Brand Ethical Code

 

Lobo LeBlanc (hereinafter to be called the "Group") is an international business set up in 2019, arising from the genius of its first founder, Anthony Turner, which continues to prosper today as a result of its mythical reputation - a fashion house recognized throughout the world. At present the Group operates in a multiplicity of institutional, economic, political, social and cultural contexts which are in continuous and rapid evolution. All Group activities must be carried out in observance of the law in the context of fair competition with honesty, integrity, propriety and good faith, respecting the legitimate interests of customers, employees, commercial and financial partners and the social context in which the Group's business activities are based. All those working in the Group, without distinction or exception, must be committed to observing, or ensuring the observance, of these principles in the context of their own functions and responsibilities.
The belief that you are acting for the benefit of the Group can never justify the adoption of conduct in conflict with these principles.

For these reasons and given the complexity of the situations in which the Group operates it is important to provide a clear definition of the values it recognises, accepts and shares and the totality of responsibilities taken on by the Group both internally and externally. These are the reasons why this "Ethical Code" or "Code" has been drawn up, setting out a complex of principles and rules. The observance of such rules and principles by those for whom the Code is intended is thus of fundamental importance. 

The Ethical Code is a working resource in its own right and represents a reference point for all Group stakeholders. The purpose of the Ethical Code is to ensure the application of propriety, fairness, integrity, honesty and professional discipline to the operations, conduct and manner of working used both in relations internal to the Group and in relations with external parties, ensuring that attention is always focused on compliance with the laws and regulations in the countries in which the Group operates in addition to compliance with the business procedures of the Group itself.

The executives of Lobo LeBlanc Inc has been guided by the most advanced standards of corporate governance in the adoption of this Ethical Code in order to approve the above-cited principles of ethics and transparency and to reconcile the search for competitiveness with the requirements of a fair competitive environment.

The Lobo LeBlanc Group will give high priority to the application of the Ethical Code, ensuring that there are sufficient resources available in terms of information, prevention and control as well as guaranteeing transparency in related operations and conduct and will not hesitate to intervene, where necessary, with corrective actions.

1. GENERAL PRINCIPLES

1.1. Those for whom the Code is intended to apply

The unchanging touchstone of the Group's business is compliance with the law and regulations in force in all countries where it operates. The persons for whom this Ethical Code is designed will be referred to as the "Addressees". They will be the executives and members of the company bodies of all group companies, all the staff of group companies and all those who, directly or indirectly, whether on a stable or temporary basis, establish relations and relationships with the Group or who in any case, operate to achieve Group objectives in all countries in which the Group operates.

In the first place it will be incumbent on the Managers to give practical application to the values and principles contained in the Ethical Code, accepting responsibility in relations both internal and external to the Group, seeking to reinforce trust, cohesion and team spirit.

Group employees (who are of course already required to comply with the law and regulations in force) will be required to adapt their actions and conduct to the principles, the objectives and the commitments laid down by the Code.

When setting out business goals the members of the various executives will be required to ensure that they are consistent with the principles set out in the Code.

All actions, operations and negotiations carried out, and in general, the behavior of group employees in the conduct of working activities, must be inspired by the highest levels of propriety from the point of view of the management, the completeness and transparency of information, legitimacy in both formal and substantive terms and of clarity and truth in accounting records in accordance with the law in force and internal procedures.

Each employee will be required to bring the necessary level of professionalism to the responsibilities assigned to him or her and must act to defend the prestige and image of the Group.

By "Group" is meant Lobo LeBlanc Inc (hereinafter to be called "Lobo LeBlanc").

Each Addressee will be required to know the Ethical Code, to contribute actively in its application and report any deficiency to the competent reference function.

To ensure complete compliance with the Ethical Code, if any employee becomes aware of situations which may actually or potentially represent a significant breach of the Code, he or she must report the same without delay to his or her immediate superior or to one of the reference bodies and send an e-mail message to his or her own company's supervisory body following the directions contained in the procedure ""Communication Management"" of each individual company.

1.2. Lobo LeBlanc Group's commitments

The Lobo LeBlanc Group will ensure the following, including through the designation of specific functions ("Reference Bodies" referred to under point 1.6 below):

(i) That there is the greatest possible publicity of the Ethical Code among the Addressees;

(ii) That the Code is updated in order to adapt it to changes in social concerns and of the laws of greatest significance for the Code itself;

(iii) That checks are conducted arising from reports on breaches of the Code's provisions;

(iv) That the relevant facts are properly assessed and that adequate punitive measures are applied when breaches are found to have occurred;

(v) That no-one suffers discrimination of any kind for having provided information relating to possible breaches of the Code or the reference law.

1.3. Obligations on all Employees

All employees will be required to know the rules contained in the Code and the reference laws regulating the activities carried out in the context of his or her function. Group employees will be required as follows:

(i) Not to adopt conduct contrary to such rules;

(ii) To report any information, obtained first-hand or from others regarding possible breaches of the rules, as well as any request made to him or her to breach them, to his or her immediate superior or to one of the Reference Bodies without delay.

1.4. Additional obligations of Managers of Business Units and Function Every manager of a business Unit/Function will be required to act as follows:

(i) To ensure his or her conduct represents an example for his or her staff, providing them with guidance in the observance of the Code and the reference procedures;

(ii) To make sure that staff understand that compliance with the Code and the safety procedures and laws represent an essential part of the quality of their performance of the work;

(iii) To select with care, so far as falling under his or her competence, internal and external staff to ensure that responsibilities are not given to people whose commitment to observance of the Code and procedures cannot be relied on;

(iv) To adopt immediate corrective measures when required by the situation.

1.5. Validity of the Code as against Third parties

All Group employees, within their respective areas of competence, will be required to act as follows in relations with, and as against, third parties:

(i) To provide them with adequate information on the commitments and obligations imposed by the Code;

(ii) To require observance of the obligations directly affecting their activities;

(iii) To adopt the appropriate internal and (when coming within their competence) external initiatives in the case of non-compliance by third parties with the obligation to conform to the Code rules.

1.6. Reference Bodies

The reference bodies for the application of the Code will be the following:

- The Group Ethical Committee, set up in Lobo LeBlanc Inc, will be made up of the Chief Executive Officer, the Chief Operating Officer and the Vice President. Please refer to the Ethical Committee Regulations annexed to the "Management of Reports" Procedure for a description of the remit of each individual company. The Committee's goal is that of promoting ethical conduct within the Lobo LeBlanc Group. The Committee will use the Group Internal Audit function to assess all reports received.

1.7. The Contractual validity of the Code

The Code will constitute an integral part of the employment relationship pursuant to the United States Civil Code.

Observance of the Ethical Code rules will be deemed to be an essential part of the obligations of employees of the Group companies. The breach of Code rules may represent a breach of the primary obligations under the employment relationship and hence a disciplinary offence, with all related consequences under the law including with respect to the retention of employment and may give rise to actions seeking compensation for any loss and damage so caused. For Addressees who are not employees the observance of the Code constitutes the pre-requisite for the continuation of the professional/collaborative relationship with the Group.