Code of Business Practices

Ethics Guide

GUCCI GROUP CODE OF BUSINESS PRACTICES 

Contents

1 Introduction from Robert B Polet, President

and C.E.O. of Gucci Group 3
2 Business Ethics in Practice 4
Shared principles
Shared responsibilities
3 Group Commitments
Rules of Conduct 6
Colleagues and Employees 7
Customers and Consumers 9
Shareholders 10
Business Partners 12
Environment and the Communities 15
4 Implementation and Follow-up 16
5 Applying the Code of Business Practices 17
6 Contacts 18

GUCCI GROUP CODE OF BUSINESS PRACTICES 

Gucci Group, the third largest luxury group
in the world, provides excitement and glamour
that attracts a broad-based audience –
thanks of course, to its young, creative, and
edgy designers. Its appeal is spread across ages,
genders and nationalities.
Introduction
Robert B Polet
President, Chief Executive Officer and
Chairman of the Management Board
As Gucci Group Employees, we are all aware
of our duty to protect the legacy of our
heritage brands such as Gucci, Yves Saint
Laurent, Boucheron and Balenciaga, while
fostering the growth of our brands such as
Bottega Veneta, Stella McCartney, Alexander
McQueen, Sergio Rossi, BEDAT&CO and
YSL Beauté.
Our Reputation
Our brands deserve their reputations for
excellence not only because of their
contributions to the world of fashion and
luxury goods, but also because of their
respect for sound business practices. To
honor the strength and history of Gucci
Group, it is critical that each of us acts with
the utmost integrity, honesty and fairness in
all we do. Only by acting consistently with
each of these principles will we be able to
protect the unique reputation which
distinguishes our Group today.
Our Code of Business Practices
PPR, our parent company, has developed a
Business Code of Conduct to provide
guidelines to everyone working within the
Group. At Gucci Group we have decided to
implement the PPR Business Code of
Conduct, and to adapt it to reflect our
businesses.
1
Each one of us has a responsibility to ensure
the growth and prosperity of the Group by
operating in an ethical manner with each
other, our partners and our shareholders.
Our Commitment
I hope that this Code of Conduct will answer
your questions on ethical business practices.
This Code outlines the rules of conduct that
we all have to follow in our daily business
practices.
It clearly expresses our wish to combine
long-term economic performance with fair
and honest business practices towards our
partners and the environment in which we
operate.
I know you will join me in making a
commitment to ethical behavior in order to
encourage even greater growth and respect
for our Group.
All the Best,
Robert Polet
GUCCI GROUP CODE OF BUSINESS PRACTICES 
Gucci Group is committed to behaving
responsibly and with integrity in all circumstances.
An unswerving ethical approach to conducting
business is critical to ensure a company’s
long-term survival.
Business Ethics in Practice
Shared principles
Success and long-term growth in our
markets depend on the confidence of
our customers, employees, shareholders,
business partners and local communities.
Such confidence is built up gradually.
It has to be earned day after day.
In the business world, ethics may take
numerous and even contradictory
appearances. This is especially true for a
company such as ours that operates in
virtually all the continents of the world,
in countries with different cultures and at
different stages of economic development.
We believe that a small number of simple
but powerful shared principles can serve as a
guideline for resolving dilemmas and conflicts,
assuming that we act in a responsible manner
and use our common sense.
These shared principles are as follows:
Behave with integrity and responsibility.
Respect applicable laws and regulations.
Respect the dignity and the rights of our
employees, customers, business partners
and shareholders.
Respect the environment.
Treat corporate assets and resources in the
interest of Gucci Group and its shareholders.
Support our employees and business units
in social solidarity initiatives.
Do not disclose information about
customers or about the business dealings
of the Group and its companies.
2
Our Code of Business Practices is based
on a number of international standards:
The United Nations Universal Declaration of
Human Rights and the European Convention
on Human Rights
International Labour Organisation
conventions 29, 105, 138 and 182 (child
labour and forced labour), 155 and 120
(occupational safety and health, and hygiene),
111 (discrimination), 183 (maternity
protection), 100 (equal remuneration),
87 and 98 (freedom of association and the
right to organise and collective bargaining)
The OECD guidelines for multinational
enterprises
The United Nations Convention on the
Rights of Children
Gucci Group shares the general philosophy
and the principles contained in the above texts
GUCCI GROUP CODE OF BUSINESS PRACTICE 
Business Ethics in Practice
Shared responsibilities
Being a manager implies specific
responsibilities in addition to those we
all have as Gucci Group employees
The first requires us to provide an example
by our own behaviour towards our team
members; this is a fundamental condition to
succeed in the implementation of this Code.
The second concerns our role as active
supporters to explain both to our
teams and to our external partners the
importance of the principles outlined in
this Code and how we can put them into
practice.
Finally, we have to be vigilant in having the
Code principles respected by our team.
The following text details the shared
responsibilities of the employees and
managers of Gucci Group.
Group employees
Contribute to maintaining health and safety
in the workplace and to ensuring the
professional and personal well-being of
colleagues.
Act in a responsible and fair manner.
Ensure that our individual actions reflect
the philosophy of Gucci Group and its
Code of Business Practices.
Exchange views on the implementation
of the Code of Business Practices with
colleagues and managers and suggest
improvements.
2
Group managers
Create and maintain health and safety in
the workplace and the professional and
personal well-being of team members.
Lead by example.
Act in a responsible and fair manner.
Encourage discussion of the Code of
Business Practices.
Promote and introduce the Code of Business
Practices within the company.
Encourage employees to seek advice and
help to answer their questions; respect
their judgment.
Take appropriate measures should actions
deviate from the principles outlined
in our Code of Business Practices.
GUCCI GROUP CODE OF BUSINESS PRACTICES 
In addition to the Principles described on previous
pages we have defined a set of rules that all our
employees should use to guide their decisions

