Training

A priority objective for Fincantieri is to ensure the dissemination on a continuous basis of the rules for a business ethical management in compliance with the laws and regulations in force. In this context, the following are of particular importance:

• the safeguard system provided for the Legislative Decree No. 231/01, whose knowledge must be promoted and shared at all levels of the Company's organization;
• the Anti-Corruption System adopted by the Company in compliance with the requirements of the UNI ISO 37001: 2016 standard for the prevention of corruption.

In order to achieve this goal, Fincantieri structured a training program aimed to assist and support the employees throughout their professional development in the Company, intended to promote an ever increasing awareness on the compliance with the Organizational, Management and Control Model pursuant to Legislative Decree No. 231/01 and the Anti-Corruption System adopted by the Company against corruption in all its forms.

The training paths are differentiated in order to obtain a targeted dissemination of the topics taking into consideration role and responsabilities of the concerned employees.

The training program related to the Decree No. 231 control system consists of the following modules:

• "general part 231", intended for all employees and interns, illustrates the principle of corporate responsibility with the aim of disseminating and sharing at all levels the measures provided by Fincantieri to prevent the perpetration of the crimes by persons which may bind the Company;
• "special part 231", intended for all employees and interns, provide for an in-depth analysis  of some criminal offences of particular relevance for Fincantieri and specifically:

                  -       crimes against the Public Administration and corporate crimes;

                  -       workplace health and safety offences and environmental crimes;

                  -       crimes against the individual and tax crimes.

The training program related to the Anti-Corruption Management System consists of two modules:

• "general part", intended for all employees and interns, illustrates the characteristics of the Anti-Corruption Management System, the control principles, the management and control tools and procedures and the Whistleblowing system;
• "specific part", intended for the Company's attorneys, examines the issues relating to the corruption risk and the damage that can arise for the Company and for the persons involved, the circumstances in which corruption can occur and how to recognize and manage the main risk indicators, describing some examples.

In order to ensure a constant learning and understanding of the topics provided for the Legislative Decree No. 231/01 and the Anti-Corruption Management System, periodic update (every three years) are programmed, as well as ad hoc updates in relation to interventions by the legislator or changes to the risk profile.