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CHAPTER 6 | GOVERNANCE AND MONITORING OF CORPORATE ETHICS AND RISK

Given that corruption is included as a serious
crime in Legislative Decree 231/2001, the
second control adopted by Ratti SpA to prevent CORRUPTION IS A TOPIC THAT IS ALSO
such a risk is Model 231/2001. The full mapping COVERED BY THE SUPPLIERS’ CODE
of activities that are sensitive to the offences APPROVED IN 2018.
covered by Legislative Decree 231/01, which THE CODE IS AN INTEGRAL PART OF
includes all corruption offences relating to both CONTRACTS AGREED WITH SUPPLIERS
public administration and private individuals, WHO ARE ASKED TO NOTE THAT
was updated in 2018. This project resulted in CORRUPTING BEHAVIOUR OF ANY TYPE
the implementation of a Whistleblowing policy WITH PRIVATE INDIVIDUALS OR THE
and a Procedure governing the handling of PUBLIC ADMINISTRATION WILL NOT BE
declarations, complaints and notifications of TOLERATED BY THE GROUP
violations of the ethical and behavioural principles
laid down in the Code of Ethics of the Ratti Group.
With regard to the project to update Ratti
SpA’s MOG 231/01, procedures and operational emergency relating to the Covid-19 pandemic.
practices aimed at preventing the crime of Training relating to MOG 231/01 topics and the
corruption have been analysed and verified. Code of Ethics (with particular regard to protocols
for the fight against corruption) started up again in
The Group’s Ethics Committee is responsible 2021, involving all newly hired personnel.
for receiving and handling any reports, including For 2022 it is expected that training activities will
those relating to conduct that could potentially/ continue to be offered to new-hires and senior
in substance violate the aforementioned anti- positions, following the updates to Model 231
corruption measures. and the Code of Ethics.
Corruption is a topic that is also covered by the The management
Suppliers’ Code approved in 2018. The Code is an of sustainability risks
integral part of contracts agreed with suppliers The Ratti Group has an appropriate process for
who are asked to note that corrupting behaviour analysing the risks associated with the issues
of any type with private individuals or the public mentioned in Legislative Decree 254/2016.
administration will not be tolerated by the Group; Responsibility for identifying and evaluating
for this reason failure to observe the provisions sustainability risks lies with the CEO of Ratti SpA,
of the Code could lead to the termination of the assisted by a team consisting of the heads of the
contract (see Chapter 3, paragraph 3.4 “A virtuous Financial Administration and Control and Internal
circle of good practices”). Audit functions.

With regard to the other companies of the Ratti From an analysis of the strategic risks and the
Group it should be noted that some activities risks mapped to maintain environmental, health
that generally risk amounting to corruption are and safety and energy certification (ISO14001,
not executed by these companies or – if they are ISO50001 and ISO45001) and social accountability
carried out – are of marginal importance, due (SA8000), using mainly qualitative evaluation,
to the fact that these companies only carry out risks were identified that could have a significant
workmanship on an outsourced basis for the impact on the activities of the Group or the
Parent company and/or on behalf of the latter. individual stakeholders. The evaluation of the
For 2022, an update of MOG 231/01 is planned risks linked to aspects of the Decree is carried
to include the new offences of this type and, out for all Group companies.
subsequently, the Code of Ethics and the The Group’s assessment was that risks of this
Suppliers’ Code will be updated. type were not significant for Ratti USA and
During 2019 steps were taken to provide training Ratti International Trading (Shanghai), given the
to the top management of Ratti SpA relating to dimension and nature of their activities.
Legislative Decree 231/01, to the principles and The analysis is carried out annually, on the basis
contents of “Model 231/01” affirming, in particular, of knowledge of processes, of any measures
the protocols for fighting corruption. In addition, taken to reduce risks, of any verifications carried
training was also provided to the directors of the out, of reports received and any evidence which
subsidiaries in relation to the principles of the emerged during ordinary activities.
Group’s Code of Ethics, focusing on the behaviour
that needs to be adopted to oppose corruption. There now follows a presentation of the main
In 2020 the training plan was limited by the health risks and the actions taken to mitigate them.

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