3
and conduct with respect to the various people
they may be in contact with, be it on a regular or
occasional basis.

Group Commitments
Rules of Conduct

Obligations and Responsibilities Shareholders Local communities and countries in

with regards to:
Ourselves
We owe it to ourselves to act with
integrity and loyalty.
Colleagues and Employees
We believe in dealing respectfully and
fairly with colleagues and employees and
in doing our best to foster motivation in
the workplace and to develop employee
potential.
Customers and Consumers
We aim to provide customers and
consumers with our very best professional
service and to earn their confidence.
We are committed to winning the
confidence and support of our shareholders
by using Gucci Group’s resources responsibly
and efficiently.
The Financial Markets
We aim to provide timely statements of
our financial results and to communicate
information accurately and efficiently.
Economic and Social Partners
We believe in nurturing and maintaining
loyal and equitable long-term relationships.
The Environment
We are committed to environmental
stewardship and to the sustainable
development of our businesses.
which we have a local presence
We are fully committed to Human Rights
standards and we intend to act as a socially
responsible company in all the countries
where we operate.
Competitors
We support free, fair and loyal competition,
both where prices and the quality and choice
of products are concerned. We believe this is
a factor of economic and social progress and
that such a policy is in the interest of both
consumers and final customers.

GUCCI GROUP CODE OF BUSINESS PRACTICES 

Group Commitments
Rules of Conduct
Colleagues and Employees
Our employees are a core asset of
Gucci Group and play a key role in
the Group’s performance.
Our human resources policy aims to
contribute to the professionalism,
motivation and satisfaction of each of our
employees. It provides opportunities for
training, mobility and internal career
promotion.
We ensure that working conditions conform
to Human Rights standards and labour
legislation, as well as to the regulations
governing environmental protection and
health and safety matters. We do not tolerate
discrimination, intimidation, harassment, child
labour or forced labour.
We encourage the freedom of speech of
employees. We also encourage dialogue and
respect freedom of association and trade
union rights within the legal framework of
the different countries in which we operate.
We ensure the health and safety
of employees
­One of our top priorities is the health and
well-being of our employees. We make sure
that the work environment of our employees
meets health and safety regulations, and we
firmly believe in prevention.
Each manager has the following obligations
concerning his/her area of responsibility:
Respect applicable legislation.
­­
Implement all necessary protection and
prevention measures.
­
Train staff on the different aspects of safety,
rules and procedures and familiarise them
with the use of safety equipment.
Analyse accidents and incidents to find out
the causes and take preventive action.
­ race, ethnic origin, nationality, political
Supervise the application of health and safety
rules and procedures.
All employees must respect the applicable
health and safety rules.
3
We ensure equal opportunities
­We support equal employment
opportunities, and we are committed to the
successful integration of all Group employees.
One of management’s missions is to
familiarise new recruits with their work
environment and guide their career
development.
­
We treat employees in a respectful and fair
manner, and this applies equally to wages and
benefits. We do not tolerate discrimination,
intimidation, or harassment. Individual
managers and employees are required to
act on these principles.
­
Where career development is concerned,
selection and promotion are made uniquely
on the basis of experience and skills and
take no account of such criteria as gender,
opinions, religion, physical handicap or
sexual orientation.
GUCCI GROUP CODE OF BUSINESS PRACTICES 
Group Commitments
Rules of Conduct
Colleagues and Employees
We optimise employee satisfaction
We are committed to empowering
employees and enhancing their skills, as we
believe this will develop their potential and
contribute to the growth of our businesses.
As part of this philosophy, we evaluate skills
and performance on a regular basis.
We inform employees about career
prospects and mobility within Gucci Group’s
companies and brands.
Each manager is responsible for ensuring a
positive climate in the workplace. This is
achieved by mutual respect, the right to make
mistakes, a team spirit and respect for privacy.
We believe that job satisfaction goes hand-
in-hand with personal satisfaction.
We therefore respect employees’ personal
engagements in the political, associative,
cultural and educational spheres insofar as
these do not interfere with their
performance of their professional
responsibilities or harm the good reputation
of Gucci Group.
We promote freedom of speech by
employees and social dialogue
We respect the freedom of association and
support a process of consultation through
the various employee representative bodies
