CODE OF
ETHICSWe take care of everyone.
We like smiling. We look for solutions.
We help each other. We are supportive.
We build. We take responsibility.
We listen. We integrate diversity.
We enable. We empower. We promote.
We are devoted to detail with passion,commitment, and accuracy.
We include. We Learn.
We support with ethics. We measure.
We reward.

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CODE OF ETHICS
Approved by resolution of the Boardof Directors on February 4, 2022.

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3

CODE OF ETHICSINDEX
01 A journey of love
02 Introduction
03 Recipients of the Code of Ethics
04 Everyone can be a Star
05 Rules of conduct
06 Implementation and control
07 Glossary

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01

A journey of love

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Golden Goose is a journey of love that began in Venice(Italy) in 2000 inspired by the creative spirit of Francesca
Rinaldo and Alessandro Gallo: a couple of young designers,
outsiders to the fashion world.
The intention that has always driven Golden Goose
has been to stand out with an innovative, artisanalproduct, a people-centric approach, an unconventional
communications strategy, and the selective positioning inlocations that reflect the brand’s philosophy.
Golden Goose defines itself as a lifestyle brand because
its values and culture are embodied in every product it
creates, thus becoming part of people’s daily lives. Everysneaker created, every retail store opened, and every action
reflects Golden’s values: Familiality, Positivity, Respect,
Quality, and Success.
The Company strongly believes in the power ofcommunity and in making all individuals feel included andvalued for their uniqueness, regardless of identity, culture,
background, or any other diverse characteristic, much like ina close-knit family. In fact, the Company refers to its people
as the Golden Family and to customers as its community of
Brand Lovers.
Respect, trust, two-way dialogue, and a common searchfor solutions are always at the core of every Golden
relationship, both within the Company and with external
suppliers, customers, and partners. This way of relating,which is integral to Golden’s corporate culture, allows
building more authentic and longer lasting ties, capable ofcreating value for all. In fact, Golden Goose believes that
long-term success and growth depend not only on the
results achieved, but also on the way they were achieved
and on the relationships created with its stakeholders.
Golden’s mission is to give life to unique creations meant
to be experienced and loved, inspiring everyone to express
their inner star through creativity and the desire to outdo
themselves.
Everyone can be a Star.

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THE GOLDEN FOUNDING VALUESFamiliality

Positivity

Respect

We include and make everyone feel welcome in our House.
We take care of everyone.

We approach what we do with positive energy. We engage and support with
optimism and self-confidence.
We like smiling. We look for solutions. We help each other. We are supportive.
We build. We take responsibility.

We truly engage in our internal and external relationships.
We listen. We integrate diversity. We enable. We empower. We promote.

Quality

Quality is intrinsic to our people, products, network, communication,and behavior. Excellence is our obsession.
We are devoted to detail with passion, commitment, and accuracy.

Success

We encourage a culture of success and support result-oriented mindsets.
We celebrate outstanding individual and team achievements.
We include. We learn. We support with ethics. We measure. We reward.

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02

Introduction

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This Code of Ethics (hereinafter also referred to as theCode) sets out the values, principles, and rules of conductof Golden Goose (hereinafter also referred to as Goldenor the Company) that govern its business activities andits relations with stakeholders (employees, contractors,
customers, suppliers, shareholders, lenders, government
bodies, institutions, the community, the environment, andthe media), including any other individual or entity it may
interact with in the course of its operations.
Everyone who works at and for Golden Goose is required
to adhere to and enforce the principles of this Code. Underno circumstances can the belief that one is acting in theinterest or for the benefit of the Company serve as ajustification for engaging in conduct that conflicts with orcontradicts the principles outlined in this document.

The following are the ethical principles shared within
Golden:→ Act with integrity and a sense of responsibility.
→ Comply with applicable laws and regulations.
→ Respect the dignity and rights of each individual.
→ Act with respect for the natural environment.
→ Use Company assets and resources in the best interestof Golden Goose and its shareholders.
→ Encourage employees in their solidarity and sustainable

development initiatives.
Therefore, the purpose of this Code is to:→ Respect business confidentiality.
→ expressly state and clarify the principles, values, andexpected conduct to be followed within the Company
and when interacting with external stakeholders

As a general rule, anyone working for or on behalf ofGolden Goose is expected to comply with the laws andregulations of the countries in which they conduct businessand abide by the norms of the international community. In
the countries of operation where the laws in force are lessstringent, the Company requires the Recipients of this Codeto adhere to ethical standards and principles of conductthat may exceed legal requirements.

→ establish the compulsory nature of these principles,

also as a means to prevent corporate misconduct and/or crimes→ ensure that anyone engaging with Golden Goose, in any

capacity, is held accountable for compliance with theCode’s principles.
The Code of Ethics is inspired by key national andinternational regulations, guidelines, and documents on
corporate social responsibility, corporate governance,
human rights, and environmental practices, including theUnited Nations Universal Declaration of Human Rights(UDHR), the Charter of Fundamental Rights of theEuropean Union, the decent work standards outlined in
the ILO (International Labour Organization) Conventions,and the Guidelines for Multinational Enterprises of theOECD (Organisation for Economic Co-operation andDevelopment).
The Code, which is regularly updated based oninternational best practices, also incorporates the corestatements of Golden’s corporate policies, including
the Environmental Policy, the Health and Safety Policy,
and those on human resources and the management offinancial and corporate assets.

