ANTI-CORRUPTION FUNCTION

In the meeting held on January 28, 2020, the Board of Directors resolved to establish the "Anti-Corruption Compliance Function”, assigned to the Head of Internal Auditing and directly reporting to the Board. The main responsibilities is to implement and manage the company's anti-corruption program who consists of the following responsibilities:

 

  • 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 standards and requirements of the UNI ISO 37001 standard;
  • Coordinating the process of identifying and assessing risks (risk assessment) in the field of anti-corruption and identifying controls to monitor the aforementioned risks;
  • Conducting 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;
  • Providing specialist assistance in activities related to assessing the reliability of the counterparties, managing any critical issues that arise and processing the related controls in areas at risk of corruption;
  • Ensuring periodic reporting, taking care of the preparation of reports, on the performance of the Anti-Corruption Management System towards the Board of Directors, the Chief Executive Officer and the other Corporate Bodies to which specific information flows are necessary;
  • Informing, whenever it deems it appropriate, the Board of Directors and the CEO, in the event that any problem or suspicion needs to be raised in relation to acts of corruption or the Anti-Corruption Management System;
  • Supporting the process of analyzing and evaluating reports of violations and / or offenses (e.g. pursuant to Legislative Decree 231/01) or in any case behaviors that are not in line with the rules of conduct adopted by the Company regarding the activity of preventing corruption.