ANTI-CORRUPTION POLICY AND FUNCTION

Within the global scope in which Fincantieri operates, the anti‑corruption policy plays a central role, defining the conduct of business in strict compliance with the highest international standards in the field and pursuing a value‑creation model based on transparency and social responsibility, capable of preventing negative impacts.

Business integrity is a key factor that characterizes the identity of the Fincantieri Group, as well as a fundamental element of the company’s reputation and image. Through responsible governance and policies aimed at “zero tolerance” toward active and passive corruption, the spread of a culture of legality is promoted and conditions of fairness in the conduct of business are ensured. In this regard, all Italian and foreign companies of the Group are encouraged to adopt preventive measures consistent with this approach, in accordance with the regulations applicable to them.

For these reasons, Fincantieri has incorporated the core values and principles of fighting corruption into its Code of Ethics, adopted since 2002 and binding for employees, as well as explicitly shared with all suppliers upon acceptance of the Suppliers’ Code of Ethics and with business partners upon contract signing.

All individuals interacting with the Group, both internal and external, are therefore required to follow these principles with the utmost care and commitment in every circumstance, immediately reporting through the dedicated channels (https://www.fincantieri.com/en/group/governance/whistleblowing) any violation—suspected or known—of our policy, of the related procedures, or of applicable laws.

In the process of continuous evolution and improvement of the Company’s anti-corruption system, in 2020 the UNI ISO 37001 certification for Anti-Bribery Management Systems was obtained, and the Compliance Function for the prevention of corruption was established, with responsibility assigned to the Head of the Group Compliance, Anti-Corruption and Model 231 Function.

The Function is responsible for the design, implementation, and continuous improvement of Fincantieri’s anti‑corruption management system, as well as for directing and coordinating activities towards the Group’s Companies.
Specifically, with regard to Fincantieri’s Anti‑Corruption Management System, it has the responsibility and authority to:

• Ensuring monitoring of legislation and case law on anti-corruption 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 applicable regulations and the requirements of the UNI ISO 37001 standard;
• Coordinating the process of identifying and assessing risks (so-called risk assessment) in the area of anti-corruption and identifying controls to safeguard against such risks;
• Conducting audits on the implementation of the Anti-Corruption Management System;
• Promoting and supporting the relevant company functions in defining and implementing training programs on Anti-Corruption and the operation of the related Management System;
• Supporting the process of analyzing and evaluating reports of violations and/or offenses or, in any case, conduct not in line with the rules of conduct adopted by the Company regarding anti-corruption activities.

In addition, periodic information on the performance of the Anti-Corruption Management System is provided to the Board of Directors, the Chief Executive Officer, and other Corporate Bodies, as well as ad hoc information flows to the same parties in the event that any issue or suspicion needs to be raised in relation to acts of corruption or the Anti-Corruption Management System.