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03

Recipients of theCode of Ethics
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This Code of Ethics applies to all Golden Goose facilities(corporate offices, warehouses, production sites, and retailstores) in every country in which the Company operates andto all aspects of its business activities.
Therefore, this Code is addressed to the members of theBoard of Directors, the members of the supervisory bodies,
the managers (or any individual holding a representative,administrative, or managerial position, or exercising control
and management of the Company or any of its units, even if
in a de facto capacity), and the employees of Golden Goose,
as well as to all those who in any capacity – whether directly
or indirectly, permanently or temporarily – act in the nameor on behalf of Golden Goose, or establish a relationshipwith it, to contribute to its objectives, such as temporary
workers, contractors, subcontractors of works or services,
consultants, agents, direct and indirect suppliers, and anyother third party involved in a partnership relationship with
the Company.
All Recipients are required to be familiar with thecontents of the Code of Ethics, comply with its provisions
in their interactions with each other and with third parties,
actively contribute to the implementation of such principles,and promptly report any emerging needs to the designatedbodies responsible for its revision and update (see also
‘Implementation of the Code’).
Golden Goose is committed to ensuring the widest
possible dissemination of the Code to all Recipients and thegeneral public.

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04

Everyone canbe a Star
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04.1 PEOPLE

RECIPIENTS OF THE CODE MUST:
Golden Goose recognizes the centrality of its people increating value for the Company, and makes every effort
to safeguard their physical and moral integrity and foster
their growth and development within a safe, meritocratic,
stimulating, and inclusive work environment, where
diversity is valued and where everyone is empowered to
fully express their skills, potential, and talents.
Inclusion, participation, and sharing are the words thatbest describe Golden. Each person is encouraged to be theirtrue selves and follow their dreams.

→ Promote equal opportunities for all.
→ Ensure a workplace free from discrimination andharassment.
→ Offer fair compensation and opportunities for

professional development and growth that alignwith the competencies of each individual, avoiding
any form of bias or discrimination in the decisions
that affect them.

04.2 EQUAL OPPORTUNITIES AND
NON-DISCRIMINATION→ Act with impartiality and honesty.

Golden Goose is committed to offering equal opportunities
to its people right from the initial stages of the recruitment
process, and to ensuring that all relevant considerations
and assessments throughout the employment relationshipare based on merit and free from any form of favoritism or
discrimination, thus supporting the creation of an inclusiveand collaborative work environment.
To ensure a welcoming work environment where no one
is discriminated against or treated unfairly, Golden Goose:→ Monitor

the work environment to ensurethat personal characteristics do not lead todiscrimination.

→ Refrain from engaging in propaganda, instigation,or incitement to hatred or violence on the basis ofrace, ethnicity, nationality, religion, gender, sexual
orientation, or disability.
→ Prohibit

any form of intimidation, threat,harassment or abuse, whether physical or verbal,
that may create an intimidating, offensive, and/or hostile work environment (including sexual
harassment, offensive language or behavior, and/or insults based on race, ethnicity, nationality,
religion, gender, sexual orientation or disability).

→ upholds the principle of equal opportunity at all stagesof the employment relationship (be it recruitment,
development and training, remuneration, promotion,a disciplinary procedure, termination, or retirement),
making every effort to prevent and avoid any form of
discrimination on the basis of ethnicity, race, religion
or belief, gender, sexual orientation, disability, age,personal or political opinion, marital status, maternity
or paternity status, or any other form of diversity→ rejects all forms of violence and harassment – whether

physical, verbal, sexual, psychological or moral (mobbing),
or be it intimidation or threats – against employees,
suppliers, customers or visitors (see also ‘Human rights’).

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04.3 HEALTH AND SAFETY

RECIPIENTS OF THE CODE MUST:
Golden Goose is committed to safeguarding the healthand safety of its people, suppliers, customers, visitors,
consultants, and anyone else within its premises, bycomplying with applicable health and safety regulations in
the countries where it operates.
The Company implements every prevention andprotection measure necessary to ensure health and safety,
as well as targeted initiatives that include, but are notlimited to, providing ad hoc training on health and safety
regulations and job skills development programs focusing
on the safety of tasks; monitoring the implementation ofhealth and safety protocols and procedures; and analyzing
the root causes of accidents and incidents.
Safety is everyone’s responsibility. It is important thateveryone is called upon to comply with applicable healthand safety regulations and take appropriate preventive
measures to protect themselves and others.
Golden Goose is also committed to assessing andpreventing work-related stress and to developing initiatives
that promote and protect the health of its people, ranging
from wellness programs and prevention campaigns to theban on smoking in the workplace (except in designatedoutdoor areas).

→ Facilitate the adoption of necessary preventive

measures to safeguard one’s own safety and thatof others.
→ Report any unsafe behaviors or working conditions.
→ Use appropriate protective equipment and engage

in risk assessments, implementing improvement
plans as needed.
→ Promote a culture of prevention.
→ Ensure the regular maintenance of workplaces,

equipment, facilities, and safety and protective
devices, as well as the adoption of innovativetechnologies and systems to operate safely.
→ Avoid any form of aggression, whether physical orverbal.
→ Refrain from abusing alcoholic beverages and/or using drugs or any other substances that
may alter consciousness, hinder effective work
performance, and expose oneself and/or others topotential safety hazards.

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04.4 THE GOLDEN FAMILY
The Golden community is an extended family united by thesame principles and values, where everyone can feel welcome
and free to express themselves. Golden Goose strives tofoster motivation, support the development and growth of
its people, and ensure that their energy and creativity findfull expression in the achievement of corporate objectives.
The Company strongly encourages participation andsharing in all business decisions, and expects its people
at all levels to work together in an atmosphere of mutual
respect and active listening and to engage in the exchange
and dissemination of essential information for the creationof shared value.

