WHISTLEBLOWINGPOLICY

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WHISTLEBLOWING POLICYINDEX
01 Purpose of the Policy
02 Definitions
03 Scope of application
04 Management of whistleblowing
05 Duty of confidentiality
06 Whistleblower protection
07 Protection of the person(s) reported
08 Processing of personal data
09 Conflict of interest management
10 Monitoring and review
11 External reporting channels

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Purpose of the
PolicyThis Whistleblowing Policy – which replaces the previous
document named ‘Acts of discrimination, harassment, andabuse reporting process’ – governs the process of receiving
and handling reports of alleged violations and the relevant
methods of investigation, in accordance with current law1.
This Policy serves as a framework of reference and applies
to all companies within the Golden Goose Group (hereinafter
the Group), without prejudice to applicable local laws andregulations that may supersede the provisions set forth
herein.
It should be noted that the principles outlined in thisPolicy do not affect or limit in any way the reporting
obligations towards the competent judicial, supervisory,or regulatory authorities in the countries in which Golden
Goose’s companies operate, nor towards any control bodies
established within each Group company.
Any person reporting a concern in good faith, as wellas any facilitators or other protected persons involved,
will be protected from retaliation in the form of negativeor adverse actions or consequences in the workplace,and anyone who engages in retaliatory behavior against
an actual or suspected whistleblower will be subject todisciplinary action.

1. Directive (EU) 2019/1937; Italian Legislative Decree No. 24 of March 10, 2023 regarding the protectionof persons who report breaches of European Union law, including provisions for the protection of persons
who report breaches of domestic law (for entities operating in Italy); Italian Legislative Decree No. 231
of June 8, 2001 for the discipline of administrative liability of legal entities, as amended pursuant to theaforementioned Legislative Decree 24/2023 (for entities operating in Italy); any other relevant legislation
in force in the countries in which the Group operates.

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Definitions

OTHER PROTECTED PERSONS:CONTROL BODY: body entrusted with the control functionof Golden Goose S.p.A. and, if applicable, its Italian and foreignsubsidiaries (i.e., the Board of Statutory Auditors).

→ individuals operating within the same work context who

are related to the whistleblower by a stable emotional or
kinship bond up to the fourth degree

DETAILED REPORT: a report in which the facts, events,
and circumstances of the alleged violation (such as type ofoffense committed; time reference; value of the monetaryimpact, if any; cause and purpose of the offense; company,
areas, units, people, and/or entities concerned or involved;
internal control system anomalies; etc.) are described witha sufficient level of detail to allow the competent corporate
bodies, on the basis of the investigative tools at theirdisposal, to effectively assess the validity of the facts orcircumstances being reported.

→ colleagues within the same work context who share aregular and current relationship with the whistleblower→ entities that the whistleblower owns, works for, or isotherwise connected with in a work-related context.
RETALIATION: any behavior, act, or omission, even if
only threatened or attempted, that occurs in response toeither an internal report, an external report to the judicial
or accounting authorities, or a public disclosure, and thatcauses or may cause unjust damage to the whistleblower,
whether directly or indirectly.

ETHICS COMMITTEE: collegial body composed of theGeneral Counsel, Internal Audit function, Chief Talent
Officer, and Chief Sustainability Officer of Golden Goose,
responsible for the management of whistleblower reports(with the General Counsel and Internal Audit function
serving as the designated recipients of all reports
submitted through the available channels). The Ethics
Committee assesses the adequacy of the reporting process
and suggests improvements to Golden Goose’s Boardof Directors accordingly, with the support of relevant
functions if deemed necessary.

SUPERVISORY BODY: body responsible for exercisingoversight of Golden Goose S.p.A. and, if applicable, its
Italian subsidiaries that have adopted an organizational andmanagement model pursuant to Art. 6 of Italian Legislative
Decree 231/2001 (i.e., the Organismo di Vigilanza, or OdV).
THIRD PARTY: any individual or entity acting for or on
behalf of the Group, including but not limited to: distributors,
retailers, agents, intermediaries, independent contractors,
consultants, sales representatives, joint venture partners,
accountants, legal representatives, lobbyists, customs
brokers, logistics companies, and supply chain partners.

FACILITATOR: natural person operating within the same
work context who assists the whistleblower in the reporting
process, and whose collaboration must be kept confidential.
GOOD FAITH: to report in good faith means to havereasonable grounds to believe that a violation has beencommitted, and that the information reported was true atthe time of reporting.

