Code

of Conduct
Code
of Conduct

March 2024
LVMH / Code of Conduct 3

Contents

A Message from the Chairman.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Executive Committee Commitment .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Group Values .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Governance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Application and dissemination of the Code of Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Alert System.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

A committed group .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Respecting fundamental rights.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Protecting the environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Promoting a responsible approach among partners and suppliers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

A responsible employer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Promoting a kind, inclusive working environment .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Ensuring quality of life at work. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Ensuring health and safety.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

A group with integrity .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Fighting corruption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
Preventing conflicts of interest.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Fighting money laundering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Complying with international sanctions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
Promoting free and undistorted competition .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
Maintaining confidentiality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
Protecting the integrity of the financial markets and preventing insider trading .. . . . . . . . . . . . . . . . . . . . 31
Respecting privacy .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
Participating responsibly in the public sphere. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
LVMH / Code of Conduct 5

A Message from the Chairman

A company’s real successes are those that stand the test of time and help build a sustainable
society.

At LVMH and in our Maisons, this longstanding conviction is embodied daily in our products,
commitments, and actions.

We owe our success to our products, which have worldwide appeal. Their desirability stems
from our demand for the highest quality, which our artisans deliver thanks to their exceptional
savoir faire. It also stems from our Maisons’ constantly renewed creativity, their innovative
spirit, and their openness to the world. Each Maison is working to make our prestigious
heritage sustainable.

We have also long distinguished ourselves by making strong commitments to and taking
care to comply with the highest standards of ethics and integrity, social responsibility, and
respect for the environment everywhere in the world.

This Code of Conduct has been completely rewritten to express these commitments in the
form of principles and rules to guide our daily activities.

It includes and details all the sustainability factors.

While the principles and rules set out in this Code are intended to be as complete and pre-
cise as possible, this Code also refers to other instruments that have been written over the
past several years. Together they form our ethics framework, which governs LVMH’s and its
employees’ activities.

It goes without saying that all LVMH employees must comply with and embody these principles.

The Ethics and Sustainable Development Committee of LVMH’s Board of Directors will
monitor compliance with these principles.

The members of the Group’s Executive Committee will promote these commitments in their
respective areas of responsibility.

In addition, each Maison’s President and their employees must make this common ethics
framework their own and embody its principles.

That is what will guarantee our long-term success.

Bernard Arnault
LVMH Chairman and Chief Executive Officer
LVMH / Code of Conduct 7

Executive Committee Commitment

Aware of the role they must play in promoting the principles set forth in this Code of Conduct,
the Executive Committee members will promote these commitments in their respective
areas of responsibility.

ANTONIO BELLONI DELPHINE ARNAULT NICOLAS BAZIRE

GROUP MANAGING DIRECTOR CHRISTIAN DIOR COUTURE DEVELOPMENT AND ACQUISITIONS

PIETRO BECCARI STÉPHANE BIANCHI MICHAEL BURKE

LOUIS VUITTON WATCHES & JEWELRY FASHION GROUP

CHANTAL GAEMPERLE JEAN-JACQUES GUIONY CHRIS DE LA PUENTE

HUMAN RESOURCES AND SYNERGIES FINANCE SELECTIVE RETAILING

STÉPHANE RINDERKNECH PHILIPPE SCHAUS

LVMH HOSPITALITY EXCELLENCE & BEAUTY WINES & SPIRITS

JÉRÔME SIBILLE JEAN-BAPTISTE VOISIN

GENERAL ADMINISTRATION & LEGAL AFFAIRS STRATEGY
LVMH / Code of Conduct 8

Group Values
The LVMH group (“LVMH” or the “Group”), which has more than 75 Maisons, is the only player
that operates in six major luxury sectors: Wines & Spirits, Fashion & Leather Goods, Perfumes
& Cosmetics, Watches & Jewelry, Selective Retailing, and Other Activities.

The Group owes its success and longevity to the values and principles on which its culture
is based and which inspire and guide everyone’s actions.

Be creative and innovative

Creativity and innovation are part of LVMH’s DNA. They have always been key to its Maisons’
success and the basis for their legitimacy. The Maisons are built on creativity and innovation,
which enable them to achieve a delicate balance between continually renewing their offer
and resolutely looking to the future while respecting their unique heritage.

