THE PR ADA GROUP
CODE OF ETHIC SPRADA GROUP’S PURPOSE
With a thoughtful and pioneering
vision, the Prada Group is a
global leader in luxury.
We own some of the world’s
most prestigious brands:
Prada, Miu Miu, Church’s, Car
Shoe, Marchesi 1824 and Luna
Rossa.

By being
DRIVERS of CHANGE,
we offer an unconventional
dialogue and interpretation of
the contemporary, as expressionof our way of doing businessfor PLANET, PEOPLE and
CULTURE.

— Table of Contents

1. INTRODUCTION

2

2. SPHERE OF APPLICATION
AND ADDRESSES

3

3. BUSINESS CONDUCT

3Trasparency
Conflict of interest
Corruption
Money laundering
Company assets

4. PLANET

5

5. PEOPLE

6

Human rights
Diversity, equity and inclusion
Health and safety
Protection of employees’ personal data

6. CULTURE

7

7. PUTTING OUR CODE OF ETHICS
INTO ACTION

7

8. MONITORING APPLICATION OF
THE CODE OF ETHICS AND
WHISTLEBLOWING SYSTEM

8

9. VIOLATIONS AND
SANCTIONARY CONSEQUENCES

8— 1. Introduction
The Prada Group (Prada S.p.A., holding company of the
Prada Group (the “Prada Group” or the “Group”), has
always based the conduct of its activities on principlesof ethical integrity. With time, the Prada Group faced
new challenges inspiring its behavior to the core values
described in this code (the “Code of Ethics”), which alsoestablishes the principles and rules of conduct derivingfrom them. The Code of Ethics is a framework for all thePrada Group’s employees, which must inspire their daily
conducts in carrying out their professional activities.

with customers, suppliers, shareholders, and all otherstakeholders, so that they can rely on the Prada Group as
an ethical business partner.
The Prada Group is committed in promoting theapplication of the principles contained in this Codeof Ethics – as well as the compliance with laws andregulations - in the belief that ethics in the conduct of its
business are crucial for a sustainable growth and successin the long-term, as well as to safeguard and strengthenGroup’s reputation.

It is also a tool to share Prada Group’s values along thewhole Prada Group’s value chain when interacting

THE PRADA GROUP’S CODE OF ETHICS2

— 2. Sphere of application
and addresses
This Code of Ethics is addressed to all corporate
bodies, and the components of the same; to thedirectors, officers, and employees of the PradaGroup (hereinafter referred to as the “Employees”);
to external collaborators, consultants, and assistantsof any kind, agents, proxies, and any other entitythat may act in the name, and on behalf of, or
provide services to, the Prada Group (hereinafter
the “Business Partners”, and together with the“Employees”, the “Addressees”).
The Prada Group considers compliance with thelaws and regulations applicable in all the countries
in which it operates, together with correctness andtransparency in the conduct of its business, as an
essential principle of its activity. Consequently,
the Group fosters the creation of an environment
characterized by a strong sense of ethical integrity,in the conviction that this also makes a decisive
contribution to the efficacy on its policies and systems
of control.
More specifically, the managers of the companies
being part of the Prada Group are bound to takeinspiration from the principles of the Code of Ethics
in establishing their corporate objectives, in proposing
investments, and in implementing projects, as well as
in any decision, or action, whatsoever relating to the
management.
Similarly, in materially implementing the management
activities of the companies of the Group, directors
and corporate function managers must takeinspiration from the same principles, both internally– thus reinforcing cohesion and spirit of reciprocalcollaboration – and in relation to Business Partners,
with the explicit prohibition on resorting to illegitimate
favoritism, collusion, bribery, corruption, and/or thesolicitation of personal advantages for oneself or forothers.
The Prada Group ensures the maximum disseminationof this Code of Ethics, preparing any instrumentsthat may appear useful to fostering knowledge
and performing a process of awareness-raisingregarding contents, as well as constantly monitoring
the degree of observance within the Group itself,
THE PRADA GROUP’S CODE OF ETHICS

and finally taking care of the updating in linewith its organizational, commercial, and financial
developments.

— 3. Business conduct
The Prada Group conducts its business in compliancewith the principle of legality and with national andinternational laws and regulations applicable whereverit carries out its activities.

