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ing commitment to ZERO TOLERANCE for
corruption and bribery and is implemented by
avoiding all transactions and contacts with
any third party which may be guilty or sus-
pect of encouraging conditions giving rise to
corruption, extortion or bribery. Furthermore,
our publicly declared commitment to Prin-
ciple 10 of the UN Global Compact, ac-
cording to which “We work against corrup-
tion in all its forms, including extortion and
bribery”, is a catalyst for the development
of our subsidiaries’ corporate culture re-
garding the promotion of transparency. To
this end, our aim as a Group is to evaluate
and improve our procedures for managing the
risk of corruption and to verify that the op-
erations of our subsidiaries, as well as those
of our key suppliers and business partners,
comply with our established policies and pro-
cedures, as these are defined in the Profes-
sional Ethics Code, in the Internal Regulations
of the individual Group companies and in the
Code of Conduct for Suppliers & Business
Partners, always ensuring our full align-
ment with the laws and regulatory provisions
in force.
Our policy on addressing corruption is or-
ganised in three key stages:
The first stage involves the analysis of the
prevailing conditions and the identifica-
tion of potential risks or threats which
may encourage the occurrence of non-eth-
ical incidents in our corporate environ-
ment. These are implemented through an-
nuals elf-assessments and internal pre-
ventive audits with a view to introducing
measures to combat corruption at the lev-
el of the Group’s subsidiaries, in parallel
with a relevant internal audit programme
at the Group level. This analysis is an im-
portant and necessary management prac-
tice which helps assess the likelihood of
occurrence of instances of corruption or
bribery in several sensitive areas, such as
political and charitable contributions,
sponsorships, facilitation payments, gifts
and hospitality, with a view to formulat-
ing relevant policies but also to estab-
lishing the procedures – where these are
not in place – which are required to deal
with such instances.
The second stage refers to ensuring that
all transactions carried out on behalf of
the Group by our shareholders, employ-
ees, subsidiaries and key business partners
and suppliers are characterised by a high
level of integrity and by high moral stan-
dards. Through established procedures, ap-
plying primarily in our Purchases and
Procurement Units for the selection of
suppliers and other business partners,
we check the conditions under which
every single transaction is carried out, in
order to identify and eliminate those
which may give rise to incidents of cor-
ruption.
The third stage refers to our operation as
a “Responsible Corporate Citizen”, re-
flected in a number of voluntary initiatives
such as: adherence to market rules, par-
ticipation in international standards to
strengthen transparency, establishing
transparency as an important item on the
agenda of the ongoing dialogue with our
key Stakeholder groups, the provision of
training on anti-corruption policies and
procedures to our employees of all lev-
els and in general in our dedication to eth-
ical business practices and proper corpo-
rate governance.
Our goal is to eliminate completely our ex-
posure to corruption, as we firmly believe that
strengthening transparency in all transactions
connected with the Group’s business activities
is crucial to its sustainability.