Deliver excellence
There is no compromising on quality in our Group. The Maisons embody what is most noble
and accomplished in the world of craftsmanship, paying meticulous attention to detail and
striving for perfection, from the product to the service. It is in our pursuit of excellence that
the Group distinguishes itself.

Cultivate an entrepreneurial spirit

The Group’s agile, decentralized organization promotes efficiency and responsiveness. It
encourages individual initiative by assigning important responsibilities to everyone. The
entrepreneurial spirit promoted by the Group makes it easier to take risks and encourages
perseverance. It also requires pragmatism and an ability to motivate one’s teams while leading
them toward ambitious goals.

Be committed to positive impact

Every action taken by the Group and its employees reflects LVMH’s commitment to ethics,
corporate social responsibility, and respect for the environment. This commitment drives the
Maisons’ performance and ensures their sustained long-term success. Firmly convinced that
truly desirable products can only come from sustainable businesses, the Group is committed
to actively contributing to a better future and to ensuring that its products and the way they
are made have a positive impact on its entire ecosystem.
LVMH / Code of Conduct 9

Governance
To ensure that its strong ethics culture is as widespread as possible, LVMH has instituted a
governance structure that fits the Group’s profile, its operational realities, and its decen-
tralized operating method.

That structure includes:

• the Ethics and Sustainable Development Committee of the Board of Directors, which
monitors respect for the individual and collective values on which the Group bases its ac-
tivities, and which has the following main duties:

– help the Board of Directors determine the Group’s main strategy in social, environ-
mental and climate matters, and help develop rules of conduct to guide the behavior
of top management and employees;
– monitor compliance with those rules; and
– monitor the systems that are set up.

• LVMH’s Chairman & CEO and Executive Committee members, who promote the
Group’s commitments in the areas of ethics and social and environmental responsibility;

• the Maisons’ Presidents, who ensure that this Code of Conduct’s principles are dissemi-
nated in their respective areas and properly applied by employees;

• the Group ESG Committee, which includes the Group’s operational divisions, supports
and coordinates the implementation of the Group’s strategic ethics and social and envi-
ronmental responsibility objectives. It relies on networks of expert correspondents who
actively help roll out Group initiatives in these areas and provide relevant information for
the consolidated report;

• the Ethics and Compliance Department, which steers and coordinates LVMH’s ethics
and compliance approach. This department is supported by a network of correspondents
appointed by the Presidents of each Maison. Their role is to implement the Group’s ethics
standards within their organization.
LVMH / Code of Conduct 10

Application and dissemination

of the Code of Conduct

Compliance with laws and regulations, in particular in the areas of ethics and environmental
and social responsibility, is key to the Group’s credibility and actions in these areas.

This Code of Conduct, which reflects the Group’s commitments in this regard, applies to all
Group employees. It must be distributed in all Maisons and Group entities and given to all
new employees when they arrive. It is supplemented by each Maison’s codes and policies,
which employees of the relevant Maison must refer to.

This Code of Conduct is available on the LVMH website and the Group’s intranet, and can be
downloaded in several languages.

Each manager is responsible for embodying the Code of Conduct’s commitments and pro-
moting them within their teams.

Each employee must personally comply with these commitments in all circumstances.

Any employee who is unsure of what they should do in a particular situation or of how to
interpret the principles set forth in this Code is encouraged to contact their manager, their
Ethics & Compliance Correspondent, or the Group’s Ethics & Compliance Director (in par-
ticular, at ethics@lvmh.com).

If an employee does not comply with the principles set forth in this Code or any related
policies, they may be subject to disciplinary measures and sanctions proportionate to the
seriousness of their actions. Such sanctions may include dismissal.
LVMH / Code of Conduct 11

Alert System

LVMH encourages a culture of dialogue and communication within the Group.

The Group has adopted a Group Alert Policy that describes the system for receiving and
following up on reports.

Any employee who is facing a situation likely to constitute a violation of applicable laws or
regulations, or of the principles set forth in this Code or in the policies of the Group or its
Maisons, is encouraged to report the situation without delay to Human Resources or to
their Ethics & Compliance Correspondent.

In addition to these channels, LVMH has set up a centralized, secure alert system that gua-
rantees confidentiality: the “LVMH Alert Line.” This online platform can be accessed on the
Group’s website or at https://alertline.lvmh.com. It is open to all employees and external
stakeholders.

