ZEGNA RESPONSIBILITYPage 1 of 13

INDEXZEGNA RESPONSIBILITY .................................................................................................. 3
HR POLICIES ........................................................................................................................ 5
SUPPLIERS CODE OF CONDUCT .................................................................................... 7
FOREWORD ................................................................................................................................................ 7
COMPLIANCE WITH LAWS ...................................................................................................................... 7
LABOUR, ENVIRONMENTAL CUSTOM STANDARDS AND SOCIAL RESPONSIBILITIES ............ 7
BUSINESS INTEGRITY REQUIREMENTS ............................................................................................... 9
AUDIT AND INSPECTION .......................................................................................................................... 9

SUPPLIER SOCIAL AUDIT COMPLIANCE SYSTEM ................................................... 10FOREWORD .............................................................................................................................................. 10
SUPPLIER SOCIAL AUDIT COMPLIANCE ............................................................................................ 101.

SOCIAL AUDIT PLAN .......................................................................................................................... 101.1. REQUIRED SUPPLIER INFORMATION ......................................................................................... 112.

AUDIT ORGANIZATION ...................................................................................................................... 113.

FIELDWORK........................................................................................................................................... 113.1. OPENING MEETING ......................................................................................................................... 113.2. PRODUCTION SITE TOUR ............................................................................................................. 113.3. DOCUMENT CHECK ....................................................................................................................... 123.4. WORKER INTERVIEWS ................................................................................................................. 133.5. CLOSING MEETING ........................................................................................................................ 134.

AUDIT REPORT AND CORRECTIVE ACTION PLAN ................................................................... 134.1. AUDIT REPORT ................................................................................................................................. 13
4.2. CORRECTIVE ACTION PLAN ....................................................................................................... 13

5.

CONTINUOUS MONITORING ........................................................................................................... 13

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ZEGNA RESPONSIBILITY

The “culture of beauty” has always guided Zegna in its choices, based primarily upon the deep
respect for people and the environment. A value inscribed in the brand’s DNA ever since 1910 whenErmenegildo Zegna founded the company that bears his name, it attests to the belief that a quality
product can only come from within a working context of inclusion, integrity, and well-being.
These principles are now part of the heritage that the Brand shares with all those who work within
the company. The Suppliers’ Code of Conduct, on the other hand, guides Zegna’s social policy. Thereis also a constant commitment within the company to comply with laws and international
conventions on ethics, social responsibility and environmental protection. Through the HR Policies,
the Brand protects and promotes respect for human dignity, combating all types of discriminationand ensuring equal development opportunities for all employees. There is also a constantcommitment to the training and development of individual talents.
Improving the quality of life for individuals and the community, developing the potential of each
person, safeguarding culture and the environment, promoting research and good practices, insideand outside the company, have always been part of Zegna’s creed.

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HR POLICIESZegna promotes and safeguards respect for human dignity against discrimination on the basis of age,gender, sexual orientation, social and personal status, race, language, nationality, political opinions,
union membership, and religious beliefs (Code of Ethics).
Zegna has always acted with complete respect to the law, regulations, and current legislation in eachof the countries where it is present. For each region, it has adopted internal policies and procedures
aimed at valuing the contribution of every single employee and guaranteeing equal opportunities forall. To do so Zegna ensures the following:-Employees enter their annual leave plan into the HR tracking systems-Employees receive and are required to be aware of the Code of Ethics of the Group-Job contracts are always provided in the local language and are signed by both the employer
and the employee-

Specific Health and Safety training are performed recurrently for manufacturing workers
where the plants are located. There are compulsory emergency exits and fire drill tests
completed regularly in all the markets where the Brand operates.

-Working hours and breaks are usually mentioned in contracts and for most of the countries
follow the local law.

