Codeof Conduct

Codeof Conduct

March 2024

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Contents
A Message from the Chairman.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Executive Committee Commitment .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7Group Values .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Governance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Application and dissemination of the Code of Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Alert System.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
A committed group .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Respecting fundamental rights.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Protecting the environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Promoting a responsible approach among partners and suppliers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
A responsible employer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Promoting a kind, inclusive working environment .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Ensuring quality of life at work. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Ensuring health and safety.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
A group with integrity .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
Fighting corruption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
Preventing conflicts of interest.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Fighting money laundering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Complying with international sanctions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
Promoting free and undistorted competition .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
Maintaining confidentiality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
Protecting the integrity of the financial markets and preventing insider trading .. . . . . . . . . . . . . . . . . . . . 31
Respecting privacy .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
Participating responsibly in the public sphere. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

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A Message from the Chairman
A company’s real successes are those that stand the test of time and help build a sustainable
society.
At LVMH and in our Maisons, this longstanding conviction is embodied daily in our products,
commitments, and actions.
We owe our success to our products, which have worldwide appeal. Their desirability stems
from our demand for the highest quality, which our artisans deliver thanks to their exceptionalsavoir faire. It also stems from our Maisons’ constantly renewed creativity, their innovative
spirit, and their openness to the world. Each Maison is working to make our prestigious
heritage sustainable.
We have also long distinguished ourselves by making strong commitments to and taking
care to comply with the highest standards of ethics and integrity, social responsibility, andrespect for the environment everywhere in the world.
This Code of Conduct has been completely rewritten to express these commitments in theform of principles and rules to guide our daily activities.
It includes and details all the sustainability factors.
While the principles and rules set out in this Code are intended to be as complete and precise as possible, this Code also refers to other instruments that have been written over the
past several years. Together they form our ethics framework, which governs LVMH’s and its
employees’ activities.
It goes without saying that all LVMH employees must comply with and embody these principles.
The Ethics and Sustainable Development Committee of LVMH’s Board of Directors will
monitor compliance with these principles.
The members of the Group’s Executive Committee will promote these commitments in theirrespective areas of responsibility.
In addition, each Maison’s President and their employees must make this common ethics
framework their own and embody its principles.
That is what will guarantee our long-term success.

Bernard Arnault
LVMH Chairman and Chief Executive Officer

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Executive Committee
Commitment
Aware of the role they must play in promoting the principles set forth in this Code of Conduct,
the Executive Committee members will promote these commitments in their respective
areas of responsibility.

ANTONIO BELLONIDELPHINE ARNAULTNICOLAS BAZIREGROUP MANAGING DIRECTORCHRISTIAN DIOR COUTURE

DEVELOPMENT AND ACQUISITIONSPIETRO BECCARISTÉPHANE BIANCHIMICHAEL BURKELOUIS VUITTONWATCHES & JEWELRYFASHION GROUPCHANTAL GAEMPERLE

JEAN-JACQUES GUIONYCHRIS DE LA PUENTEHUMAN RESOURCES AND SYNERGIESFINANCE

SELECTIVE RETAILINGSTÉPHANE RINDERKNECHPHILIPPE SCHAUS

LVMH HOSPITALITY EXCELLENCE & BEAUTY

WINES & SPIRITSJÉRÔME SIBILLE

JEAN-BAPTISTE VOISIN

GENERAL ADMINISTRATION & LEGAL AFFAIRSSTRATEGYLVMH / Code of Conduct

Group Values
The LVMH group (“LVMH” or the “Group”), which has more than 75 Maisons, is the only playerthat operates in six major luxury sectors: Wines & Spirits, Fashion & Leather Goods, Perfumes& Cosmetics, Watches & Jewelry, Selective Retailing, and Other Activities.
The Group owes its success and longevity to the values and principles on which its cultureis based and which inspire and guide everyone’s actions.

Be creative and innovative

Creativity and innovation are part of LVMH’s DNA. They have always been key to its Maisons’
success and the basis for their legitimacy. The Maisons are built on creativity and innovation,
which enable them to achieve a delicate balance between continually renewing their offer
and resolutely looking to the future while respecting their unique heritage.

Deliver excellence

There is no compromising on quality in our Group. The Maisons embody what is most noble
and accomplished in the world of craftsmanship, paying meticulous attention to detail andstriving for perfection, from the product to the service. It is in our pursuit of excellence that
the Group distinguishes itself.

Cultivate an entrepreneurial spirit

The Group’s agile, decentralized organization promotes efficiency and responsiveness. It
encourages individual initiative by assigning important responsibilities to everyone. The
entrepreneurial spirit promoted by the Group makes it easier to take risks and encourages
perseverance. It also requires pragmatism and an ability to motivate one’s teams while leadingthem toward ambitious goals.

Be committed to positive impact

Every action taken by the Group and its employees reflects LVMH’s commitment to ethics,
corporate social responsibility, and respect for the environment. This commitment drives the
Maisons’ performance and ensures their sustained long-term success. Firmly convinced that
truly desirable products can only come from sustainable businesses, the Group is committed
to actively contributing to a better future and to ensuring that its products and the way they
are made have a positive impact on its entire ecosystem.

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LVMH / Code of ConductGovernanceTo ensure that its strong ethics culture is as widespread as possible, LVMH has instituted agovernance structure that fits the Group’s profile, its operational realities, and its decentralized operating method.
That structure includes:• the Ethics and Sustainable Development Committee of the Board of Directors, whichmonitors respect for the individual and collective values on which the Group bases its activities, and which has the following main duties:– help the Board of Directors determine the Group’s main strategy in social, environmental and climate matters, and help develop rules of conduct to guide the behaviorof top management and employees;– monitor compliance with those rules; and– monitor the systems that are set up.
• LVMH’s Chairman & CEO and Executive Committee members, who promote theGroup’s commitments in the areas of ethics and social and environmental responsibility;• the Maisons’ Presidents, who ensure that this Code of Conduct’s principles are disseminated in their respective areas and properly applied by employees;• the Group ESG Committee, which includes the Group’s operational divisions, supports
and coordinates the implementation of the Group’s strategic ethics and social and environmental responsibility objectives. It relies on networks of expert correspondents who
actively help roll out Group initiatives in these areas and provide relevant information forthe consolidated report;• the Ethics and Compliance Department, which steers and coordinates LVMH’s ethics
and compliance approach. This department is supported by a network of correspondents
appointed by the Presidents of each Maison. Their role is to implement the Group’s ethics
standards within their organization.

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Application and disseminationof the Code of Conduct
Compliance with laws and regulations, in particular in the areas of ethics and environmental
and social responsibility, is key to the Group’s credibility and actions in these areas.
This Code of Conduct, which reflects the Group’s commitments in this regard, applies to all
Group employees. It must be distributed in all Maisons and Group entities and given to all
new employees when they arrive. It is supplemented by each Maison’s codes and policies,
which employees of the relevant Maison must refer to.
This Code of Conduct is available on the LVMH website and the Group’s intranet, and can be
downloaded in several languages.
Each manager is responsible for embodying the Code of Conduct’s commitments and promoting them within their teams.
Each employee must personally comply with these commitments in all circumstances.
Any employee who is unsure of what they should do in a particular situation or of how tointerpret the principles set forth in this Code is encouraged to contact their manager, their
Ethics & Compliance Correspondent, or the Group’s Ethics & Compliance Director (in particular, at ethics@lvmh.com).
If an employee does not comply with the principles set forth in this Code or any related
policies, they may be subject to disciplinary measures and sanctions proportionate to theseriousness of their actions. Such sanctions may include dismissal.

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Alert System

LVMH encourages a culture of dialogue and communication within the Group.
The Group has adopted a Group Alert Policy that describes the system for receiving andfollowing up on reports.
Any employee who is facing a situation likely to constitute a violation of applicable laws or
regulations, or of the principles set forth in this Code or in the policies of the Group or its
Maisons, is encouraged to report the situation without delay to Human Resources or totheir Ethics & Compliance Correspondent.
In addition to these channels, LVMH has set up a centralized, secure alert system that guarantees confidentiality: the “LVMH Alert Line.” This online platform can be accessed on theGroup’s website or at https://alertline.lvmh.com. It is open to all employees and external
stakeholders.
The Group maintains the integrity and confidentiality of reports at all times.
Retaliation is prohibited against anyone who uses this system in good faith or anyone who
assists a whistleblower or is connected with them, even if the reported allegations turn out
to be inaccurate.
For more information, please see the Group Alert Policy.

