Page 84 - Bilancio Sostenibilità Ratti 2020_en

Chapter 6
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Governance and monitoring of corporate ethics and risk management 83

The commitment to promoting and adopting workmanship on an outsourced basis for the Parent
high ethical standards is stipulated in the company and/or directly on behalf of the latter.
Group’s Code of Ethics, in which one of the
fundamental principles is “Integrity and the During 2019 steps were taken to provide training
fight against corruption”, through the adoption to the top management of Ratti SpA relating to
of a structured system of organisational and Legislative Decree 231/01 and to the principles
procedural measures containing rules, controls and contents of “Model 231/01” affirming, in
and reporting mechanisms aimed at preventing particular, the protocols for fighting corruption.
illegal behaviour and protecting the reputation In addition, training was also provided to the
of the Group at global level. directors of the subsidiaries in relation to the
principles of the Group’s Code of Ethics,
Given that corruption is included as a serious focusing on the behaviour that needs to be
crime in Legislative Decree 231/2001, the second adopted to oppose corruption.
control adopted by Ratti SpA to prevent such a
risk is Model 231/2001. The 2020 training plan was extended to all
The full mapping of activities that are sensitive employees including new-hires. However, only
to the offences covered by Legislative Decree a small part of the plan was implemented owing
231/01, which includes all corruption offences to problems associated with the spread of the
relating to both public administration and private COVID-19 virus, and it was re-scheduled for 2021.
individuals, was updated in 2018.
This project resulted in the implementation of a
whistleblowing policy and a procedure governing The management of sustainability risks
the handling of declarations, complaints and The Ratti Group has an appropriate process for
notifications of violations of the ethical and analysing the risks associated with the issues
behavioural principles laid down in the Code of mentioned in Legislative Decree 254/2016.
Ethics of the Ratti Group. Responsibility for identifying and evaluating
sustainability risks lies with the CEO of Ratti SpA,
The Group’s Ethics Committee is responsible for assisted by a team consisting of the heads
receiving and handling any reports, including of the Financial Administration and Control and
those relating to conduct that could potentially/ Internal Audit functions.
substantially violate the aforementioned anti-
corruption measures. From an analysis of the strategic risks and the
risks mapped to maintain environmental, health
Corruption is a topic that is also covered by the and safety and energy certification (ISO 14001, ISO
Suppliers’ Code approved in 2018. 50001 and ISO 45001) and social accountability
The Code is an integral part of contracts agreed (SA8000), using mainly qualitative evaluation, risks
with suppliers who are asked to note that were identified that have a significant potential
corrupting behaviour of any type with private impact on the activities of the Group or the
individuals or the public administration will not stakeholders.
be tolerated by the Group; for this reason failure
to observe the provisions of the Code could lead An evaluation of the risks linked to aspects of the
to the termination of the contract (see Chapter 3, Decree is carried out for all Group companies.
paragraph 3.4 “A virtuous circle of good practices”). The Group’s assessment was that risks of this
type were not significant for Ratti USA and
With regard to the other companies of the Ratti Ratti International Trading (Shanghai), given the
Group it should be noted that some activities dimension and nature of their activities.
that generally risk amounting to corruption are
not executed by these companies or – if they are There now follows a presentation of the main risks
carried out – are of marginal importance, due and the actions taken to mitigate them.
to the fact that these companies only carry out