within the legislative framework of the
countries where we operate.
We encourage information sharing and
dialogue as a way to understand, share and
address the aspirations and constraints of all
parties. In particular, we keep employees
informed of our business performance and of
key events affecting them collectively or
individually.
In line with Gucci Group’s 'speak honestly'
policy, all employees should feel free to
express their views and defend their ideas
when speaking with managers or colleagues.
In addition, employees should take care
to respect the opinions of others when
expressing their views.
What happens if the rules are not respected?
Non-respect of the above rules may
adversely affect the climate in the workplace
as well as employee satisfaction and health
and safety. Breach of the rules may include
harassment, discrimination, and disregard of
safety regulations.
3
Notwithstanding the existing procedures in
place within each division, if the rules are
infringed or are simply not applied, or if they
give rise to conflict, employees are
encouraged to discuss the matter among
themselves and/or to inform either their
immediate superiors or an HR manager, an
employee representative, or a representative
of the worker health and safety committee
when it does exist.
At all times, employees may inform the
Gucci Group representative for the PPR
Committee for Ethics and Social and
Environmental Responsibility. He/she will
listen to them impartially and fairly and will
ensure that the situation is dealt with in an
appropriate manner. In addition, he/she will
ensure that their discussions remain
confidential and will take into account the
legitimate interests of both the employee
and Gucci Group.
In all cases, employees will be informed of the
measures taken as a result of their action.
GUCCI GROUP CODE OF BUSINESS PRACTICES 
Group Commitments
Rules of Conduct
Customers and Consumers
Gucci Group is active in the luxury goods sector
through a range of brand names. We place our
customers at the heart of our business, and we firmly
believe that customer satisfaction and confidence are
the keys to our continuing business success.
To win and preserve the confidence of
customers, our companies market products
and services that conform to applicable
quality and safety standards. They provide
accurate and reliable information on
services and products, and they ensure that
personal information supplied to them by
their customers is kept strictly confidential.
We provide customers with accurate
information on group products and services
Our professionalism and commitment to
customer service means that we seek to
provide guarantees of quality and safety.
Our commercial and advertising
communication reflects our commitment to
honesty and to consumer safety. In this way,
we help our clients become informed
consumers.
Our commercial and advertising
communication conforms to recognised
professional practice.
We ensure that information about
customers is kept strictly confidential
We conform to applicable laws and
regulations to collect, protect, use and
communicate information provided to us
by customers.
We are determined to prevent any breach
of confidentiality and to ensure that no
improper use is made of personal
information provided to us by our customers.
Each customer is free to decide on the
nature of the information that he/she gives
to us. No information will be given to third
parties outside Gucci Group if this has
not first been approved by the customer,
in compliance with the applicable laws
and regulations.
We respect the laws and regulations
applicable in all our business areas
We ensure that all our products and services
conform to the relevant standards and
regulations in respect of quality, safety and
industrial ownership.
3
What code of conduct should we follow
with our customers?
A satisfied customer is a faithful client.
This simple rule should be kept in mind
when dealing with past, present and
future clients. We can demonstrate our
professionalism by paying attention to
quality in such areas as customer service
and customer greeting, and in the way in
which we listen to and inform customers
and manage our after-sales service.
In the event of discrepancies with our
standards of conduct, employees can inform
their manager, their company’s customer
relations department, or their Gucci Group
representative for the PPR Committee for
Ethics and Social and Environmental
Responsibility. The name of Gucci Group
representative can be found on the last page
of this Code or through your Human
Resources office.
GUCCI GROUP CODE OF BUSINESS PRACTICES 
Group Commitments
Rules of Conduct
Shareholders
PPR, our parent company, is listed
on the stock market and is therefore
owned by its shareholders
We are dedicated to winning the
confidence of shareholders through the
responsible use of Gucci Group’s resources
aimed at securing a long-term return on
investment. Gucci Group provides full,
accurate and sincere information to our
shareholders. As necessary, we comply
with applicable financial regulations.
We publish regular and reliable
financial results
We carefully manage all registers, books, and
financial and reporting documents so that