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A committed group

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Respecting
fundamental rights
LVMH respects human rights wherever the Group operates.
The Group believes that this is a requirement inherent in its corporate purpose, inseparablefrom the values of the Group and its Maisons and from their corollary, respect for the dignityof every individual.
LVMH expects all its employees and partners to comply with the same standards in this area.
LVMH supports the continual improvement of social, societal, and health conditions, which
are key factors in development and in the protection of persons.
For example, LVMH strives to have fair and equitable pay practices. The Group has developed
a fair wage policy (the Fair Wage Principles) based on fifteen principles that must be compliedwith by the Maisons and their partners and suppliers.
Within its sphere of influence, LVMH promotes the fundamental principles, rights and freedoms adopted by the international community, and in particular the Universal Declarationof Human Rights, the International Covenants on Civil and Political Rights and on Economic,
Social, and Culture Rights, the United Nations Guiding Principles on Business and Human
Rights, the fundamental conventions of the International Labor Organization, and the OECD’s
Guidelines for Multinational Enterprises, especially Chapter IV.
The Group is vigilant, in accordance with the law, about identifying any direct or indirect
negative societal impacts its business may have in order to prevent and, where necessary,
remedy them.
LVMH has therefore developed a vigilance plan to ensure that its business model is consistent
with respect for human rights and fundamental freedoms, personal health and safety, andthe environment.
In performing their duties, all LVMH employees must comply with and promote human rights
every day.

For more information, please see:– Supplier and Business Partner Code of Conduct;– Group Vigilance Plan (Universal Registration Document);– LVMH Social and Environmental Responsibility Report

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LVMH / Code of ConductProtecting the environment
LVMH respects the environment and complies with the ten principles of the United Nations
Global Compact and the related Sustainable Development Goals.
LVMH aims to limit negative environmental impacts and maximize positive measures in orderto help combat climate change and protect natural resources and biodiversity.
The LIFE (LVMH Initiatives for the Environment) program, which is frequently updated toreflect the direct and indirect calculation of our environmental footprint, is the operational embodiment of the Group’s responsible, forward-looking approach to protecting theenvironment. LIFE includes four strategic plans and sets precise targets to be reached bydefined dates. These targets apply to all Maisons, which are encouraged to adopt circularand creative economy methods to protect natural resources while improving their products’sustainability and intergenerational transmissibility.

Developing creative circularity

The Group uses creativity, a core LVMH value, to reduce its products’ environmental impact.
By upcycling, recycling, using fabric and leather remnants, and developing new processes,
LVMH creates inventive materials that will help change society’s representations of what isbeautiful.

Protecting biodiversity

Nature’s wealth is what makes each Maisons’ products exceptional. Protecting and regenerating ecosystems and combating hydric stress are therefore imperatives that requirelong-term multi-partner actions grounded in science.

Taking action for the climate

In accordance with the Group’s climate goals, LVMH and its Maison implement action plansthat reflect the reality of the stakes in each business sector and mobilize their stakeholders,
whether they are internal functions (purchasing, logistics, retail, studio, etc.) or external
partners and suppliers.

Guaranteeing traceability and transparency

Supply-chain traceability is a prerequisite for guaranteeing responsible practices. It requires anambitious, strict definition of the chain of custody system. LVMH has therefore adopted thedefinition of the International Social and Environmental Accreditation and Labelling Alliance(ISEAL), which is based on knowledge of “the complete set of documents and mechanisms
used to verify the traceability between the verified unit of production and the claim about
the final product.”
All LVMH employees are encouraged to take steps to save energy and respect biodiversity,and to actively participate in the Group’s awareness and training programs.

For more information, please see:
– LIFE 360 Program;– Group Vigilance Plan (Universal Registration Document);– LVMH Social and Environmental Responsibility Report.

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Promoting a responsible
approach among partners
and suppliers
LVMH strives to maintain and promote a responsible approach vis-à-vis its partners and suppliers, which are a key link in the LVMH value chain. The Group thus aims to share its valuesof excellence, innovation, and commitment.
LVMH also helps its partners and suppliers institute and comply with demanding social andenvironmental practices while raising awareness about new issues in these areas.
In particular, in its contracts with partners and suppliers, LVMH asks them to comply withthe principles set forth in the LVMH Supplier and Business Partner Code of Conduct and toensure that their own partners and suppliers do the same when doing business for the Group.

The Supplier and Business Partner Code of Conduct sets forth:• the Group’s social responsibility standards;• the environmental performance challenges set by LVMH;• the Group’s business ethics and integrity requirements;• the need for the partners and suppliers to have a grievance mechanism and the fact thatthey can access the LVMH Alert Line;  
• LVMH’s right to control its partners and suppliers and access information in their possession; and• the partners’ and suppliers’ agreement to comply with the Supplier and Business Partner
Code of Conduct’s requirements.

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LVMH / Code of ConductIf a partner or supplier does not comply with the Supplier and Business Partner Code of
Conduct, the Group entities doing business with them may demand that non-compliances
be corrected, suspend purchasing, refuse to accept deliveries or return any goods until
remedial measures are being taken, and may terminate their business relationship with any
such partner or supplier, without prejudice to any other right or recourse.
In addition, any partners or suppliers that are aware of a violation (or a risk of violation) of thisCode of Conduct, the Supplier and Business Partner Code of Conduct, and/or any applicablelaws or regulations are encouraged to make their concerns known to their LVMH Group
contact(s) or to file a report through the LVMH Alert Line.
All LVMH employees must ensure that the partners and suppliers with which they work agree
to comply with the principles set forth in the Supplier and Business Partner Code of Conduct.
.
For more information, please see the Supplier and Business Partner Code of Conduct.

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A responsible employer

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Promoting a kind,inclusive working environment
Combating all forms of discrimination

LVMH is committed to ensuring that its employees enjoy their rights without distinction
based on ethnic, national, social, or cultural origin, gender, sexual orientation, disability, age,family situation, religion, political beliefs, or union affiliation.
Equal treatment of employees is a key component of LVMH’s human resources policy of
respecting occupational and social diversity. The Group prohibits discrimination in all aspects
and stages of interpersonal relations, whether in hiring, pay, working hours, time off or paid
leave, maternity or paternity protection, job security, job assignments, evaluations, training,career prospects, and occupational health and safety.
All LVMH employees must adhere to the Group’s commitment to combat all forms of discrimination and to exhibit exemplary behavior in this regard.

Fighting harassment

LVMH is firmly opposed to all forms of intimidation, humiliation, threats, violence, and physical, sexual, verbal, or moral harassment expressed through behavior, actions, or gestures,or in writing.
All LVMH employees must treat each other and their external stakeholders with respect.

Fostering an inclusive culture

Diversity drives our creativity and success. It is a result of our commitment to foster an
inclusive culture based on respect for uniqueness, where everyone can evolve and innovatein order to contribute to our long-term success. This commitment runs through everything
the Group does and its relationships with its stakeholders: employees, partners, suppliers,
and customers.
In particular, the Group has set up programs including mentorship and active support for the
professional development of women and underrepresented groups, depending on local context.
LVMH also fosters the development of early talent through many partnerships with theacademic and non-profit sectors.

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The Group fosters the employment of seniors by providing training and adjusting working
hours and conditions, and encourages the passing on of savoir faire.
LVMH is also firmly committed to employing people with disabilities and actively supports
training, hiring, or keeping them employed through dedicated initiatives and partnerships.
All LVMH employees must embody the Group’s commitment to inclusion in their day-to-day
activities, both internally and in their relations with partners, suppliers, customers, and anyother external stakeholders.

For more information, please see:
−Recruitment Code of Conduct;−LVMH Social and Environmental Responsibility Report.

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Ensuring quality of life
at work
LVMH ensures professional development and quality of life at work throughout its employees’
careers.

Well-being at work

LVMH creates the necessary conditions for its employees to thrive in their jobs and develop
to their full potential.
LVMH encourages managers to foster collaborative, agile work methods and to mobilize
their team members’ ability to take initiative, skills, and responsibilities.
Each manager must pay particular attention to instituting an atmosphere of trust, constructive
dialogue, and recognition of each team member’s contributions.
The Group pays attention to feedback from its employees and labor partners. The LVMHHeart Fund, a solidarity fund created as a result of discussions with the Group’s employee-representation bodies, is available for all employees. It offers them free social and psychologicalsupport and, if necessary and subject to eligibility requirements, emergency financial aid.