In order to help its people maintain a good work-life balanceand ensure their well-being in the workplace, Golden iscommitted to fostering a supportive, caring, and productive
work environment. To this end, the Company implements
several policies and mechanisms based on local needs thatfacilitate its people’s daily lives while enhancing the quality of
their work life, such as remote work, flexible hours, parental
leave, concierge services, and corporate volunteering.

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04.5 CUSTOMERSRECIPIENTS OF THE CODE MUST:
Golden Goose recognizes that customer relationships
are key to building long-term success. Every moment ofinteraction presents an opportunity not only to welcome
and get to know them, but also to engage, share a story, andco-create with them.
The Company believes it is essential that its customers
are always treated with honesty, fairness, transparency,
and impartiality, going above and beyond to meet their
expectations to the fullest.

→ Ensure that products meet market expectations

and requirements, including but not limited thoserelated to the safety of materials and of thechemicals used to process them.
→ Ensure high standards of product and service

quality.
→ Provide accurate, comprehensive, and truthful

information about products and services, enablingcustomers to make informed purchasing decisions.
→ Pay utmost attention to customer suggestions

and/or complaints.
→ Fulfill all commitments and obligations undertaken.
→ Protect the personal data provided by customers

in accordance with applicable laws, ensuring theirprivacy and confidentiality.
→ Conduct themselves in a manner that conveys

openness, respect, courtesy, and the highest levelof professionalism.
→ Avoid any form of discrimination in dealings withcustomers.
→ Denounce

the use of advertising and/or
communication tools that may in any way mislead
customers regarding the quantity, quality, origin,and source of the products/services offered.

→ Ensure that communication is not offensive tohuman dignity, discriminatory, or suggestive ofviolence or dangerous behaviors.

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04.6 PARTNERS
Golden Goose is committed to establishing a partnershipwith its suppliers that is based not only on the technicaland qualitative excellence and reliability of the products
manufactured, but also (and most importantly) on sharedvalues and principles of social, ethical, and environmental
responsibility.
Golden Goose does not collaborate with partners who
do not align with its same standards of conduct. Throughthe Supplier Code of Conduct, a separate document fromthis Code of Ethics, the Company duly shares details ofsuch principles with all its suppliers, which are required
to uphold and respect them.
Golden’s supplier selection process, as well as itspurchase conditions, are guided by principles of objectivity,
competence, cost-effectiveness, transparency, fairness,and quality of the goods or services, and contingent uponcompliance with relevant internal procedures, giving
due weight to the suppliers’ after-sales support andwarranties and overall service offerings. Specifically, theCompany is committed to seeking suppliers and external
contractors that can ensure professionalism and full
acceptance of its Code of Ethics and Supplier Code of
Conduct, and to building lasting relationships that enable
continuous improvement in upholding and promoting theCode’s principles and contents.
The Company refrains from entering into or maintaining
relationships with suppliers suspected of belonging to or
aiding criminal organizations, or of engaging in conductthat does not comply with applicable laws and sharedprinciples.
Every supplier is required to review and adhere to all ofGolden’s contract terms and conditions, which include theobligation to comply with this Code of Ethics and otherrules of conduct set and shared by the Company, theviolation of which qualifies as a serious breach associatedwith specific penalties.

RECIPIENTS OF THE CODE MUST:→ Interact with suppliers with the utmost fairness

and professionalism, fostering ongoing, solid, andlasting relationships of trust and mutual growthin compliance with applicable laws and regulations.
→ Educate suppliers on the principles set forth in

this Code of Ethics, encouraging them to adopt
their own code of ethics within their companies
and respective supply chains.
→ Monitor the effective adherence to the principles

outlined in both the Code of Ethics and Supplier
Code of Conduct.
→ Refrain from offering or accepting gifts or any

other form of benefit that could be construed
as a means to obtain preferential treatment for
any activity related to Golden Goose, and thatare not attributable to normal business dealings
or courtesy (see also ‘Conflict of interest’ and‘Corruption’).
→ Avoid entering into contractual agreements thatcreate mutual dependence.

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04.7 SHAREHOLDERS AND THE FINANCIAL MARKET

04.8 CONTROL BODIES

Golden Goose is committed to maintaining a relationshipwith shareholders and the financial market based on trust,transparency, and integrity, and is firmly convinced thatthe responsible allocation of resources, aimed at increasing
the value generated by the Company, can secure long-term
investment returns.
The Company promotes the timely, comprehensive, andaccurate dissemination of information that can affectthe investment or divestment decisions of shareholders,preventing any information asymmetry among the parties
involved.
Moreover, Golden complies with applicable financial andaccounting regulations (see also ‘Accounting information’),publishes its financial results on a regular and reliable basis,and diligently maintains all records, commercial books, andfinancial and reporting documents, so as to provide accurate
and truthful information at all times.

Golden Goose’s relationship with control bodies is basedon principles of maximum cooperation and transparency.

RECIPIENTS OF THE CODE MUST:→ Refrain from engaging in any conduct, whether

through action or omission, aimed at obstructing
investigations or diverting the attention ofcontrol bodies from their respective supervisory
activities.

04.9 OTHER GROUP COMPANIESThe Company is committed to avoiding conduct ordecisions for its own benefit that may be detrimental
to the integrity, autonomy, or reputation of othercompanies within the group to which Golden Goose belongs(hereinafter referred to as the Group).