Trasparency
The Group operates transparently to makeinformation as accessible and as accurate as possible,
as it is considered key to preserve stakeholders’ trust
What we do:
We operate transparently in all our activities
and with all our counterparts.
We cooperate transparently with authorities
and institutions.
We manage relationships with customers
transparently.
We ensure transparent, clear, accurate, andcomplete communication and an equal accessto information for all the shareholders andinvestors.
We do not have relations with representativesof institutions and authorities for exercising
improper influence.

Conflict of interest
Preventing and managing any actual and potential
conflict of interest is an essential value for the Groupto ensure fair and unbiased decisions, and to support
the integrity of the organization and its Employees.
What we do:
We prevent and manage conflicts of interest.
We fight corruption.
3

We refrain from personally taking advantage
of business opportunities of which we becameaware in the performance of our functions.
We avoid situations in which actual or potential
conflicts of interest may arise and interferewith our ability to make decisions in theinterest of the Prada Group.
We train our people, and raise their awarenesson how to recognize and communicate aconflict of interest.

We do not accept any promise or giving money,
goods, or other benefits from third parties ifthey involve the violation of the duty of loyalty,or the obligations linked to the performance,
and aimed at favoring them with the PradaGroup.
We comply with the regulations in force on theprevention and fight against corruption.
We apply the “zero tolerance” principle.
We do not tolerate behaviors that facilitate
corruption.

DEFINITION
A conflict of interest may arise in any situation
where decision taken within the scope of one’s
work can generate an immediate or deferredadvantage, including a non-economic advantage,for persons of the Prada Group or any of theirfamily members or anyone else with whom they
have close personal or business relationships.
Conflict of interest may therefore be any actualor potential situation in which the secondaryinterest of a person of our Group tends tointerfere (real conflict) or could interfere in
the future (potential conflict) with the primaryinterest of the Group towards which the person
has specific duties and responsibilities.

We train our people and raise their awarenesson what corruption means, and which
behaviors/transactions are admitted and which
are not.

DEFINITION
Corruption is defined as the conduct of a person
who directly or indirectly (and therefore also
through a third party) offers, promises, receives
or gives undue benefits and/or compensations
to third parties, for a personal advantage or to
the advantage of any Group companies or third
parties, while directly or indirectly carried out
activities on behalf, or in the interest, of Group
companies.

Corruption
Corruption, in addition to being illegal, can curb
economic development, undermine legitimate
business activities, distort fair competition, destroy
any company’s reputation, and expose the PradaGroup, and its Employees, to high risks.
What we do:
We do not pay, offer or promise, whether
directly or indirectly, undue payments,
services, or favors to national and international
authorities and institutions.
We do not offer, promise or give money, goods,
advantage, or any direct or indirect benefits, toany business partners unless they are part of awider commercial framework, having balanced
and lawful obligations from each counterparty.
THE PRADA GROUP’S CODE OF ETHICS

Money laundering
Money laundering, in addition to being illegal, cancurb economic development, undermine legitimate
business activities, distort fair competition, destroy
the company’s reputation, and expose the PradaGroup and its Employees to high risk.
What we do:
We comply with all national and internationallaws and regulations on anti-money launderingand financing of terrorism.
We conduct our business in compliance withthe principle of the utmost transparency inall the commercial and financial transaction,
ensuring the traceability of the relevant
underlying operations.
4We implement appropriate controls to preventand fight money laundering.
We train our people and raise their awarenesson what money laundering means and on how
to prevent, and detect, money laundering.

DEFINITION
Money laundering is defined as the replacement
or transfer of money, goods, or other proceedsof crime, or the performance of other operations
aimed at interfering with the identification of thecriminal origin of the proceeds.

— 4. Planet
The Prada Group is committed to preserve the planet
and its ecosystems mainly reducing its footprint
through the management of the impact of all theGroup companies operations.
What we do:
We mitigate our impact on climate change.
We preserve the ecosystems.
We embrace circular thinking.

Company assets
Working diligently to protect and preserve thecompany’s assets by using, responsibly andscrupulously, the resources made available to us, andavoiding any improper use of the same, is a priority
for the Prada Group.
What we do:
We secure the integrity and protectionof company’s assets, whether tangible orintangible.
We ensure company’s assets are correctly usedin pursuit of the Group’s objectives.
We encourage a corporate culture of
responsible behavior.