A healthy work-life balance

LVMH respects its employees’ work-life balance, aware that this is key to their well-being
and quality of life at work.
The Group pays particular attention to the right to disconnect.
When the type of activity permits, the Group supports flexible work arrangements for
employees.

Employee development

LVMH ensures employee development by providing numerous training programs and fostering
geographical and functional mobility. The Group is especially committed to transmitting thesavoir faire and cultural heritage of craft and creative trades.
While each employee bears primary responsibility for their career, LVMH’s managers andhuman resources teams are fully committed to supporting employees’ development.
Managers must create a working environment that is respectful and fulfilling and promotes
well-being. They must foster their employees’ development, listen to their concerns, andpay attention to their work-life balance.

For more information, please see the LVMH Social and Environmental Responsibility Report.

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Ensuring healthand safety
LVMH believes that its responsibility as an employer is to provide a safe, fulfilling work environment for its employees and anyone working on a Group site or for the Group.
LVMH protects its employees’ health and safety, ensures that its business activities comply
with the health laws and regulations applicable in the countries in which it operates, andstrives to implement best practices in the area of workplace safety.
LVMH has adopted a five-part Health and Safety Charter intended to foster a “zero accident” culture:• identify the issues;• develop a dedicated action plan;• roll out and manage it;• get every employee involved; and• maintain a virtuous culture for a safe ecosystem.
LVMH protects its employees from exposure to hazardous materials or dangerous situations
while they are on the job. Employees are informed of the applicable internal regulations, which
set forth the Group’s workplace health and safety rules.
Whether in the context of health crises or as part of the social responsibility strategy, LVMH
and its Maisons have developed various permanent systems for organizing work, supporting
employees, and exchanging best practices.
LVMH has also adopted a Charter on the working relations with fashion models and theirwell-being in order to promote high standards of integrity, responsibility, and respect for
the individuals in question and to ensure that they have appropriate working conditions..
All LVMH employees must follow the Group’s health and safety approach and pay close
attention to situations that pose a health and/or safety risk.
.
For more information, please see:– Health and Safety Charter;– Charter on the working relations with fashion models and their well-being;– Group Vigilance Plan (Universal Registration Document);– LVMH Social and Environmental Responsibility Report.

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A group withintegrity

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Fighting corruption
LVMH has a “zero tolerance” policy with respect to corruption, anywhere in the world.
LVMH and its Maisons take measures to prevent, detect, and punish the commission of actsof corruption or influence peddling in the doing of business.
The Group has adopted an Anti-Corruption Charter to help employees identify the various
types of conduct that may constitute acts of corruption or influence peddling and are
therefore prohibited. For instance, particular attention must be paid to gifts and invitations.
The Anti-Corruption Charter provides practical examples to help employees develop theproper reflexes.
In addition to the Charter, training is offered to all Group employees, and especially to those
who are the most exposed to risks of corruption and influence peddling.
LVMH requires its partners and suppliers to comply with the same rules and to take appropriate
measures to prevent, detect, and punish any conduct that may be related to corruption or
influence peddling.
All LVMH employees must comply with the rules set forth in the Anti-Corruption Charterand be especially careful in this regard.
Employees working with Group business partners must make sure these partners agree tocomply with the anti-corruption rules and principles in LVMH’s Supplier and Business Partner
Code of Conduct.

For more information, please see:– Anti-Corruption Charter;– Supplier and Business Partner Code of Conduct.

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LVMH / Code of ConductPreventing conflictsof interest
A conflict of interest is a situation where a Group employee’s personal interests conflict,seem to conflict, or may conflict with those of the Group or one of its Maisons.
Such a situation must be declared and managed in order to eliminate or reduce the risks it
may pose.
It is the responsibility of each employee to show good judgement about their personal
situation when assessing potential conflicts of interest and to immediately report any suchconflicts to their manager and/or the relevant department(s) (Ethics & Compliance, Human
Resources, Legal) according to their Maison’s internal procedures.
All LVMH employees must conduct business and do their jobs with integrity and loyalty.
Employees who might have a conflict of interest must declare such potential conflict
immediately.

For more information, please see the Anti-Corruption Charter.

Fightingmoney laundering
Money laundering is concealing or disguising the origins of illegally obtained proceeds sothat they appear to have originated from legitimate sources.
The Group takes appropriate measures in every country in which it operates to prevent its
operations from being used as a vehicle for money laundering, including by limiting or providing
guidance on cash payments, and requiring employees and partners to pay close attention tomoney laundering risks.
All LVMH employees must comply with anti-money laundering rules and, in the case of sales
personnel in particular, cash payment thresholds.

For more information, please see the internal Anti-Money Laundering Policy.

27

LVMH / Code of ConductComplying withinternational sanctions
LVMH attaches particular importance to compliance with laws and regulations on internationalsanctions and export controls.
Every Group transaction, regardless of size, is carefully monitored to:• identify any direct or indirect links with countries or regions subject to international sanctions;• verify that the transaction in question does not involve an entity, organization, or person
whose name is on an international sanctions list; and• comply with any restrictions related to export controls.
All LVMH employees must be especially careful about complying with laws and regulations
applicable to the international sanctions and export control regimes.
Given the complexity of such regulations, employees must contact their Ethics & Compliance
Correspondent before entering into any transaction that has a connection to a country or
region subject to international sanctions or restrictions related to export controls.

For more information, please see the internal International Sanctions Policy.

28

LVMH / Code of Conduct

Promoting free andundistorted competition
LVMH strives to maintain free, undistorted competition in accordance with applicable law
and practice and ensure that employees comply with the competition rules that apply in eachcountry in which the Group does business.
LVMH has formalized its commitment to compliance with competition law in an internal
Competition Law Charter designed to help develop a genuine compliance culture withrespect to competition law.
That Charter sets forth the main rules that employees must follow in their day-to-day commercial relations, as well as practical illustrations of the standards they are expected to meet.
LVMH will not under any circumstances tolerate abuse of economic dependence, illicit
exchanges of information, cartels or illicit collusion through agreements, plans, arrangements, or concerted conduct among competitors, concerning prices, territories, market
shares, customers, etc.
In particular, LVMH strives to prevent abuse of a dominant position.
All LVMH employees must comply scrupulously with competition law. All relationships withGroup competitors must be closely scrutinized and all employees must refrain from taking
any action that might distort competition.
.
For more information, please see the internal Competition Law Charter.

29

LVMH / Code of Conduct

Maintaining
confidentiality
LVMH employees must protect the confidentiality and integrity of internal information thathas not been made public.
This information may include financial data or information relating to strategy, employees,
customers, collections and product launches, potential acquisitions, or commercial activities
that give us a competitive edge.
In general, confidentiality is key to maintaining trust both within the Group and in relationships
with our partners and customers. LVMH protects all external confidential information provided to the Group, using such information only for the authorized purposes and taking all
appropriate precautions.
In particular, LVMH expects employees not to disclose internal information using means ofcommunication that unauthorized individuals may have access to, or in places where they
may be overheard.
LVMH also expects employees, in accordance with the Social Media User Guide, to be very
careful about expressing their opinions on the Internet, and in particular to be sure to indicatethat any opinions they express are their own, to show restraint, to respect others, and notdisclose confidential information or trade secrets.
In particular, the use of computerized means of communication must comply with the rules
and principles set forth in the Maisons’ cybersecurity charters.
All LVMH employees must refrain from directly or indirectly disclosing any internal or external confidential information that may have been made known to them to anyone external
to the Group or to LVMH employees whose jobs do not require them to have knowledge ofsuch information.

For more information, please see the internal Social Media User Guide.