RECIPIENTS OF THE CODE MUST:→ Ensurethat transactions are recorded inaccordance with applicable accounting standards
and executed with the authorization of thedesignated persons as appropriate to the activities
performed.

RECIPIENTS OF THE CODE MUST:→ Encouragecommunication
among
Group
companies, as well as synergies and cooperationin the common interest, for example, but notlimited to, in the preparation of consolidated
financial statements and in existing contractual
relationships.

→ Ensure the implementation of security measures

to protect the confidentiality, availability, andintegrity of Golden Goose’s accounting andfinancial information.
→ Promote ongoing dialogue with shareholders andthe financial market so as to enhance knowledge
and understanding, among other things, of theCompany’s results and future development plans.

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04.10 PUBLIC ADMINISTRATIONRECIPIENTS OF THE CODE MUST:
Golden Goose ensures maximum cooperation with the
public administration, public officials, or any individual
providing a public service, while strictly adhering toapplicable laws and regulations and protecting its integrity
and reputation.
The Company acts with the utmost transparency,
clarity, accuracy, and impartiality in all its relationships, so
as to not create any partial, false, ambiguous, or misleadinginterpretations among the public institutions with whom
it interacts.

→ Refrain from offering – either directly or throughan intermediary – money or other benefits topublic officials, their family members, or any otherindividuals connected to them, with the aim of
directly or indirectly influencing their activities (seealso ‘Corruption’).
→ Refrain from seeking or establishing personal

relationships intended for undue favor, advantage,influence, or interference, and from solicitingor obtaining confidential information that may
compromise the integrity or reputation of either
parties or that, in any case, violate the principles of
equal treatment and public disclosure procedures
initiated by public institutions or public officials.
→ Decline any requests from public officials formoney, gifts, or services to perform or refrain fromperforming, or to facilitate, an expected activity as
part of their job position (see also ‘Corruption’).
→ Refrainfrom accepting any requests forcontributions or sponsorships (see also
‘Sponsorships and contributions’) that may
influence business negotiations or create undue
advantage for the Company in the event of controls,
inspections, or audits by the authorities.

→ Refrain from delegating representation in dealings

with the public administration to contractors and/or third parties when a conflict of interest may
arise, even if only potentially (see also ‘Conflict ofinterest’).
→ Refrain from diverting contributions, subsidies,or funding obtained from the State or any otherpublic entity for purposes other than those forwhich they were granted, regardless of their value
or amount.
→ Refrain from any conduct aimed at obtaining

contributions, funding, subsidized loans, or othersimilar disbursements from the State or other public
entity by means of altered or falsified statements
and/or documents or omitted information, including
those created by means of a computer or electronicsystem.
→ Refrain from evasive, omissive, or obstructive

conduct towards national and foreign judicial
authorities.

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04.11 TRADE UNIONS AND POLITICAL PARTIES
Golden Goose recognizes and respects the right of
employees to be represented by labor organizations, andmaintains relationships with such representatives basedon mutual recognition, open dialogue, and cooperation.
Relations with trade unions and political parties aremanaged in accordance with the highest principles oftransparency, independence, and fairness, and in strict
compliance with applicable laws.

RECIPIENTS OF THE CODE MUST:→ Refrain from making any kind of direct orindirect contributions to political parties,
movements, committees, political organizations
or trade unions, or to their representatives orcandidates, both in Italy and abroad.
→ Refrain from any direct or indirect pressure

on political officials, for example by accepting
recommendations for recruitment, consultancy
contracts, etc.

04.12 ASSOCIATIONS
Golden Goose believes that dialogue with stakeholder
associations is important for the development of its business,and encourages the creation of communication channels
based on principles of impartiality and independence aimed
at fostering cooperation in the mutual interests of all.

RECIPIENTS OF THE CODE MUST:→ Be as responsive as possible to the observationsof all associations.
→ Refrainfrom making contributions toorganizations that may give rise to a conflict ofinterest, including but not limited to consumer
protection associations.

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05

Rules of conduct
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05.1 HUMAN RIGHTS
Golden Goose recognizes the utmost importance ofpromoting and respecting fundamental human and laborrights across its value chain.
The Company rejects the use of forced or child laborand any type of physical, verbal, sexual, or psychologicalharassment, abuse, threat, or intimidation in theworkplace, thus ensuring respectful and favorable working
conditions in the countries in which it operates, including
in terms of working hours and wage determination.

RECIPIENTS OF THE CODE MUST:→ Ensure a workplace free from discrimination andharassment (see also ‘Equal opportunities and nondiscrimination’).
→ Avoid knowingly establishing any relationships,

whether directly or indirectly, with individuals or
entities that violate the laws and regulations onchild labor and the protection of women, and/oron the use of labor resulting from illegal migrantsmuggling practices or human trafficking.
→ Prohibit any form of physical or verbal intimidation,

threat, harassment, or abuse that may create an
intimidating, offensive, or hostile work environment(including sexual harassment, offensive language or
behavior, and insults based on race, ethnicity, sexual
orientation, or religious belief).
→ Make every effort to ensure a safe, healthy, andlegally compliant work environment for employees
and contractors (see also ‘Health and safety’).
→ Recognize

everyone’s right to freedom of
association and collective bargaining.

