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Chapter 7 | Governance and monitoring of corporate ethics and risk management

Impacts and risks associated with this risk to be limited given that it does not take
corruption part in tenders.
With regard to the phenomenon of corruption
the reputational and financial damage which The risk from acts of corruption is still less
could result if representatives of the Company significant for other Group companies since the
committed acts – illicit from an administrative and/ activities that generally are at risk of amounting to
or penal point of view – against third parties has corruption are not executed by these companies
been identified as being of material impact. To this or – if they are carried out – are of marginal
end, with regard to private individuals the risk of importance due to the fact that these companies
corruption is adequately monitored by the Parent only carry out workmanship on an outsourced
company, which in 2018 carried out a complete basis for the Parent company and/or on behalf of
mapping of activities that are sensitive to crimes the latter.
covered by Legislative Decree 231/01, which
includes all corruption offences relating to both For further details see the paragraph “The
public administration and private individuals. As for prevention of corruption” in Chapter 7, paragraph
the public administration, the Ratti Group considers 7.3 “Managing risks to include sustainability”.

Table 6 – Impacts and risks associated with corruption in the Ratti Group

IMPACTS DESCRIPTION OF THE MAIN RISKS MITIGATION ACTION TAKEN

Reputational and financial The possibility that corporate represen- The Ratti Group is adopting organisational and procedural measures aimed at
damage arising from an illicit act tatives might commit illegal acts that are reducing the risks of illicit acts being committed – especially the risk of cor-
related to episodes of corruption particularly significant from an admini- ruption. During 2018, Ratti updated the Organisation, Management and Con-
in the Group strative and/or criminal point of view, trol Model 231/01 (“Organisational Model”) by adding the offence of corruption
and could lead to penalties or reputatio- between private individuals.
nal 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 repor-
ts 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. In the first half of 2023 updates to the
Organisational Model to include new offences, to the Code of Ethics and to the
Suppliers Code are planned, as well as the drafting of an anti-corruption policy
at Group level.

During 2019, training was carried out for first-level staff on the Organisational
Model in Ratti SpA BC and on the Code of Ethics in Creomoda, La Maison des
Accessoires and Textrom. In 2022, training was carried out for new hires on the
Organisational Model and the Code of Ethics. After the Model and the Code of
Ethics have been updated in the first half of 2023, training will be provided to the
Group’s senior management.

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