30

LVMH / Code of ConductProtecting the integrityof the financial markets andpreventing insider trading
Financial-market integrity is key to a functioning economy.
LVMH is committed to protecting the integrity of the markets and to complying with therules designed to prevent market abuse. In particular, LVMH will not give the market false
information or take any action to cause the price of a financial instrument to change on
false premises.
Because LVMH shares are traded on financial markets, it is subject to legal obligations withrespect to inside information.
“Inside information” is precise information that has not been made public and that directly or
indirectly concerns one or more issuers, or one or more financial instruments issued by one
or more issuers, and that, if made public, might noticeably influence the price of the financial instruments in question or the price of derivative financial instruments related to them.
Anyone in possession of such information must refrain from directly or indirectly buying or
selling the shares (or related financial instruments) of the issuer in question, or from doing
so through an intermediary, for so long as such information has not been made public. They
also have a heightened non-disclosure obligation.
The Group has procedures for determining whether information is inside information or not;deciding whether or not to delay making the information public; and, if public disclosure isdelayed, taking the necessary steps and identifying who qualifies as an insider for each pieceof inside information.
Employees in possession of inside information must comply with the regulations designed toprevent insider training. In particular, they must not engage in stock market trading involving
the financial instrument(s) in question and must not disclose the information in question.

31

LVMH / Code of Conduct

Respecting privacy
LVMH attaches great importance to the privacy of its customers and employees (“data subjects”) and takes the utmost care to protect it, and in particular to protect their personal data.
LVMH is therefore committed to the six major principles set forth in its Privacy Charter. Thisis essential to guarantee the minimum protection of data subjects’ rights when their data arecollected, processed, or transferred, regardless of the transfer destination.
Each Maison or Group entity, wherever it may be, must therefore comply with these six major
principles and the laws and regulations governing the protection of privacy and personal data.
In particular, they must each ensure that:• all personal data processing is lawful and does not infringe the data subject’s other rights
or human dignity (“lawfulness principle”);• the personal data are adequate, relevant, and strictly limited to what is necessary in relation to the purposes for which they are processed (“necessity principle”);• the personal data are used only for the purposes for which they were collected, in a manner that protects the data subject’s privacy and intimacy (“proportionality principle”);• any risks that may be posed during the personal data’s life cycle are identified, assessed,and documented so that measures may be taken to prevent such risks from being realized
and to protect the confidentiality, integrity, and availability of such data (“security principle”);• data subjects are informed of how their personal data is processed (“transparency principle”);• data subjects are able to exercise their rights over their personal data (“principle of respecting data subjects’ rights”).
All LVMH employees, whatever their job, must pay close attention to respecting privacy
and the personal data collected and processed in connection with their daily activity. Each
employee must make sure that each principle set forth in the Privacy Charter is complied with.

For more information, please see the internal Privacy Charter.

32

LVMH / Code of Conduct

Participating responsiblyin the public sphere
LVMH takes part in public policy discussions in a spirit of constructive dialogue and cooperation with the stakeholders concerned, including but not only political leaders.
Compliance with laws and regulations is a prerequisite for the Group’s credibility when it
participates in public debate.
In addition, integrity, transparency, and honesty are the key principles of the Group’s participation in the public sphere.
In particular, LVMH attaches great importance to the reliability of the information provided
to its discussion partners and is registered as an “interest representative” (lobbyist) whereits business so requires. The Group’s external providers must comply with the same rules.
The Group also respects its employees’ right to participate in political or union activities
as private individuals. However, employees undertake to ensure that their activities in theprivate sphere do not involve or compromise the performance of their duties or damage theGroup’s reputation.
LVMH prohibits the payment of money to political parties or political or union organizations.
LVMH prohibits the remuneration and recruitment, whether permanent or temporary, of any
member of a national or European parliament, for the duration of their elective mandate.
All LVMH employees who represent LVMH or a Maison in the public sphere must act withintegrity, transparency, and accuracy.

For more information, please see the internal Responsible Lobbying Charter.

33

Anti-Corruption
Charter

Anti-Corruption
CharterMarch 2024

LVMH / Anti-Corruption Charter

Contents

Preface.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
1. Application of the Anti-Corruption Charter. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1.1. To whom does this Charter apply?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1.2. What should I do in a questionable situation?.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
1.3. What are the sanctions for noncompliance with this Charter?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2. Ethics and Compliance Governance.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.1. At Group level. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.1.1. The Ethics and Sustainable Development Committee of LVMH’s Board of
Directors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.1.2. LVMH’s Chairman & CEO and Executive Committee. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.1.3. Group Ethics and Compliance Director.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.1.4. ​Ethics and Compliance Correspondents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.2. At Maison level . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
3. ​Preventing corruption in the Group.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.1. Corruption and influence peddling: what are they?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3.2. How to recognize and manage certain situations that pose risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3.2.1. ​Gifts and Invitations.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
3.2.2. ​Conflicts of interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
3.2.3. ​Recruitment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.2.4. ​Facilitation payments.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
3.2.5. ​Relations with agents and intermediaries.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
3.2.6. ​Donations, patronage, and sponsorship.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
3.2.7. ​Lobbying. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Appendix - LVMH anti-corruption compliance program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

2

LVMH / Anti-Corruption Charter

3

PrefacePreventing corruption is part of the LVMH Group’s approach to ethics as described in its
Code of Conduct, which contains the rules and principles that all employees must follow
when performing their duties.
Supplementing that Code of conduct, this Anti-Corruption Charter contains a set of rulesof conduct common to all Group employees and thus constitutes the framework of rules
for preventing corruption.
The Charter is designed to be practical. Based on the Maisons’ corruption and influencepeddling risk maps, it gives concrete examples to describe and illustrate the various typesof conduct to avoid and provides guidance on the reflexes employees should develop.
It also explains the Group’s system of governance, which is designed to transmit a strong
ethics culture and enforce a robust anti-corruption compliance program.
It is the business of every Group employee to prevent corruption, regardless of which Maisonor entity they work for, what their position or scope of responsibility is, or the country inwhich they work.
Because our behavior reflects our commitment to integrity, it must be exemplary.  
I am counting on the commitment of each and every one of you.

Jérôme Sibille
General Administration & Legal Affairs Director
LVMH Executive Committee Member

LVMH / Anti-Corruption Charter

1. Application of the Anti-Corruption Charter
The Anti-Corruption Charter (hereinafter the “Charter” or “Anti-Corruption Charter”)
adopted by the LVMH group (hereinafter “LVMH” or the “Group”) sets forth a common setof rules on preventing corruption (in the sense of bribery) and influence peddling that apply
to all Group employees.

1.1. To whom does this Charter apply?
This Charter applies to all Group employees, everywhere in the world.1  
They are all active participants in preventing corruption. LVMH and its Maisons count on
every employee to watch out for situations that might arise in their daily activities that
could expose them, their Maison, or the Group to a risk of corruption and to manage thosesituations as well as possible.
Managers play a key role in implementing this Charter. Their behavior must be exemplary
and they must communicate its values and the stakes in play to their teams.
The Charter must be distributed in all the Maisons and Group entities. It (or a Maison-specificanti-corruption charter or code) must be given to all new employees during onboarding.
It is available on the LVMH website and the Group’s intranet, and can be downloaded inseveral languages.

Any employees who have questions about the application of the Charter’s rules should contact
their Maison’s Ethics & Compliance Correspondent or the Group’s Ethics & ComplianceDirector (including at  ethics@lvmh.com).

1

Some Maisons have developed their own anti-corruption charter or code which may, in some circumstances,prevail over the Group's Anti-Corruption Charter.

4

LVMH / Anti-Corruption Charter

1.2. What should I do in a questionablesituation?
LVMH encourages a culture of dialogue and communication within the Group.  
The Group has adopted a Group Alert Policy that describes the system for receiving andfollowing up on reports.
Any employee who is facing a situation likely to constitute a violation of applicable laws or
regulations, or of the principles set forth in this Anti-Corruption Charter or in the policiesof the Group or its Maisons, is encouraged to report the situation without delay to Human
Resources or to their Ethics & Compliance Correspondent.
In addition to these channels, LVMH has set up a centralized, secure alert system that guarantees confidentiality: the “LVMH Alert Line.” This online platform can be accessed on
the Group’s website or at https://alertline.lvmh.com. It is open to all employees and external
stakeholders.
The Group maintains the integrity and confidentiality of reports at all times.
Retaliation is prohibited against anyone who uses this system in good faith or anyone who
assists a whistleblower or is connected with them, even if the reported allegations turn out
to be inaccurate.
For more information, please see the Group Alert Policy.

