Page 84 - Sustainability report 2018 Ratti Group

CHAPTER 6 | Governance and monitoring corporate ethics and risk management
The Group’s Ethics Committee is responsible for receiving and handling any reports, including those relating
to conduct that could potentially/ substantially violate the aforementioned anti-corruption measures.
The BoD is responsible for the ICRMS and, assisted by the Risks Control Committee, defines guidelines and periodically checks that the main corporate risks have been identified, measured, managed
and monitored in an adequate and proper manner. A meeting of the BoD is convened annually to analyse the trend for the main corporate risks and to evaluate their impact on the Company’s strategy and performance.
The Director Responsible – in the shape of the CEO – has the task of implementing the guidelines of the BoD through the planning, management and monitoring of the ICRMS. Ratti SpA has also established an Internal Audit department, which supports the BoD, the Director Responsible,
the Risks Control Committee and the management in carrying out their respective tasks in relation
to the ICRMS.
Other control bodies include the Supervisory Body, the Board of Statutory Auditors, the Manager Responsible and the Group Ethics Committee.
To maximise the efficiency of the ICRMS and coordinate the activities of those involved Ratti SpA, in compliance with the Code of Conduct, has specifically separated control activities and has implemented various organisational practices, such as annual board meetings, regular reporting to the BoD, the participation of the relevant parties in meetings of the Control Committee, and the implementation and maintenance of the management system.
corruption, through the adoption of a structured system of organisational and procedural measures containing rules, controls and reporting mechanisms aimed at preventing illegal behaviour and protecting the reputation of the company at global level”.
In the Group’s Code of Ethics some examples are given of actions that are not tolerated such as “any exchange of gifts, presents, money or any other benefit in favour of third parties whether they
be private or part of the Public Administration, such as could alter the normal relationship of cooperation, professionalism and impartiality of judgement, unjustly favouring the interests of the Ratti Group and/or one of the Group’s companies”.
Given that corruption is included as a serious crime in Legislative Decree 231/2001, the second control adopted by Ratti SpA to prevent such a risk is Model 231/2001.
During 2018, with regard to the project to update MOG 231/01 a complete mapping was carried out in Ratti SpA of activities sensitive to offences included in Legislative Decree 231/01, which includes all corruption offences relating to public administration and private individuals.
This project resulted in the implementation, with regard to the MOG 231/01 of Ratti SpA, of a whistleblowing policy and a Procedure governing the handling of declarations, complaints and notifications of violations of the ethical and behavioural principles laid down in the Code of Ethics of the Ratti Group
Corruption is one of the areas covered by the new Suppliers’ Code approved by the BoD of Ratti SpA with the resolution of 14 November 2018.
The Code is an integral part of contracts agreed with suppliers who are asked to note that corrupting behaviour of any type with private individuals or the public administration will not be tolerated by the Group; for this reason failure to observe the provisions of the Code could lead to the termination of the contract (see the paragraph “Selecting suppliers” in Chapter 3).
The Group’s Ethics Committee is responsible for receiving and handling any reports, including those relating to conduct that could potentially/ substantially violate the aforementioned anti- corruption measures.
With regard to the other companies of the Ratti Group (other than Ratti SpA) it should be noted that some activities that generally risk amounting to corruption are not executed by these companies
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The prevention of corruption
The regulations with regard to non-financial reporting (Legislative Decree 254/2016), include the fight against active and passive corruption.
The commitment to promote and adopt high ethical standards is stipulated in the Group’s Code of Ethics, in which one of the fundamental principles is “Integrity and the fight against corruption” where it is reported that the Group has “decided to prevent and avoid the risk of