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05.2 ENVIRONMENT

05.3 ANIMAL WELFARE

Golden Goose regards the environment as the heritage ofthe community and of future generations, and is committed
to promoting its protection and conservation by encouraging
business practices aimed at minimizing its environmental
impact in every country of operation.
This entails reducing its emissions, energy consumption,
waste, and use of potentially hazardous substances in
production processes, and applies to both its facilities(corporate offices, warehouses, production sites, and retailstores) and logistics. The Company is also committed to
not contributing to deforestation in the procurement of its
packaging and leather materials.

When sourcing raw materials of animal origin, Golden
Goose requires its people and suppliers to ensure that they
were not obtained through cruel breeding and/or harvesting
practices, rejecting any form of mistreatment or otherharmful activities. The Company also requires suppliers tocomply with the so-called ‘Five Freedoms1’ of animal welfare.
Golden is also committed to not using animal fur or theskins of endangered animals (as per the CITES2 Species
List and the IUCN3 Red List) in the manufacture of its
products.

RECIPIENTS OF THE CODE MUST:RECIPIENTS OF THE CODE MUST:→ Comply with applicable environmental regulations and→ Complywith applicable laws and regulations
concerning the health and welfare of animals, andensure their well-being with respect, among otherthings, to their breeding, transportation, hunting, andslaughter.

standards throughout the value chain.
→ Commit to spreading a culture of respect for theenvironment, contributing to its protection, andpromoting responsible behaviors.

→ Ensure the legality of the origin of animal-derived→ Promote the pursuit of knowledge and technologies

materials.

aimed at reducing environmental impact, andimplement effective measures in production
processes to achieve continuous improvement.

→ Promote compliance with the latest and mostadvanced scientific standards and best practices foranimal welfare across the supply chain.
→ Ensure that fragrances and any ingredients used fortheir production have not been tested on animals.

1. As per the Brambell Report published in 1965, the Five Freedoms describe the right to welfare ofanimals under human control (i.e., subject to intensive farming).
2. Convention on International Trade in Endangered Species of Wild Fauna and Flora.
3. International Union for Conservation of Nature (IUCN) Red List of Threatened Species.

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05.4 CONFLICT OF INTERESTRECIPIENTS OF THE CODE MUST:
Guided by the values of honesty, impartiality, and fairness,
Golden Goose is committed to adopting all necessary measures
to prevent and avoid conflicts of interest.
Every business endeavor must be aligned with the Company’s
best interests and contribute to social development.

→ Prevent the emergence of situations and/or

activities that could lead to conflicts of interest,or that could interfere with or jeopardize a person’s
independence of judgment and choice – andtherefore impartiality – when making businessdecisions.
→ Act in accordance with ethical and legal standards,

explicitly prohibiting any form of unlawful favoritism,collusive practices, corruption, or solicitation of
personal benefits for oneself or others.
→ Immediately report any actual or potential conflict ofinterest and refrain from engaging in any activities
related to the conflicting situation.

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05.5 CORRUPTIONRECIPIENTS OF THE CODE MUST:
Golden Goose strictly prohibits all forms of bribery andcorruption, including favoritism, in all countries where it
operates, even in jurisdictions where such activities arecommonly accepted or not prosecuted.

→ Prevent any form of bribery of public officials when

dealing with public authorities on matters such as
customs practices, taxes, entry visas, and permits,which may require collaboration with local agents,
consultants, or third-party intermediaries.
→ Refrain from accepting or offering, whether directly

or indirectly, money, gifts, services, gratuities
or any other form of benefit when dealing withpublic officials, political representatives or parties,
customers, suppliers, consultants, agents, business
partners, or any other individual or organization, thus
respecting the autonomy of their decision-making
processes. Exceptions can be made for modest-value
gifts in accordance with local customs (the Company,
however, prefers donations in support of charitableorganizations).
→ Avoid entertainment expenses that may raisesuspicions of impropriety or create the perception of
attempting to influence the actions of public officials,
political parties or representatives, customers,
suppliers, consultants, agents, business partners, or
any other individual or organization.
→ Refrain from obtaining false licenses and permits,

expediting processes, or avoiding the inspection of
new stores.
→ Prevent any attempts to influence inspection

checks, ensuring that they are carried out correctly
and providing the entirety of the information anddocumentation required.
→ Ensure the highest level of transparency and accuracy

when preparing documentation to request public
contributions or funding and when engaging with
officials from public funding agencies.
→ Prevent the creation of funds linked to illegal activities.
→ Ensure respect for the autonomy of regulatory bodies

and public institutions when engaging in normalinteractions with representatives of institutions orpolitical parties.

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05.6 MONEY LAUNDERINGRECIPIENTS OF THE CODE MUST:
Golden Goose condemns any conduct that could facilitate orindirectly support the receipt, laundering, or use of proceeds,
assets, or benefits derived from criminal activities in any formor manner.
The Company is committed to complying with applicableanti-money laundering and anti-organized crime andterrorism legislation in all relevant jurisdictions, and toensuring that its commercial operations and transactions
do not pose an actual or potential risk of aiding the receipt,
laundering, or use of money or assets derived from criminal
activities.

→ Not be implicated, under any circumstances or inany manner, in incidents related to the launderingof money from criminal activities or the handling ofgoods or other assets of illicit origin.
→ Preemptively verify the information available on

suppliers, contractors, partners, consultants, and key
customers in order to ascertain their ethical integrity
and technical and professional qualifications, as well as
the legitimacy of their activities, prior to establishing
any business relationships with them.
→ Refrain from entering into or continuing business

relationships with counterparts
belonging to criminal organizations.

suspectedof→ Exercise

caution in commercial transactions,particularly when receiving or spending coins,banknotes, negotiable instruments, and othersecurities, in order to prevent the circulation ofcounterfeit values in the market.

