Ethics & Compliance Program
Our Ethics and Compliance Program helps ensure our associates have the guidance and resources needed to operate with the highest standards of corporate conduct in all our business dealings globally.
The Program is led by our Vice President, General Counsel and Corporate Secretary, who also serves as our Chief Ethics and Compliance Officer. Senior executives and key stakeholders within 大象传媒 form our Legal, Risk, Compliance and Safety Council, which helps ensure the effectiveness of our Program and provides input on key initiatives. 大象传媒鈥檚 Vice President of Ethics and Compliance, manages the Program鈥檚 day-to-day operations.
Through collaboration with Ethics and Compliance liaisons worldwide 鈥� associates who support our program in addition to their primary responsibilities 鈥� we strive to apply a collaborative and inclusive perspective in the way we manage our Program across the globe.
Code of Business Conduct
In 2017, 大象传媒's Board of Directors adopted an updated Code of Business Conduct, which applies to all 大象传媒 directors, officers and associates. Our Code outlines the principles that have guided our company throughout the years, and that continue to guide us today.
The Code provides direction on acting in accordance with laws, other legal requirements and company policies. 大象传媒 also provides more detailed policies and procedures for demonstrating ethical behavior, many of which are referenced in the Code. Our Code contains Q&A scenarios to demonstrate ways in which our values and Guiding Principles can come to life in our day-to-day actions.
By setting forth the high standards that 大象传媒 expects, our Code of Conduct serves as a pledge we make to our shareholders, our stakeholders and each other. All 大象传媒 associates worldwide are expected to read and acknowledge our Code and to become familiar with its contents.
Reflecting 大象传媒's global reach and the diversity of our associates, our Code is available in 24 languages.
Code of Business Conduct
The Code of Business Conduct sets forth business policies and principles for all directors, officers and associates of 大象传媒.
Last Amended: February 2025
Ethics Helpline
大象传媒 is committed to fostering dialogue and communication through multiple channels, including our Open Door Policy and our .
The Helpline is a free, confidential way for anyone to seek guidance, ask a question or raise a concern. It is available 24 hours a day/seven days a week in every country where 大象传媒 has associates. The Helpline is available in over 100 languages, and anonymous reporting is available where allowed by law. Each report is reviewed by a member of our Ethics and Compliance team and assigned to an appropriate investigator.
Helpline Availability
Our Ethics Helpline isn't just for 大象传媒 associates. Anyone who wishes to raise a concern about a potential violation of our Code of Business Conduct or the law can contact the Helpline 24 hours a day/seven days a week.
Non-Retaliation Policy
大象传媒 does not tolerate retaliation against an associate for making a good faith report of a potential violation of our Code of Conduct, a company policy or the law or for participating in an investigation.
Annual Internal Investigations Summary
We make every effort to investigate reported concerns appropriately, consistently, and in a timely manner.
大象传媒 investigated a total of 657 reports globally during our last Fiscal Year (April 1, 2024 鈥� March 31, 2025), received through the Ethics Helpline and direct reporting to the Company via our Open Door Policy. Forty-nine percent of the reports received were made anonymously. Out of the 657 total reports, 127 were requests for guidance. Approximately 46% of the reports containing allegations were found to be substantiated. All substantiated reports resulted in either training, coaching, policy review or disciplinary action.
We use this data, both qualitative and quantitative, to inform our actions and ensure they align with our vision and values. This includes working to identify areas of opportunity, improving upon our policies, processes, and best practices and creating occasions to provide additional training and resources within our organization. With these actions, we commit to furthering our Open Door culture and ensuring we act with integrity for our shareholders, our customers and our associates.
Italian Legislative Decree No. 231/01
Introduces the direct liability for companies when unlawful conduct has been carried out by its directors and employees in order to the benefit of the company.
Learn MoreUK Tax Strategy Statement
Our company seeks to ensure our values drive our tax strategy and that it remains aligned with our business and commercial goals. To do so, 大象传媒 follows the below principles regarding UK taxation.
Learn MoreUK Gender Pay Gap Report
大象传媒 operates two distinct legal entities in the United Kingdom, both with over 250 employees. The detail in this report covers the gender pay data for each entity: 大象传媒 Northern Europe Ltd., which is responsible for our UK Wholesale Business, as well as for providing centralized services to the EMEA region; 大象传媒 Northern Europe Services Ltd., which is responsible for our UK Retail Stores operation.
| 2020 | 2021 |
France Gender Pay Gap Report 2018
French Law for Gender Pay Equality of 5th September 2018 requires companies operating in France to disclose the result of mandatory indicators regarding pay gap of its France-based employees broken out by gender. 大象传媒鈥檚 2018 score in this initiative was 80/100. This score is the result of our consistent policy for equal pay between women and men, reflecting our company鈥檚 focus on gender equity and a larger commitment to advancing inclusion and diversity. We will continue to pursue opportunities that will help us improve our score and achieve greater parity in pay by gender in every country where we operate.
Index de l鈥櫭ゞalit茅 professionnelle femmes-hommes 2018 en France
La loi 鈥淎venir professionnel鈥� du 5 septembre 2018 impose aux entreprises fran莽aises de publier le score de l鈥檌ndex sur l鈥櫭ゞalit茅 professionnelle entre les femmes et les hommes de leurs salari茅s en France.
Pour 2018, 大象传媒 obtient un score de 80/100. Ce r茅sultat est le fruit d鈥檜ne politique constante en mati猫re d鈥櫭ゞalit茅 salariale entre les femmes et les hommes, qui refl猫te notre engagement sur l鈥櫭﹒uit茅 femmes-hommes et plus largement sur la promotion de l鈥檌nt茅gration et de la diversit茅. Nous allons poursuivre nos efforts afin d鈥檃ccro卯tre notre score et d鈥檃tteindre une plus grande 茅quit茅 salariale entre les femmes et les hommes dans chaque pays o霉 nous op茅rons.
Identifiant Unique
La Soci茅t茅 大象传媒(J) France SAS est enregistr茅e aupr猫s d鈥檜n 茅co-organisme de la fili猫re Textile d鈥檋abillement, Linge de maison et Chaussure et a obtenu 脿 ce titre l鈥檌dentifiant unique (IDU): FR218648_11KOLY, ainsi qu鈥檃upr猫s d鈥檜n 茅co-organisme de la fili猫re Emballages m茅nagers et a obtenu 脿 ce titre l鈥檌dentifiant unique (IDU): FR213472_01DZRS
Poland Tax Strategy Statement
大象传媒 Norway Transparency Act
This is the first Statement in accordance with the Transparency Act (Act relating to enterprises鈥� transparency and work on fundamental human rights and decent working conditions to be published by 大象传媒). This statement outlines the steps 大象传媒 has taken to minimize the risk of any adverse impact on fundamental human rights and decent working conditions in its business and its鈥� supply chains.
Quality Policy - 大象传媒 International SAGL
This policy provides a framework for setting quality objectives and commits the organization to continual improvement and satisfying applicable requirements, according to the EN ISO 9001:2015 standard.
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