Zegna is deeply committed to the training, development and retention of their employees and talents,
and the enhancement of their capabilities and competencies.
Zegna creates the conditions for working in a climate of harmony and cooperation, with particularattention to fostering a positive work-life balance.
Zegna adopts market-led remuneration policies thanks to an efficient exchange of information
between the head office and local markets, and the use of sector specialists who provide us withstate-of-the-art statistics and benchmarks, with the aim of attracting and retaining the most highperforming and professional people.
Zegna remuneration policies, tailored to each specific role, guarantee a suitable balance of fixedsalary and medium/long-term incentive plans, ensuring equity in everyone’s compensation package.
All of the direct, indirect and deferred aspects of the remuneration packages and the benefits applied
according to specific company policies are subject to local pension and tax laws.
Zegna respects all local labour laws and legislation with regards to employment contracts andemployees’ rights. Working hours, breaks, the use of holidays and days off, paid and unpaid leave andnotice periods are applied in line with local employment laws. In many countries, entitlements tomaternity and paternity leave are integrated with Zegna Group policies with additional benefits.
Zegna provides local welfare packages in order to best meet the needs of our employees. The
services offered include, for example: medical campaigns, campuses for children, company canteens,crèches, etc.

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Zegna manages industrial relations with complete respect to current laws and regulations and iscommitted to working with unions, where they are present, to improve working conditions foremployees.
Zegna Group respects all local labour laws and legislation with regard to employment contracts andemployees’ rights. Working hours, breaks, the use of holidays and days off, paid and unpaid leave,and notice periods are applied in line with local employment laws. In many countries, entitlements tomaternity and paternity leave are integrated with Zegna Group policies with additional benefits forparents in terms of longer leave periods, gifts, etc.
Zegna Group provides local welfare packages to best meet the needs of our employees. The services
offered include, for example, medical campaigns, campuses for children, company canteens,crèches, etc.
Zegna Group manages industrial relations with complete respect to current laws and regulations andis committed to working with unions, where they are present, to improve working conditions foremployees.

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SUPPLIERS CODE OF CONDUCTFOREWORDThe Code of Conduct is an important pillar of Ermenegildo Zegna‘s social policy. This means that weare committed to observing and complying with all regulations and national and international
conventions, with regards to ethics, social responsibility, and protection of the environment.
This Code of Conduct shall apply to all employees in the production facilities of all external suppliers
and represent a set of minimum standards to be respected.

COMPLIANCE WITH LAWS
When national law or other applicable regulations address the same issue as this Supplier Code ofConduct, the highest standards or most restricting provisions must be applied. In case this Supplier
Code of Conduct conflicts with applicable law, the applicable law must be applied.
Our suppliers remain guarantors, regarding the working activities performed by their authorized
subcontractors and suppliers and must grant the compliance of this Supplier Code of Conduct.

LABOUR, ENVIRONMENTAL CUSTOM STANDARDS AND SOCIALRESPONSIBILITIESWe share with our suppliers a commitment to high ethical standards in order to grant the following
principles of the Code of Conduct:✓ Workplace: A workplace that complies with laws and regulations like proper break areas forgeneral rest and dining purposes and guarantees reasonable minimum conditions of light,
ventilation, minimum space, hygienic standards and access to a free drinking water supply.
✓ Health & Safety: Suppliers shall provide a safe and healthy work environment guaranteeingthat the following health & safety requirements (among others) are in place: adequate medicalresources, fire prevention measures including fire exits, safety equipment, etc.
✓ Environment: All our suppliers must comply with the national and international environmental
rules, regulations and standards. In particular, the procedures and standards applied in thedisposal of waste, the handling and disposal of chemicals and other hazardous substances
as well as in the handling of emissions and wastewater must at least comply with theminimum statutory requirements. The supplier is required to continuously work on reducing
and avoiding environmental pollution and to ensure that he uses natural resources asefficiently as possible.
✓ Prohibition of Forced Labour: Suppliers will not use involuntary, forced or trafficked labour,will maintain employment strictly on a voluntary basis.

