On 21 May 2025, the Italian Competition Authority (“ICA”) concluded one of two proceedings initiated last year against leading fashion industry players, by accepting commitments from Christian Dior Couture S.A., Christian Dior Italia S.r.l. and Manufactures Dior S.r.l. (together the "Dior Group" or the "Companies"), for alleged unfair commercial practices involving the promotion and sale of fashion items.

In July 2024, the ICA launched two parallel investigations against the Dior Group and the Armani Group concerning potentially misleading ethical and social responsibility claims.

In the Dior case, the ICA alleged that the Companies outsourced leather goods production to workshops with inadequate worker compensation, excessive working hours and substandard health and safety conditions, contradicting the ethical and social claims they made about their supply chain.

The ICA emphasised that companies such as Dior, which promote ethical and social values, must demonstrate a genuine commitment to these principles by going substantially beyond minimal legal requirements and ensuring that their business practices align with the social standards they publicly promote.

On 12 March 2025, the Companies presented their final commitments, which the ICA considered sufficient to address the concerns raised during the investigation.

The commitments include:

• enhancing supply chain transparency by updating the website to provide clearer information on ethical standards, production details and annual audit results;
• strengthening the current selection and audit procedures for suppliers by introducing new methods of audit and developing an internal digital platform to track compliance with ethical and legal standards;
• investing €2 million over five years to help identify and assist labour exploitation victims across all production chains;
• creating a new compliance function that reports directly to Christian Dior Couture S.A., which will independently monitor compliance with the Code of Conduct, evaluate suppliers and produce annual reports;
• implementing training programmes for internal teams on consumer protection law and ethical standards and for external suppliers and subcontractors on labour laws, workplace safety, and the Supplier Code of Conduct.

The ICA made these commitments legally binding and closed the proceedings without making any findings of infringement.

This case highlights the ICA’s increasing attention to ethical and social issues, which it acknowledges as a growing priority for consumers and should not be misrepresented in commercial communications.

The ICA decision (in Italian only) is available at the following link

The ICA press release (in English) is available at the following link.

For more information or guidance in this area, please contact Federico Marini Balestra and Bianca Maria Gorlero.