In accordance with the terms defined by the Code of Ethics and in observance of the 10th principle of the Global Compact, according to which "businesses should work against corruption in all its forms, including extortion and bribery", the fight against corruption in Salini Impregilo led to the Anti-corruption Compliance System, certified as UNI ISO 37001: 2016 (Anti-Bribery Management System) compliant and consisting of an Anticorruption Model;
Guidelines and company procedures, in order to define roles and responsibilities of the subjects involved and operating methods for control processes referred to in the Anticorruption Model.
The Anticorruption Model is an element of the internal control system aimed at the strengthening of certain prevention protocols in order to eliminate active or passive corruption and ensure compliance with the principles introduced by the anti-corruption laws and in accordance with international best practices.
It provides a systematic reference framework of legal instruments and policies on anticorruption, which Salini Impregilo intends to pursue acting as a guide in facing corruption risks that may arise in the conduct of business activities.
In order to ensure effective measures to provide assistance and advice on anticorruption, Salini Impregilo has founded, within the Compliance Department, the Anticorruption Legal Support Unit, responsible for giving specialised indications on anti-corruption measures and providing clarification on:
- contents of the Model and Guidelines, Italian anticorruption laws, and laws in the countries of operation;
- application of provisions in the Anticorruption Model and Guidelines, also with regard to the laws applicable in the country of operation.
The unit is also responsible for the regular revision and monitoring of the Anticorruption Model to ensure that it is as effective as possible. It also checks to ensure that the Model is applied correctly.
The application of the Anticorruption Model is the direct responsibility of the directors, statutory auditors, managers and employees of Salini Impregilo, and all those who, both directly and indirectly, permanently or temporarily, establish relations, each within his/her relevant functional area and responsibilities (the “Recipients”). All recipients are required, therefore, to comply, with the utmost care and attention, with all the principles and provisions set forth therein. In order to spread appropriate knowledge and understanding of the Model, Salini Impregilo has defined:
- a binding anti-corruption training program for Recipients, modulated with according to the qualifications of the Recipients and the different levels of involvement in sensitive activities;
- specific contractual “compliance” clauses, which include, among others, the obligation to comply with the principles contained in the Code of Ethics and the Anticorruption Model of Salini Impregilo.
Policies and procedures contained in the Anticorruption Model and in the Guidelines are an integral part of the Anticorruption Compliance System.
The violation of the principles and provisions of the Anticorruption Model, and, in general, of the Anticorruption System by Salini Impregilo personnel constitutes a serious breach of contract, for which Salini Impregilo reserves the right to impose disciplinary measures in compliance with the legal framework and/or contract applicable to the individual relationship, with disciplinary measures and through the conclusion of the relationship (dismissal or termination). In any case, Salini Impregilo reserves the right to take action for damages pursuant to current legislation.
The Recipients are required to report any violation of the Anticorruption System in general, of Salini Impregilo’s policies and / or of any anticorruption law of which they become aware, even indirectly, in the course of their business.
To this end, there are proper channels of communication that allow the sending of reports of violations, even anonymously protecting in this manner the whistle-blower against any form of retaliation, discrimination or penalty, guaranteeing the confidentiality of the identity.
The Whistleblowing platform is one of the channels of communication through which employees, collaborators, consultants, suppliers of Salini Impregilo or any other person who has a rapport with the company can send, even anonymously, a report of violations, presumed or known, of applicable laws or regulations, the Ethics Code, the Anti-Corruption Model and/or the Organisation, Management & Control Model pursuant to the Italian Legislative Decree 231/01.