WHISTLEBLOWER: person who reports or publicly
discloses information on discriminatory acts, harassment,
abuse, or other behaviors and/or violations falling within thescope of this Policy, which they have personally experienced
or witnessed, or of which they have direct knowledge owing
to their function within the Company.

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WHISTLEBLOWING POLICY

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Scope of application

Golden Goose promotes an open culture, emphasizing theimportance of employees and other stakeholders raising any
concerns or doubts so that the Company may assess them,investigate, and gather additional information, if necessary.
Pursuant to this Policy, any person who becomes awareof actual or potential wrongdoing in a work-related context
can submit a report, even in their native language, throughthe reporting channels at their disposal.

03.2 WHAT CAN BE REPORTED?
The violations of which a person has become aware ina work-related context2 and that can be reported include:→ violations of the Group’s Code of Ethics and core values

and principles→ violations of laws and regulations3

03.1 WHO CAN REPORT A CONCERN?
→ violations of regulatory provisions

Reports can be submitted by:→ violations of corporate policies→ shareholders

and individuals in administrative,
managerial, control, supervisory, or representative
positions, even if in a de facto capacity→ violations of human rights, including any act of→ all Group employees (under employment contracts,→ behaviors that cause or may cause damage or prejudicediscrimination, harassment, or abusecollaboration agreements, or self-employed, as well as
paid or unpaid volunteers and trainees)to the Group, even if only reputational.
Reports must be based on facts, without bias, prejudice,or ulterior motives. Any misleading reports submitted inbad faith based on false accusations or with malicious
intent may result in disciplinary action.

→ third parties.

2. The work-related context, and the information obtained therein, also encompasses the selection

3. In particular, pursuant to Italian Legislative Decree No. 24 of March 10, 2023 implementing

process, the pre-contractual stage, the probationary period, and the duration of the employment

Directive (EU) 2019/1937, the following violations can be reported: i) unlawful conduct underrelationship, even if the report is submitted after employment termination.

Italian Legislative Decree 231/2001 (known as ‘predicate offences’ for the administrative liabilityof entities) or violations of the organizational and management model adopted by the entity; ii)
offenses, behaviors, acts, and omissions as per Art. 2, par. 1, letter a), Nos. 3, 4, 5, and 6.

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WHISTLEBLOWING POLICY03.3 WHICH REPORTING CHANNELS ARE AVAILABLE?

03.4 WHAT INFORMATION SHOULD BE INCLUDED IN THE
REPORT?

Anyone who wishes to file a report in good faith can doso using the Ethics and Integrity Line, which guarantees
the anonymity and confidentiality of the whistleblower
also through the use of encryption tools.
The Ethics and Integrity Line can be reached atgoldengoose.integrityline.com in the countries whereavailable.
Alternatively, reports may also be submitted throughthe following channels:

The contents of the report should be based on truthfuland factual information and submitted in good faith.
Reports must include the following information:→ name(s) of the person(s) being reported→ time reference of the alleged violation→ location of the alleged violation→ the dedicated email at ethics@goldengoose.com→ a description of the alleged violation→ in person (one-to-one meetings): employees can makea report in person by requesting a one-to-one meetingwith the Internal Audit function and/or the GeneralCounsel→ circumstances related and/or leading to the alleged

violation→ estimated frequency of the alleged violation.

→ by post to: Ethics Committee c/o Golden Goose S.p.A. -Via Privata Ercole Marelli 10 - 20139 Milan, Italy.

It is not necessary for the whistleblower to have fullknowledge or evidence of the alleged violation in order toreport it through the designated channels.
Furthermore, any doubts can be discussed in fullconfidentiality with the General Counsel and Internal
Audit function, as mentioned above.

Regardless of the channel, when submitting a report,
whistleblowers have the right to remain anonymous or tovoluntarily reveal their identity if deemed necessary. In
either case their confidentiality is guaranteed.
However, they are encouraged to disclose their name
and/or contact details in order to facilitate the appropriate
investigations, if any.

