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

making use of specialised external consultants if The Organisational Model and the
necessary. For Ratti SpA BC, managing significant Supervisory Body
risk profiles is in any case corroborated by Since 2006, Ratti SpA BC has had an
appropriate evaluations carried out by the bodies organisational, management and control
which form part of the management and internal model which complies with Legislative Decree
control system. 231/2001 (“Organisational Model”) and has
appointed a Supervisory Body.
In addition, the Ratti Group has for some time
been following a strategy of formally declaring The Organisational Model and the related
its compliance in respect of social, financial attachments (the Group’s Code of Ethics, the
and environmental issues. It has obtained and Suppliers’ Code, the Whistleblowing Policy), were
maintains a series of product and process updated at the end of 2018. All the Company’s
certifications. It should also be noted that on subsidiaries have subsequently adopted the Code
17 May 2022 Ratti became a benefit company, of Ethics and the Suppliers’ Code.
in accordance with Law 208/2015, adding the
resulting clarifications and amendments to its
by-laws and, in particular, adding to its corporate
purpose the specific goal of mutual benefit which
Ratti SpA BC is already pursuing and which it
intends to continue to pursue.
As had already been planned for its subsidiary Ratti
International Trading (Shanghai) Co. Ltd, in 2022 the
Ratti Group launched a privacy compliance project
in relation to the relevant current applicable
Chinese law called “Personal information
protection law”. More time has been needed to
complete the project than expected, but it is
reasonable to suppose that it will be concluded in
the first half of 2023.

The Group’s Code OF Ethics, updated in 2018,
summarises all elements on which the company’s
identity and culture is based, and to which all
subjects must adhere who act in the name of or
on behalf of the Group and, in various ways and
at various levels, maintain relationships with the
different companies. The main recipients, who
are explicitly referred to, are: the directors, the The Group’s ethical principles
statutory auditors, all the employees of all the
companies in the Ratti Group, all freelance workers, 9 principles of the Code of Ethics underpin the governance and the
all external partners (consultants, trading partners, management of the Group’s activities:
agents) and suppliers.
• Legality, loyalty and probity
The Code of Ethics stipulates the rules of conduct • Respect for the individual and development of our personnel
that recipients must follow when conducting • Safeguarding health and safety and the environment
corporate business and activities, and when • Social Accountability
managing people and information. In order to • Safeguarding the trademarks, patents and original works
manage any reports of violations of the Group’s • Prevention of conflict of interests
Code of Ethics a procedure has been defined that
• Integrity and the fight against corruption
is valid for all the Group’s companies.
• Transparency and anti-money laundering
This identifies the operating modality and the
• Freedom and duty to report violations
rules to follow. With regard to the project to
update the Organisation, Management and The Code of Ethics may be consulted by accessing the Communications
Control Model 231/01 which began in September
area of Ratti’s self-service Human Resources portal or the website www.ratti.
2022 and which is expected to be completed in
it in the section: “Investitori / corporate governance / procedure e codici”
the first half of 2023, more detail is planned for the
(Investors / corporate governance / procedures and codes).
chapter relating to the conflict of interests in the
Code of Ethics.
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