1.3. What are the consequences for notcomplying with this Charter?
LVMH has a “zero tolerance” policy with respect to corruption and influence peddling: any
Group employee or top management who does not comply with the rules and principles set out
in this Charter may be subject to disciplinary measures proportionate to the seriousness of
their actions. Such measures may include dismissal, without prejudice to possible legal action.

5

LVMH / Anti-Corruption Charter

2. Ethics and Compliance GovernanceTo ensure that its anti-corruption compliance program is an integral part of operations
and that the rules and principles set forth in its Anti-Corruption Charter are disseminatedthroughout the Group, LVMH has adopted a governance structure that fits the risk profile,
operations, and constraints of the Group and of each Maison.

2.1. At Group level
2.1.1. The Ethics and Sustainable Development Committee of LVMH’s Board of Directors
The Ethics and Sustainable Development Committee of the Board of Directors monitors
respect for the individual and collective values on which the Group bases its activities. Its
main duties include:– helping the Board of Directors determine the Group’s main strategy in ethics, social, environmental, and climate matters and helping develop rules of conduct to guide the behaviorof top management and employees;– monitoring compliance with those rules; and  – monitoring the compliance systems, including the anti-corruption system.  
The Group's Ethics and Compliance Director regularly reports to this Committee, and inparticular on the progress of the anti-corruption compliance program.
2.1.2. LVMH’s Chairman & CEO and Executive Committee
LVMH’s Chairman & CEO and Executive Committee promote the Group’s commitments withrespect to integrity, and combating corruption in particular.  
The General Administration & Legal Affairs Director, who is a member of the Executive
Committee, supports and promotes Group-wide implementation of the compliance program,
making sure the Group has the necessary human and financial resources for this purpose..
2.1.3. Group Ethics and Compliance Director
The Group's Ethics and Compliance Director is responsible for determining the content ofand developing the Group’s anti-corruption program. In particular, they are responsible forpromoting, instituting, and updating the program’s procedures, policies, and tools. They
also manage and monitor implementation of the program throughout the Group with thehelp of a dedicated team.
The Group's Ethics and Compliance Director regularly reports to the Group’s management
bodies, and in particular on the progress of the compliance program.

6

LVMH / Anti-Corruption Charter

2.1.4. Ethics and Compliance Correspondents
The Group’s Ethics and Compliance Director relies on a network of Ethics and Compliance
Correspondents, whom they coordinate with and meet with regularly.
Each Maison’s Ethics and Compliance Correspondent is responsible for implementing theGroup’s anti-corruption compliance program, adjusting it to fit the business and operationsof their Maison. They regularly report to the Ethics and Compliance Director on the implementation of the program within their Maison.

2.2. At Maison level
2.2.1. The President and management committee of each Maison
The President and management committee of each Maison ensure that the anti-corruption
program is implemented in their respective areas of responsibility and is properly appliedby their Maison’s employees.
2.2.2. The Ethics and Compliance Committee of each Maison
The Ethics and Compliance Committee of each Maison, headed by that Maison’s President,
makes sure the compliance program is properly implemented in their Maison.
2.2.3. The Ethics and Compliance officer of each Maison
As indicated above (section 2.1.4), the Ethics and Compliance officer is responsible for implementing the Group’s anti-corruption compliance program within their Maison. They are thus
the “Ethics and Compliance Correspondent” of the Group’s Ethics and Compliance Director.
They regularly report to their Maison’s management bodies, in particular during meetingsof their Maison’s Ethics and Compliance Committee, on the implementation of the program
within their Maison and the effectiveness of the related measures.

7

LVMH / Anti-Corruption Charter

8

3. Preventing corruption in the Group
3.1. Corruption and influence peddling:
what are they?
Corruption (in the sense of bribery) and influence peddling are criminal offenses punishable
under several laws that apply to LVMH, some of which apply extraterritorially and all ofwhich are becoming increasingly harsh: French Penal Code provisions, the United States
Foreign Corrupt Practices Act, the UK Bribery Act, Chinese criminal law provisions, andItalian legislative decree 231.
To prevent, identify, and control the risk of corruption and influence peddling, LVMH has
instituted an anti-corruption compliance program (see the appendix to this Charter) as
required by the French law of December 9, 2016, called “Sapin 2.”
What is corruption?
Active corruption is committed when a bribegiver gives or agrees to give (directly or indirectly) an advantage to another person (thebribe taker) so that this person will carry out
or refrain from carrying out their duties forthe bribe giver's benefit.

Passive corruption is committed when abribe taker solicits or accepts an advantage
given (directly or indirectly) by a bribe giver.
In exchange, the bribe taker carries out or
refrains from carrying out their duties in orderto further the bribe giver's interests.

Public and private corruption
Corruption is “public” when the bribe taker is a public official,2 and “private” when the bribetaker is a private individual.
Both public and private corruption are strictly prohibited.

Private corruption

Public corruption

advantageadvantage

Bribe giver

Bribe taker(private individual)

favorable action

2

Bribe giver

Bribe taker(public official: elected official,civil servant, customs officer, etc.)

favorable action

A public official is (i) anyone, whether appointed or elected, who carries out public service duties or holds political, judicial, or administrative office; (ii) anyone employed by a public administration, agency, or authority(including a public international organization or a local government), a political party, or a state-owned orstate-controlled entity or business, or (iii) any candidate for a public position or public office. This includes
civil servants, prefects, parliamentarians, local elected officials, judges/magistrates, prosecutors, political party
representatives, ministerial advisers, etc. They may be national, foreign, European, or international public
officials.

LVMH / Anti-Corruption Charter

9

The different forms of corruption
Corruption comes in several forms.
It may involve money:– payment of bribes or kickbacks,– facilitation payments,– price reduction,– charitable contributions or sponsorship,– payment of someone else’s debt,– etc.
… or take other forms:– gifts, travel, or invitations in violation of the Group’s policies,– a job or promise to hire someone,– performance of work for free,– preferential treatment in a call for tenders,– disclosure of confidential information,– etc.
What is influence peddling?
Influence peddling requires the involvement of an intermediary (a private individual or apublic official) who uses (or claims to use) their influence to help someone obtain a favorable
decision from a public authority or administration.
Active influence peddling is when someone(the beneficiary) gives (directly or indirectly)
an advantage to an intermediary so theintermediary will use their influence (real or
alleged) with an authority or administration
to obtain a decision in favor of the beneficiary(permit, authorization, employment, etc.).

Passive influence peddling is the solicitationor acceptance by an intermediary of an advantage given (directly or indirectly) by someone(the beneficiary) so that the intermediary
will use their influence with an authority or
administration to obtain a favorable decision.

Influence peddlingadvantage

BeneficiaryIntermediaryinfluence

Authority/Administration

favorable decisionLVMH / Anti-Corruption Charter

What are the penalties?
Corruption (or bribery) and influence peddling are criminal offenses that may lead toheavy penalties not only for the Group and its Maisons, but also for the employee.
Note that attempted corruption and influence peddling, even if unsuccessful, are also
subject to criminal penalties.
Under most laws, corruption and influence peddling are punishable by:– a prison sentence,3– heavy fines,4– heavy additional penalties. 5

In addition to criminal penalties, corruption and influence peddling may have a very heavy
financial or commercial impact (end of a commercial relationship, loss of a contract, a
court order to pay damages, etc.) and damage the reputation and image of the Group andits Maisons, causing them to lose the trust of their partners, shareholders, and customers.

3

For example, up to 10 years' imprisonment in France, and up to 20 years' imprisonment in the United Statesand Italy.
4

For example, in France, a fine of up to 500,000 euros or 1 million euros for an individual, and up to 2.5 million or 5 million euros for a company, which can be increased to double the proceeds of the offence; in the UnitedStates, a fine of up to 250,000 dollars or 5 million dollars for an individual, and up to 2 million or 25 million
dollars for a company, which can be increased to double the proceeds of the offence.
5

For example: confiscation, obligation to return profits, prohibition from carrying out a commercial activity or
exercising a profession.

10

LVMH / Anti-Corruption Charter

3.2. How to recognize and manage certain
situations that pose risks
LVMH employees may encounter situations in the course of their professional activities thatpose risks of corruption or influence peddling.
Given the wide variety of situations that can arise, this Charter cannot provide exhaustive
principles and examples.
Employees must therefore use good judgment and be guided by a sense of responsibility.
In all circumstances, they must ask the following questions:
1. Am I acting in accordance with the Group's values and policies?
2. Did I consult my manager when required?
3. Will I be comfortable if my actions are made public?
If the answer to any of these questions is “no” or in the case of doubt, employees should
contact their manager, their Maison’s Ethics & Compliance Correspondent, or the Group’s
Ethics & Compliance Director at ethics@lvmh.com.

