Art. 1 – Introduction and Purpose
This Corporate Policy is drafted to ensure compliance with the highest ethical standards, in accordance with national legislation (Legislative Decree 231/2001) and best international practices in anti-corruption (including ISO 37001).
The Company is committed to combating all forms of corruption, direct and indirect, public or private, in every area of its activities, adopting a zero-tolerance approach.
The purpose of this regulation is to clearly define prohibited behaviors, control procedures, and individual and collective responsibilities in the fight against corruption. It enters into force on 01/01/2026 and remains valid until revised or updated by
Company Management.
Art. 2 – Scope of Application
This Regulation applies to all individuals acting in the name and on behalf of the Company, regardless of their legal relationship.
The provisions are binding for Board members, managers, employees, and collaborators at all levels and under any contractual form,
as well as for external consultants, agents, intermediaries, and suppliers of goods or services.
These obligations also extend to all business partners and, more generally, to any other entity having economic, contractual, or
other relations with the Company. All parties must know, understand, and comply with the provisions of this document.
Art. 3 – Definitions
- Active corruption: any behavior involving offering, promising, or giving money, benefits, or other undue advantages to a public official, public service officer, or private individual, directly or through third parties, to obtain an improper benefit for oneself or the company.
- Passive corruption: receiving, accepting a promise or proposal of money, benefits, or other undue advantages from a third party in relation to one’s professional duties.
- Extortion: behavior by a public official who, abusing their position or powers, induces someone to give or promise money or other benefits unjustly, causing harm.
- Conflict of interest: any situation, even potential, where a personal, financial, or family interest may interfere with impartiality, integrity, and fairness in company decisions or activities.
- Undue advantage: any benefit, tangible or intangible, not due by law, contract, or regulation, that may influence or appear to influence a person’s impartial behavior.
Art. 4 – General Principles of Conduct
- Adopt ethical, lawful, transparent, and responsible behavior to protect the company’s reputation and integrity.
- Refuse any form of improper advantage, whether economic or not.
- Manage company resources and funds in compliance with current regulations and principles of traceability and transparency.
- Promptly report any suspicious situations or unlawful behavior.
Art. 5 – Gifts, Hospitality, and Other Benefits
It is prohibited to offer or accept gifts, hospitality, or other benefits that may improperly influence company decisions or create
suspicion of unlawful conduct.
Only modest-value gifts (typically under €50), in line with business customs, and hospitality strictly related to professional purposes
are allowed, provided they are authorized or relevant to professional activities.
Any exception must be approved by Company Management.
Art. 6 – Conflict of Interest Management
Recipients must avoid situations where personal interests may affect impartiality and objectivity in performing their duties.
Any actual or potential conflict of interest must be immediately reported to Management or HR.
Art. 7 – Relations with Public Administration
All relations with public entities, officials, authorities, or administrations must be conducted with the utmost fairness,
transparency, and legality. Specifically:
- It is prohibited to promise or give money or other benefits to public officials to obtain undue advantages.
- All interactions with Public Administration must be documented.
- Authorized personnel must handle formal relations with public entities.
Art. 8 – Selection and Management of Third Parties
The Company is committed to selecting suppliers, consultants, and business partners based on legality, integrity, professionalism,
and compliance with anti-corruption regulations.
- Specific anti-corruption clauses;
- The Company’s right to terminate the contract in case of violation;
- The obligation to adhere to the principles of this Regulation.
Art. 9 – Whistleblowing System
The Company guarantees anonymity (if requested), confidentiality, and protection against retaliation or discrimination for those
reporting unlawful or fraudulent activities.
Art. 10 – Disciplinary System and Sanctions
Violations of this Regulation constitute disciplinary offenses and may result in:
- Sanctions as per applicable collective agreements;
- Civil or criminal liability actions;
- Termination of contracts with third parties.
All measures will be adopted respecting proportionality, gradualness, and the right to be heard.
October 1, 2025
