Page 82 - Sustainability report 2018 Ratti Group

CHAPTER 6 | Governance and monitoring corporate ethics and risk management
Disciplinary measures and sanctions
Integration of management systems
THE 231 ORGANISATIONAL MODEL
Commitment to prevent offences
Organisational choices to ensure legality
Organisational Model 231
and, finally, the duties of the Supervisory Body. Finally, the Model is completed by the Code of Ethics and the list and description of offences stipulated in Legislative Decree 231/01, the suppliers’ code and the whistleblowing policy.
The Code of Ethics
The Group’s Code of Ethics summaries all the elements which underpin its corporate identity
and culture; the updated version was updated by the BoD of Ratti SpA on 14 November 2018 and, through subsequent resolutions, by the subsidiaries Textrom Srl, Creomoda Sarl and Ratti USA Inc. Ratti Shanghai will approve and adopt the Code of Ethics by February 2019.
The Code sets out the principles and values that characterise the management of the Group’s activities and to which all subjects must adhere who act in the name of or on behalf of the Group and, in various ways and at various levels, maintain relationships with the various companies. The main recipients, who are explicitly referred to, are: the Directors, the Statutory Auditors, all the employees of all the companies in the Ratti Group, all freelance workers, all external collaborators (consultants, trading partners, agents) and suppliers.
The Code of Ethics lists nine ethical principles which underpin the governance and the management of the Group’s activities. Two paragraphs are dedicated to the themes of safeguarding and protecting the environment and the social accountability of the Group, principles which find concrete expression
in certified policies and actions (see Chapter 3, paragraph 3.4 “A commitment anchored in the most advanced standards”).
The Code stipulates the rules of conduct that recipients must follow when conducting corporate business and activities, and when managing people and information.
The code underlines the importance of dialogue and transparency between the parties as necessary prerequisites for the creation of shared value, reiterating respect for health and safety in the
Supervision, updating, information and training
Document and system of prevention
Rules, regulations and procedures
Guidelines and indications regarding behaviour
The new Whistleblowing Policy
Article 2 of Law no. 179/2017, amending Article 6 of Legislative Decree 231/2001, added to Legislative Decree 231/2001 the requirement
to safeguard the whistleblower from offences or irregularities of which he or she had become aware during activities carried out in relation to
a private employment relationship, known as “whistleblowing”.
Ratti SpA complemented the General Part of the Model with a section dedicated to the regulations and penalties relating to violations of
the prohibition of acts of retaliation against whistleblowers and the abusive use of reporting channels.
The Company has adopted a
whistleblowng policy which governs: • the parties involved
• the purpose, the channels of
communication and the contents
of the whistleblowing report
• the recipients of the report
• the duties of the recipients of the
report
• protection of the whistleblower • the penalty system
All recipients must be familiar with the document and must comply with its contents. MOG 231/01 may be consulted by accessing the Procedures area of the Company’s intranet and is also published (only the general part) on the page https://www.ratti.it/it/ societa/sostenibilita.
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