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Ratti Group
                               Sustainability report 2020





                 Principal risks associated with corruption



               The risk of acts of corruption includes the possibility that corporate representatives could commit acts that are illegal and
               significant from an administrative point of view and/or criminal in relation to third parties. With regard to private individuals
               the risk of corruption is adequately monitored by the Parent company, which in 2018 carried out a complete mapping of activ-
               ities that are sensitive to crimes covered by Legislative Decree 231/01, which includes all corruption offences relating to both
               public administration and private individuals. As for the public administration, the Ratti Group considers this risk to be limited
               given that it does not take part in tenders.
               The risk from acts of corruption is still less significant for other Group companies since the activities that generally are at risk
               of 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 on
               behalf of the latter.
              ✱   For details see paragraph 6.3 “Managing risks to include sustainability”.



              Table 6 – Principal risks associated with corruption in the Ratti Group



              Description of the main risks  Mitigation action taken



              The possibility that corporate   The Ratti Group is adopting organisational and procedural measures aimed at reducing the risks
              representatives might commit illegal   of illicit acts being committed – especially the risk of corruption. During 2018, Ratti updated MOG
              acts that are particularly significant   231/01 by adding the offence of corruption between private individuals..
              from an administrative and/or   Presence of a whistleblowing policy.
              criminal point of view, and could lead
              to penalties or reputational damage.  At Group level the Code of Ethics was updated and the Suppliers’ Code was introduced – as was a pro-
                                          cedure for allowing Group stakeholders to file reports relating to the Code of Ethics. To this end, a Group
                                          Ethics Committee was established, with the role of disseminating the principles of the Code of Ethics and
                                          dealing with any reports of violations..
                                          During 2019, training was carried out for top management on MOG 231/01 in Ratti SpA and on the Code
                                          of Ethics in Creomoda, La Maison des Accessoires and Textrom.
                                          For 2021, it is expected that the Code of Ethics and MOG 231/01 will be updated (for offences introduced
                                          after 2018). Training activities, suspended in 2020 as a result of COVID-19, will continue.



























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