Page 7 of 13✓ Prohibition of Child Labour: No employment of minors. For this purpose, we consider a minor
as one who is below the minimum age mandated by the applicable law, or the age forcompleting compulsory education, whichever of the two is higher.
✓ Prohibition of illegal, clandestine and undeclared workforce: Our suppliers have to conformwith all applicable regulations in order to avoid the employment of illegal, clandestine andundeclared workforce.
✓ Treatment of Migrant Workers: The United Nations defines migrant workers as: “A person
who is engaged or has been engaged in a remunerated activity in a State of which he or she
is not a national.” Consequently, the suppliers that use migrant workers like a steady
workforce have to define a policy on migrant workers in order to ensure compliance with alllegal standards.
✓ Prohibition of Harassment, Abuse and discrimination: A workplace where there is dignity
and respect, free from any form of harassment, abuse or corporal punishment. Respect andequality, regardless of race, religion, age, sex, social origin, political views, sexual orientation,or position.
✓ Working Contract, compensation and benefits: Employees and employers must have proper
documentation related to employment on hand. This documentation could be either a working
contract or any other legally acceptable document. The wage must be respectful of basic
needs, minimum pay by category and all benefits mandated by law. Overtime compensation
policies must be in accordance with local law. All wage deductions must not be used as adisciplinary measure.
✓ Hours of Work: Hours worked each day, and days worked each week and month, should notexceed the limitations of the country’s law. Suppliers will provide at least one day off in every
seven-day period, except as required to meet urgent business needs.
✓ Freedom of Association and Collective Bargaining: Freedom of association and the right tojoin unions or other work or industry-related associations as well as the right to collective
bargaining in accordance with local law.
✓ Disciplinary Systems: Our suppliers have to define a discipline process in order to evaluatethat each employee ensures adherence to company policies and procedure and eachviolation must be grouped according to the gravity of the offense and the number of times
violation has occurred. The disciplinary measurement will not be used to punish or embarrass
an employee in order to maintain labour discipline. Deductions must be limited to thoseallowed by local law.
✓ Customs Compliance and Security: We require our suppliers to comply with applicablecustoms laws, including those relating to imports and the ban on transshipment ofmerchandise to the importing country. Facility security procedures to guard against theintroduction of non-manifested cargo into outbound shipments (e.g. drugs, explosives,biohazards, and/or other contraband) have to be put in place.

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BUSINESS INTEGRITY REQUIREMENTS
Miscellaneous integrity requirements are requested to suppliers in the conduct of their businessactivities.
✓ Anticorruption: All our suppliers must respect all applicable laws regarding corruption andimplement appropriate measures to prevent, detect and sanction any corruption, directly orindirectly, crosswise the scope of their activities.
✓ Intellectual property: All suppliers, who have been granted the use of Brands and distinctive
belonging to Ermenegildo Zegna, must guarantee the correct use and compliance with allelements defined in the business agreement.
✓ Protection of personal information: We require our suppliers to comply with all applicablelaws and regulations concerning the protection of personal information.
✓ Trade restrictions and international sanctions: All our suppliers must respect international
trade restrictions and sanctions, and regulations concerning export controls.
✓ Protection of assets: Our suppliers are required to set up all necessary measures in order toprotect our resources and assets, fight counterfeit, and guarantee adequate cooperation andcommunication flows.

AUDIT AND INSPECTION✓ Audit and access to information: We reserve the right to conduct periodic compliance audits
at our suppliers and their own suppliers and subcontractors in order to verify the level ofcompliance with respect to this Supplier Code of Conduct. During the audit activities, thesupplier must provide all information and data. The supplier auditee must define an action
plan in order to define the corrective action in order to resolve the deficiencies identified.
In the event of any violation of this Supplier Code of Conduct by the supplier or one of its suppliers orsubcontractors, Ermenegildo Zegna reserves the right to review the business relationship andpossibly terminate it in conformity with applicable law.

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SUPPLIER SOCIAL AUDIT COMPLIANCE SYSTEMFOREWORD
Zegna has a Social Compliance Program to ensure a fair working environment within the global
supply chain.
Our Social Compliance Program includes social standards, health & safety as well as environmental
standards and ensures that they are being properly implemented within its finished goods suppliers.

