and invitations spond to a legitimate price agreed with this third party. LVMH has established internal guidelines concerning gifts and invitations with which all employees are expected to comply. preventing and managing Moreover, practices to be respected in this area conflicts of interest are governed by laws and normal practice that vary according to countries, professions and Conflicts of interest may arise when the per- the status of the persons involved. The LVMH sonal interests of an employee or those of third Group does not tolerate any violation of appli- parties (private individuals or companies) with cable laws and regulations and takes measures which the employee has a close relationship to ensure that all employees comply with these conflict or could potentially conflict with the rules. interests of LVMH and could compromise or give the appearance that this relationship might compromise the impartial and objective exer- protecting confidentiality cise of the employee’s responsibilities.

LVMH Group employees who could potentially LVMH employees are committed to protecting find themselves in situations such as this are the confidentiality and integrity of internal required to report potential conflicts of interest information that has not be made public. as soon as they are identified. This information may in particular concern In addition to immediately reporting potential financial data, information on strategy, employ- conflicts of interest, employees whose positions ees or clientele, product collections and and responsibilities render them particularly launches, potential acquisitions or commercial exposed to possible conflicts of interest are initiatives designed to bring the Group a com- required to periodically report the absence of petitive advantage. any conflicts of interest or report any potential As a general rule, discretion is essential in order conflicts of interest that have been identified. to maintain trust within the Group and within The Group has established specific internal the framework of relationships established with guidelines designed to avoid and manage con- customers and partners. LVMH is committed to flicts of interest; employees are expected to act ensuring the protection of all confidential infor- in accordance with these guidelines. mation entrusted to the Group by external

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sources and to using this information only for arrangements or coordinated behavior between the purposes authorized, taking necessary pre- competitors, in particular concerning prices, cautions. markets, market shares or customers.

Employees agree to refrain from divulging, whether directly or indirectly, any internal or fighting money-laundering external confidential information in their pos- session to both persons outside the Group Money-laundering involves the investment of and to other LVMH employees whose respon- funds derived from criminal activities in legiti- sibilities do not require knowledge of this mate economic activities in order to conceal information. the illegal origin of these funds.

LVMH takes appropriate measures designed to respecting competitors avoid its activities being used as a vehicle for money-laundering, an illegal activity that might LVMH believes in maintaining an open and fair in particular involve the payments in cash or competitive environment that respects appli- other bearer instruments. cable laws and practices and does not violate LVMH has established internal guidelines and competition rules. procedures to fight money-laundering, in par- LVMH’s commitment to respecting competi- ticular by limiting or establishing rules for cash tion has been formalized in the adoption of the payments and requires that its employees and internal Competition Law Compliance Charter, partners be especially vigilant in this regard. which has been prepared to foster a robust culture of compliance with competition law throughout the Group. respecting trade restrictions and international sanction programs This Charter explains the main rules governing day-to-day commercial relationships with which LVMH attaches great importance to respect employees are expected to be conversant, for international agreements, as well as laws and provides pragmatic standards of conduct and regulations concerning export controls, that employees are expected to respect. For financial sanctions and international trade example, LVMH prohibits any abuse of domi- restrictions for countries where the Group and nant position, concerted practice or unlawful its Maisons do business, taking into account agreement through understandings, plans, changes in these measures.

23 No transactions with direct or indirect links to LVMH prohibits any payment to political par- states, entities, organizations or persons sub- ties or organizations or labor unions. ject to international sanctions, regardless LVMH prohibits the awarding of any mandate of their size, may be executed if they fail to or compensation, either permanent or tempo- respect existing sanctions programs, and with- rary, to any member of a national or European out prior approval from the LVMH Finance and parliament during their term of office. Legal departments.

acting in a loyal and responsible manner in public life

In a spirit of dialogue and cooperation with public authorities and decision leaders, LVMH contributes to public discussions in countries where this is authorized and relevant for its businesses.

The Group’s involvement in public life is governed by respect for the laws and rules specific to the institutions and organizations concerned, as well as those set out in this Code of Conduct. LVMH places great importance on the accuracy of information provided to third parties and is registered as a lobbyist where required by its activities. Outside service pro- viders under contract with the Group are required to respect these same principles.

24 LVMH . Code of Conduct

Implementation AND COMPLIANCE

Scope of governance by its Maisons in the The principles of this Code of Con- application following areas: duct may be detailed by each Mai- environment; son to reflect its business sector or This Code of Conduct aims to relationships with suppliers; geographic location. In addition, ensure the integrity of LVMH’s recruitment; local codes of conduct or charters operations. This Code is shared information systems security; may be applied when necessary to with all LVMH Group companies fighting corruption, in particu- conform to local legislation and and consistently applied in all lar to address some specific geo- regulations. LVMH Maisons. graphical areas; compliance with competition All LVMH Group employees must law; respect the principles set out in Governance advertising; this Code of Conduct. other issues and areas covered To ensure effective dissemination by this Code of Conduct for which and respect for the principles and the Group has established internal values set out in this Code of Dissemination guidelines. of the Code of Conduct, LVMH has established corporate governance aligned Conduct Employees who fail to respect the with the profile of the Group and principles set out in this Code of This Code of Conduct is available its operational realities. Conduct and in internal guidelines on the LVMH website and is also are liable to appropriate discipli- available and can be downloaded This organization is based on: nary measures proportionate to in several languages on the the seriousness of the infraction, in a Board of Directors’ Ethics Group’s intranet. compliance with the Internal Reg- and Sustainable Development ulations (or any equivalent docu- Committee whose duties are: to This Code of Conduct is given to ment) of the company that contribute to the definition of all new employees. employs them and to applicable rules of conduct inspiring the laws and regulations. Group’s executives and employees The LVMH Group has also estab- in the areas of ethics, corporate lished resources to support good

