Page 71 - Sustainability Report 2019
P. 71

 RATTI GROUP | Sustainability report 2019
 Supervisory Body
 Verification of the need to update the Model
  Self-regulation
Access to corporate documents Timely receipt of information Recourse to external consultants
  Supervision of compliance with the Model
      POWERS
SUPERVISORY BODY
FUNCTIONS
Verification of the validity and adequacy of the Model
      Communication to the appropriate bodies
   Coordination and verification of the activities for disseminating the Model in a corporate context
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 promoting and adopting 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”, 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.
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. The full mapping of activities that are sensitive to the offences covered by Legislative Decree 231/01, which includes all corruption offences relating to both public administration and private individuals, was updated in 2018.
This project resulted in the implementation 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 Ratti Group’s Code of Ethics.
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.
Corruption is a topic that is also covered by the Suppliers’ Code approved in 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 Chapter 3, paragraph 3.2 “A virtuous circle of good practices”).
With regard to the other companies of the Ratti Group it should be noted that some activities that generally risk amounting to corruption are not executed by these companies or – if they are carried out – are of marginal importance, due to the fact that these companies only carry out workmanship on an outsourced basis for the Parent company and/or directly on behalf of the latter.
During 2019 steps were taken to provide training to
the top management of Ratti SpA relating to Legislative Decree 231/01, to the principles and contents of Model 231/01 affirming, in particular, the protocols for fighting corruption.
In addition, training was also provided to the directors of the subsidiaries in relation to the principles of the Group’s Code of Ethics, focusing on the behaviour that needs to be adopted to oppose corruption.
In 2020 it is planned to extend the training to all white- collar personnel.
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