Page 98 - Ratti_bilancio di sostenibilità_2021_en

RATTI GROUP | SUSTAINABILITY REPORT 2021

Principal risks associated As for the public administration, the Ratti Group
with corruption considers this risk to be limited given that it
The risk of acts of corruption includes the does not take part in tenders.
possibility that corporate representatives could
commit acts that are illegal and significant from The risk of acts of corruption is still less
an administrative point of view and/or criminal significant for other Group companies since the
in relation to third parties. activities that are generally at risk of amounting
to corruption are not executed by these
With regard to private individuals the risk of companies or – if they are carried out – are of
corruption is adequately monitored by the marginal importance due to the fact that these
Parent company, which in 2018 carried out companies only carry out workmanship on an
a complete mapping of activities that are outsourced basis for the Parent company and/
sensitive to crimes covered by Legislative or on behalf of the latter.
Decree 231/01, which includes all corruption
offences relating to both public administration For details see paragraph 6.3 “Managing risks to
and private individuals. 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 representatives The Ratti Group is adopting organisational and procedural measures aimed at reducing the risks of illicit acts being
might commit illegal acts that are particularly committed – especially the risk of corruption. During 2018, Ratti updated MOG 231/01 by adding the offence of cor-
significant from an administrative and/ ruption between private individuals..
or criminal point of view and could lead to
penalties or reputational damage. Presence of a Whistleblowing policy.

At Group level the Code of Ethics was updated and the Suppliers’ Code was introduced – as was a procedure 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. For 2022, an update of MOG 231/01 is planned to include the new
offences of this type and, subsequently, the Code of Ethics and the Suppliers’ Code will also be updated.
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. In 2021, training was carried out for new-hires on MOG 231/01
and the Code of Ethics. After the Model and the Code of Ethics have been updated in 2022, training will be provided
to the Group’s senior management.

96