We promote the adoption of raw materials witha lower environmental impact.
We train our people and raise their awarenesson our sustainability strategy and initiatives.
We collaborate with all of our business
partners to develop solutions in response
to contemporary and future environmental
challenges and to achieve our goals.
We participate in multi-stakeholder initiatives
aimed at establishing business models that
contribute to improve environment and society.
We support educational programs to raiseawareness of sustainability and environmental
protection among the youngsters.

DEFINITION
By company’s assets we mean any tangible orintangible asset open to economic evaluationthat can be owned or controlled by any companyof the Prada Group, and that can be used forthe purpose of obtaining a profit or advantage
in the future.

THE PRADA GROUP’S CODE OF ETHICS5

— 5. People
The Prada Group is committed to operating with fullrespect for the value of the individual and for thehuman and workers’ rights.

Human rights
Ensuring respect of Human Rights for workers and forthe people in general is a priority for the Prada Group.
For this reason, the Group formalized a Policy for
Human Rights that is available on its corporate website
www.pradagroup.com.

We are committed to guaranteeing the rightsof people in every activity carried out by theGroup and throughout our supply chain.

DEFINITIONBy Human Rights, we mean the universal andinalienable rights granted to everyone without
distinction of race, nationality, language, age,sex, gender, gender identity, sexual orientation,
ethnicity/culture, religion, physical conditionand disability, economic condition, political ortrade union opinion and more.

What we do:
We conduct our business in full compliancewith human rights, also considering thepotential and actual impact on human rightsof the activities performed by our business
partners.
We operate with full respect for the value ofthe individuals and for the human and workers’
rights enshrined in Italian and international
treaties and declarations, in line with theUnited Nations Universal Declaration of Human
Rights (UNGP), the International Labour
Organization (ILO), Declaration of Fundamental
Principles and Rights at Work, the Organization
for Economic Cooperation and Development(OECD) for Multinational Enterprises, and with
the United Nations 2030 Agenda and its 17
Sustainable Development Goals (SDGs).
We improve our procedures for detecting
and addressing human rights violations in our
supply chain.

Diversity, equity and inclusion
Diversity, equity and inclusion are essential values for
the Prada Group, which firmly believes in the valueof different perspectives as sources of inspiration
and, more generally, as a form to establish a bond ofaffinity with a global base of diversified stakeholders.
What we do:
We build an inclusive working environment.
We ensure equal conditions and opportunities
to all our employees.
We cultivate, recruit and retain diverse talent.
We adopt measures (training, communication,
behavioral, and operational) that contribute toenforce a culture of inclusion of all diversities,
also within our industry.
We fight any form of discrimination andharassment.

We do not tolerate any form of violation ofhuman rights.
We do not tolerate any sort of physicaland/or verbal harassment, discrimination,
intimidation, bullying, or humiliating behavior.
We fight against all forms of discrimination,
forced labour, child labour, modern slavery,and human trafficking.

6

Health and safety
Personal protection and promoting health and safety are
key priorities for the Prada Group. Furthermore, ensurethat its employees maintain a good balance between
their working lives and personal lives is a priority for theGroup.
What we do:
We adopt measures to prevent and protectfrom any negligent behavior, which could cause
direct and/or indirect damage to employees or
to our business partners.

— 6. Culture
The bond with culture is an integral part of the corporate
identity; culture enables the Prada Group to understandand interpret changes in society and stimulate new ways
to grow. The commitment to culture is the tool to extend
the benefits of the Group’s activities to civil society, witha view to shared value.
What we do:
We contribute to cultural debate.
We support cultural and scientific Institutions.

We operate in full compliance with local andinternational regulations.
We build and maintain inclusive, safe, balanced
and motivating work environments.
We train our people, also through digitalplatforms, and raise their awareness on Healthand Safety risks and preventive measures.
We support our supply chain to raise awarenesson Health and Safety matters as well.

Protection of employees’ personal data
Recognizing the value of our employees’ data, and assuch, respecting and protecting their privacy, is a key
priority for the Prada Group.
What we do:

We adopt all the specific technical andorganizational measures to ensure theprotection of employees’ personal data.
We commit to treat employees personal
data in compliance with all applicable laws,
regulations, and best practices.
We guarantee data protection, integrity andconfidentiality in accordance with what isprescribed by applicable laws and regulations,as well as in compliance with our internal
procedures.