they provide a regular and accurate view
of Gucci Group’s assets and liabilities and
its operating profits and losses.
We do not undertake transactions with a
view to recording them in an irregular or
misleading manner.
We organise checks and controls so that
we can be reasonably sure that:
Transactions are executed with the
appropriate authorisation by the managers
of the businesses concerned.
Transactions are recorded in compliance with
the applicable accounting principles.
­ information pertaining to Gucci Group and
The assets of individual companies are used
only in the interest of the company that
owns the assets.
Balance sheet assets and liabilities are
regularly compared with current asset values
and with the value of current and potential
future liabilities. Any differences that may
arise are investigated and adjustments are
made if necessary.
We communicate on accounting and financial
matters in a reliable and trustworthy manner.
3
We comply with accounting and
financial regulations
We respect relevant accounting rules and
principles.
We implement security measures designed
to protect the confidentiality, availability
and integrity of the accounting and financial
its companies.
We prevent insider trading or the misuse
of privileged information
PPR, our parent company, is listed on the
main Euronext Paris market.
Because of the nature of their jobs, some
of our employees may have access to
confidential or privileged information
concerning Gucci Group and/or its business
partners. Disclosure of such information
could influence PPR’s share price or the
share price of one of our business partners.
Employees with access to such information
are subject to the existing law on insider
trading until the information has officially
been made public by PPR, Gucci Group or
by the company concerned.
GUCCI GROUP CODE OF BUSINESS PRACTICES 10
Group Commitments
Rules of Conduct
Shareholders
While PPR encourages employees to
purchase its shares, we remind you that
employees are strictly forbidden to disclose
confidential or privileged information about
Gucci Group to friends or relatives or to
use it themselves for unfair advantage. This
particularly applies to using such information
directly or via a third party in order to carry
out unauthorised and generally speculative
transactions on the stock market, in the
interest of personal gain or for the benefit
of a third party.
On the basis of recommendations made by
the 'Autorité des Marchés Financiers’ (the
French Market Authority), a Stock Market
Rules Compliance Committee within PPR
designates blackout periods prior to the
publication of the annual and interim results,
during which time, certain managers and
selected employees are legally prohibited
from trading in PPR’s shares.
How can I avoid being involved in
insider trading?
What is insider trading?
You would be guilty of insider trading if you
passed privileged information that had not
yet been made public on to your friends or
relatives or if you used it personally for unfair
advantage. The use of such information can
affect the share price of listed companies.
Insider trading also applies when those
responsible for ensuring that information is
confidential, or for communicating such
information, do not take all the necessary
steps to protect this information until it is
officially published by PPR or Gucci Group.
What are the risks?
If you are accused of insider trading, you
risk legal, financial and administrative penalties
that vary from one country to another.
In addition, you would be damaging Gucci
Group’s financial reputation.
3
What should I do?
To purchase or sell PPR shares related to the
exercise of PPR options, beneficiaries should
refer to the procedures described in the
option plan document that was included with
the letter informing you that you had been
granted options. If you have additional
questions, you can contact your advisory staff
or the PPR Legal Department. They will help
you clarify any doubts you may have as to a
possible conflict with the rule that employees
with privileged information may not trade
PPR shares on the stock market. The advice
they give you in no way alters the fact that
employees are responsible for ensuring that
they are not involved in insider trading.
GUCCI GROUP CODE OF BUSINESS PRACTICES 11
Group Commitments
Rules of Conduct
Business Partners
Gucci Group firmly believes in conducting
its business with integrity and in ensuring that
the principles of loyalty and equal treatment
are mutually respected in our dealings with
suppliers and service providers.
We expect our employees to act according
to these principles and to ensure the
success of our business. We categorically
prohibit the use of child labour or forced
labour. We do not knowingly work with any
partner that disregards our standards of
conduct.
We treat suppliers fairly
We treat suppliers with courtesy and
respect. We adhere to the principles of
loyalty, impartiality and fair treatment when
putting contracts out to bid, notably with
respect to specifications, price negotiations,
and service and product quality. Our
procedures in awarding contracts are
designed to ensure economic objectivity and
transparency. We avoid transactions with
companies not owned by the Group