The Group maintains the integrity and confidentiality of reports at all times.

Retaliation is prohibited against anyone who uses this system in good faith or anyone who
assists a whistleblower or is connected with them, even if the reported allegations turn out
to be inaccurate.

For more information, please see the Group Alert Policy.

LVMH / Code of Conduct 13

A committed group

13
LVMH / Code of Conduct 14

Respecting fundamental rights

LVMH respects human rights wherever the Group operates.

The Group believes that this is a requirement inherent in its corporate purpose, inseparable
from the values of the Group and its Maisons and from their corollary, respect for the dignity
of every individual.

LVMH expects all its employees and partners to comply with the same standards in this area.

LVMH supports the continual improvement of social, societal, and health conditions, which
are key factors in development and in the protection of persons.

For example, LVMH strives to have fair and equitable pay practices. The Group has developed
a fair wage policy (the Fair Wage Principles) based on fifteen principles that must be complied
with by the Maisons and their partners and suppliers.

Within its sphere of influence, LVMH promotes the fundamental principles, rights and free-
doms adopted by the international community, and in particular the Universal Declaration
of Human Rights, the International Covenants on Civil and Political Rights and on Economic,
Social, and Culture Rights, the United Nations Guiding Principles on Business and Human
Rights, the fundamental conventions of the International Labor Organization, and the OECD’s
Guidelines for Multinational Enterprises, especially Chapter IV.

The Group is vigilant, in accordance with the law, about identifying any direct or indirect
negative societal impacts its business may have in order to prevent and, where necessary,
remedy them.

LVMH has therefore developed a vigilance plan to ensure that its business model is consistent
with respect for human rights and fundamental freedoms, personal health and safety, and
the environment.

In performing their duties, all LVMH employees must comply with and promote human rights
every day.

For more information, please see:

– Supplier and Business Partner Code of Conduct;
– Group Vigilance Plan (Universal Registration Document);
– LVMH Social and Environmental Responsibility Report.
LVMH / Code of Conduct 15

Protecting the environment

LVMH respects the environment and complies with the ten principles of the United Nations
Global Compact and the related Sustainable Development Goals.

LVMH aims to limit negative environmental impacts and maximize positive measures in order
to help combat climate change and protect natural resources and biodiversity.

The LIFE (LVMH Initiatives for the Environment) program, which is frequently updated to
reflect the direct and indirect calculation of our environmental footprint, is the operatio-
nal embodiment of the Group’s responsible, forward-looking approach to protecting the
environment. LIFE includes four strategic plans and sets precise targets to be reached by
defined dates. These targets apply to all Maisons, which are encouraged to adopt circular
and creative economy methods to protect natural resources while improving their products’
sustainability and intergenerational transmissibility.

Developing creative circularity

The Group uses creativity, a core LVMH value, to reduce its products’ environmental impact.
By upcycling, recycling, using fabric and leather remnants, and developing new processes,
LVMH creates inventive materials that will help change society’s representations of what is
beautiful.

Protecting biodiversity
Nature’s wealth is what makes each Maisons’ products exceptional. Protecting and rege-
nerating ecosystems and combating hydric stress are therefore imperatives that require
long-term multi-partner actions grounded in science.

Taking action for the climate

In accordance with the Group’s climate goals, LVMH and its Maison implement action plans
that reflect the reality of the stakes in each business sector and mobilize their stakeholders,
whether they are internal functions (purchasing, logistics, retail, studio, etc.) or external
partners and suppliers.

Guaranteeing traceability and transparency

Supply-chain traceability is a prerequisite for guaranteeing responsible practices. It requires an
ambitious, strict definition of the chain of custody system. LVMH has therefore adopted the
definition of the International Social and Environmental Accreditation and Labelling Alliance
(ISEAL), which is based on knowledge of “the complete set of documents and mechanisms
used to verify the traceability between the verified unit of production and the claim about
the final product.”

All LVMH employees are encouraged to take steps to save energy and respect biodiversity,
and to actively participate in the Group’s awareness and training programs.