11

LVMH / Anti-Corruption Charter

12

3.2.1. Gifts and Invitations
It is common in business to offer gifts and invitations. Caution must be exercised, however,
because gifts and invitations can be used to commit corruption or influence peddling.
.
In general, any gifts or invitations, whether offered or received, must:– be reasonable in nature and value,– be offered and accepted with complete transparency,– be occasional,– not be offered during negotiations, calls for tenders, or competitive bidding,– be offered in a business context, for a legitimate commercial purpose.  
They must under no circumstances be offered with the expectation of receiving something
in exchange or put the relationship partners on unequal footing.
Gifts or invitations to public officials may be authorized only exceptionally.
All LVMH employees must comply with local laws and with the policies adopted by their
Maisons, in particular by referring to the conditions under which gifts and invitations may beoffered or received (threshold, prior approval, reporting obligation, etc.).  
They must in all cases comply with the rules set forth in this Charter.

Gifts and Invitations - Remember the Rules

Do’s

Don’ts– I refuse all gifts, invitations, and advantages that do
not satisfy the requirements of this Charter or that
may be perceived as likely to influence my decision.

– Giving gifts of money or cash equivalents (checks,
wire transfers).

– I read the policy on gifts and invitations that applies
in my Maison so that I can follow the rules (threshold,prior approval, reporting obligation, etc.).
– I ask my manager or the Ethics and Compliance
Correspondent of my Maison if I am not surewhat to do.

– Giving gifts and invitations that are contrary to
propriety or decency.
– Soliciting gifts or invitations or receiving gifts at home.
– Accepting gifts or invitations received during calls fortenders or competitive bidding, or when a contract isbeing renewed or renegotiated (such gifts or invitations
must be refused).
– Offering or accepting gifts or invitations in order toestablish a contractual relationship, obtain an order
or advantage of any kind, or pay for a service.

In relations with public officials:– As a rule, I do not offer gifts or extend invitations
to public officials or their family members, friends,
or relatives, and I refer to the policy that applies in
my Maison.
– If a public official solicits a gift or invitation, I
immediately contact my Ethics and Compliance
Correspondent.

LVMH / Anti-Corruption Charter

13

Example 1:

What should she do?

Julia works for the purchasing department.
The department decides to renew one of its
portfolio of suppliers for the coming year andinforms them of that decision. When New
Year’s wishes are being exchanged a few
weeks before the competitive bidding, Julia
receives an expensive item from a supplier
whose renewal is at stake.

The gift seems to have been given in a business
context and to symbolize a preexisting relationship between the Maison and the supplier.
But Julia must be careful because competitive
bidding has been scheduled. She cannot ignore
the fact that this gift may be intended toinfluence her so that she favors this supplierover others. She must therefore refuse andreturn the gift to the supplier, with an explanation of why she is returning it.
Note also that the gift’s value alone shouldmake Julia suspicious and consult the gifts andinvitations policy that applies in her Maison
before she accepts anything.

Example 2:

What should he do?

William, a retail development manager, isnegotiating with the owner of a luxury shopping center to obtain a strategically locatedspot for his Maison. The owner intimatesthat several of the Maison’s competitors areinterested in the same location, and implies
that she could give the Maison preference inexchange for leather goods from the Group's
Maisons.

Even though it is only implied, the owner’s
request constitutes solicitation of undue
advantages in exchange for favoring the
Maison. This is a form of corruption. William
must refuse this solicitation.

Example 3:

What should she do?

Sofia works in the Research and Development
department of a Maison. Her team is working
on a new product that incorporates components of high technological value. Sofia is
invited to lunch by someone she has met at
professional events who works for a competitor. During lunch, this person suggests thatthey would give Sofia two hard-to-get tickets
to a highly popular event if Sofia gives theminformation about the new product.

Protecting information about LVMH, theMaisons and/or their products is vital to theGroup. If Sofia breaches her duty of confidentiality, she could be subject to disciplinary
action and criminal penalties.

He must also inform his manager and the
Ethics and Compliance Correspondent of
his Maison so that they are aware of thisowner's practices.

If she agrees to the competitor’s proposal,
she would be committing an act of corruption
because she would be accepting an advantage
in exchange for violating her obligations as
an employee. She must therefore refuse theoffer and inform her manager and/or her Ethics
and Compliance Correspondent.

LVMH / Anti-Corruption Charter

14

3.2.2. Conflicts of interest
A conflict of interest is not in itself prohibited. However, any such conflict must be reported
so that the risks it may pose can be managed, because a conflict of interest may provide abasis for corruption.
A conflict of interest, whether real, apparent, or potential, is a situation in which a Group
employee’s personal interests6 conflict, seem to conflict, or potentially conflict with thoseof the Group or one of its Maisons, and may therefore compromise (or give the impressionthat it may compromise) the impartial, loyal, and objective performance of the employee’s
duties for the Group.
All employees must exercise good judgment when examining their personal situation forpotential conflicts of interest.
They must immediately report any such conflicts in writing to their managers and/or the
relevant department(s) –Ethics & Compliance, Human Resources, Legal– according to their
Maison’s internal procedures.
Top management and employees whose jobs and responsibilities expose them to a high risk ofcorruption must, as provided by their Maison, file periodic reports indicating either the lackof any conflicts of interest or situations that might cause such a conflict. This is especiallythe case for members of the LVMH Executive Committee and the Presidents of the Maisons,whose reports should be sent to the Group's Ethics and Compliance Director every year.
Conflicts of interest are resolved through discussions between the employee in question
and their manager, in liaison with the relevant departments of their Maison.
Intentional non-disclosure of a conflict of interest may result in disciplinary measures,
including dismissal.

Conflicts of interest - Rules to Remember

Do’s

Don’ts– I report my elected or judicial office or my public,
union, or nonprofit positions that may interferewith my job or position with the Group.

– Using my position with the Group for personal gain.

– I do not hold a significant financial stake (including
indirectly through a family member, friend, or relative)in any of the Group’s competitors, suppliers, orproviders.

– Obtaining favorable treatment for a third party(supplier, business partner, etc.) because of the linkor relationship between us.

– I read my Maison’s policy and immediately reportany conflicts of interest (real, apparent, or potential).
– I f I have any doubts about whether there is a potential
conflict of interest, I reach out to my manager,
Human Resources, or my Ethics and Compliance
Correspondent.

6“Personal interests” means any relationship or connection of any kind that an employee has with a third party.
That connection may be direct, indirect, past, present, or future.

LVMH / Anti-Corruption Charter

15

Example:What should she do?

Emma is a store planner responsible for renovating several stores. She receives several
bids, including one from an interior design
company managed by her sister. Emma has
doubts about this situation, given that thecompany in question has a good reputationand submitted a bid at market rate.

Emma’s personal interest (seeing the company
managed by her sister win the contract) might
conflict with the interests of her Maison (finding the best provider at the best price). She
therefore has a conflict of interest.
She must report the situation in accordancewith her Maison’s policy. Her managers may
decide to entrust the selection and negotiation process to another employee to preventthe risk that this conflict will affect her decision-making. The company may then be
selected based on objective criteria, suchas its good reputation (if confirmed) and thequality of its bid given the needs of the Maison.

LVMH / Anti-Corruption Charter

16

3.2.3. Recruitment
At LVMH, recruiting and career development practices support diversity and equal opportunity. The Group’s Recruitment Code of Conduct promotes diversity in terms of candidates’
profiles as well as the use of selection criteria based on skills.
In addition, each Maison has human resources procedures that must be followed in all instances.
Recruiting family or friends of a Group employee may lead to conflicts of interest thatmust be reported as soon as possible by the employee in question so the situation may be
managed, if necessary (for example, the employee in question may be excluded from therecruiting procedure).  
No one may be hired in exchange for favorable treatment or advantages for the Group.
Caution must be exercised when recruiting former public officials. The necessary formalities and verifications must be carried out with the competent authorities (in France forexample, the High Authority for Transparency in Public Life, which rules on whether theprivate activities under consideration are compatible with the public official’s former duties).