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Management ofwhistleblowing

Reports are processed according to the following stages:

04.2 PRELIMINARY ASSESSMENT→ receipt

Golden Goose’s Internal Audit function conducts an
initial assessment of any report received and classifies it
based on the nature and description of the facts, events, or
circumstances being reported.
The Internal Audit function then informs the Ethics
Committee and, with the support of the competentfunctions, prepares the supporting documents andinformation required to either open an investigation or filethe case.
If deemed relevant, based on the subject matter of thereport and the geographic location of the whistleblower,
the Internal Audit function may request the relevant
local function(s) (e.g., Talent, Legal Affairs, Finance) toparticipate in the preliminary assessment and, if necessary,in the subsequent investigation, to ensure compliance withapplicable local laws and regulations and respect for local
culture and practices, granting them formal authorization
as per applicable law.

→ preliminary assessment→ investigation→ closure→ feedback→ reporting on whistleblowing cases.

04.1 RECEIPT
Regardless of the reporting channel, the designatedrecipients of all reports are Golden Goose’s General Counsel
and Internal Audit function, who are responsible for
acknowledging receipt within seven days. Reports received
verbally will be transcribed and documented in writing, andsubmitted to the respective whistleblowers for verification
and approval.
If a report is received through channels other thanthose indicated in this Policy, the person who received thereport must immediately forward it through the official
reporting channels, adhering to the highest standards ofconfidentiality and following the appropriate procedures, so
as to protect the whistleblower and the identity and integrityof the person(s) being reported, and not compromise theeffectiveness of subsequent investigations.
Every report received through one of the designatedreporting channels will be assigned a unique and sequential
case number within the Ethics and Integrity Line system,
and will be tracked and reviewed accordingly.

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WHISTLEBLOWING POLICY04.3 INVESTIGATION

04.5 FEEDBACK

The purpose of the investigation process is to review,
assess, and analyze the reported allegations. Depending on
the circumstances, the investigation is conducted by theInternal Audit function either independently or, if deemednecessary or appropriate, with the support of other internalfunctions or an external consultant, ensuring the necessaryconfidentiality of the process.
Given the varied nature of the reports, it is notpossible to predict the exact duration for the completionof the investigation process, which in any case must be
conducted as quickly as possible without compromising
the quality and thoroughness of the process itself.
Investigations will be fair, impartial, meticulous, and wellplanned. Upon completion of the investigation process, theInternal Audit function will prepare a report to be submitted
to the Ethics Committee, unless the latter participated in
the process.
To ensure the effectiveness of the investigation, as well
as fair disciplinary measures, the individuals conducting theinvestigation must have free and unrestricted access to all
relevant documents and Company premises throughout theprocess.
Furthermore, they must be able to maintain independence
at all times, and be free to conduct the investigation andsubstantiate the facts without any external influence,
interference, or fear of reprisal.

Golden Goose’s Internal Audit function or GeneralCounsel will provide feedback to the whistleblower on thestatus of the report within three months from the date of
the acknowledgment of receipt. If the report is still underinvestigation at this time, a new update will be provided
within the following three months. In any case, Golden
Goose’s Internal Audit function or General Counsel will
provide feedback to the whistleblower when the procedure
is closed.
Whistleblowers must bear in mind that any information
shared with them regarding an investigation and theactions taken in connection therewith must be treated asconfidential.
The Group cannot guarantee that an investigation willlead to the whistleblower’s desired or expected outcome.
However, Golden Goose is committed to addressing any
legitimate concerns in a fair and appropriate manner.
04.6 REPORTING ON WHISTLEBLOWING CASESThe Ethics Committee will provide Golden Goose’sControl Body and Board of Directors with a report on thewhistleblowing cases processed in the period of reference,either on a semi-annual basis or as needed.
Likewise, it will provide the CEOs/managing directorsof the other Group companies with a report on the casesthat originated from, or had an impact on, their respective
organizations, so that they may in turn inform theirrespective control bodies of reference.
Furthermore, in the event of reports regarding relevant
violations pursuant to Italian Legislative Decree 231/01, or
violations of the Organizational and Management Model
adopted by Golden Goose, the Ethics Committee will
provide timely updates to the Supervisory Body at eachof the following stages, while ensuring anonymity andconfidentiality:

04.4 CLOSURE
Without prejudice to the above, the Ethics Committee(and the relevant functions where deemed necessary) will:→ review the investigation report and its findings→ determine whether the investigation was sufficient or if

further investigations are needed→ approve any measures deemed necessary or appropriate→ upon completion of the preliminary assessment

to address the issues highlighted in the investigation
report.

→ upon completion of the investigation→ upon closure of the procedure.

Based on each update, the Supervisory Board may
ask the Ethics Committee to conduct further in-depth
investigations and/or specific inquiries.