whenever there is a lack of mutual interest or
a risk of economic abuse.
3
We respect the relevant laws concerning the We are working to communicate our
cancellation of contracts, product or supplier principles to all our partners, which we
delistings, price dumping and other require them to share and respect.
prohibited pricing strategies.
To ensure that these principles are effectively
shared and implemented, we reserve the
We respect industrial ownership and ensure
right to carry out controls, notably via the
that our products and services do not violate
intermediary of private organisations. In the
industrial ownership rights or the ownership
event that suppliers do not comply with our
rights of third parties.
codes of business practice, we will encourage
them to do so and help them determine
We actively dissuade child labour and
what actions need to be taken so that we
forced labour and seek to ensure that our
can continue working with them.
suppliers adhere to these principles
We are profoundly attached to respecting
We do not work with suppliers if we know the guidelines drawn up by International
or discover that they: Labour Organisation and to the conventions
on child labour, safe working conditions and
Infringe the economic, commercial, tax or
human rights.
social laws and regulations applicable in the
countries where they operate,
Employ children under the age of 15, in
conformity with International Labour
Organisation conventions.
Use forced labour of any sort,
­Infringe health and safety rules,
Infringe environmental protection laws and
standards.
GUCCI GROUP CODE OF BUSINESS PRACTICES 12
Group Commitments
Rules of Conduct
Business Partners
We seek to prevent corruption by acting
in strict conformity with the law in respect
of the financing of political parties, conflicts
of interest, gifts or other inducements
from suppliers
Gucci Group requires its employees to
comply with applicable laws and avoid all
situations giving rise to real or potential
conflict between their personal interests
and those of Gucci Group and its companies
or brands, whether directly or indirectly.
To avoid conflict with Gucci Group’s
interests, employees should make sure
that they:
Do not own shares in a company belonging
to a supplier, customer or competitor, other
than minority holdings in a listed company
that are part of a personal investment
portfolio,
Do not act as a director, associate, consultant,
agency, manager or employee for a company
belonging to a supplier, customer or
competitor,
Do not trade stocks or assets in the Group,
or in companies owned by customers or
competitors, when they have confidential
information on the said stocks or assets.
The Group prohibits the financing of political
parties, trade unions, and cultural and social
solidarity organisations in exchange for
material benefits, whether these benefits are
commercial or personal or obtained directly
or indirectly.
Gucci Group prohibits its employees, officers,
and directors from offering or giving illegal
bribes, ‘kickbacks’, or other payments or
gifts designed to improperly influence or
compromise the conduct of the recipient,
and no Gucci Group employee is permitted
to accept such improper payments or gifts
for assisting the payer in obtaining business
or for securing special concessions from
Gucci Group.
­
Most countries in which we do business have
laws that prohibit making payments or giving
gifts to government officials, and countries also
have laws prohibiting payments or gifts to union
officials, business partners, or customers. If you
have questions as to whether a payment or gift
might violate the law in the country in which
you are working, you should consult with your
superior, Human Resources, the Legal
Department, or your Gucci Group representative
for the PPR Committee for Ethics and Social
and Environmental Responsibility.
3
We believe that free, fair and loyal
competition where prices and product
quality and choice are concerned drives
economic and social progress and is in
the interest of both consumers and final
customers
We ensure that we do not infringe fair
competition rules by engaging in defamatory
advertising or making misleading claims.
We apply the laws regarding competitor
and consumer rights. In particular:
We do not enter formal or informal
agreements with competitors when these
would prevent prices from being determined
by standard competitive practice.
We do not enter agreements with
customers and/or suppliers when these
would improperly fix the sales or cost price
of products, illegally restrict a customer’s
rights to sell the product, or improperly
influence the way a product is packaged and
marketed.
GUCCI GROUP CODE OF BUSINESS PRACTICES 13
Group Commitments
Rules of Conduct
Business Partners
What should I do about gifts?
In many countries and fields of business,
gifts and invitations are used to strengthen
a commercial relationship. Gucci Group’s
position on the issue is very clear. No gift,
favour or invitation should be offered or
accepted if it implies or appears to imply
that the person receiving it is under an
obligation to do something in return.
The Company reconizes that in certain
cultures, there may be an occasion when