Recruiting - Rules to Remember

Do’s

Don’ts– I report all conflicts of interest related to a potential
recruitment as soon as they arise.

– Giving someone a position requiring little or nowork, or fictitious employment.

– If a former public official or a family member,friend, or relative of a public official is being
recruited, I carry out the necessary verifications and/or
I contact my Ethics and Compliance Correspondent.

– Deciding to hire someone or promoting or approving
their hiring in exchange for a gift or advantage.

– I make sure that all hiring is based on objective
selection criteria reflecting candidates’ skills, abilities,
and experience.
– If I have any doubts, I reach out to my manager,
Human Resources, or my Ethics and Compliance
Correspondent.

– Giving someone a promotion or raise, or making
any other favorable decision in connection with ahuman resources procedure, in exchange for a giftor advantage.

LVMH / Anti-Corruption Charter

17

Example 1:

What should he do?

Ali is a purchasing manager for a Maison. His
best friend’s sister has applied for a juniorposition that just opened up in his team. Ali
believes she has the necessary skills for the job.

Ali has a conflict of interest: because of his
personal knowledge of the candidate, theother candidates might be treated unfairly.
However, this situation must not prevent
Ali’s friend’s sister from being considered ina procedure in which her skills and abilities
will be examined.
Ali must report the situation in accordancewith the rules of his Maison, and may notparticipate in this particular hiring procedure.

Example 2:

What should she do?

Linh is conducting negotiations for her Maison,
which is entering a new market. Her local
counterparty intimates that she could agree
to the Maison’s terms if Linh were to find a
job for the counterparty’s brother in a Groupsubsidiary.

If Linh were to agree and find a job in the Groupfor the counterparty’s brother in exchange foradvantageous terms for the Group, she would
be committing bribery. She must therefore
refuse to do so and inform her manager and/or her Ethics and Compliance Correspondent
about it.  

LVMH / Anti-Corruption Charter

18

3.2.4. Facilitation payments
A facilitation payment is a payment, usually of a modest amount (often in cash), made toa public official in order to facilitate or expedite, in the ordinary course of business, theobtaining of a decision or authorization (permit, license, visa, etc.) or the accomplishmentof certain procedures or legal formalities (such as customs clearance).
Such payments are prohibited.

Facilitation Payments - Rules to Remember

Do’s

Don’ts– I refuse all undue solicitations of payment made or
implied by a public official, regardless of the amount.

– Making facilitation payments, regardless of the reason
for them, their amount, or the country in which they
are solicited, even if such payments are permitted
or tolerated locally.

– I immediately report such solicitation of payment
to my manager and/or my Ethics and Compliance
Correspondent.

– The only exception is when payment is made underduress or the failure to pay would expose the employee
to a risk of immediate physical harm. In such case,the employee must inform their manager and/or
Ethics and Compliance Correspondent as soon as
possible after making the payment.

Example:What should he do?

John appointed an intermediary to export
certain products. He receives a phone callfrom the intermediary, who tells him that acustoms agent of the country to which the
products must be delivered has blocked thecargo and is demanding payment of a small
amount of money to release it. He tells John
that this is not the first time that this has happened and that making the payment usually
solves the problem quickly.

The customs agent is demanding payment tofacilitate or expedite the customs clearanceof the products. He is therefore demandinga facilitation payment. Group employees arestrictly prohibited from making such payments,
either directly or through an intermediary,even if the amount in question is small.
John must therefore refuse to make thepayment and inform his manager and/or his
Ethics and Compliance Correspondent.

LVMH / Anti-Corruption Charter

19

3.2.5. Relations with agents and intermediaries
Agents and intermediaries are third parties appointed or hired to provide representation
or assistance. Working with such third parties is not a problem in itself. However, it poses arisk because their actions may implicate the Group in the commission of acts for which theGroup may incur liability.
If any corruption or influence peddling is committed, the fact that the Group was only indirectly involved, through an agent or intermediary, does not exonerate it.
Caution must therefore be exercised both before entering into relationships with agentsand intermediaries, and for as long as such relationships last.
The Group is especially careful about making sure such third parties comply with the same
ethics and integrity standards as the Group does, in particular with respect to combating
corruption and influence peddling. Agents and intermediaries must therefore comply withthe ethics rules and principles set forth in the LVMH Supplier and Business Partner Codeof Conduct.  
Agents and intermediaries must also be evaluated in advance using the Maisons’ processes
or systems for assessing third parties’ integrity.

Agents and Intermediaries - Rules to Remember

Do’s

Before entering into a relationship:– I follow the selection procedure and apply my
Maison’s rules for assessing third parties’ integrity;

Don’ts– Obtaining assistance or help from a third party when
the purpose or effect of that party’s intervention
is, even indirectly, to exercise influence in orderto obtain an advantage for the Group unlawfully.

– I make sure that using this third party is warranted
and that the suggested pay is in exchange for realand justifiable services. If necessary, I ask my Ethics
and Compliance Correspondent for help;– I formalize the relationship in a written agreementthat includes an anti-corruption clause in which
the third party agrees not to engage in any conductthat might constitute an act of bribery or influencepeddling;– I have the third party sign the LVMH Supplier andBusiness Partner Code of Conduct;– I am even more careful if the agent’s or intermediary’s
duties would be carried out by a former public official.
I ask my Ethics and Compliance Correspondent
for advice.
During the relationship:– If a suspicion arises during the relationship, I
immediately inform my manager and/or my Ethics
and Compliance Correspondent.

For more information, please see the LVMH Supplier and Business Partner Code of Conduct.

LVMH / Anti-Corruption Charter

20

Example 1:

What should he do?

Dimitri is in charge of opening a new store.
The opening requires administrative authorization. Dimitri has been advised to hire anintermediary chosen for their close personal
relationship with a member of the local
authority responsible for granting such
authorizations.  

Using this intermediary would be basedon their close personal relationship witha member of the local authority. Theirintervention with that authority to obtain
the authorization in question would posea high risk of corruption of a public official(through bribery or influence peddling).
Dimitri must not enter into a relationshipwith this intermediary.

Example 2:

What should she do?

Sarah handles intellectual property litigation for a Maison. A case that might have asignificant impact on the Maison’s businessis being litigated in a country with a high riskof corruption. The local lawyer advises her
to use the services of a consultant who isvery familiar with how the wheels of justiceturn in that country and could use theirinfluence to obtain a favorable decisionfrom the court.

Using a consultant in this situation would
be deemed influence peddling because
the consultant would be hired to influence
a judicial decision. This type of conduct isstrictly prohibited and could result in heavy
criminal penalties for Sarah and her Maison.
She must refuse to hire this consultant.

LVMH / Anti-Corruption Charter

21

3.2.6. Donations, patronage, and sponsorship
By making donations and acting as a patron or sponsor, the Group expresses its values ofsolidarity and creativity and wishes to spread heritage, art, fashion, and artistic education
throughout the world.
All donations, patronage, and sponsorships must be part of the strategy of the Maison inquestion and must always comply with applicable laws and regulations.
A donation is the transmission of an asset or money to a third party, without receiving
anything in exchange.
Patronage consists of making a donation, in cash or in kind, to a public interest organization
so that it can conduct its activities, with no expectation of anything in return.
Patronage is thus different from sponsorship, which is the provision of financial or material
support to an event or an organization in order to benefit from the commercial impact
generated by participating in the event.
These forms of support may be diverted from their purpose and become ways of committing
corruption. They may therefore pose a risk for the Group and must therefore be closely
supervised.

Donations, Patronage, and Sponsorship- Rules to Remember

Do’s

Don’ts– I follow my Maison’s rules for assessing third
parties’ integrity concerning donation, patronage,
and sponsorship recipients.

– Using donations, patronage, or sponsorship to
unlawfully obtain any type of advantage for the Group.

– I make sure the operation is formalized in a writtenagreement.
– I verify that the project to which funds were donated
was carried out and that it complies with the agreement,
and check the conditions in which it was carried out
and how the funds were used.

Example:What should she do?

Rose is in charge of donations and patronage
for her Maison. A nonprofit organization
contacts her to obtain a large donation.
Rose replies that such a donation does not
fall within the Maison’s donation and patronage strategy. The organization’s president
insists, emphasizing that she will “thank” theGroup “properly” if Rose agrees to help her
obtain this financial support.