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Duty of confidentiality

All Group employees involved in any capacity in theprocessing of the reports must ensure the utmost
confidentiality regarding the existence and contents ofa report and the identities of the reporting and reported
persons.
Every exchange of information regarding the existence
and content of a report, or the identities of the reporting
and reported persons, must be strictly on a ‘need toknow’ basis. To this end, the Ethics and Integrity Line
allows tracking, for each report, what information has
been shared and with whom.
These individuals are expressly authorized tohandle and process such information pursuant to Art.
29 and Art. 32(4) of Regulation (EU) 2016/679, andArt. 2-quaterdecies of the Personal Data Protection Codepursuant to Italian Legislative Decree 196/2003.
In all cases where the name or other personal data of
the whistleblower were provided with the initial report,
this information will be removed from the contents of
the report before the latter is processed by the Ethics
Committee and other authorized individuals, and replacedwith the case number assigned when the report wasreceived.
The Group ensures the confidentiality of the identity ofwhistleblowers and any facilitators from the moment thereport is received, regardless of the reporting channel, in
accordance with the provisions of the law.

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Whistleblower
protection

06.1 WHISTLEBLOWER PROTECTION AGAINSTRETALIATION AND DISCRIMINATION
In compliance with the law and the Group’s Code of Ethics,
it is strictly prohibited to retaliate or discriminate in any
way against whistleblowers, facilitators, other protected
persons, or those who assisted in investigations. Any andall retaliatory or discriminatory behavior will be subject
to penalties, even if a report is subsequently found to be
unsubstantiated.
The protective measures in place against retaliatoryand discriminatory behavior also apply to anonymous
whistleblowers if eventually identified.

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Protection of theperson(s) reported
The Group requires everyone’s collaboration to ensure
mutual respect within the organization, and strictly
prohibits any behavior or actions that may undermine thedignity, integrity, and reputation of others. Therefore, theconfidentiality provisions outlined in this Policy also apply
to any person being reported.
A person who has been reported cannot be subjected to
disciplinary sanctions in the absence of concrete, objective
evidence of the alleged violation, or if the reported facts
were not duly investigated, or if the person reported
was not granted the opportunity to contest the charges
in accordance with applicable laws and/or contractual
procedures.
It should be noted that a person who has been reported
is not allowed to inquire about the identity of thewhistleblower, except in cases expressly provided for by
law.

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Processing of
personal data

The processing of personal data in relation to the reports
is carried out in accordance with Regulation (EU) 2016/679(i.e., the General Data Protection Regulation, or GDPR) on theprotection of personal data, as well as with other applicablelaws and regulations to the extent that they are compatible
with the GDPR itself.
In handling the reports for the purposes stated in thisdocument, the information that is processed includes the
personal data of whistleblowers and the person(s) being
reported (i.e., name, position held, etc.), as well any additional
information relevant to the alleged violations and subsequent
investigations, or regarding any third parties involved in thecase. Golden Goose will only process the data that is strictly
necessary for report management purposes, and will promptly
erase any information that is excessive or irrelevant, or thatwas collected inadvertently. In this regard, whistleblowers
are advised to provide only the information that is strictly
necessary to process the report, omitting any personal data
belonging to special categories that could reveal the identity
or sensitive facts about the whistleblowers themselves and/or the person(s) being reported (e.g., personal identification
numbers, bank details, criminal records, health information,
sexual orientation, and/or religious beliefs) while not being
pertinent or relevant to the report.
If deemed necessary, the person(s) being reported and thethird parties involved, if any, may not be immediately notified
about the processing of their personal data, so as to avoid
compromising the effectiveness of an investigation into themerits of an allegation and/or the collection of evidence. Thismeasure is taken for the time strictly necessary to ensure
the proper management of investigations, in compliance withthe provisions of applicable national collective bargaining
agreements.
The legal basis for the processing of personal data is thefulfilment of Golden Goose’s obligations under its Code of
Ethics and Inclusion & Belonging Act, also in light of Italian
Legislative Decree 231/01, Directive (EU) 2019/1937, andItalian Legislative Decree 24/2023, as well as its legal andcontractual obligations, including those towards employees
and collaborators.
Furthermore, where mandated by applicable law, thelegal basis for data processing is the explicit consent of thewhistleblowers and other parties involved, obtained in themanner deemed appropriate and pursuant to the provisionsof the law. If obtaining the data subjects’ consent provesdifficult, Golden Goose may still process their data wherepermitted by applicable law, if deemed necessary to protect
the life, property, rights, and relevant legitimate interests ofthe data subjects themselves or other individuals.
Personal data is accessible to the members of the Ethics