For more information, please see:

– LIFE 360 Program;
– Group Vigilance Plan (Universal Registration Document);
– LVMH Social and Environmental Responsibility Report.
LVMH / Code of Conduct 16

Promoting a responsible
approach among partners
and suppliers
LVMH strives to maintain and promote a responsible approach vis-à-vis its partners and sup-
pliers, which are a key link in the LVMH value chain. The Group thus aims to share its values
of excellence, innovation, and commitment.

LVMH also helps its partners and suppliers institute and comply with demanding social and
environmental practices while raising awareness about new issues in these areas.

In particular, in its contracts with partners and suppliers, LVMH asks them to comply with
the principles set forth in the LVMH Supplier and Business Partner Code of Conduct and to
ensure that their own partners and suppliers do the same when doing business for the Group.

The Supplier and Business Partner Code of Conduct sets forth:

• the Group’s social responsibility standards;

• the environmental performance challenges set by LVMH;

• the Group’s business ethics and integrity requirements;

• the need for the partners and suppliers to have a grievance mechanism and the fact that
they can access the LVMH Alert Line;

• LVMH’s right to control its partners and suppliers and access information in their posses-
sion; and

• the partners’ and suppliers’ agreement to comply with the Supplier and Business Partner
Code of Conduct’s requirements.
LVMH / Code of Conduct 17

If a partner or supplier does not comply with the Supplier and Business Partner Code of
Conduct, the Group entities doing business with them may demand that non-compliances
be corrected, suspend purchasing, refuse to accept deliveries or return any goods until
remedial measures are being taken, and may terminate their business relationship with any
such partner or supplier, without prejudice to any other right or recourse.

In addition, any partners or suppliers that are aware of a violation (or a risk of violation) of this
Code of Conduct, the Supplier and Business Partner Code of Conduct, and/or any applicable
laws or regulations are encouraged to make their concerns known to their LVMH Group
contact(s) or to file a report through the LVMH Alert Line.

All LVMH employees must ensure that the partners and suppliers with which they work agree
to comply with the principles set forth in the Supplier and Business Partner Code of Conduct.

.
For more information, please see the Supplier and Business Partner Code of Conduct.
LVMH / Code of Conduct 18
LVMH / Code of Conduct 19

A responsible employer

19
LVMH / Code of Conduct 20

Promoting a kind,
inclusive working environment

Combating all forms of discrimination

LVMH is committed to ensuring that its employees enjoy their rights without distinction
based on ethnic, national, social, or cultural origin, gender, sexual orientation, disability, age,
family situation, religion, political beliefs, or union affiliation.

Equal treatment of employees is a key component of LVMH’s human resources policy of

respecting occupational and social diversity. The Group prohibits discrimination in all aspects
and stages of interpersonal relations, whether in hiring, pay, working hours, time off or paid
leave, maternity or paternity protection, job security, job assignments, evaluations, training,
career prospects, and occupational health and safety.

All LVMH employees must adhere to the Group’s commitment to combat all forms of discri-
mination and to exhibit exemplary behavior in this regard.

Fighting harassment
LVMH is firmly opposed to all forms of intimidation, humiliation, threats, violence, and phy-
sical, sexual, verbal, or moral harassment expressed through behavior, actions, or gestures,
or in writing.

All LVMH employees must treat each other and their external stakeholders with respect.

Fostering an inclusive culture

Diversity drives our creativity and success. It is a result of our commitment to foster an
inclusive culture based on respect for uniqueness, where everyone can evolve and innovate
in order to contribute to our long-term success. This commitment runs through everything
the Group does and its relationships with its stakeholders: employees, partners, suppliers,
and customers.

In particular, the Group has set up programs including mentorship and active support for the
professional development of women and underrepresented groups, depending on local context.

LVMH also fosters the development of early talent through many partnerships with the
academic and non-profit sectors.
LVMH / Code of Conduct 21

The Group fosters the employment of seniors by providing training and adjusting working
hours and conditions, and encourages the passing on of savoir faire.

LVMH is also firmly committed to employing people with disabilities and actively supports
training, hiring, or keeping them employed through dedicated initiatives and partnerships.

All LVMH employees must embody the Group’s commitment to inclusion in their day-to-day
activities, both internally and in their relations with partners, suppliers, customers, and any
other external stakeholders.

