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            CODEOF ETHICS
          
        
        
          In2015, PANDORA launched a new internal Code of
        
        
          Ethics setting out our ethical aspirations as a company and
        
        
          our expectationswith respect to responsible staff behaviour.
        
        
          The code has been distributed to all our peopleworldwide,
        
        
          andhas been accommodated byGroup-wide training and
        
        
          amandatory e-learningmodule for office and store staff.
        
        
          As part of the PANDORACode of Ethics implementation,
        
        
          we also launched an improved ethics hotline, allowing our
        
        
          people to raise concerns if they perceive that our standards
        
        
          are being breached.The ethics hotline is externally
        
        
          administered and enables our people to raise concerns in
        
        
          their own language through bothweb and phone.
        
        
          
            TRAINING
          
        
        
          Themain contact between PANDORA andour consumers
        
        
          is established and nurturedby themore than 30,000
        
        
          people passionately engaged in selling our jewellery
        
        
          inmore than 100 countries around theworld.We are
        
        
          dedicated tohelping the sales people, in themore than
        
        
          9,300 PANDORApoints of sales, to develop their skills
        
        
          and knowledge. Our extensive training programmes span
        
        
          face-to-face training, coaching, on the job training and
        
        
          e-learning.The scope is broad and entails training in
        
        
          PANDORA’s values, CSR, identity andhistory, jewellery and
        
        
          materials expertise, production processes and professional
        
        
          sales skills, sales psychology and techniques. Our training
        
        
          programmes are implemented by 100 trainers, and face-to-
        
        
          face training is supported by our comprehensive e-learning
        
        
          programme available in 19 languages. In 2015, more
        
        
          than 621,000 training sessionswere completed, up from
        
        
          380,000 in 2014 and 200,000 in2013.
        
        
          
            DIVERSITY
          
        
        
          At PANDORA, three out of fourmanagers arewomen,
        
        
          heavily biasedby the highnumber of female store
        
        
          managers.We are deeply committed to ensure gender
        
        
          diversity in our seniormanagement positions.The Boardof
        
        
          Directors has set a number of gender diversity objectives
        
        
          which it reviews annually:
        
        
          • By 2020, the gender split in seniormanagement
        
        
          positions (members of the Executive Board, general
        
        
          managers and vice presidents) shouldbe 40%-60%,
        
        
          representedbywomen andmen respectively. At the end
        
        
          of 2015, 33% of seniormanagement roleswere heldby
        
        
          women, compared to 34% in2014, 31% in2013 and
        
        
          26% in2012.
        
        
          • The gender compositionof theGroup’s leadership
        
        
          programmes for the years 2012-2015 shouldmirror
        
        
          the gender composition of staff in vice president and
        
        
          director positions (on aggregate). In2015, women
        
        
          accounted for 59%of thismanagement group, and
        
        
          made up 48%of the enrolment in our leadership
        
        
          programmes. For thewhole period, women accounted
        
        
          for 47% of the participants on leadershipprogrammes.
        
        
          The Boardwill continue to follow the gender
        
        
          composition of our leadership programmes in the years
        
        
          to come.
        
        
          • Finally, it is PANDORA’s objective that, by 2018, at
        
        
          least 35%of Boardmembers elected at theAnnual
        
        
          GeneralMeetingmust bewomen. At the end of 2015,
        
        
          two female Boardmembersmade up 22%of a total
        
        
          of nine Boardmembers, still well above the 2015
        
        
          average of 11% for Danish listed companies.The Board
        
        
          will continue to consider gender compositionwhen
        
        
          appointing newmembers.
        
        
          PROVIDING PROPER
        
        
          WORKINGCONDITIONS
        
        
          FOROUR PEOPLE