gift-giving of a more substantial nature is
expected and/or customary. Decisions
about these situations must be carefully
weighed, and discussed with your supervisor.
In addition, there may occasionally be times
when refusing a gift would be embarrassing
or impractical. In those rare instances where
the gift is of substantial value, accept the
gift on behalf of the Company, report it to
your supervisor, and turn the gift over to
your local finance director who will handle
its disposition.
Only invitations or gifts that conform
to recognised commercial practice are
authorised by Gucci Group and must in
all cases conform to relevant legislation
and jurisprudence.
What should I do if there is a conflict of interest?
Anyone worried about a conflict of interest,
current or potential, should ask his/her
manager for instructions on how to deal
with the matter. If necessary, the manager can
consult with senior management and should
give the employee concerned a timely and
confidential reply.
How does Gucci Group ensure that suppliers
respect the rules of conduct?
We conduct internal and external audits
of supplier practices which can lead to
corrective action plans and in some cases to
supplier delisting.
What should I do if I have information that
suggests that a supplier is breaking our Code
of Business Practices?
Any information or eyewitness accounts
according to which a supplier is not
complying with our codes of conduct
should be communicated in writing to
the purchasing manager of your company,
who will decide whether the supplier is in
infringement. If this is the case, your manager
will take the necessary steps to deal with the
situation with the approval of the executive
management, and a copy of the file will be
sent to the PPR Committee for Ethics and
Social and Environmental Responsibility for
information.
3
What should I do if I find that a supplier
is neglecting principles that we believe are
important?
If specific factors give you reason to believe
that our codes of conduct are not being
complied with, you should immediately
prepare a detailed report on them and pass
this on to the purchasing manager of your
company. He/she will take the necessary
steps to deal with the situation with the
approval of our executive management.
A copy of the file will be sent to the PPR
Committee for Ethics and Social and
Environmental Responsibility for information.
If this happens, how should I behave toward
the supplier?
Depending on the situation, we could ask for
additional information, engage in a corrective
action plan to remedy the situation or cease
working with the supplier. These decisions
will be passed down the management line
to you. Unless told otherwise, you should
not discuss the matter any further with your
counterparts at the supplier involved.
GUCCI GROUP CODE OF BUSINESS PRACTICES 14
Group Commitments
Rules of Conduct
The Environment and Communities
Gucci Group is present in many countries
around the world and is dedicated to making
a positive contribution in all the regions
where it operates
This contribution is expressed in our
respect and defence of such fundamental
principles as the universality of Human
Rights and the respect of laws and
regulations, notably as regards the
environment, competition and social
legislation.
Our businesses contribute positively through
their participation in the economic and social
development of the countries where they
operate. We listen to the concerns expressed
by institutions, organisations and international
and local community associations concerned
by our businesses.
We respect the culture of the countries in
which we operate, and we seek to minimise
the environmental impact of our businesses.
We are committed to the Principles
of Human Rights
We seek to ensure that Human Rights
are respected in our spheres of business
and influence.
We combat the use of child labour and
forced labour as defined by International
Labour Organisation conventions.
We are attentive to the concerns expressed
by international and nongovernmental
organisations as well as by the elected
representatives of local communities.
We constantly strive to improve our
contribution to the economic and
social conditions of the countries where
we operate
Through our businesses, we contribute to
the economic and social development of
the countries where we operate, but as
a corporate entity, we do not seek to
influence or get involved in national politics.
3
We respect the culture of the countries
where we operate.
We favour initiatives taken by our
companies and employees with respect
to sustainable development and social
solidarity, when possible.
We are seeking to minimise the
environmental impact of our businesses
We are extremely careful to respect the
environmental regulations and standards
applicable in each of the countries we
operate in.
We attempt to minimise the impact of
our businesses on the environment.
We encourage discussion and
implementation of best practices and
consider this to be an extremely positive
feature of our management procedures.
GUCCI GROUP CODE OF BUSINESS PRACTICES 15
This Code of Business Practices is intended for
and concerns all managers and employees of
Gucci Group. Every employee will receive an

