Anti-Corruption Function

As part of the Company’s ongoing process of evolving and improving its anti-corruption system, in 2020 it obtained the UNI ISO 37001 certification for Anti-bribery Management Systems and established the Compliance Function for the Prevention of Corruption, which is under the responsibility of the Head of Group Compliance, Anti-Corruption, and Model 231.

The main responsibility is to implement and manage the company's anti-corruption program which consists of the following duties:

• Ensuring the monitoring of anti-corruption legislation and jurisprudence as well as the evolution of leading practices at national and international level;
• Supervising the design and implementation of the Anti-Corruption Management System in accordance with the applicable regulations and requirements of the UNI ISO 37001 standard;
• Coordinating the process of identifying and assessing corruption-related risks (i.e., risk assessment), as well as the identification of safeguard controls to mitigate such risks;
• Performing checks on the implementation of the Anti-Corruption Management System;
• Promoting and supporting the competent corporate functions in the definition and implementation of training programs on anti-corruption and the functioning of the related Management System;
• Providing consultancy, specialist assistance and guidance to employees of the Company and to other Group companies on the Anti-Corruption Management System and on issues related to corruption;
• Managing the Company’s whistleblowing system and supporting the process of analyzing and assessing reports of violations and/or unlawful acts, or in any case, behaviors not aligned with the rules of conduct adopted by the Company in relation to anti-corruption activities.

Furthermore, periodic reporting on the performance of the Anti-Corruption Management System is ensured to the Board of Directors, the Chief Executive Officer, and other corporate bodies. Event-driven reporting is also provided to the same entities in cases where any issue or suspicion needs to be raised in relation to acts of corruption or the Anti-Corruption Management System.