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WHISTLEBLOWING POLICYCommittee and to a limited number of individuals who
provide support to the Ethics Committee. The data is alsoavailable to any other colleagues who may be involved in thereport management process and in the activities connected
therewith, strictly on a need-to-know basis and limited towhat is required for the purpose at hand.
In certain cases, personal data may also be sharedwith external consultants and professionals (e.g., legal
representatives) or public authorities if a reported matter
requires specific measures, including judicial and legal
actions, to safeguard and protect Golden Goose and/or otherthird parties.
All personal data related to the reports will be stored andprocessed in Italy. However, relevant information pertaining
to individual reports may be shared abroad if deemednecessary to facilitate their processing. In such instances,Golden Goose will protect the personal data being transferred
to other countries, including outside the European Union,
through all necessary organizational and technical security
measures.
Golden Goose will store personal data for no longer than isstrictly necessary for the purpose for which it was collected– or, in any case, for no longer than five years from the dateof communication of the final outcome of the reporting
procedure. This means that personal data will be stored forthe period of time required to process the reports and tocompile documentary evidence, should this be necessary toensure the protection of Golden Goose and/or other third
parties, including judicial protection. Personal data will be
stored in both physical and electronic filing systems, inclosed records accessible only to authorized individuals.
Data subjects retain the right to contact the Data
Controller at privacy@goldengoose.com to request, within

the limits of the law, access to and rectification or erasureof their personal data, the restriction of processing, or data
portability. They also have the right to lodge a complaint withthe competent data protection authorities for unlawful dataprocessing.
However, should there be a real risk that the exercise of
the data subjects’ rights pursuant to Articles from 15 to 22of the GDPR (which are exercisable through a request to
the Data Controller or a complaint filed with the competent
data protection authorities for unlawful processing) may
breach the confidentiality of the whistleblower’s identity,
or compromise the effectiveness of investigations into themerits of allegations and/or the collection of necessary
evidence, Golden Goose reserves the right to limit or delay theexercise of such rights, in accordance with applicable laws.
In light of the above, whistleblowers may be asked toacknowledge that they have received and read the personal
data processing information provided herein, or to give
their consent to the transfer of personal data to Golden
Goose S.p.A. from other countries, as per specific local legal
requirements. In such instances, Golden Goose will fulfil all
relevant obligations in accordance with applicable laws andensure adequate levels of personal data protection.

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Conflicts of interest
management

If a report involves, either directly or indirectly, one
or more members of the Ethics Committee, they will be
excluded from the management of the report itself.
Furthermore, in the event of circumstances orsituations in relation to which a member of the Ethics
Committee has a conflict of interest, that individual isrequired to disclose it.
The other members of the Ethics Committee will thendetermine if the conflicted member should be excluded
from meetings regarding reports related to the specificconflict.

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Monitoring and review

The Ethics Committee is responsible for the proper
functioning of the report management process and its
regular monitoring, by defining:

The Ethics Committee provides Golden Goose’s Boardof Directors with documented information ensuring thetraceability of the activities performed, as evidence of theresults achieved.
It is also responsible for the periodical revision of this Policy
and of report management system, and for reporting theresults of its activities to the Board at scheduled intervals toensure the ongoing suitability, adequacy, and effectivenessof the process.

→ areas to be monitored→ monitoring methods→ measurement and assessment timeframes→ communication channels of monitoring outcomes.

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External reporting
channels

08.1 EXTERNAL REPORTING CHANNELS AND PUBLICDISCLOSURES – VALID FOR ITALY ONLY
Whistleblowers are entitled to file a complaint with thecompetent judicial authorities, utilize any available externalreporting channels, and/or make a public disclosure, in
accordance with applicable legislation. In each of these cases,
the Group will protect the whistleblowers, facilitators, andother protected persons as per the provisions of this Policy(e.g., protection against retaliation).
With particular regard to external reporting channels,
whistleblowers may file a report with the Autorità Nazionale
Anticorruzione4 (ANAC – https://www.anticorruzione.it/-/whistleblowing) if the violation being reported meets thecriteria of Italian Legislative Decree 24/2023, available atthe same link.

4. Italian national anti-corruption authority.

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WHISTLEBLOWING POLICYPolicy adopted
on July 05, 2023