4
electronic or hard copy version of this Code.

Implementation
and follow-up

Managers will be available to explain
the philosophy behind the Code, why it is
important and how it should be applied.
Employees should use their copy of the
Code to familiarise themselves with the
commitments and principles that shape our
Code of Business Practices. In addition, our
parent company, PPR, has set up a special
organisation to advise employees on
business ethics and to determine ways and
means of improving the implementation of
our code of practice.
In view of PPR’s decentralised structure,
PPR has asked Gucci Group to choose
a representative who will liaise with the
PPR Committee for Ethics and Social and
Environmental Responsibility. This person’s
mission is to help ensure that our Code of
Business Practices is properly implemented.
He/she will deal with any questions you may
have concerning its application. Companies
may also set up additional support structures,
for example by appointing assistant
representatives to liaise with employees in
overseas markets or businesses.
Please note that the existence of the
PPR Committee and the Gucci Group
representative does not change existing
grievance or disciplinary procedures already
in place for various divisions, countries
or workplaces.
A list of representatives can be obtained
from the Human Resources Department
of Gucci Group or downloaded from
PPR’s website (www.ppr.com), and contact
information for Gucci Group representative
is on the last page of this Code.

This organisation, known as the PPR
Committee for Ethics and Social and
Environmental Responsibility, reports to the
PPR Board. It is composed of at least one
representative from the companies, functional
managers and external experts. The
Committee’s primary mission is to help PPR
companies implement the Code of Business
Practices and formulate recommendations
based on questions that may arise during this
task and on questions asked by PPR and its
companies.
Application of the Code of Business Practices Representatives undertake to reply to all
may sometimes raise questions of a sensitive employees who contact them and to inform
nature. As a result, any information that them of the decisions made in the respect
employees provide to the PPR Committee of their questions and comments.
for Ethics and Social and Environmental
Responsibility, or to one of its representatives,
will be treated in a confidential manner,
taking into account the legitimate interests
of Gucci Group and its companies.
Employees with questions concerning
the application of the Code of Business
Practices should contact Gucci Group
representative or address directly the
PPR Committee for Ethics and Social
and Environmental responsibility at PPR’s
corporate headquarters.