We commit to further sustainability literacy.
We foster artisanal and know-how preservation.
We support educational programs within andoutside our company.

— 7. Putting our Codeof Ethics into action
This Code of Ethics applies to every employee within
the Prada Group and it is provided to every new recruit,
everywhere in the world.
This Code of Ethics is available to all stakeholders andcan be downloaded online from the corporate website
www.pradagroup.com and intranets. Subsidiaries receiveand comply with this Code of Ethics. Representativesof non-controlled subsidiaries and joint ventures must
promote the principles and contents of the Code of
Ethics in their respective areas of competence.
The Corporate Affairs Department and Compliancefunction are committed to ensuring correct and effective
dissemination of the principles contained within thisCode of Ethics, promoting it through communication andtraining programs, in order to ensure that everyone iscorrectly informed about this Code of Ethics, and that its
contents are aligned to changes in legislation and/or inGroup companies’ choices.
The Corporate Affairs Department and Compliancefunction can be contacted directly in order to obtainclarification about the contents of this Code of Ethics.
7

Once obtained the opinion of the Board of Statutory
Auditors, and the Control and Risks Committee, thisCode and any subsequent significant amendments must
be approved by the Board of Directors of Prada S.p.A..
The other companies of the Group also receive andadopt the present Code of Ethics through resolutionof their competent corporate bodies. Any additional
specific conduct rules deriving from local practices,
laws or regulations, may be included in specific conduct
codes to be locally adopted in addition to the present
Code of Ethics.
The Code of Ethics does not replace current and future
corporate procedures, which continue to have effect tothe extent that the same are not in conflict with the Codeof Ethics.

— 8. Monitoring
application of thecode of ethics andwhistleblowing system
A Whistleblowing system is in place at Group level, withthe aim of managing properly, and verifying timely, any
illegal and disrespectful conduct, reported by employees
or external parties, in breach of the Code of Ethics,
internal rules, regulations and procedures. The PradaGroup adopted a web platform managed by a specialized
third party, available in several languages, that ensures
full compliance with international privacy regulation,and makes possible for the whistleblower to choose
anonymity. Other reporting channels such as, but notlimited to, ordinary mail or e-mail are available on theGroup’s corporate website and intranet.
The management of reports from Employees, suppliers,
clients, and counterparties of all the Group Companies
is entrusted to the Ethics Committee of Prada S.p.A.,
which is responsible to conduct investigations,
supported by the Internal Audit Department, and takes
immediate and appropriate actions when necessary. The
composition of the Ethics Committee is available on theGroup’s corporate website and intranet.
The Ethics Committee guarantees strict confidentiality
in handling any case received. The strict confidentiality
attached to the identity of the whistleblower, and theinformation passed on, including the identity of theperson at whom the whistleblower’s report aimed,
and the prohibition against taking any reprisals against
the whistleblowers, are aimed at guaranteeing theirprotection. Anyone taking reprisals will be subject todisciplinary penalties. This means that, even if the facts
are not proven, a whistleblower acting in good faith will
not have any cause for concern, and will be protected if
subject to intimidation.

— 9. Violations
and sanctionary
consequences
Measures considered opportune will be adopted inrelation to the perpetrators of unlawful conduct,
independently of eventual criminal proceedings taken up
by the judiciary, and shall proceed to communicate to
the competent corporate functions the penalty measures
imposed.
Compliance with the provisions of the present Codeof Ethics must be considered as an essential part ofthe contractual obligations assumed by any Employee.
Any infringement of the provisions of the Code of
Ethics constitutes breach of the obligations of the work
contract and/or a disciplinary offence, in compliancewith applicable local laws and regulations and, inparticular for Italian companies, in accordance with theprocedures laid down by art. 7 of the Workers’ Statuteand the applicable collective bargaining, with all thelegal consequences (including possible dismissal), also in
relation to the maintenance of the working relationship,and may entail the compensation for damages derivingfrom the same.
Compliance with the provisions of the present Code of
Ethics constitutes part of the contractual obligations
undertaken by collaborators, by consultants and byother entities in business relations with the companies of
the Group. The eventual infringement of the provisions
contained in the same can constitute breach of thecontractual obligations undertaken, with all the legal
consequences as regards the termination of the contract
or appointment assigned and the compensation of thederiving damages.

Approved by the Board of Directors of
Prada S.p.A. on July 28, 20228