SUPPLIER SOCIAL AUDIT COMPLIANCE
The following scheme describes the process of the Supplier Social Audit Compliance Program:

AUDIT
PLANNING

AUDIT
ORGANISATIONFIELDWORKREPORTING AND
CORRECTIVE PLAN

CONTINUOUS
MONITORING

1. SOCIAL AUDIT PLAN
The Audit Plan is defined by Zegna Internal Audit with respect to objective parameters that allow
assigning a scoring (0 to 100) to the supplier to determine a priority audit ranking.
SCORING>6733<>66<320

PRIORITY AUDIT RANKINGHighMediumLow
Supplier not active

The parameters are:1. Supplier Status: Active or Not Active
2. Nature of Agreement
3. Number of Employees
4. Labour Rights Policies adopted
5. Anti-bribery, Corruption & Presentation of False Information
6. Health & Safety Conditions
7. Country/Countries where the Supplier operates

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8. Use of subcontractor
9. Last Social Audit received (timing): 1 year, 2 years, etc.
10. Grading of the last Social Audit received: Low, Intermediate, High or Critical
11. Grading of follow-up of the action plan agreed: closed, in progress, on delay, action plan underdefinition

1.1. REQUIRED SUPPLIER INFORMATION
Zegna Supply Chain fills and periodically updates (at least once a year) the supplier master datawith all information requested.

2. AUDIT ORGANIZATION
Social compliance audits are conducted by Zegna Internal Audit team or by a qualified third party.

3. FIELDWORKThe social audit process consists of five steps as shown in the following figure which are describedin the following paragraphs.

OPENINGMEETINGPRODUCTION
SITE TOUR

DOCUMENTCHECK

WORKER
INTERVIEWS

CLOSINGMEETINGTIMELINE 1 – 2 WORKING DAYS

3.1. OPENING MEETINGThe audit starts with an opening meeting with the auditors and the supplier management involvedin which the audit team gives an overview of the audit procedure as well as an explanation about
the Zegna Social Standards. Any open questions that might arise will be addressed and answeredto the full extent possible.

3.2. PRODUCTION SITE TOUR
During the production site tour the audit team will visit the entire factory, including, but not limited
to, all production and non-production areas, such as material storage, chemical warehouse, wastestorage, water treatment (if available), kitchen, dining rooms, clinic, dormitories, sanitaryarrangements including restrooms and shower facilities, recreational areas, etc.

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3.3. DOCUMENT CHECKOne of the major parts of the audit process is the analytical review of the supplier documentation
provided.
Documents that must be received are:•Business registration papers;•Licenses on Occupational Health & Safety and Environmental Protection;•Company policies and regulations, such as:
oAnti-Bribery, Corruption & Presentation of False Information

oSafety and environmental policies•Health & Safety Documents•Labour Rights Policies which include:
oChild Labour

oContracts & Terms of Employment (including notice period, dismissal & disciplinaryactions)oForced & Bonded Labour

oForeign & Migrant Labour

oFreedom of Association, Right to Organize & Collective BargainingoHarassment & Violence•Personal employees records archive, e.g. Employment Contract, Identity Cards;•Payroll, attendance records system;

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3.4. WORKER INTERVIEWSInterviewing the employees in the factory is the most important and sensitive part of the entire
audit. The auditor must ensure that the interviews are to be conducted in a quiet and friendly
atmosphere, without any disturbance from others.
The interviews may be done individually or within small groups, depending on the issue and on theinformation expected to be received during the interview.
Therefore, it is up to the auditor to conduct the interviews either: within the premises of the factory,
on-site; or offsite at the convenience of the employee.

3.5. CLOSING MEETINGAt the end of the audit, a closing meeting will be held to share and review in detail the summary offindings. The supplier management can discuss and comment on any findings. The summary offindings document is signed by the supplier.

4. AUDIT REPORT AND CORRECTIVE ACTION PLAN
4.1. AUDIT REPORTThe audit report summarizes all findings and included a final grade for the audit that is generated asa weighted result based on individual findings. The final grade can be: Low, Intermediate, High, andCritical.

4.2. CORRECTIVE ACTION PLAN
The Internal Audit team or by a qualified third party Zegna Internal Audit, at the end of every audit,
prepares a Corrective Action Plan (CAP) which summarizes all findings identified and discussedwith the supplier management during the closing meeting. The CAP is subsequently sent to thesupplier for the remediation phase that includes the following information that must be filled in by
the supplier:• Correction to Prevent Recurrence of Finding•

Target Completion Date (it generally cannot exceed 6 months from the receipt of the CAP).

•Responsible Staff

The supplier must send the filled document within 30 days of the receipt.

5. CONTINUOUS MONITORING
Zegna Internal Audit monitors all targets due dates defined by the supplier into the CAP.

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