For more information, please see:

−Recruitment Code of Conduct;
−LVMH Social and Environmental Responsibility Report.
LVMH / Code of Conduct 22

Ensuring quality of life at work

LVMH ensures professional development and quality of life at work throughout its employees’
careers.

Well-being at work
LVMH creates the necessary conditions for its employees to thrive in their jobs and develop
to their full potential.

LVMH encourages managers to foster collaborative, agile work methods and to mobilize
their team members’ ability to take initiative, skills, and responsibilities.

Each manager must pay particular attention to instituting an atmosphere of trust, constructive
dialogue, and recognition of each team member’s contributions.

The Group pays attention to feedback from its employees and labor partners. The LVMH
Heart Fund, a solidarity fund created as a result of discussions with the Group’s employee-re-
presentation bodies, is available for all employees. It offers them free social and psychological
support and, if necessary and subject to eligibility requirements, emergency financial aid.

A healthy work-life balance

LVMH respects its employees’ work-life balance, aware that this is key to their well-being
and quality of life at work.

The Group pays particular attention to the right to disconnect.

When the type of activity permits, the Group supports flexible work arrangements for
employees.

Employee development
LVMH ensures employee development by providing numerous training programs and fostering
geographical and functional mobility. The Group is especially committed to transmitting the
savoir faire and cultural heritage of craft and creative trades.

While each employee bears primary responsibility for their career, LVMH’s managers and
human resources teams are fully committed to supporting employees’ development.

Managers must create a working environment that is respectful and fulfilling and promotes
well-being. They must foster their employees’ development, listen to their concerns, and
pay attention to their work-life balance.

For more information, please see the LVMH Social and Environmental Responsibility Report.
LVMH / Code of Conduct 23

Ensuring health and safety

LVMH believes that its responsibility as an employer is to provide a safe, fulfilling work envi-
ronment for its employees and anyone working on a Group site or for the Group.

LVMH protects its employees’ health and safety, ensures that its business activities comply
with the health laws and regulations applicable in the countries in which it operates, and
strives to implement best practices in the area of workplace safety.

LVMH has adopted a five-part Health and Safety Charter intended to foster a “zero acci-
dent” culture:

• identify the issues;

• develop a dedicated action plan;

• roll out and manage it;

• get every employee involved; and

• maintain a virtuous culture for a safe ecosystem.

LVMH protects its employees from exposure to hazardous materials or dangerous situations
while they are on the job. Employees are informed of the applicable internal regulations, which
set forth the Group’s workplace health and safety rules.

Whether in the context of health crises or as part of the social responsibility strategy, LVMH
and its Maisons have developed various permanent systems for organizing work, supporting
employees, and exchanging best practices.

LVMH has also adopted a Charter on the working relations with fashion models and their
well-being in order to promote high standards of integrity, responsibility, and respect for
the individuals in question and to ensure that they have appropriate working conditions..

All LVMH employees must follow the Group’s health and safety approach and pay close
attention to situations that pose a health and/or safety risk.

.
For more information, please see:
– Health and Safety Charter;
– Charter on the working relations with fashion models and their well-being;
– Group Vigilance Plan (Universal Registration Document);
– LVMH Social and Environmental Responsibility Report.
LVMH / Code of Conduct 25

A group with
integrity

25
LVMH / Code of Conduct 26

Fighting corruption
LVMH has a “zero tolerance” policy with respect to corruption, anywhere in the world.

LVMH and its Maisons take measures to prevent, detect, and punish the commission of acts
of corruption or influence peddling in the doing of business.

The Group has adopted an Anti-Corruption Charter to help employees identify the various
types of conduct that may constitute acts of corruption or influence peddling and are
therefore prohibited. For instance, particular attention must be paid to gifts and invitations.
The Anti-Corruption Charter provides practical examples to help employees develop the
proper reflexes.

In addition to the Charter, training is offered to all Group employees, and especially to those
who are the most exposed to risks of corruption and influence peddling.

LVMH requires its partners and suppliers to comply with the same rules and to take appropriate
measures to prevent, detect, and punish any conduct that may be related to corruption or
influence peddling.

All LVMH employees must comply with the rules set forth in the Anti-Corruption Charter
and be especially careful in this regard.

Employees working with Group business partners must make sure these partners agree to
comply with the anti-corruption rules and principles in LVMH’s Supplier and Business Partner
Code of Conduct.