25 . This Code of Conduct aims to ensure the integrity of LVMH’s operations. This Code is shared with all LVMH Group companies. It must be consistently applied in all LVMH Maisons. .

social and environmental respon- within the LVMH Group. In this an Environment Committee sibility; to ensure the respect of respect, an annual report on comprising environment corre- these rules; to review the Group’s implementation of the principles spondents from the Maisons, strategy and reports in these of the Code of Conduct will be which meets several times each areas; submitted to the Ethics and Sus- year. This Committee provides a tainable Development Committee; forum for exchanges of ideas and an Ethics and Compliance discussion of environmental per- Director, reporting to the Group a network of Ethics and Com- formance opportunities and issues, Managing Director, and an Ethics pliance correspondents appointed as well as the LIFE program; and Compliance Commission at each Maison to encourage comprising representatives of dif- experience sharing, sharing of a Supplier Sustainability Day, ferent LVMH corporate depart- best practices and consistent and which each year brings together ments (human resources, finance, uniform application of the princi- purchasing, branch managers and operations, purchasing, audit and ples and values promoted by the managers responsible for supplier internal control, environment, legal Code of Conduct. relations from the Maisons. These and communications). This Com- meetings review priority issues, mission is specifically responsible The governance structure also launch new initiatives and cascade for promoting the principles set includes: best practices within the Group; out in the Code of Conduct, for a network of Social Responsi- a network of Internal Control driving the development of best bility correspondents appointed correspondents headed by the practices in these areas, ensuring within the Maisons, which meets Audit and Internal Control depart- compliance with the Code, analyz- several times each year to struc- ment, responsible for coordinating ing and ranking the seriousness ture initiatives to be taken and implementation of internal control of risks identified via a regularly allow the Maisons to adopt and and risk management procedures. reviewed mapping, contributing adapt these initiatives to reflect Within the different Maisons, these to compliance and due diligence their specific values, business correspondents are responsible audits of partners and managing environment and the expectations both for ensuring compliance with the functioning and tracking of of their employees and customers; the Group’s internal control proce- the alert procedures put in place dures and for carrying out internal

26 LVMH . Code of Conduct

controls of their businesses and ies, etc.) are included in this map- terms of job profile, geography functions. ping. Each Maison must adapt its and business). Training is regularly internal codes of conduct and provided for Group managers and procedures to reflect their specific employees who are most exposed Support risks in this mapping. to risks of corruption, influence resources peddling and money-laundering. Internal control and assess- Social responsibility training ment – Control of compliance Mapping of risks – Risk map- focused on preventing discrimina- with the Code of Conduct is part ping identifies and when possible tion is provided for recruiters, of existing LVMH internal control ranks the seriousness of risks to executives and managers, and procedures and is carried out in which the Group and its Maisons continual monitoring of recruit- compliance with the procedure are exposed against all types of ment practices is carried out applied by the Group. Internal and behaviors that are non-compliant through discrimination test cam- external accounting control pro- with this Code of Conduct, par- paigns conducted by an inde- cedures implemented by LVMH ticularly external attempts at cor- pendent firm. are designed in particular to ruption and serious violations of ensure that the accounts are not Audits and due diligence – The human rights, fundamental free- used to mask instances of corrup- Group performs audits and due doms, the health and safety of tion or influence peddling, and to diligence of stakeholders to better individuals and the environment. assess due diligence measures identify, assess and anticipate risks These risks are assessed in par- taken to prevent and fight against and opportunities for improve- ticular in relation to partners, all forms of corruption and influ- ment and to ensure in-depth geographies and business sec- ence peddling. knowledge of its partners. These tors. This mapping is regularly procedures allow the Group to reviewed to take into account the Training – The LVMH Group verify that the performance of its changing environments in which deploys a range of effective train- partners is aligned with its require- the Maisons conduct their busi- ing resources. The content of ments and respects the best prac- nesses. Based on the risks identi- these programs and choice of tices detailed in this Code of fied, procedures for evaluation of staff who benefit from them are Conduct, in particular in terms of partners (suppliers, intermediar- based on the risk mapping (in

27 ethics, social and environmental document) and applicable laws for the person raising the alert to issues and respect for human and regulations. the extent reasonably possible rights. Through these controls, the and unless otherwise required Alert procedures – All employ- Group can also help its partners by law (in particular in France ees who have questions about implement and apply best prac- with the conditions stipulated the appropriate behavior to be tices to resolve minor non-con- by the French Data Protection adopted or the interpretation of formities. These measures and Authority Cnil single authorization the principles set out in this Code compliance with them, are stipu- No. AU-004). of Conduct, or those who become lated in agreements between the directly or indirectly aware of vio- Retaliations are prohibited against Group and its partners. lations of this Code of Conduct, people who use this procedure in Disciplinary sanctions – Failure are invited to contact their man- good faith even when the suspi- by employees to respect the rules ager, Ethics and Compliance cor- cions at the origin of the alert set out by the Code of Conduct, respondent, human resources prove groundless. specific codes of conduct, char- manager, the Group’s Ethics and ters, and internal policies, guide- Compliance Director or any other lines and Internal Regulations (or authorized persons. any equivalent document) of the Maisons that employ them may The LVMH Group has established be considered as misconduct. In an internal alert procedure ena- such cases, the Group may take bling reporting and processing of appropriate and necessary meas- alerts raised by employees ures in order to terminate the regarding violations or risks of misconduct identified, including violation of the measures set out appropriate disciplinary sanctions in this Code of Conduct. proportionate to the seriousness This alert procedure is available to of the violation, according to the all employees. In compliance with measures stipulated in the Internal applicable regulations, this proce- Regulations (or any equivalent dure guarantees confidentiality

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