→ Strictly adhere to the law, ensuring full traceabilityof incoming and outgoing financial flows and fullcompliance of such transactions with anti-money
laundering provisions.

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05.7 SPONSORSHIPS AND CONTRIBUTIONSRECIPIENTS OF THE CODE MUST:
Golden Goose may decide to sponsor events andinitiatives through agreements with reputable and qualified
beneficiaries.
The only requests for contributions that the Company
takes into consideration are those from non-profit
organizations and associations or entities of cultural and/or social value, as per internal guidelines and procedures.
When participating in such initiatives, the Company iscommitted to exercising caution so as to identify potential
personal or corporate conflicts of interests. Sponsorships
are contingent upon the definition of specific agreements
and verification of the integrity of both the beneficiaryand the event/initiative being promoted, and shall not beprovided to any counterpart that is even only suspectedof being involved in organized crime or in money laundering
offenses.

→ Assess the reliability of beneficiaries and theiralignment with the values of the Company.
→ Ensure that the contributions made are inaccordance with applicable laws and accurately
documented.

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05.8 CONFIDENTIAL INFORMATION, PRIVACY, AND
SOCIAL MEDIACONFIDENTIAL INFORMATION
Golden Goose is committed to protecting any sensitive,
confidential, privileged, or classified information concerning
the Company, operating in accordance with the principles
of loyalty, fairness, equal access to information, andtransparency and in full compliance with current laws onmarket protection and the abuse of confidential information.

PRIVACY
In carrying out its business, Golden Goose collects asignificant amount of confidential information and personaldata, which is handled in accordance with Regulation (EU)2016/679 and relevant best practices to avoid improper orillegal use.
Golden Goose relies on a comprehensive and regularly
updated privacy policy to ensure the right to the protectionof personal data of all data subjects (employees, contractors,
customers, suppliers, partners, etc.), including special dataacquired or to be acquired and/or processed during business
operations. The Company requires consent to the processingof personal data whenever required by applicable law for the
purposes of lawful processing.
Golden Goose is committed to ensuring the protectionof data from any form of breach, misuse, and/or theft,by implementing specific technical measures and by
guaranteeing an adequate level of security of the IT
systems used to process the personal data and confidential
information.

RECIPIENTS OF THE CODE MUST:→ Maintain the confidentiality of any non-public

information acquired as a result of their position within
Golden Goose (or through business dealings with theCompany), and refrain from using such information
for personal gain, either for themselves or for otherindividuals unrelated to the Company’s businessobjectives. This prohibition applies to current andfuture activities, as well as to undisclosed informationand news, even if expected to be released in thenear future. Furthermore, this prohibition remains ineffect even after termination of the employment and/or contractual relationship.

SOCIAL MEDIA
Everyone at Golden Goose is encouraged to act as a
Company ambassador. However, only individuals who
have been duly authorized are allowed to communicate on
Golden’s behalf. This means that it is permitted to speak
about the Group, but not on behalf of the Company without
proper authorization. The publication of online content must
always adhere to principles of propriety and avoid damaging
the Company’s reputation.

→ Refrain from disclosing false or misleading information

about Golden Goose or other parties with whom
the Company interacts in the course of its businessactivities. It is also prohibited to disclose any pricesensitive information acquired while conducting
Company business or other professional or official
activities.

RECIPIENTS OF THE CODE MUST:→ Ensure

data confidentiality through adequate
measures that prevent unauthorized access fromthird parties.

→ Always bear in mind that actions taken on social→ Reserve the Company’s media relations exclusively

networks, even in a personal capacity, can have anindirect negative impact on the Company.

to the designated functions, so as to ensure thecompleteness and consistency of information.

→ Avoid making comments or engaging in discussions

about Golden’s business activities based on
information posted by third parties or the generalpublic. This applies to all interactive digital media,
such as social networking websites (e.g., Facebook,
Instagram, LinkedIn, and Twitter), blogs, and video/
photo sharing platforms (e.g., YouTube, Flickr, andother forums).

→ Use personal data appropriately and retain it only for

as long as necessary for the purposes for which it wascollected.

→ Use social media responsibly.

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05.9 INDUSTRIAL AND INTELLECTUAL PROPERTY
Golden Goose consistently promotes the innovation andtechnological advancement of its products, processes, andservices, both internally and among third parties engaged in
activities on behalf of the Company.
Golden is committed to fully respecting the industrial
and intellectual property rights legitimately held by theCompany itself and by third parties, as well as the relevantlaws, regulations, and conventions protecting such rights atnational, EU, and international level.

RECIPIENTS OF THE CODE MUST:→ Refrain from engaging in any behavior intended tocounterfeit, alter, duplicate, reproduce, or distribute,in any form and without proper authorization, thework of others.
→ Refrain from misappropriating industrial property

rights, designs, or industrial models, and/or fromaltering or counterfeiting trademarks or otherdistinctive product features.
→ Avoid importing or circulating industrial products withcounterfeit trademarks or other distinctive featuresby misappropriating the rights of third parties.
→ Prohibit others from using registered trademarks orother intellectual property.
→ Safeguard intellectual property with the utmost

care and, if authorized, disclose it in compliance withconfidentiality agreements.

