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

reporting (Legislative Decree 254/2016), include The last quarter of 2022 saw the launch
the fight against active and passive corruption. of a project to update the Organisation,
The commitment to promoting and adopting
high ethical standards is stipulated in the Management and Control Model to reflect
Group’s Code of Ethics, in which one of the new criminal offences and, concomitantly,
fundamental principles is “Integrity and the the Code of Ethics and the Suppliers’ Code.
fight against corruption”, through the adoption
of a structured system of organisational and The conclusion of the project
procedural measures containing rules, controls is scheduled for the first half of 2023.
and reporting mechanisms aimed at preventing
illegal behaviour and protecting the reputation of
the Group at global level.
Given the delicacy of the topic, although no
Given that corruption is included as a serious incidents of corruption have been signalled
crime in Legislative Decree 231/2001, the second and/or reported, the Company has decided to
control adopted by Ratti SpA BC to prevent such a reinforce its monitoring activities by adopting –
risk is the Organisation, Management and Control in the near future and hopefully in the first half of
Model 231/01. 2023 – an anti-corruption policy at Group level.
The full mapping of activities that are sensitive
to the offences covered by Legislative Decree In addition, the prevention of corruption is a
231/01, which includes all corruption offences topic that is also covered by the Suppliers’ Code
relating to both public administration and approved in 2018. The Suppliers’ Code is an
private individuals, was updated in 2018. This integral part of contracts agreed with suppliers
project resulted in the implementation of who are asked to note that corrupting behaviour
a Whistleblowing policy and a procedure of any type with private individuals or the Public
governing the handling of declarations, Administration will not be tolerated by the
complaints and notifications of violations of the Group; for this reason failure to observe the
ethical and behavioural principles laid down in provisions of the Suppliers’ Code could lead to
the Code of Ethics of the Ratti Group. the termination of the contract (see Chapter 5.4
As mentioned previously, the last quarter of “A virtuous circle of good practices”).
2022 saw the launch of a project to update the With regard to the companies of the Ratti Group
Organisation, Management and Control Model to other than Ratti SpA BC, it should be noted that
reflect new criminal offences and, concomitantly, some activities that generally risk amounting
the Code of Ethics and the Suppliers’ Code. The to corruption are not executed by these
conclusion of the project is scheduled for the first companies or – if they are carried out – are of
half of 2023. marginal importance, due to the fact that these
companies only carry out workmanship on an
outsourced basis for the Parent company and/
or on behalf of the latter.
During 2019 the first levels of Ratti SpA BC
received training on Legislative Decree
231/01 and the principles and contents of the
Organisation, Management and Control Model
231/01 emphasising, in particular, the protocols
for fighting corruption. In addition, training was
also provided to the directors of the subsidiaries
in relation to the principles of the Group’s Code
of Ethics, focusing on the behaviour that needs to
be adopted to oppose corruption.

The 2022 training plan relating to the topics
featured in the Organisation, Management and
Control Model 231/01 and the Code of Ethics (with
particular reference to the protocols for fighting
corruption) involved all newly hired personnel.
The training was carried out by Internal Audit on
behalf of the Supervisory Body and the Ethics
Committee.

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