For more information, please see:

– Anti-Corruption Charter;
– Supplier and Business Partner Code of Conduct.
LVMH / Code of Conduct 27

Preventing conflicts of interest

A conflict of interest is a situation where a Group employee’s personal interests conflict,
seem to conflict, or may conflict with those of the Group or one of its Maisons.

Such a situation must be declared and managed in order to eliminate or reduce the risks it
may pose.

It is the responsibility of each employee to show good judgement about their personal
situation when assessing potential conflicts of interest and to immediately report any such
conflicts to their manager and/or the relevant department(s) (Ethics & Compliance, Human
Resources, Legal) according to their Maison’s internal procedures.

All LVMH employees must conduct business and do their jobs with integrity and loyalty.
Employees who might have a conflict of interest must declare such potential conflict
immediately.

For more information, please see the Anti-Corruption Charter.

Fighting money laundering

Money laundering is concealing or disguising the origins of illegally obtained proceeds so
that they appear to have originated from legitimate sources.

The Group takes appropriate measures in every country in which it operates to prevent its
operations from being used as a vehicle for money laundering, including by limiting or providing
guidance on cash payments, and requiring employees and partners to pay close attention to
money laundering risks.

All LVMH employees must comply with anti-money laundering rules and, in the case of sales
personnel in particular, cash payment thresholds.

For more information, please see the internal Anti-Money Laundering Policy.
LVMH / Code of Conduct 28

Complying with
international sanctions
LVMH attaches particular importance to compliance with laws and regulations on international
sanctions and export controls.

Every Group transaction, regardless of size, is carefully monitored to:

• identify any direct or indirect links with countries or regions subject to international sanctions;

• verify that the transaction in question does not involve an entity, organization, or person
whose name is on an international sanctions list; and

• comply with any restrictions related to export controls.

All LVMH employees must be especially careful about complying with laws and regulations
applicable to the international sanctions and export control regimes.

Given the complexity of such regulations, employees must contact their Ethics & Compliance
Correspondent before entering into any transaction that has a connection to a country or
region subject to international sanctions or restrictions related to export controls.

For more information, please see the internal International Sanctions Policy.
LVMH / Code of Conduct 29

Promoting free and

undistorted competition
LVMH strives to maintain free, undistorted competition in accordance with applicable law
and practice and ensure that employees comply with the competition rules that apply in each
country in which the Group does business.

LVMH has formalized its commitment to compliance with competition law in an internal
Competition Law Charter designed to help develop a genuine compliance culture with
respect to competition law.

That Charter sets forth the main rules that employees must follow in their day-to-day com-
mercial relations, as well as practical illustrations of the standards they are expected to meet.

LVMH will not under any circumstances tolerate abuse of economic dependence, illicit
exchanges of information, cartels or illicit collusion through agreements, plans, arrange-
ments, or concerted conduct among competitors, concerning prices, territories, market
shares, customers, etc.

In particular, LVMH strives to prevent abuse of a dominant position.

All LVMH employees must comply scrupulously with competition law. All relationships with
Group competitors must be closely scrutinized and all employees must refrain from taking
any action that might distort competition.

.
For more information, please see the internal Competition Law Charter.
LVMH / Code of Conduct 30

Maintaining confidentiality

LVMH employees must protect the confidentiality and integrity of internal information that
has not been made public.

This information may include financial data or information relating to strategy, employees,
customers, collections and product launches, potential acquisitions, or commercial activities
that give us a competitive edge.

In general, confidentiality is key to maintaining trust both within the Group and in relationships
with our partners and customers. LVMH protects all external confidential information pro-
vided to the Group, using such information only for the authorized purposes and taking all
appropriate precautions.

In particular, LVMH expects employees not to disclose internal information using means of
communication that unauthorized individuals may have access to, or in places where they
may be overheard.

LVMH also expects employees, in accordance with the Social Media User Guide, to be very
careful about expressing their opinions on the Internet, and in particular to be sure to indicate
that any opinions they express are their own, to show restraint, to respect others, and not
disclose confidential information or trade secrets.

In particular, the use of computerized means of communication must comply with the rules
and principles set forth in the Maisons’ cybersecurity charters.