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05.10 COMPETITION

05.11 ACCOUNTING INFORMATION

Golden Goose firmly believes in fair, open, and equitablecompetition, which it considers a driver of economic
and social progress in terms of price, quality, and range
of offerings, all in the best interest of end customers.
Recognizing the importance of a competitive market, theCompany is committed to complying with national and EU
antitrust legislation, as well as similar non-EU regulations,to protect competition and ensure a free market.
Golden Goose ensures its full cooperation withcompetition authorities during investigative procedures,
does not obstruct any inspections, and does not withhold,conceal, or delay any information requested.

When preparing its financial statements and any othertype of accounting documentation, Golden Goose complies
with applicable laws and regulations, adopts generally
accepted accounting practices and principles, and isguided by the principle of transparency in its relationships
with stakeholders, faithfully representing its operations
according to criteria of clarity, truthfulness, completeness,
and accuracy.
All financial transactions and cash inflows and outflows
are carried out and managed by authorized parties and duly
tracked and recorded.

RECIPIENTS OF THE CODE MUST:RECIPIENTS OF THE CODE MUST:→ Refrain from using illegal means to acquire a→ Assume responsibility for the authenticity andcompetitor’s trade secrets or other confidential
information.

truthfulness of any documentation and information
provided in the course of their work.

→ Avoid applying specific price and contractual→ Ensure that business activities and events areconditions that have the sole purpose of excluding
competitors from negotiations.

accurately and promptly reflected in financial
statements,
reports,orother
corporate
communications.

→ Comply with antitrust laws that prohibit theformation of monopolistic agreements or cartels andinterference in the mechanisms of competition.

→ Facilitate the availability of supporting documentation→ Refrain from encouraging and/or engaging in unfair→ Keep accurate and complete accounting records andand ensure it is properly filed.

competition practices.

refrain from falsifying, omitting, misstating, altering,or concealing any information.

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05.12 COMPANY ASSETS AND IT TOOLS
Golden Goose provides its people with Company assets
and tools to carry out their work-related activities.
With specific reference to IT tools, it is expressly
prohibited to engage in conduct that may damage, alter,
deteriorate, or destroy the Company’s IT or electronicsystems, programs or data, or unlawfully intercept orinterrupt IT or electronic communications. It is also
prohibited to illegally access or break into computer systems
protected by security measures, or to obtain or distributeaccess codes to protected computer or electronic systems.

RECIPIENTS OF THE CODE MUST:→ Use Company assets responsibly and in line with theoperating instructions in place. Specifically, as regards
tangible resources (phones, vehicles, computers,etc.), employees are required to observe the relevant
instructions for use that have been duly provided tothem. As regards intangible resources (Internet, email,etc.), personal or non-work-related use is strictly
prohibited unless expressly authorized.
→ Avoid waste, misuse, or improper use of Company

assets for purposes contrary to the law, public orderor morality, or for the purpose of committing or
inducing the commission of crimes, promoting racialintolerance, glorifying violence, and/or violating
human rights.
→ Assume responsibility for the safekeeping, protection,and preservation of assigned assets and resources.
→ Access only authorized IT resources, safeguard thecredentials, passwords, and personal encryption
keys used to access the Company’s network andapplications according to suitable criteria to prevent
easy identification and/or improper use, and comply
with internal policies on anti-intrusion and antivirus
systems.

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06

Implementationand control
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This Code of Ethics, and any amendments or updates
thereof, shall be approved by the Golden Goose Boardof Directors and disseminated accordingly to all Group
companies, which are required to formalize its application
by resolution of their respective governing bodies.
Additional specific rules of conduct and policies resulting
from local practices or regulations may be adopted inaddition to this document.

06.1 IMPLEMENTATION OF THE CODE
Primary responsibility for the implementation of theCode lies with the directors and management, who arecalled upon to translate the values and principles outlined inthis document into concrete actions, assume responsibility
both internally and externally, strengthen trust, cohesion,and the spirit of the Company, and lead by example as they
guide Recipients in their daily endeavors.
All other Recipients are required to cooperate in theimplementation of the Code as well, within the limits of
their respective responsibilities and roles.
In order to pursue compliance with the principles andstandards set forth in this document, the Company shallensure:→ the dissemination, accessibility, and clear understandingof the Code→ the consistent interpretation and implementation of the

Code→ the provision of training courses for its people andawareness-raising activities for other Recipients→ the investigation of reported Code violations andapplication of relevant sanctions in accordance withapplicable regulations→ the periodic update of the Code based on emerging needs

and its timely dissemination to all Recipients.
The Code of Ethics can be downloaded through theGolden Goose website (www.goldengoose.com) and isavailable in the main languages of the countries in which
the Company operates.
Golden is committed to providing a copy of the Codeto all employees upon joining the Company, to building
a culture of compliance with its principles throughtraining and awareness activities, and to making it
known to external stakeholders (customers, suppliers,
consultants, contractors, etc.). It is also committed tomaking it an integral part of supply contracts, including
through the use of specific contractual clauses. Golden
requires all Recipients to sign a statement (even digitally)
acknowledging that the Code has been read and accepted,
in order to ensure full awareness of the principles statedtherein.