If Rose agrees to the president’s proposal,
such donation could constitute bribery.
She must refuse and inform her Ethics andCompliance Correspondent so that they
are aware of this organization’s practices.

LVMH / Anti-Corruption Charter

22

3.2.7. Lobbying
The Group takes part in public policy discussions in a spirit of constructive dialogue andcooperation with the stakeholders concerned, including but not only political leaders.
Although lobbying is legitimate, it can expose the Group to risks of corruption and influencepeddling, so it must be closely supervised.
When participating in the public sphere, the Group always complies with applicable laws andregulations and the rules specific to the institutions and organizations involved. In particular, the Group is registered as an “interest representative” (lobbyist) wherever its business
requires and complies with the applicable ethics obligations, in particular the obligation not
to offer or give gifts, donations, or any advantages of significant value to any public officials.
Employees who publicly represent the Group or whose jobs involve interacting with public
officials or authorities must be especially careful and make sure that these situations cannot
form the basis for acts of corruption or influence peddling. The Group’s external providers
must comply with the same rules.

Lobbying– Rules to Remember

Do’s

Don’ts– I am careful when lobbying or representing interests
to avoid situations that might be seen as ambiguous,in particular with respect to gifts and invitations, forwhich the rules are stricter when public officials are
involved (see section 3.2.1 on Gifts and Invitations).

– Giving money to political parties or to political orunion organizations.
– Giving advantages to a public leader in exchange
for a position or for the leader acting or expressing
themselves in favor of LVMH.
– Paying or hiring a member of a parliament (national
or European), whether permanently or temporarily,during such person’s term of office.

For more information, please see the internal Responsible Lobbying Charter.

Example:Can he give such a gift?

A draft directive that would deprive theGroup of some of its business is currently
being reviewed by the European Parliament.
José works in the Group’s Corporate Affairs
Department. He knows a member of parliament who is going to vote on the draft
directive. He would like to invite him to amajor sports event, with hotel and transportation included.

This invitation may constitute an act of corruption designed to influence the memberof parliament in connection with the draft
directive. Given the circumstances, José
must not extend this invitation.

LVMH / Anti-Corruption Charter

Appendix - LVMH anti-corruption
compliance program
LVMH has developed a rigorous program for preventing and detecting breaches of applicableanti-corruption laws.

1. Anti-corruption standards
The rules and principles governing LVMH’s anti-corruption compliance activities are set forthin its Code of Conduct, its Supplier and Business Partner Code of Conduct, and its AntiCorruption Charter. These documents are supplemented by the Group’s internal policies
and procedures and those specific to each Maison.
1.1. LVMH Code of Conduct
The principles set out in the Code of Conduct form the ethics framework governing all theactivities of LVMH and its employees.
The Code applies throughout the Group and has been made public. It expresses the Group’s
values — creativity and innovation, excellence, entrepreneurial spirit, and commitment topositive impact — which underlie its culture and inspire and guide the actions of everyone
who works for the Group.
The management bodies of the Group and each Maison fully support this Code and all
employees must comply with it.
1.2. LVMH Supplier and Business Partner Code of Conduct
The Supplier and Business Partner Code of Conduct sets forth the commitments LVMH
requires its partners to make with respect to its social, environmental, ethics, and businessintegrity standards (in particular, the measures for preventing and combating corruption).
This Code gives LVMH the right to verify compliance with these principles. In the event ofa breach of the Code, LVMH or the Maison concerned may suspend temporarily or terminate the commercial relationship with the partner, in accordance with applicable law anddepending on how serious the breach is.
1.3. LVMH Anti-Corruption Charter
The Anti-Corruption Charter contains a set of rules of conduct that all Group employees
must follow and constitutes a common framework of rules for preventing corruption. It gives
guidance on what to do and what not to do to prevent risks of corruption.
The Charter also sets out LVMH’s “zero tolerance” policy with respect to corruption andinfluence peddling.
1.4. The anti-corruption policies and procedures of the Group and the Maisons
The internal policies and procedures developed by the Group or specific to the Maisons set
forth the rules and principles governing each topic covered by the anti-corruption compliance program and explain how to apply them, taking into account any aspects specificto the business context and locations of the Maisons.

23

LVMH / Anti-Corruption Charter2. Corruption risk mapping
Through corruption risk mapping, the Maisons identify, analyze, and rank the risks of corruption and influence peddling inherent in their business activities and processes.
The aim is for each Maison’s risk map to include all of that Maison’s activities and processes,
as well as the geographical areas in which it operates, so that it provides an understandingof the risks the Group is exposed to as a result of the Maison’s activities and establishments.
An action plan must therefore be developed in order to gradually cover all the risks thateach Maison is exposed to.
These risk maps and the resulting action plans are presented to the top management of the
Maisons and the Group, which are regularly informed of the progress on the action plans.
Every year the Maisons review the need to update their maps, and new risk mapping isundertaken regularly in any event.

3. System for assessing the integrity of third parties
To prevent corruption, the risk posed to the Group by entering into or continuing a relationship with a third party must be assessed.
Each Maison must therefore institute a system, based on its corruption risk map, for evaluating the integrity of the third parties it works with.
To manage the risk of corruption, such evaluation of third-party integrity:− must make it possible to know the third parties under consideration better and assess therisks posed by the potential relationship;− must be of appropriate scope and detail given the type and level of the risks that havebeen identified;− must be conducted before the relationship is entered into;− can make it possible to take appropriate mitigating and monitoring measures to prevent
identified risks;− must be documented, and the documents must be retained in accordance with applicable law.

4. Awareness program and training activities
The Group conducts training and awareness-raising initiatives so that its employees fully
understand the Code of Conduct, the Anti-Corruption Charter, and in general, the corruption prevention program.
Training programs are developed based on the corruption risk maps of the Maisons andreassert the rules and principles set out in the Anti-Corruption Charter.
Employees exposed to a greater risk of corruption due to their jobs and/or the geographicalarea in which they work receive specific enhanced training.

24

LVMH / Anti-Corruption Charter

5. A global alert system
LVMH promotes a culture of dialogue and communication.
The Group has adopted an Alert Policy that describes the system for collecting and processing reports.
Any employee who is facing a situation likely to constitute a violation of applicable laws or
regulations, or of the principles set forth in this Code or in the policies of the Group or its
Maisons, is encouraged to report the situation without delay to Human Resources or to their
Ethics & Compliance Correspondent.
In addition to these channels, LVMH has set up a centralized, secure alert system that guarantees confidentiality: the “LVMH Alert Line.” This online platform can be accessed on
the Group’s website or at https://alertline.lvmh.com. It is open to all employees and external
stakeholders.
The Group maintains the integrity and confidentiality of reports at all times.
Retaliation is prohibited against anyone who uses this system in good faith or anyone who
assists a whistleblower or is connected with them, even if the reported allegations turn out
to be inaccurate.

6. Anti-corruption accounting controls
LVMH and its Maisons must maintain a system of internal control and keep accurate, detailed
accounts and records to ensure that the funds and other assets of the Group and the Maisons
are used in good faith and in accordance with applicable laws and regulations and Group
policies and procedures.
Each Maison must formalize anti-corruption accounting procedures and controls that are
based on the risks identified in the Maisons’ risk maps and designed to ensure that theaccounts and records are not used to cover up or serve as vectors of corruption.

7. Auditing and assessing the anti-corruption system
LVMH regularly audits the implementation of the anti-corruption compliance program
throughout its organization. These audits are formalized and documented, and include
three levels of control. Each Maison must have an audit program that covers the entireanti-corruption system.
First-level controls are usually implemented at the operations level.
Through its Enterprise Risk and Internal Control Assessment, the Group’s Internal Control
Department contributes to the second-level control and helps assess the effectiveness of
the Group’s anti-corruption compliance program by examining ten issues specific to anti-corruption. The Group’s Ethics and Compliance Department also helps with the second-level
control of the anti-corruption compliance program.
Lastly, the Group’s Internal Audit Department carries out third-level audits, which are dedicated to the anti-corruption compliance program in each of the Group’s Maisons.

25

LVMH / Anti-Corruption Charter

8. Disciplinary measures
It is of great importance to the Group that its employees act with exemplary integrity inall circumstances.
Employees who do not comply with the Group’s rules, and in particular the rules set out in
the Anti-Corruption Charter, may be subject to disciplinary measures, including dismissal.

26