All LVMH employees must refrain from directly or indirectly disclosing any internal or exter-
nal confidential information that may have been made known to them to anyone external
to the Group or to LVMH employees whose jobs do not require them to have knowledge of
such information.

For more information, please see the internal Social Media User Guide.
LVMH / Code of Conduct 31

Protecting the integrity

of the financial markets and
preventing insider trading
Financial-market integrity is key to a functioning economy.

LVMH is committed to protecting the integrity of the markets and to complying with the
rules designed to prevent market abuse. In particular, LVMH will not give the market false
information or take any action to cause the price of a financial instrument to change on
false premises.

Because LVMH shares are traded on financial markets, it is subject to legal obligations with
respect to inside information.

“Inside information” is precise information that has not been made public and that directly or
indirectly concerns one or more issuers, or one or more financial instruments issued by one
or more issuers, and that, if made public, might noticeably influence the price of the finan-
cial instruments in question or the price of derivative financial instruments related to them.

Anyone in possession of such information must refrain from directly or indirectly buying or
selling the shares (or related financial instruments) of the issuer in question, or from doing
so through an intermediary, for so long as such information has not been made public. They
also have a heightened non-disclosure obligation.

The Group has procedures for determining whether information is inside information or not;
deciding whether or not to delay making the information public; and, if public disclosure is
delayed, taking the necessary steps and identifying who qualifies as an insider for each piece
of inside information.

Employees in possession of inside information must comply with the regulations designed to
prevent insider training. In particular, they must not engage in stock market trading involving
the financial instrument(s) in question and must not disclose the information in question.
LVMH / Code of Conduct 32

Respecting privacy

LVMH attaches great importance to the privacy of its customers and employees (“data sub-
jects”) and takes the utmost care to protect it, and in particular to protect their personal data.

LVMH is therefore committed to the six major principles set forth in its Privacy Charter. This
is essential to guarantee the minimum protection of data subjects’ rights when their data are
collected, processed, or transferred, regardless of the transfer destination.

Each Maison or Group entity, wherever it may be, must therefore comply with these six major
principles and the laws and regulations governing the protection of privacy and personal data.

In particular, they must each ensure that:

• all personal data processing is lawful and does not infringe the data subject’s other rights
or human dignity (“lawfulness principle”);

• the personal data are adequate, relevant, and strictly limited to what is necessary in rela-
tion to the purposes for which they are processed (“necessity principle”);

• the personal data are used only for the purposes for which they were collected, in a man-
ner that protects the data subject’s privacy and intimacy (“proportionality principle”);

• any risks that may be posed during the personal data’s life cycle are identified, assessed,
and documented so that measures may be taken to prevent such risks from being realized
and to protect the confidentiality, integrity, and availability of such data (“security prin-
ciple”);

• data subjects are informed of how their personal data is processed (“transparency principle”);

• data subjects are able to exercise their rights over their personal data (“principle of respec-
ting data subjects’ rights”).

All LVMH employees, whatever their job, must pay close attention to respecting privacy
and the personal data collected and processed in connection with their daily activity. Each
employee must make sure that each principle set forth in the Privacy Charter is complied with.

For more information, please see the internal Privacy Charter.

LVMH / Code of Conduct 33

Participating responsibly
in the public sphere

LVMH takes part in public policy discussions in a spirit of constructive dialogue and coope-
ration with the stakeholders concerned, including but not only political leaders.

Compliance with laws and regulations is a prerequisite for the Group’s credibility when it
participates in public debate.

In addition, integrity, transparency, and honesty are the key principles of the Group’s parti-
cipation in the public sphere.

In particular, LVMH attaches great importance to the reliability of the information provided
to its discussion partners and is registered as an “interest representative” (lobbyist) where
its business so requires. The Group’s external providers must comply with the same rules.

The Group also respects its employees’ right to participate in political or union activities
as private individuals. However, employees undertake to ensure that their activities in the
private sphere do not involve or compromise the performance of their duties or damage the
Group’s reputation.

LVMH prohibits the payment of money to political parties or political or union organizations.

LVMH prohibits the remuneration and recruitment, whether permanent or temporary, of any
member of a national or European parliament, for the duration of their elective mandate.

All LVMH employees who represent LVMH or a Maison in the public sphere must act with
integrity, transparency, and accuracy.

For more information, please see the Responsible Lobbying Charter.