GUCCI GROUP CODE OF BUSINESS PRACTICES 16

Below are some questions that you can ask yourself.
They will help you ensure that you comply with our
Code of Business Practices and enable you to
participate actively in its implementation.
Applying the
Code of Business Practices
Is it legal?
You should not decide or do anything unless
the answer is YES with respect to the
relevant laws and regulations. You should take
no action if the answer is NO or if you
strongly suspect that it is NO. In any case,
you should either contact the Gucci Group
representative for the PPR Committee for
Ethics and Social and Environmental
Responsibility, or the Human Resources or
Legal Department of your company.
Could my conduct or conduct that I know
about damage the group’s interests in the
short, medium or long term?
Take for example environmental practices
that could result in a serious health and/or
financial crisis. In such a case, you should put
a stop to these practices and ask either your
manager or your Ethical Committee
representative for advice.
Can I speak freely about the matter?
If, barring confidentiality rules, you find it
difficult to speak freely about what you have
done (or might do) or of actions that you
know about, it is highly probable that the
practice does not comply with our Code of
Business Practices.
What should I do if I can’t speak freely
about the matter to my manager?
Whether or not the action has been
performed, it is recommended that you talk
to the Gucci Group representative of the
PPR Committee for Ethics and Social and
Environmental Responsibility, who will advise
you on how to proceed. Our Code of
Business Practices requires that what you say
is carefully listened to and that the relevant
issues are dealt with in an appropriate
confidential manner, in the legitimate interest
of both the employee and Gucci Group.
Do I feel guilty?
If doing something or not doing something
makes you feel guilty, you can decide to stop
doing it or stop not doing it, or you can
discuss the matter before making a decision.
You can either talk to your manager or to
the Gucci Group representative for the PPR
Committee for Ethics and Social and
Environmental Responsibility.
How can I make up my mind?
If you have any doubts whatsoever
concerning what to do or what not to do,
you can contact the Committee for Ethics
and Social and Environmental Responsibility
or talk to your committee representative.
5
What should I do if I disapprove of
someone’s conduct?
You can do several things. You can speak
directly to the person concerned or to your
manager. Depending on the situation, you can
also contact your human resources manager,
employee representatives, or your Health
and Safety Committee representative.
In every situation, you can contact the Gucci
Group representative for the PPR
Committee for Ethics and Social and
Environmental Responsibility. He/she must
ensure that what employees say is kept
confidential, in the legitimate interest of
employees and Gucci Group.
In all cases, he/she shall inform you of what
decision has been made. With respect to
some legal issues in our Code of Business
Practices, you can directly contact the Legal
or Internal Audit Departments of Gucci
Group and/or one of the Group’s companies.
GUCCI GROUP CODE OF BUSINESS PRACTICES 17
Gucci Group
Contacts
Gucci Group
The Gucci Group representative for the
PPR Committee for Ethics and Social
and Environmental Responsibility is
Cheryl Solomon, General Counsel
and can be reached at
Gucci Group
Rembrandt Tower
Amstelplein I
1096 HA Amsterdam
The Netherlands
T +44 20 7898 3015 or
E generalcounsel@guccigroup.com
Legal
The Legal Department can be
reached through the General Counsel
Cheryl Solomon, or her successor, at
T +44 20 7898 3015
E generalcounsel@guccigroup.com
6
Internal Audit This document is published by the Gucci
The Internal Audit Department can Group Communications Department
be reached through the Director of Internal
Gucci Group
Audit Stefano Comotti, or his successor, at
Rembrandt Tower
T +39 055 7592 2439 or Amstelplein I
E internalaudit@guccigroup.com 1096 HA Amsterdam
The Netherlands
Or you can send a confidential email to
E ethics@guccigroup.com
Security
The Security Department can be
reached through the Director of Security,
Carlo Del Bo, or his successor, at
T +39 02 8800 5530
E directorsecurity@guccigroup.com
If you wish to contact the PPR
Committee directly, you can write to
The Committee Secretary
10 avenue Hoche
75381 Paris Cedex 08
FRANCE
Send a confidential email to
E ethics@pprgroup.com
GUCCI GROUP CODE OF BUSINESS PRACTICES 18