We conduct our business in compliance with the law, internal regulations and professional ethics. To this end, we have developed a set of policies and guidelines that support us in our daily activities.
We have adopted an integrated approach to business ethics, starting from the value of integrity, a fundamental principle that inspires us in the management of our activities. For this reason, we have established rules through the Code of Conduct and developed compliance models, such as the Organization, Management and Control Model pursuant to Legislative Decree 231/01 (Model 231). In addition to adhering to institutional initiatives for the control and protection of legality (National Framework Protocol of Legality), we have introduced and updated policies and operational procedures, provide specific training to our employees, and involve all our stakeholders in the monitoring of the program through the whistleblowing system.
Our approach is summarized in the anti-corruption management system, for which we obtained ISO 37001 certification in 2020. The ongoing effectiveness of anti-corruption initiatives is ensured by actions to maintain system certification, the role of the Anti-Corruption Function and its manager, oversight of the validity and adequacy of Model 231, targeted audits based on an annual program, and periodic assessment of corruption and fraud risk within the Enterprise Risk Management framework.
All Group activities are also carried out in compliance with International Conventions (such as the 1997 OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions) and in strict observance of human rights as enshrined in the UN Universal Declaration.