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06.2 WHISTLEBLOWING

06.3 CONSEQUENCES OF NON-COMPLIANCE WITH THE
CODE

Should the provisions of this Code be violated or simply
not enforced despite the procedures in place, or give rise
to a conflict, the Recipients are required to inform the
Ethics Committee, a dedicated body established by Golden
Goose comprising the heads of the Talent, Legal Affairs,
Sustainability, and Internal Audit departments, serving,
among other things, as the point of reference for theinterpretation of all relevant aspects of the Code. The Ethics
Committee is tasked with reviewing reports of potential
Code violations and initiating investigations and inquiries
as appropriate, with the support of the relevant functions
within the Company. Consequently, it is responsible
for assessing the results of the investigations and forcommunicating them to the relevant corporate bodies, so
as to implement appropriate corrective measures based on
the nature and severity of the violations. The Committee
also provides feedback regarding investigation outcomes tothose who report a violation (whistleblowers).
Any Recipient of this Code in possession of information
regarding the commission of crimes or practices not in linewith the rules and principles of conduct set forth herein may
submit a non-compliance report, anonymously or otherwise,
as per Golden Goose’s Whistleblowing Policy.
To ensure the protection of whistleblowers, the Company
implements strict confidentiality measures to protect
their identity and the information they disclose, including
the identity of the person being reported, and prohibitsof any form of retaliation against them. Any individual
who resorts to retaliation of any kind will be subject todisciplinary action. This means that, even if a report is foundto be unsubstantiated, any person reporting a violation orconcern in good faith shall have no cause for concern andwill be protected in the event of intimidation.
However, the Company will also take punitive action
against anyone who submits a report with malice or grossnegligence that proves to be unfounded. In fact, anyone who
falsely or unjustly accuses another person will themselves
be subject to sanctions and/or appropriate measures, assuch conduct will be treated as a violation of this Code.

Failure to comply with the Code of Ethics constitutes aviolation thereof and a serious breach of contract.
Therefore, depending on the circumstances, failure tocomply with the principles of the Code may result in theapplication of disciplinary measures and/or sanctions, up
to and including termination of employment.
Specifically:→ For employees and contractors, violating the Codeconstitutes a breach of the obligations deriving fromthe employment or contractual relationship and/or a disciplinary offense that may jeopardize thecontinuity of the relationship itself. In such cases, theCompany reserves the right to take legal action to seek
compensation for any damages incurred.
→ For directors, violating the Code may result in the

adoption of proportionate measures by the Board of
Directors based on severity, recurrence, and/or degreeof fault, up to and including dismissal for just cause.
→ For all other Recipients, compliance with the Codeis a prerequisite for the continuation of the existing
professional/collaborative relationship with theCompany. Therefore, any violation thereof may
constitute a breach of contractual obligations entailinglegal consequences, up to and including contract
termination and compensation claims for damages
suffered by the Company.

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07

Glossary
41

CODE OF ETHICSACTIVE CORRUPTION: The unlawful act of offering or
promising benefits to a person, either directly or indirectly,with the aim of inducing that person to take or refrain fromtaking a specific action as part of their job position.

FAVORITISM: The direct or indirect offering ofpromises, donations, gifts, or any kind of benefits to aperson to encourage them to abuse, or in exchange forhaving abused, their presumed or actual influence toobtain recognition, employment, contracts, or otherfavorable decisions from a public authority or public
administration.

CIVIL SERVICE: Activities governed by rules of publiclaw pertaining to legislative, administrative, and judicial
functions.

MORAL HARASSMENT (MOBBING): Actions and conduct
in the workplace that are deliberately hostile, aggressive,
and/or vexatious in nature, and perpetrated in a repetitive,
systematic, escalating, and persecutory manner by either
peers, superiors, or subordinates of the victim, aimed atviolating the latter’s personal dignity and damaging their
psychophysical integrity, including by marginalizing themfrom the work environment.

CONFIDENTIAL
INFORMATION:
Any
Company
information regarding: projects (e.g., commercial,strategic, industrial, and operational plans); investments
and divestments; employees; know-how and processes;
databases containing supplier, customer, and contractor
information; technological innovation endeavors; acquisition
or merger plans; corporate agreements. Any economic andfinancial information concerning the Company that has not
yet been disclosed to the financial community shall also be
considered confidential.

PASSIVE CORRUPTION: The deliberate act of requestingor receiving money, gifts, services, or any other benefits,
or of accepting a promise of such advantages, to performor refrain from performing, or to facilitate, an expected
activity as part of one’s job position.

CONFLICT OF INTEREST: By way of example, a conflictof interest occurs when:→ there are economic or financial interests, including
through family members, in dealings with suppliers,
customers, competitors, or any external parties
seeking to do business with the GroupPUBLIC ADMINISTRATION: Private and public entities
that perform a civil or public service.
PUBLIC SERVICE: Activities involving the productionof goods and services of general interest and subject tothe supervision of a public authority, as well as activities
aimed at guaranteeing a person’s right to life, health, andfreedom of communication, including those implemented
under public contracts and/or concessions.

→ people use their position within the Company or

information acquired in the course of their work forpersonal gain or the benefit of a third party, conflictingwith the interests of Golden Goose→ performing any kind of work (such as labor or

intellectual services) or holding a position with
suppliers, customers, competitors, and/or third parties
that conflicts with the interests of the Company

SEXUAL HARASSMENT: Conduct that includes, but
is not limited to, the demand of sexual favors and/or
private interpersonal relationships in exchange for careeradvancement, as well any other behavior that is expressly
or evidently inappropriate or unwanted and that has thecapacity, given its specific nature, to create a hostileenvironment for the victim.

→ concluding or initiating negotiations and/or contracts– in the name and/or on behalf of the Company –involving family members, partners, or legal entities
of companies of which the person is the owner orstakeholder

STAKEHOLDERS: Individuals or groups with a legitimate
interest in an organization’s activities and outcomes, andthat can either affect or be affected by the organization’s
decisions.

→ accepting money or other benefits or favors fromindividuals or entities that are or intend to be in
business with Golden Goose.

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